This Notice describes the information we process to support Swike and other products provided by Swike Limited (the “Products”).
By creating an account with Swike you consent to this policy governing your use of our Products.
What kinds of information do we collect?
To provide the Products, we must process certain information about you.
Things that you and others do and provide
- Information and content you provide: we collect the content and other information you provide when you use our Products, including when you sign up for an account, and when you choose, create or share content. This can include information in or about the content that you provide (e.g. metadata), such as the location of a photo or the date a file was created.
- Connections: we collect information about the people and accounts that you are connected to and how you interact with them across our Products.
- Your usage: we collect information about how you use our Products, such as the types of content that you view or engage with, the actions you take, and the time, frequency and duration of your activities. For example, we log when you’re using and have last used our Products, and what posts and other content you view and choose on our Products.
- Things others do and information they provide about you: we also receive and analyse content and information that other people provide when they use our Products. This can include information about you, such as when others share a photo of you.
How do we use this information?
We use the information that we have (subject to choices you make) as described below, and to provide and support the Products and related services.
Provide and improve our Products
We use the information we have to deliver our Products, including to personalise content, and for continuous improvement, including:
- Information across Products and devices: we may connect information about your activities on different Products and devices to provide a more tailored and consistent experience on all Products that you use, wherever you use them.
- Location-related information: we use location-related information – such as your home country – to provide, personalise and improve our Products, including ads, for you and others. Location-related information can be based on things such as precise device location (if you’ve allowed us to collect it), IP addresses and information from your and others’ use of our Products.
- Product research and development: we use the information we have to develop, test and improve our Products, including by conducting surveys and research, and testing and troubleshooting new products and features.
- Ads and other sponsored content: please the ‘Marketing’ section below for more details
Providing measurement, analytics and other business
We use the information we have to help advertisers and other partners measure the effectiveness and distribution of their ads and services, and understand the types of people who use their services and how people interact with their websites, apps and services.
Promote safety, integrity and security
We use the information that we have to verify accounts and activity, combat harmful conduct, detect and prevent spam and other bad experiences, maintain the integrity of our Products, and promote safety and security on and off Swike Products. For example, we use data that we have to investigate suspicious activity or violations of our Terms.
Communicate with you
We use the information that we have to send you marketing communications, communicate with you about our Products and let you know about our terms. We also use your information to respond to you when you contact us.
Is user data used for marketing?
We allow advertising on our platform, so that we can continue to offer it for free.
Swike provides some adverts directly. These are not based or targeted using users’ past behaviour. However, to ensure that adverts are more relevant and interesting, we do attempt to align adverts to users’ ‘my topics’ choices.
In addition, some adverts may be provided by third party providers. These partners may collect anonymous identifiers to enable and optimize their advertising, to deliver tailored ads related to your interests (Interest-Based Advertising ” or ” IBA “), and to improve and measure the effectiveness of ad campaigns. These identifiers are non-permanent, non-personal, device identifiers.
You can opt-out of personalised advertising directly through these partners:
AdMob by Google
AdMob by Google is provided by Google Inc.
You can opt-out from AdMob by Google service by following the instructions described by Google Inc.: https://support.google.com/ads/answer/2662922?hl=en
How is this information shared?
Your information is shared with others in the following ways:
Sharing on Swike Products
- Content that you share: when you post on Swike, the post (which includes a link to your account) will be accessible by other account holders around the world.
- Content that others share or re-share about you: other account holders are able to share your activity with others on and off our Products. For example, when you post to Swike, they can screenshot or re-share that content to others across or off our Products. People can also use our Products to create and share content about you with other account holders. For example, people can share a photo of you. If you are uncomfortable with what others have shared about you on our Products, please contact us at ‘[email protected]’.
If the ownership or control of all or part of our Products or their assets changes, we may transfer your information to the new owner.
Sharing with third-party partners
We work with third-party partners who help us provide and improve our Products. We impose strict restrictions on how our partners can use and disclose the data we provide. Here are the types of third parties that we share information with:
- Advertisers: we provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don’t share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission. For example, we may provide general demographic and interest information to advertisers (for example, that an ad was seen by a woman between the ages of 25 and 34 who lives in Spain) to help them better understand their audience.
- Service providers: we provide information and content to service providers who support our business, such as by providing technical infrastructure services, analysing how our Products are used, providing customer service, or conducting surveys.
- Regulators / law enforcement: we share your information with regulators, law enforcement or others:
- In response to a legal request, if we have a good-faith belief that the law requires us to do so. We can also respond to legal requests when we have a good-faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction and is consistent with internationally recognised standards.
- When we have a good-faith belief that it is necessary to: detect, prevent and address fraud, unauthorised use of the Products, breaches of our Terms of Service, or other harmful or illegal activity; to protect ourselves (including our rights, property or Products), you or others, including as part of investigations or regulatory enquiries; or to prevent death or imminent bodily harm. For example, if relevant, we provide information to and receive information from third-party partners about the reliability of your account to prevent fraud, abuse and other harmful activity on and off our Products.
What is our legal basis for processing data?
We collect, use and share the data that we have in the ways described above:
- As necessary to fulfil our Terms of Service;
- As necessary to comply with our legal obligations;
- To protect your vital interests, or those of others;
- As necessary in the public interest; and
- As necessary for our (or others’) legitimate interests, including our interests in providing an innovative, personalised, safe and profitable service to our users and partners, unless those interests are overridden by your interests or fundamental rights and freedoms that require protection of personal data.
How can you exercise your rights provided under data protection legislation?
You have the right to access, rectify, port and erase your data. You also have the right to object to and restrict certain processing of your data. This includes:
- The right to object to our processing of your data for direct marketing, which you can exercise by using the “unsubscribe” link in such marketing communication; and
- The right to object to our processing of your data where we are performing a task in the public interest or pursuing our legitimate interests or those of a third party. You can exercise this right by contacting [email protected]
Data retention, account deactivation and deletion
We store data until it is no longer necessary to provide our services and Products or until your account is deleted – whichever comes first. This is a case-by-case determination that depends on things such as the nature of the data, why it is collected and processed, and relevant legal or operational retention needs. When you delete your account, we delete things that you have posted and you won’t be able to recover this information later. Information that others have shared about you isn’t part of your account and won’t be deleted. To delete your account at any time, please visit the Swike settings
How do we operate and transfer data as part of our global services?
Information will be shared globally with our partners and with account holders around the world in accordance with this Notice. These data transfers are necessary to globally operate and provide our Products to you. We utilise standard contractual clauses approved by the European Commission and rely on the European Commission’s adequacy decisions about certain countries, as applicable, for data transfers from the EEA to the United States and other countries.
How will we notify you of changes to this Notice?
We’ll notify you before we make changes to this Notice and give you the opportunity to review the revised Notice before you choose to continue using our Products.
How to contact us if you have any questions
If you have any questions about this Notice, you can contact us at [email protected] You also have the right to lodge a complaint with Swike Limited’s lead supervisory authority, the Information Commissioner’s Office (ICO), or your local supervisory authority.