Privacy Policy
Effective October 1, 2006
Explanation of Service
Swirl provides the Swirl Connect software (software) and the My Swirl web site and control panel (service) for use by its registered members. Registered members create accounts, and have the option of adding a profile and pictures, creating buddy lists, connecting with other Swirl members, and sharing information with other members. Members can control how other members and the service communicate with them.
Use of Information
Swirl respects your privacy. We will not sell, rent, loan, trade, lease, or otherwise transfer any personal information collected through our software or service to any third party. We may, however, engage a third party in order to carry out communications and / or marketing, strictly on Swirl’s behalf and under our responsibility.
Any private information you provide to Swirl will be considered confidential, and we will not disclose it to anyone outside the Swirl service, nor for any reason other than to run the Swirl software and service. The privacy of any information you provide in your communications with other Swirl members, or through your profile or similar means, will be governed by the applicable settings you have selected in the software.
In the event that Swirl is ever sold, acquired, merged, liquidated, reorganized, or otherwise transferred, Swirl reserves the right to transfer its user databases together with any personally identifiable information contained therein, to a third-party acquiring Swirl’s assets. In this event, public notices of such will be available via the web site.
Types of Information Collected
Non-personal Information
Swirl logs non-personally-identifiable information including IP address, aggregate user data, browser type, phone and carrier types, etc. from users and visitors to the site. This data is used to manage the web site, track usage, and improve our services. Additionally, user IP addresses are recorded for security and monitoring purposes.
Account Information
When user accounts are created, information about your phone, your name, age, home address, and e-mail address are required. This information is used internally by Swirl to configure and operate the service, and is never shared with anyone, including other Swirl users. Swirl may use any of this information to provide service alerts or to customize your experience using the software or service.
For the geomapping and location features, your home location is randomly altered, and cannot be discovered by other users. To users on your buddy list, an approximation of your location appears, never a precise location, similar to the approximations used in local connections.
Your age is used to preconfigure privacy and communication settings during your use of the software and service, and may be shared with other users of the service, depending on your privacy settings.
If billing information should be collected at any time in the future, it will be stored directly and securely by a third-party billing provider according to local laws and regulations. Swirl will never have access to this information, but will have access to billing status. Billing information will only be stored in order to comply with local regulations, and to provide you with accurate billing information and service.
Profile Information
Swirl members have the option to build out their personal and award profiles, where information like descriptive tags, education, occupation, links to social networking sites, and photos is collected. This information is viewable by other Swirl members.
Service Information
During the course of using the service, information like location and hotspot tags can be submitted by users. This information is associated with a particular location and is viewable by any Swirl member.
Other types of service information include geotagged pictures, notes, or videos that can be submitted by users. This information is publicly viewable or only viewable to a buddy list, depending on your settings. Your current and past locations are only disclosed to other Swirl members (non-buddies) when you actively do so by submitting content of this nature.
Messages and communications between users can be stored on Swirl servers, but only to provide you with ongoing access to such information. This information is not used by Swirl for any purpose, and is only viewable by those Swirl members who are a party to it, and only for as long as they wish to have access to it.
Passive Information
Passive information is limited to information that is necessary in order to provide you with the desired functionality of the software and service, and may include information like a session ID token, source and destination addressing information, and software version. Passive information is automatically generated and is not stored centrally, except for anonymously aggregated statistical information used to provide you with better service, or statistical information used solely for the purposes of detecting fraud or to block access to Swirl.
Like many other sites, our web site utilizes cookies. Cookies are small data text files stored on your hard drive. Cookies were designed to help web sites save and remember any preferences that may have been set while the web site is browsed. Swirl uses cookies for the limited purposes of enhancing your visit to our web site and enabling us to track and target interests of Swirl members. A cookie cannot be read by any site other than the one that set the cookie. No other company will have access to our cookies. A cookie cannot retrieve any other data from your hard drive, pass on a computer virus, or capture your e-mail address.
Spyware-Free / Adware-Free
No information concerning your computing facilities is collected that is not related to providing Swirl services, including other installed software systems, non-service-related content, or hardware peripherals. No information about your specific computing facilities will be provided to any third party unless required by the Terms of Service.
Feedback
In some cases, Swirl might solicit input and feedback from Swirl users, or Swirl might receive unsolicited feedback from forms or trouble tickets. Swirl reserves the right to utilize this information for marketing, informational, or support purposes, for instance by displaying selected comments on its web site or in other communications. If Swirl chooses to display a user-submitted comment it will either display it anonymously, stripping away all personally identifiable information, or request permission directly from you before displaying it.
Security
Swirl member accounts are protected by a user-generated password. It is the member’s responsibility to keep this password safe, and to monitor usage of an account. Sensitive information of this type stored on a member’s phone is encrypted, and private information is password-protected.
We employ industry-recognized information technology to protect the security of the information you submit to us. Our secure servers protect this information using password protection and advanced encryption, and we may use firewall technology for additional protection. All of the data we collect is protected against unauthorized access by physical security means.
While we use reasonable measures to protect member information that is stored within our databases, please note that we cannot guarantee the security of member account information. Unauthorized entry or use, hardware or software failure, and other factors may compromise the security of member information at any time.
Sharing and Disclosure of Information
Except as otherwise described in this privacy statement, Swirl will not disclose personal information to any third party unless we believe that disclosure is necessary: 1) to conform to legal requirements or to respond to a subpoena, search warrant or other legal process, whether or not a response is required by applicable law; 2) to protect the safety of members of the public and users of the service; or 3) to enforce the Swirl Terms of Service or to protect our rights.
Children
No part of the software or service is directed towards children. The minimum age requirement to use Swirl is 14. We will never knowingly collect information from users under the age of 14. Special precautions are made to protect users aged 14 through 17.
Risks and Disclaimers
Please be careful and responsible whenever you’re online. If you post personal information online that is accessible to the public, you may receive unsolicited messages from other parties in return. While we strive to protect your personal information, we cannot ensure or warrant the security of any information you transmit to us, except for information specifically covered by our Terms of Service. The use of the Swirl software and service is done at your own risk.
Changes in Our Privacy Policy
From time to time we may make changes to our privacy policy. If changes are made, they will be posted to our web site, and a notice will be posted on the Swirl Blog. Swirl members are bound by any minor changes to the policy when the software or service is used after the changes are posted. If, however, there are material changes to this privacy policy, a notice will be posted on our web site home page for 30 days.
Contacting Us
If you have any questions about this privacy statement or the practices of this site, please contact us.