CONDUIT LTD., AND/OR ITS SUBSIDIARIES (DOING BUSINESS UNDER THE BRAND NAME: “SWIFTIC”) (“SWIFTIC”, “WE”, “US”, “OUR”), RESPECTS YOUR PRIVACY.
This Policy describes the ways your personal information and data is collected and used and the rights and options available to you with respect to your information. You hereby agree to the use of: (a) electronic means to consent to and complete This Policy and to provide you with any notices given pursuant to This Policy; and (b) electronic records to store information related to this Policy and your use of the App.
Personal information that you voluntarily provide
You may engage in certain activities provided or supported by Swiftic Solution, including the App, such as: registration, request forms, signing-up for features, promotions, e-commerce, customer membership / community / “followers” club / association (or their equivalent), reward programs, loyalty features (e.g.: scratch card, point accumulation plans, punch card, coupons, gift card, cash back or their equivalent; collectively: “Loyalty Features”), scheduling/booking services, newsletter, etc. (together: “Forms”). When you do this, you may be asked to provide certain personal information, as determined by the Brand Owner (or Brand Owners, if you downloaded several apps powered by us) or the third party providing such features, services and/or reward programs. This information is provided by you voluntarily and stored in our database once you provide or submit it to Swiftic Solution (as the case may be).
Your information may be provided in several occasions or phases and/or in separate submissions, as determined by the Brand Owner (or Brand Owners, if you downloaded several apps powered by us) and enabled by us. Please note that refusal or avoidance to provide any additional information or to accept further terms or offers shall not derogate from our right to store former information provided or submitted to Swiftic Solution.
The Brand Owner may choose fields for mandatory completion, which will be explicitly indicated. If you do not provide the requisite data in these fields, you may not be able to register or engage in that specific activity, feature or service.
The App may also allow you to upload photos, in which case the photos you upload will be shared with and may be viewed by all other users of the App and will be stored by us.
Other Information collected
We collect information about your mobile device, such as your mobile device identifier and/or account identifier (Android UDID, iOS UUID; Advertising ID: IDFA for iOS devices and AAID for Android devices, or their equivalent), the Internet protocol (IP) address your device uses to access the Internet, geo-location, your device type and its operating system version. We also collect information regarding the websites and content you have accessed, clicked or interacted with through the App as well as information regarding the interactions you make with the App’s interface such as your logging info, the App’s tabs, banners, or pages that you have clicked on or accessed, ads and/or promotions you have viewed through the App and receipt of notifications sent to you through the App.
We may collect information regarding your participation in or use of certain Loyalty Features.
Other information such as purchase details (e.g., time and date of your purchase, place where purchase was made, the amount paid and information about the items purchased), may be collected while you use App features and/or when you make a purchase at the Brand Owner.
E-commerce Providers may be collecting additional information regarding your interactions with their systems and may share such information with us. For information about their privacy practices, refer to their privacy policies.
When you place online orders through the App, we may collect information that you, or the E-commerce Providers choose to share with us. This information may include your name, email address, shipping address, amount billed and information about the items ordered. We may use, share and transfer such information as described in this Policy.
By disabling your geo-location (through the mobile device operating system), certain features which require your geo-location information may not function or may be interrupted.
Collection of some information may be performed if the Brand Owner (or Brand Owner, if you downloaded several apps powered by us) chooses to enable the relevant feature or to use the relevant form or capability enabled by Swiftic Solution.
Information Shared with Us
We may receive other information collected by third parties which may include information you voluntarily provided or was collected from you, or information which is referred to you if you voluntarily identified yourself with the Brand Owner (“Shared Information”). We are not responsible for the Shared Information, nor for its collection or sharing practices or authorizations. You hereby agree that the Shared Information shall be used in accordance with and subject to the terms of this Policy, and it will be added to or combined with collected, used and/or shared information about you under this Policy.
Personal information about children who are under 13 years of age is not knowingly or intentionally collected. If you are under age of 13 years, you are not permitted to use any aspect of Swiftic Solution, including the App.
Use of collected information
The information collected may be used for the following purposes:
Sharing it with or transferring it to others, as the case may be, as detailed in the next section (“Sharing collected information”);
To provide you with Swiftic Solution’s (including the App) functionality, features and services, send you, from time to time, push notifications from the Brand Owner or from us.
To remotely update the App on your mobile device when a new version is released;
To provide you with the specific and/or personalized activity, promotion, feature and/or service via the App and send you, from time to time, push notifications regarding your use of such specific activity, promotion, feature and/or service;
To provide you with offers and/or promotions from the Brand Owner which are based on your location as identified and collected by us (“Location Based Services”). Location Based Services may apply whenever your location is made available to us via your mobile phone operating system or from other available sources that we are connected withvia our Swiftic Solution, such as purchases you make at the Brand Owner’ (or Brand Owner if you chose to download several apps powered by us) premises.
To improve and customize the experience of using the App and the offerings made through the App;
To develop new services and update or upgrade existing services;
To manage the administrative and operational aspects of Swiftic Solution, including the App (such as Brand Owner and advertisers’ payments);
To enforce this Policy and the Terms and prevent unlawful activities and misuse of the App;
To comply with any applicable law and assist law enforcement agencies when we have a good faith belief that our cooperation with them meets the applicable legal standards; and
To take any action in any case of dispute involving you with respect to the App.
Sharing and transferring collected information
The information outlined in the preceding sections, may be shared with, or transferred to others, as the case may be, in any of the following instances:
Personal and/or registration information or Forms you have filled out and requests you have submitted which are intended for the Brand Owner – will all be shared with or transferred to the Brand Owner, for its own purposes;
We may share with the Brand Owner (or Brand Owner, if you downloaded several apps powered by us), for their own purposes, information obtained from: your use or participation in the App, Loyalty Features, purchases you have made which are handled via Swiftic Solution, including purchases made through the App (or Apps, if you downloaded several apps powered by us), and items you have ordered;
Information of the activities you scheduled via the App will be shared with Ping Up in order to provide you with scheduling services and with the Brand Owner, for its own purposes;
Photos you have uploaded through the App will be shared with all other users of the App as well as the Brand Owner;
Your location may be shared with the Brand Owner (or Brand Owner, if you downloaded several apps powered by us), for ad delivery and promotion purposes;
Information that we collect or obtain through the App may be shared with third parties such as service providers, to operate, maintain and enhance the App, your engagement with the App and Swiftic Solution, and provide you with the App’s features and functionalities (such as online ordering and push notification);
If you have breached the Terms or this Policy, abused your rights to use the App, or violated any applicable law, or in any other case of dispute, or legal proceeding of any kind involving you with respect to the App, your information may be shared with competent authorities and with any third party, as may be required;
We may share information that we collect or obtain through the App with the relevant authorities, entities or persons if we reasonably believe that we are required by law to share or disclose your information;
Personal identifiable information may be shared with, or transferred to, our affiliated corporate group entities (entities controlled by, under common control with, or controlling us, directly or indirectly), but their use of such information must comply with this Policy; and
Please note that the Brand Owner may choose to make available additional terms in regard of the App (“Brand Owner Terms”) which may include, inter alia, provisions with respect to the information collected by the Brand Owner and/or shared with it by Swiftic. In any discrepancy between this Policy and the Brand Owner Terms this Policy shall prevail.
Upon bankruptcy, dissolution or other liquidation or insolvency events or in the event of merger, sale or transfer of all or a portion of our assets or shares or other reorganization or reconstruction in our ongoing business, the information that we collect or obtain, as outlined in the preceding sections, may be shared with or transferred to, that respective entity, provided that it undertakes to be bound by the provisions of this Policy, with reasonably necessary changes taken into consideration. Upon such transfer or sharing of information, that entity will assume full and exclusive responsibility for all subsequent use and processing it makes of the information and we will be released from any liability to you, regarding the succeeding entity’s use and processing of the information.
In any case other than the above mentioned in this Policy, your personally identifiable information will be shared with others only if you provide your consent.
Aggregated or anonymized information
The App collects anonymized as well as aggregated information, which does not identify you personally. Such anonymized or aggregated information may be used in any way, including by posting, disseminating, transmitting or otherwise communicating or making it available to the Brand Owner, Partner as well as any other third party.
Third party services, links and advertisements
You may be providing information through certain areas, features, frames or sections of the App, that are operated by or for third parties. Those third parties may include the Brand Owner from whom you may place certain orders, POS, e-commerce platforms such as Amazon and Shopify, scheduling partners such as PingUp, payment services providers such as, PayPal and Stripe and Payment Processors (as defined in the Terms) (all collectively “E-commerce Providers”).
It may happen that the App may contain or present advertisements (including banners) as well as links to third party websites. Advertisements may be facilitated by third party ad networks that serve advertisements originating from third parties, or by Swiftic that serves advertisements or promotions regarding other mobile application generated or administered by Swiftic. Though we collect certain parameters related to your interactions with advertisements (as detailed in this Policy), we are not responsible for the privacy practices of third party advertisers and ad networks, and this Policy does not apply to them. We are also not responsible for the privacy practices of third party websites that the App may contain links to. Please refer to the privacy policies of those advertisers, ad networks, and third party websites to determine whether their privacy practices are acceptable to you.
Transfer of data outside your territory
The App, by its nature as an online service, may store and process information in Europe, the United States and in other various locations throughout the globe. If you are a resident in a jurisdiction where transfer of your personal information to another jurisdiction requires your consent, then you hereby provide your express and unambiguous consent to such transfer.
Accessing or deleting personal information
You may submit to the following mail address: firstname.lastname@example.org, a request to delete or remove the personal information collected through your use of the App and/or Swiftic Solution to. You may be asked to provide additional information to verify your identity. Note that the App or certain features or services of the App may not be available or function if such information is deleted or removed.
Be advised that following deletion of your personal identifiable information from primary storage, you will no longer be registered as a user in our systems, however, some personal information may still reside in our systems in archived form in such areas which we do not access for using such information.
PLEASE NOTE THAT REMOVAL OF THE APP FROM YOUR DEVICE DOES NOT CAUSE A DELETION OF THE INFORMATION YOU VOLUNTARILY PROVIDED OR INFORMATION THAT WE COLLECTED IN ACCORDANCE WITH THIS POLICY. YOUR PERSONAL INFORMATION WILL BE DELETED BY US FOLLOWING YOUR REQUEST AND/OR IN ACCORDANCE WITH OUR DATA RETENTION POLICY.
Security measures are implemented to reduce the risks of damage, loss of information and unauthorized access or use of information. However, these measures are unable to provide absolute information security. Therefore, although efforts are made to secure your personal information, it is not guaranteed and you cannot reasonably expect that the App and its related databases will be immune from any wrongdoings, malfunctions, unauthorized interceptions or access, or other kinds of abuse and misuse.
Changes to this Policy
This Policy may be changed from time to time. Substantial changes will take effect 30 days after an initial notification is posted through the App. Other changes will take effect 7 days after their initial posting within the App and in the following link: http://app4mobilebiz.wpengine.com/swiftic-mobile-app-end-user-privacy-policy.html. However, if the Policy is amended to comply with legal requirements, the amendments will become effective immediately upon their initial posting, or as required. The most up-to-date Policy is accessible through the App’s settings or information menu and in the following link: http://app4mobilebiz.wpengine.com/swiftic-mobile-app-end-user-privacy-policy.html.
You agree to be bound by any of the changes made to this Policy. Your continued use of the App after the changed take effect will indicate your acceptance of the amended Policy. If you do not agree with the amended Policy, you must uninstall the App and avoid any further use of it.
You may send requests, responses, questions and complaints by email.
For your convenience, this Policy may be translated from English to several other languages. Please note that in any discrepancies between the translation available to you (if any) and the English version, the English version (available at: http://app4mobilebiz.wpengine.com/swiftic-mobile-app-end-user-privacy-policy.html) shall prevail.
Last Updated: 14.12.2017