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Privacy Policy

Last Updated: June 04, 2026

At swsh, we take your privacy seriously. Please read this Privacy Policy to learn how we treat your personal data. By using or accessing our Services in any manner, you acknowledge that you accept the practices and policies outlined below, and you hereby consent that we will collect, use and share your information as described in this Privacy Policy.

Remember that your use of swsh’s Services is at all times subject to our Terms of Use — opens in a new tab, which incorporates this Privacy Policy. Any terms we use in this Policy without defining them have the definitions given to them in the Terms of Use — opens in a new tab.

You may print a copy of this Privacy Policy by clicking here — opens in a new tab.

As we continually work to improve our Services, we may need to change this Privacy Policy from time to time. We will alert you of material changes by placing a notice on the swsh website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes.

PRIVACY POLICY TABLE OF CONTENTS

1. What this Privacy Policy Covers

This Privacy Policy covers how we treat Personal Data that we gather when you access or use our Services. “Personal Data” means any information that identifies or relates to a particular individual and also includes information referred to as “personally identifiable information” or “personal information” under applicable data privacy laws, rules or regulations. This Privacy Policy does not cover the practices of companies we don’t own or control or people we don’t manage.

2. Personal Data

2.1. Categories of Personal Data We May Collect

This chart details the categories of Personal Data that we may collect and may have collected over the past 12 months:

Category of Personal DataBusiness or Commercial Purpose(s) for CollectionCategories of Third Parties With Whom We Share this Personal Data:
Profile or Contact Data such as first and last name, email address, and phone number.• Providing, Customizing and Improving the Services • Marketing the Services • Corresponding with You• Service Providers • Parties You Authorize, Access or Authenticate
Device/IP Data such as IP address and IP-based location data, device ID, Domain server, type of device/operating system/browser used to access the Services.• Providing, Customizing and Improving the Services • Marketing the Services• Service Providers
Web Analytics such as web page interactions, referring webpage/source through which you accessed the Services, non-identifiable request IDs, and statistics associated with the interaction between device or browser and the Services.• Providing, Customizing and Improving the Services • Marketing the Services• Service Providers
Social Network Data such as your email address, handle, or other social media information that is publically-available or that you send us or tag us in.• Providing, Customizing and Improving the Services • Marketing the Services • Corresponding with You• Service Providers • Parties You Authorize, Access or Authenticate
Sensory Data such as photos or videos that you upload to the Services.• Providing, Customizing and Improving the Services• Service Providers • Parties You Authorize, Access or Authenticate
Categories of Data that May be Considered “Sensitive” • Biometric information for our facial recognition feature. • As described in the “Information about Biometric Information” section below• As described in the “Information about Biometric Information” section below
Inferences Drawn From Other Personal Data in connection with your use of our Services.• Providing, Customizing and Improving the Services• Service Providers • Parties You Authorize, Access or Authenticate
Other Identifying Information that You Voluntarily Choose to Provide such as feedback, in surveys or questionnaires, album or group chats, emails, texts, or other communications you send to us or using the Services. • Providing, Customizing and Improving the Services • Corresponding with You• Service Providers • Parties You Authorize, Access or Authenticate

2.2. Categories of Sources of Personal Data

We collect Personal Data about you from the following categories of sources:

  • You
    • When you provide such information directly to us.
  • When you create an account or use our interactive tools and Services.
  • When you voluntarily provide information in free-form text boxes through the Services or through responses to surveys or questionnaires.
  • When you send us an email or otherwise contact us.
    • When you use the Services and such information is collected automatically.
  • If you download our mobile application or use a location-enabled browser, we may receive information about your location and mobile device, as applicable.
  • If you download and install certain applications and software we make available, we may receive and collect information transmitted from your computing device for the purpose of providing you the relevant Services, such as information regarding when you are logged on and available to receive updates or alert notices.
  • Third Parties
    • Vendors
    • Social Networks
  • We may use analytics providers to analyze how you interact and engage with the Services, or third parties may help us provide you with customer support.

2.3. Our Commercial or Business Purposes for Collecting or Disclosing Personal Data

  • Providing, Customizing and Improving the Services
    • Creating and managing your account or other user profiles.
    • Providing you with the products, services or information you request.
    • Meeting or fulfilling the reason you provided the information to us.
    • Providing support and assistance for the Services.
    • Improving the Services, including testing, research, internal analytics and product development.
    • Personalizing the Services, website content and communications based on your preferences.
    • Doing fraud protection, security and debugging.
    • Carrying out other business purposes stated when collecting your Personal Data or as otherwise set forth in applicable data privacy laws.
  • Marketing the Services
    • Marketing and selling the Services.
  • Corresponding with You
    • Responding to correspondence that we receive from you, contacting you when necessary or requested, and sending you information about swsh or the Services.
    • Sending emails and other communications according to your preferences or that display content that we think will interest you.
  • Meeting Legal Requirements and Enforcing Legal Terms
    • Fulfilling our legal obligations under applicable law, regulation, court order or other legal process, such as preventing, detecting and investigating security incidents and potentially illegal or prohibited activities.
    • Protecting the rights, property or safety of you, swsh or another party.
    • Enforcing any agreements with you.
    • Responding to claims that any posting or other content violates third-party rights.
    • Resolving disputes.

We will not collect additional categories of Personal Data or use the Personal Data we collected for materially different, unrelated or incompatible purposes without providing you notice.

3. How We May Disclose Your Personal Data

We may disclose your Personal Data to the categories of service providers and other parties listed in this section. Depending on state laws that may be applicable to you, some of these disclosures may constitute a “sale” of your Personal Data. For more information, please refer to the state-specific sections below.

  • Service Providers. These parties help us provide the Services or perform business functions on our behalf. They may include:
    • Hosting, technology and communication providers.
    • Analytics providers that help us analyze web traffic or usage of our Services.
  • Parties You Authorize, Access or Authenticate
    • Third parties you access through the Services.
    • Social media Services.
    • Other users or businesses, including those that you interact with through our Services in connection with any groups or albums.

Profile Data Visible to All swsh Users

By default, certain Profile or Contact Data – specifically, your profile picture, name, and social media handles that you include, will be visible to any swsh user that has logged into the Services.

Groups and Albums

As part of our Services, businesses and users can create groups or albums for other swsh users to participate in. If you join a group, you will automatically be added to that group’s collection of albums, however, you have the option to leave particular albums at any time. When you join a group or album, some of your Profile and Contact Data will be shared with the owner and other participants of that group or album, including your profile picture, name, and social media handle, if you have one. All owners and participants of an album will also have access to photos you upload into that album and photos that you are tagged in, and any information you include in the album chat feature. When you join a group or album owned or managed by a business, business’ term and privacy policy will apply to its processing of your Personal Data. By joining the group or album, you are authorizing us to share your Personal Data with the related business to process in accordance with that business’ terms and privacy policy. We are not responsible for the processing of any third party’s processing of your Personal Data. When you leave an album, all photos that you have uploaded to that album will be removed and your Profile and Contact Data will no longer be visible to the group or album’s owner or participants. Please note that tags of you in photos that others upload of you will remain visible to the group’s owner and participants as long as those photos remain in such album.

Legal Obligations

We may share any Personal Data that we collect with third parties in conjunction with any of the activities set forth under “Meeting Legal Requirements and Enforcing Legal Terms” in the “Our Commercial or Business Purposes for Collecting Personal Data” section above.

Business Transfers

All of your Personal Data that we collect may be transferred to a third party if we undergo a merger, acquisition, bankruptcy or other transaction in which that third party assumes control of our business (in whole or in part). Should one of these events occur, we will make reasonable efforts to notify you before your information becomes subject to different privacy and security policies and practices.

Data that is Not Personal Data

We may create aggregated, de-identified or anonymized data from the Personal Data we collect, including by removing information that makes the data personally identifiable to a particular user. We may use such aggregated, de-identified or anonymized data and share it with third parties for our lawful business purposes, including to analyze, build and improve the Services and promote our business, provided that we will not share such data in a manner that could identify you.

4. Information about Biometric Information

We may collect biometric information about our users in order to provide our “Find Photos of You” facial recognition feature. Biometric information is a form of personal data based on an individual’s biometric identifier – such as an iris scan, fingerprint, voiceprint, hand geometry, or facial geometry – that is used to identify an individual. As used in this Privacy Policy, “Biometric Information” refers to both “biometric information” and “biometric identifiers” as those terms are defined under applicable law. With your consent, we use your Biometric Information to recognize your face in photos that you or others may post to our Services. We may also use Biometric Information to comply with applicable legal obligations or comply with a request from law enforcement or government entities, unless prohibited by law.

How We May Share Biometric Information. We may share Biometric Information with our facial recognition provider, Amazon Rekognition, as well as our hosting and cloud compute service provider to host and process information for us and/or make certain services, features or functionality available to our users on our behalf. We may also share your Biometric Information with third parties where permitted to enforce our terms of use, comply with legal obligations, or cooperate with law enforcement agencies where required by law. Note that we never sell or rent Biometric Information.

Our Retention of Biometric Information. We retain your Biometric Information in accordance with the specific retention periods determined by our customers. Biometric Information will be retained until the earlier of (i) if you refuse or otherwise later revoke your consent to our use of your Biometric Information; (ii) the initial purpose for collecting or obtaining such Biometric Information has been satisfied or (iii) three (3) years following the user’s last interaction with us. Our hosting and cloud compute provider will only store Biometric Information on our behalf for the retention periods set forth in this section. Such storage by our hosting and cloud compute provider is necessary for us to provide you with the Services.  Our hosting and cloud compute provider will not access or use your Biometric Information for any other purpose. Once the retention periods in this section have expired, Biometric Information will be permanently and irretrievably deleted by our hosting and cloud compute provider.

How We Secure Biometric Information. We seek to protect your Biometric Information from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures. We endeavor to protect Biometric Information in the same or more protective manner than the manner in which we store, transmit, or protect other confidential and sensitive information. Although we work to protect the security of your data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

How to Revoke Your Consent. We will only collect your Biometric Information with your consent. You can revoke your consent at any time by changing our settings in the “Permissions” section of your swsh profile settings. We will delete your Biometric Information after you revoke your consent. Please note that any previously made identifications of you in photos (which is not Biometric Information) will remain on such photos.

You can find more information in our Facial Recognition Consent — opens in a new tab. If you have questions about the collection and use of your Biometric Information, please contact us at policy@joinswsh.com.

5. Cookies

The Services use cookies and similar technologies such as pixel tags, web beacons, clear GIFs and JavaScript (collectively, “Cookies”) to enable our servers to recognize your web browser, tell us how and when you visit and use our Services, analyze trends, learn about our user base and operate and improve our Services. Cookies are small pieces of data– usually text files – placed on your computer, tablet, phone or similar device when you use that device to access our Services. We may also supplement the information we collect from you with information received from third parties, including third parties that have placed their own Cookies on your device(s).

We use the following types of Cookies:

  • Essential Cookies. Essential Cookies are required for providing you with features or services that you have requested. For example, certain Cookies enable you to log into secure areas of our Services. Disabling these Cookies may make certain features and services unavailable.
  • Functional Cookies. Functional Cookies are used to record your choices and settings regarding our Services, maintain your preferences over time and recognize you when you return to our Services. These Cookies help us to personalize our content for you, greet you by name and remember your preferences (for example, your choice of language or region).
  • Performance/Analytical Cookies. Performance/Analytical Cookies allow us to understand how visitors use our Services. They do this by collecting information about the number of visitors to the Services, what pages visitors view on our Services and how long visitors are viewing pages on the Services. Performance/Analytical Cookies also help us measure the performance of our advertising campaigns in order to help us improve our campaigns and the Services’ content for those who engage with our advertising. For example, Google LLC (“Google”) uses cookies in connection with its Google Analytics services. Google’s ability to use and share information collected by Google Analytics about your visits to the Services is subject to the Google Analytics Terms of Use and the Google Privacy Policy. You have the option to opt-out of Google’s use of Cookies by visiting the Google advertising opt-out page at www.google.com/privacy_ads.html or the Google Analytics Opt-out Browser Add-on at https://tools.google.com/dlpage/gaoptout/.

You can decide whether or not to accept Cookies through your internet browser’s settings. Most browsers have an option for turning off the Cookie feature, which will prevent your browser from accepting new Cookies, as well as (depending on the sophistication of your browser software) allow you to decide on acceptance of each new Cookie in a variety of ways. You can also delete all Cookies that are already on your device. If you do this, however, you may have to manually adjust some preferences every time you visit our website and some of the Services and functionalities may not work.

To explore what Cookie settings are available to you or to modify your preferences with respect to Cookies, you can access your Cookie management settings by clicking “options” section of your browser’s menu. To find out more information about Cookies generally, including information about how to manage and delete Cookies, please visit http://www.allaboutcookies.org/ — opens in a new tab or https://ico.org.uk/for-the-public/online/cookies/ if you are located in the European Union.

6. Data Security

We seek to protect your Personal Data from unauthorized access, use and disclosure using appropriate physical, technical, organizational and administrative security measures based on the type of Personal Data and how we are processing that data. You should also help protect your data by appropriately selecting and protecting your password and/or other sign-on mechanism; limiting access to your computer or device and browser; and signing off after you have finished accessing your account. Although we work to protect the security of your account and other data that we hold in our records, please be aware that no method of transmitting data over the internet or storing data is completely secure.

7. Data Retention

We retain Personal Data about you for as long as necessary to provide you with our Services or to perform our business or commercial purposes for collecting your Personal Data. When establishing a retention period for specific categories of data, we consider who we collected the data from, our need for the Personal Data, why we collected the Personal Data, and the sensitivity of the Personal Data. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. We may further retain information in an anonymous or aggregated form where that information would not identify you personally.

For example:

  • We retain your profile information and credentials for as long as you have an account with us.
  • We retain your payment data for as long as we need to process your purchase or subscription.
  • We retain your device/IP data for as long as we need it to ensure that our systems are working appropriately, effectively and efficiently.

8. Personal Data of Children

As noted in the Terms of Use — opens in a new tab, we do not knowingly collect or solicit Personal Data about children under 16 years of age; if you are a child under the age of 16, please do not attempt to register for or otherwise use the Services or send us any Personal Data. If we learn we have collected Personal Data from a child under 16 years of age, we will delete that information as quickly as possible. If you believe that a child under 16 years of age may have provided Personal Data to us, please contact us at policy@joinswsh.com.

9. European Union, United Kingdom, and Swiss Data Subject Rights

EU and UK Residents

If you are a resident of the European Union (“EU”), United Kingdom (“UK”), Lichtenstein, Norway or Iceland, you may have additional rights under the EU or UK General Data Protection Regulation (the “GDPR”) with respect to your Personal Data, as outlined below.

For this section, we use the terms “Personal Data” and “processing” as they are defined in the GDPR, but “Personal Data” generally means information that can be used to individually identify a person, and “processing” generally covers actions that can be performed in connection with data such as collection, use, storage and disclosure. swsh will be the controller of your Personal Data processed in connection with the Services.

If there are any conflicts between this section and any other provision of this Privacy Policy, or if you have any questions about this section or whether any of the following applies to you, please contact us at policy@joinswsh.com. Note that we may also process Personal Data of our customers’ end users or employees in connection with our provision of certain services to customers, in which case we are the processor of Personal Data. If we are the processor of your Personal Data (i.e., not the controller), please contact the controller party in the first instance to address your rights with respect to such data.

Personal Data Use and Processing Grounds

The “Our Commercial or Business Purposes for Collecting Personal Data” section above explains how we use your Personal Data.

We will only process your Personal Data if we have a lawful basis for doing so. Lawful bases for processing include consent, contractual necessity and our “legitimate interests” or the legitimate interest of others, as further described below.

  • Contractual Necessity: We process the following categories of Personal Data as a matter of “contractual necessity”, meaning that we need to process the data to perform under our Terms of Use — opens in a new tab with you, which enables us to provide you with the Services. When we process data due to contractual necessity, failure to provide such Personal Data will result in your inability to use some or all portions of the Services that require such data.
    • Profile or Contact Data
    • Device/IP Data
    • Sensory Data
    • Categories of Data that May be Considered “Sensitive”
  • Legitimate Interest: We process the following categories of Personal Data when we believe it furthers the legitimate interest of us or third parties:
    • Profile or Contact Data
    • Device/IP Data
    • Web Analytics
    • Social Network Data
    • Sensory Data
    • Categories of Data that May be Considered “Sensitive”
    • Inferences Drawn From Other Personal Data
    • Other Identifying Information that You Voluntarily Choose to Provide
    • We may also de-identify or anonymize Personal Data to further our legitimate interests.
  • Examples of these legitimate interests include (as described in more detail above):
    • Providing, customizing and improving the Services.
    • Marketing the Services.
    • Corresponding with you.
    • Meeting legal requirements and enforcing legal terms.
    • Completing corporate transactions.
  • Consent: In some cases, we process Personal Data based on the consent you expressly grant to us at the time we collect such data. When we process Personal Data based on your consent, it will be expressly indicated to you at the point and time of collection.
  • Other Processing Grounds: From time to time we may also need to process Personal Data to comply with a legal obligation, if it is necessary to protect the vital interests of you or other data subjects, or if it is necessary for a task carried out in the public interest.

EU, UK and Swiss Data Subject Rights

You have certain rights with respect to your Personal Data, including those set forth below. For more information about these rights, or to submit a request, please email us at privacy@joinswsh.com. Please note that in some circumstances, we may not be able to fully comply with your request, such as if it is frivolous or extremely impractical, if it jeopardizes the rights of others, or if it is not required by law, but in those circumstances, we will still respond to notify you of such a decision. In some cases, we may also need you to provide us with additional information, which may include Personal Data, if necessary to verify your identity and the nature of your request.

  • Access: You can request more information about the Personal Data we hold about you and request a copy of such Personal Data.
  • Rectification: If you believe that any Personal Data we are holding about you is incorrect or incomplete, you can request that we correct or supplement such data.
  • Erasure: You can request that we erase some or all of your Personal Data from our systems.
  • Withdrawal of Consent: If we are processing your Personal Data based on your consent (as indicated at the time of collection of such data), you have the right to withdraw your consent at any time. Please note, however, that if you exercise this right, you may have to then provide express consent on a case-by-case basis for the use or disclosure of certain of your Personal Data, if such use or disclosure is necessary to enable you to utilize some or all of our Services.
  • Portability: You can ask for a copy of your Personal Data in a machine-readable format. You can also request that we transmit the data to another controller where technically feasible.
  • Objection: You can contact us to let us know that you object to the further use or disclosure of your Personal Data for certain purposes, such as for direct marketing purposes.
  • Restriction of Processing: You can ask us to restrict further processing of your Personal Data.
  • Right to File Complaint: You have the right to lodge a complaint about swsh’s practices with respect to your Personal Data with the supervisory authority of your country or EU Member State. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.

Transfers of Personal Data

The Services are hosted and operated in the United States (“U.S.”) through swsh and its service providers, and if you do not reside in the U.S., laws in the U.S. may differ from the laws where you reside. By using the Services, you acknowledge that any Personal Data about you, regardless of whether provided by you or obtained from a third party, is being provided to swsh in the U.S. and will be hosted on U.S. servers, and you authorize swsh to transfer, store and process your information to and in the U.S., and possibly other countries pursuant to standard contractual clauses or the Data Privacy Framework (described below).

Data Privacy Framework(s)

Somewhere Somehow Inc. (“swsh”) complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF (“UK-U.S. DPF”), and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce. swsh has certified to the U.S. Department of Commerce that it adheres to the EU-U.S. Data Privacy Framework Principles (“EU-U.S. DPF Principles”) with regard to the processing of all personal data received from the European Union in reliance on the EU-U.S. DPF and in reliance on the UK Extension to the EU-U.S. DPF (the “UK-US DPF Principles”) as to the processing of all personal data received from the United Kingdom (and Gibraltar). swsh has certified to the U.S. Department of Commerce that it adheres to the Swiss-U.S. Data Privacy Framework Principles (“Swiss-U.S. DPF Principles”) with regard to the processing of personal data received from Switzerland in reliance on the Swiss-U.S. DPF.  If there is any conflict between the terms in this Privacy Policy and the EU-U.S. DPF Principles, the UK-U.S. DPF Principles, and the Swiss-U.S. DPF Principles, the EU-U.S. DPF Principles, the UK-U.S. DPF Principles, and the Swiss-U.S. DPF Principles shall govern.  To learn more about the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-US DPF, and to view our certification, please visit https://www.dataprivacyframework.gov/.

The Federal Trade Commission has jurisdiction over swsh’s compliance with the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF. This Privacy Policy describes the types of Personal Data we collect, the purposes for which we collect and use your Personal Data, and the purposes for which we disclose your Personal Data to certain types of third parties in the sections above.  Pursuant to the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF, EU, UK, and Swiss individuals have the right to obtain our confirmation of whether we maintain Personal Data relating to them in the U.S. Upon request, we will provide EU, UK, and Swiss individuals with access to the Personal Data that we hold about them. EU, UK, and Swiss individuals may also correct, amend, or delete the Personal Data we hold about them where it is inaccurate, or has been processed in violation of the EU-U.S. DPF Principles, the UK-U.S. DPF Principles, and the Swiss-U.S. DPF Principles, except where the burden or expense of providing access would be disproportionate to the risks to the individual’s privacy in the case in question, or where the rights of persons other than the individual would be violated. An EU, UK, and Swiss individual who seeks access, or who seeks to correct, amend, or delete inaccurate data transferred to the U.S. under the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF, should direct their query to privacy@joinswsh.com.  If requested to remove data, we will respond within a reasonable timeframe. For more information about rights afforded to EU, UK, and Swiss individuals, please see the “EU, UK, and Swiss Data Subject Rights” section of this Privacy Policy.

In addition, under the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF, we will provide EU, UK, and Swiss individuals with the choice to opt-out from the sharing of their Personal Data with any third parties (other than our agents or those that act on our behalf or under our instruction), or before we use it for a purpose that is materially different from the purpose for which it was originally collected or subsequently authorized.

We will provide EU, UK, and Swiss individuals with the choice to opt-in to sharing their sensitive Personal Data with any third parties or if we plan to process their Personal Data for a purpose other than those for which it was originally collected or subsequently authorized. EU, UK, and Swiss individuals may request to limit the use and disclosure of your Personal Data by submitting a written request to privacy@joinswsh.com.

In addition to any other disclosures described in our Privacy Policy, in certain situations, we may be required to disclose Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

swsh accountability for Personal Data that it receives in the U.S. under the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF and subsequently transfers to a third party acting as an agent on our behalf is described in the EU-U.S. DPF Principles, the UK-U.S. DPF Principles, and the Swiss-U.S. DPF Principles. In particular, swsh remains liable under the EU-U.S. DPF Principles, the UK-U.S. DPF Principles, and the Swiss-U.S. DPF Principles if our agents process Personal Data in a manner inconsistent with the EU-U.S. DPF Principles, the UK-U.S. DPF Principles, and the Swiss-U.S. DPF Principles, unless swsh proves that we are not responsible for the event giving rise to the damage.

In compliance with the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF, swsh commits to resolve EU-U.S. DPF Principles, UK-U.S. DPF Principles, and Swiss-U.S. DPF Principles-related complaints about our collection and use of your Personal Data. EU, UK, and Swiss individuals with inquiries or complaints regarding our handling of personal data received in reliance on the DPF should first contact swsh at privacy@joinswsh.com.

In compliance with the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF, swsh commits to refer unresolved complaints concerning our handling of personal data received in reliance on the EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF to JAMS, an alternative dispute resolution provider based in the U.S. If you are an EU, UK, or Swiss individual and you do not receive timely acknowledgment of your EU-U.S. DPF Principles, UK-U.S. DPF Principles, or Swiss-U.S. DPF Principles-related complaint from us, or if we have not addressed your EU-U.S. DPF Principles, UK-U.S. DPF Principles, or Swiss-U.S. DPF Principles-related complaint to your satisfaction, please visit https://www.jamsadr.com/dpf-dispute-resolution for more information or to file a complaint. The services of JAMS are provided at no cost to you.

If your EU-U.S. DPF, the UK-U.S. DPF, and the Swiss-U.S. DPF complaint cannot be resolved through the above channels, under certain conditions, you may invoke binding arbitration for some residual claims not resolved by other redress mechanisms. See Annex 1 of the Data Privacy Framework Principles, located at

https://www.dataprivacyframework.gov/s/article/ANNEX-I-introduction-dpf?tabset-35584=2.

10. California Resident Rights

If you are a California resident, the California Consumer Privacy Act (“CCPA”) may afford you certain rights over your Personal Data, as further set forth in this section. To submit a request as described in this section, please contact policy@joinswsh.com and title your email “CCPA Request”. Your rights may be subject to additional requirements and exceptions under the CCPA.

Please note that we may process Personal Data of our customers’ end users or employees in connection with our provision of certain services to our customers. If we are processing your Personal Data as a service provider, you should contact the entity that collected your Personal Data in the first instance to address your rights with respect to such data.

If there are any conflicts between this section and any other provision of this Privacy Policy and you are a California resident, the portion that is more protective of Personal Data shall control to the extent of such conflict. If you have any questions about this section or whether any of the following rights apply to you, please contact us at policy@joinswsh.com.

Access

You have the right to request certain information about our collection and use of your Personal Data over the past 12 months. In response, we will provide you with or instructions for you to access the following information:

  • The categories of Personal Data that we have collected about you.
  • The categories of sources from which that Personal Data was collected.
  • The business or commercial purpose for collecting or selling your Personal Data.
  • The categories of third parties with whom we have shared your Personal Data.
  • The specific pieces of Personal Data that we have collected about you.

If we have disclosed your Personal Data to any third parties for a business purpose over the past 12 months, we will identify the categories of Personal Data shared with each category of third party recipient. If we have sold your Personal Data over the past 12 months, we will identify the categories of Personal Data sold to each category of third party recipient.

Deletion

You have the right to request that we delete the Personal Data that we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, we may need to retain your Personal Data to provide you with the Services or complete a transaction or other action you have requested, or if deletion of your Personal Data involves disproportionate effort. If your deletion request is subject to one of these exceptions, we may deny your deletion request.

Correction

You have the right to request that we correct any inaccurate Personal Data we have collected about you. Under the CCPA, this right is subject to certain exceptions: for example, if we decide, based on the totality of circumstances related to your Personal Data, that such data is correct. If your correction request is subject to one of these exceptions, we may deny your request.

Limit the Use of Sensitive Personal Data

Biometric Information is deemed “Sensitive” Personal Data under the CCPA. We will only collect your Biometric Information with your consent, in connection with our “Find Photos of You” feature. You can revoke your consent at any time by changing our settings in the “Permissions” section of your swsh profile settings. For more information, please see the “Information about Biometric Information” section of this Privacy Policy.

Personal Data Selling and Sharing

We will not sell or share (as such terms are defined under the CCPA) your Personal Data, and have not done so over the last 12 months. To our knowledge, we do not sell or share the Personal Data of minors under 16 years of age.

We Will Not Discriminate Against You for Exercising Your Rights Under the CCPA

We will not discriminate against you for exercising your rights under the CCPA. We will not deny you our goods or services, charge you different prices or rates, or provide you a lower quality of goods and services if you exercise your rights under the CCPA. However, we may offer different tiers of our Services as allowed by applicable data privacy laws (including the CCPA) with varying prices, rates or levels of quality of the goods or services you receive related to the value of Personal Data that we receive from you.

11. Other State Law Privacy Rights

Under California Civil Code Sections 1798.83-1798.84, California residents are entitled to contact us to prevent disclosure of Personal Data to third parties for such third parties’ direct marketing purposes; in order to submit such a request, please contact us at policy@joinswsh.com.

Your browser may offer you a “Do Not Track” option, which allows you to signal to operators of websites and web applications and services that you do not wish such operators to track certain of your online activities over time and across different websites. Our Services do not support Do Not Track requests at this time. To find out more about “Do Not Track,” you can visit www.allaboutdnt.com — opens in a new tab.

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A..

12. Changes to this Privacy Policy

We’re constantly trying to improve our Services, so we may need to change this Privacy Policy from time to time, but we will alert you to any material changes by placing a notice on the swsh website, by sending you an email and/or by some other means. Please note that if you’ve opted not to receive legal notice emails from us (or you haven’t provided us with your email address), those legal notices will still govern your use of the Services, and you are still responsible for reading and understanding them. If you use the Services after any changes to the Privacy Policy have been posted, that means you agree to all of the changes. Use of information we collect is subject to the Privacy Policy in effect at the time such information is collected.

13. Contact Information

If you have any questions or comments about this Privacy Policy, the ways in which we collect and use your Personal Data or your choices and rights regarding such collection and use, please do not hesitate to contact us at:

https://www.joinswsh.com — opens in a new tab

policy@joinswsh.com

169 Madison Ave #2350 New York, NY 10016

Individuals and the data protection supervisory authorities in the EU/EEA and individuals and the data protection supervisory authority (“ICO”) in the UK may also contact our data protection representatives according to Article 27 GDPR:

EU: DP-Dock GmbH, Attn: SOMEWHERE SOMEHOW, Ballindamm 39, 20095 Hamburg, Germany

UK: DP Data Protection Services UK Ltd., Attn: SOMEWHERE SOMEHOW, 16 Great Queen Street, Covent Garden, London, WC2B 5AH, United Kingdom

www.dp-dock.com — opens in a new tab

swsh@gdpr-rep.com