Last updated: July 20, 2022
1. Children Under the Age of 18
We do not knowingly collect personally identifiable information from anyone under the age of 16, and you should not provide us with any information regarding any individual under the age of 16. If we learn that we have inadvertently gathered information from anyone under the age of 16, we will take reasonable measures to promptly remove that information from our records.
2. What Information We Collect and How We Collect It
We receive and collect several types of information about you, such as the information described below.
Information you provide to us: From time to time, you may provide us with certain information, including Your Information, such as your name and email address. Instances where you may provide this information include when you sign up for an account on our Site, purchase products or merchandise on or through our Site, fill out forms or fields on or through our Site, or sign up for any promotions or to receive newsletters or other materials from or about us.
Information we receive from third parties: We may obtain information about you from sources other than you, such as from our payment processing services provider (currently Shopify Inc.) when you make payments for a product or merchandise on or through our Site. Any content or information submitted by you to third-parties will be used and disclosed by such third parties in accordance with their respective privacy policies. You should review the privacy policies and practices of such third parties prior to disclosing information to them.
We may also collect information on third party platforms such as Google AdWords, Google Analytics, etc. Additionally, some information we collect is publicly available. For example, we may collect information you submit to a blog, a chat room, or a social network like Facebook, Instagram, Twitter or Google+.
Information we collect automatically: As you navigate through and interact with our Site, we and third parties acting on our behalf may use automatic data collection technologies to collect certain information. See Section 3 “Cookies and Other Automatic Tracking Technologies” for more information.
Our Collection Practices with Respect to Certain Specific Information:
Device Information. When you access or use our Site through your computer, mobile phone or other device, we may collect information regarding and related to your device, such as hardware models and IDs, device type, operating system version, the request type, the content of your request, and basic usage information about your use of our Site, such as date and time. In addition, we may collect information regarding application-level events, such as crashes, and associate that temporarily with your account (if any) to provide customer service. We may also collect and store information locally on your device using mechanisms such as browser web storage and application data caches.
Location Information. If you submit your zip code or other geographic information to us, you may provide us with your location information. Furthermore, if you enable the collection of location information on your device, then we may collect information about your actual location, such as your mobile device’s GPS coordinates. We may also use other technologies to determine your location (such as through the location of nearby Wi-Fi access points or cell towers) or obtain your location information from third parties.
Communications with Us. We may collect information about your communications with us, including relating to support questions, your account, and other inquiries.
3. Cookies and Other Automatic Tracking Technologies
Description of the Technologies Utilized on our Site: We may use various technologies to collect and store information when you access or use our Site, including sending cookies, embedded scripts, web beacons, pixel tags or other anonymous identifiers to your device, or otherwise tracking your activities on our Site over time. We also may use these technologies to collect information about your online activities over time and across third-party websites or other online services (a practice known as “behavioral tracking”).
• “Cookies” are small web files that a site or its provider transfers to your device’s hard drive through your web browser that enables the site’s or provider’s system to recognize your browser and remember certain information. The length of time a cookie will stay on your browsing device depends on whether it is a “persistent” or “session” cookie. Session cookies will only stay on your device until you stop browsing. Persistent cookies stay on your browsing device until they expire or are deleted. A “web beacon” is a type of technology that lets us know if you visited a certain page or whether you opened an email. A “pixel tag” is a type of technology placed within a website or e-mail for the purpose of tracking activity, which is often used in combination with cookies. Other “anonymous identifiers” include random strings of characters used for the same purposes as cookies, such as with mobile devices where cookie technology may not be available. These technologies help us know that you are logged on to or using our Site, provide you with features based on your preferences, help us understand when and how you are interacting with our Site, and compile other information regarding your use of our Site.
• With respect to Cookies, we use first-party and third-party cookies to: make our Site function properly; improve our Site; make access to our Site easier; recognize you when you return to our Site; track your interaction with our Site; enhance your experience with our Site; remember information you have already provided; collect information about your activities over time and across third-party websites or other online services in order to deliver content and advertising tailored to your interests; and to provide a secure browsing experience during your use of our Site. The categories of cookies used or that may be used on our Site include:
- Strictly Necessary Cookies, which are needed for our Site to operate as you reasonably expect.
- Functional or Preference Cookies, which are used to remember your name or choices.
- Performance or Analytic Cookies, which collect passive information about your use of our Site.
- Advertising or Targeting Cookies, which are used to make advertising messages more relevant and
• We may use Third-Party Service Providers to monitor and analyze the use of our Site. For example, we may use Google Analytics as one of our analytics service providers that tracks and reports Site traffic.
The information collected through these technologies, standing alone, cannot be used to determine your identity. Such information may, however, be combined in a way that makes it become personally identifiable information (i.e., information that can identify you). For example, we may tie this information to personal information about you that we collect from other sources or that you provide to us. If this happens, we will treat the combined information as personally identifiable information.
Choices as to Cookies and Other Automatic Tracking Technologies: It may be possible to disable some (but not all) Cookies or automatic data collection technologies through your device or browser settings, but doing so may affect the functionality of all or a portion of our Site. The method for disabling Cookies or other automatic collection technologies may vary by device and browser but can usually be found in preferences or security settings. For example, iOS and Android devices each have settings which are designed to limit forms of ad tracking. See Section 6 “Choices About How We Use and Disclose Your Information” for more information.
Do Not Track Requests: Some Internet browsers, such as Internet Explorer, Firefox, and Safari, include the ability to transmit “Do Not Track” or “DNT” signals. Since uniform standards for “DNT" signals have not been adopted, our Site does not currently process or respond to “DNT” signals.
4. How We Use Your Information
We may use the information we collect for various lawful business purposes. Among others, these purposes may include using this information, including Your Information, to:
• Present our Site and related content to you. For example, to provide our Site, including its features, products and services to you and/or other account owners, and to customize services features and recommendations for accounts users. We may also use Your Information to manage our relationships and contracts with customers and account holders, including billing, compliance with contractual obligations, and related administration.
• Contact you and provide you with information. For example, if you complete the “contact us” form on our Site, we might contact you via e-mail or other communications to provide you with information regarding our Site, products, promotions, offers, personalized information and other information from us or our third-party service providers or business partners or to respond to comments, inquiries, and other information submitted by you.
• Provide you with customer support. For example, if you request us to contact you in connection with any customer support matters, we may collect certain information from you in order to assist you as requested.
• Analyze, improve and manage our Site, products, service offerings and operations. For example, we might obtain feedback regarding our Site, products, and service offerings, understand and anticipate your needs and preferences, better understand your use of our Site or products or service offerings, customize and tailor Site content and advertising, improve our marketing and promotional efforts, engage in statistical analysis and provide feedback or information to our business partners, vendors, advertisers and other third parties.
• Display advertisements to our advertisers' target audiences. For example, we may use your device information for direct advertising and retargeting ads, such as providing you with information or advertising relating to our products and services based on your precise geolocation, when in line with the preferences you have shared with us. Additionally, even though we do not disclose your personal information for these purposes without your consent, if you click on or otherwise interact with an advertisement, the advertiser may assume that you meet its target criteria. Note also that our third-party content providers may use information they collect via our Site to provide you with interest-based (aka behavioral) advertising or other targeted content.
• Comply with a request from you in connection with the exercise of your rights. For example, where you have asked us not to contact you for marketing purposes, we or our service providers will keep a record of this on our suppression lists to be able to comply with your request.
• Other Purposes. We may also use Your Information in other ways. To the extent required by applicable law, we will provide notice at the time of collection and obtain your consent.
5. How We Disclose Your Information
General Disclosure of Your Information: We may disclose the information we collect, including Your Information:
• to our third-party vendors or suppliers (including our payment processing third-party provider and our hosting provider) so that they may provide support for our internal and business operations, including for the processing of your payment for a product, data verification, data storage, surveys, research, internal marketing, delivery of promotional, marketing and transaction materials and our Site’s maintenance and security. For example, we use (and thus disclose certain of Your Information to):
• Our third-party contact management and message sending provider (currently Klaviyo, Inc.). Klaviyo Inc.’s privacy and opt-out policies are located here: https://www.klaviyo.com/legal/privacy-policy.
• Google Analytics so that they can help us understand how our customers use our Site – you can read more about how Google uses Your Information here: https://www.google.com/intl/en/policies/privacy/. You can also opt-out of Google Analytics here: https://tools.google.com/dlpage/gaoptout.
• to our affiliates and their respective employees, agents and representatives involved in delivering our Site, products and other services to you;
• to fulfill the purpose for which you provide it;
• to any person who, in our reasonable judgment, is authorized to receive Your Information as your agent, including as a result of your business dealings with that person (for example, your attorney);
• to third parties when you engage in certain activities through our Site, such as those financial or other institutions with which you maintain accounts to which you have authorized us to access for purposes of providing our Site to you;
• as required by applicable law or ordered by a court, regulatory or administrative agency;
• as we deem necessary, in our sole discretion, if we believe that you are violating any applicable law, rule, restriction or regulation, or are otherwise interfering with another’s rights or property, including our rights or property;
• if requested by authorities in the event of any act instance of local, regional or national emergency;
• with your consent;
• to otherwise enforce or protect our rights; and
• in connection with a Business Transfer (see “Other Disclosures by Us” below).
Please note that the list above is not exhaustive and that we may, to the extent permitted by applicable law, disclose the information we collect to third parties at any time, for any lawful purpose, without notice or compensation to you.
Other Disclosures by Us:
Aggregation and De-Personalization. We may use and disclose any de-identified information for any lawful purpose, including for any commercial purpose. De-identified Information means information that does not identify you, including any identifiable information de-identified by either combining it with information about others, for example, by aggregating Your Information with information about other persons, or by removing characteristics, such as your name, that make the information personally identifiable to you.
Circumvention of Security Measures: We use certain technical, administrative and organizational security measures to keep Your Information safe. However, despite our efforts, please be aware that methods of transmission and electronic storage are not completely secure. We cannot guarantee the privacy or security of Your Information, as third parties may unlawfully intercept or access transmissions or electronic storage. Further, to the extent permitted by law, we are not responsible for circumvention of any privacy settings or security measures of our Site. Therefore, you use our Site at your own risk, you should not expect that Your Information will always remain private, and we do not guarantee the performance or adequacy of our security measures. In the event that an unauthorized third party compromises our security measures, to the extent permitted by law, we will not be responsible for any damages, directly or indirectly, caused by an unauthorized third party’s ability to view, use or disseminate Your Information.
6. Choices About How We Use and Disclose Your Information
We strive to provide you with choices regarding our collection, use and disclosure of the information that we collect. Below are some mechanisms that provide you with control over such collection, use or disclosure:
Cookies and Other Tracking Technologies. It may be possible to disable some (but not all) Cookies or automatic data collection technologies through your device or browser settings, but doing so may affect the functionality of our Site. The method for disabling Cookies or other automatic collection technologies may vary by device and browser, but can usually be found in preferences or security settings. You can exercise your preferences in relation to cookies served on our Site by taking the steps outlined below.
- First-Party Cookies. You can use the browser with which you are viewing our Site to enable, disable or delete Cookies. To do this, follow the instructions provided by your browser (usually located within the “Help”, “Tools” or “Edit” settings). Please note, if you set your browser to disable Cookies, you may not be able to access secure areas of our Site. Also, if you disable certain Cookies, other parts of our Site may not work properly. You can find more information about how to change your browser Cookie settings at allaboutcookies.org.
- Third-Party Cookies. To opt out of third-party advertising networks and similar entities that use advertising Cookies go to aboutads.info/choices .
We do not control third parties’ collection or use of Your Information to serve interest-based advertising. However, these third parties may provide you with ways to choose not to have Your Information collected or used in this way. In addition, most web browsers provide help pages relating to setting Cookie preferences. More information may be found for the following browsers here:
• E-mail Offers. If you do not wish to receive e-mail offers or other information or communications from us, you can opt-out of receiving such e-mail offers or other information or communications from us (other than e-mails or other information or communications related to correction of user data, change of password and other similar communications essential to your transactions on or through our Site) by using the unsubscribe process at the bottom of the e-mail. Please be aware that it can take up to 10 business days to remove you from our marketing e-mail lists. If you opt-out from receiving our marketing e-mails, you may continue to receive certain status e-mails relating to your transactions on or through our Site.
• Managing Your Information. If you create an account with us, then you can review and update Your Information by logging into that portion of our Site, visiting your account profile page and making changes.
• Online Behavioral Advertising. As described above, we may use Your Information to provide you with targeted advertisements or marketing communications we believe may be of interest to you. Certain third-party advertising networks that deliver behavioral advertising are members of the Network Advertising Initiative (“NAI”). You can prevent NAI member companies from collecting preference data about you by visiting http://www.networkadvertising.org/choices/ and following the NAI’s directions. Note that if you opt out through the NAI, you will still receive advertising. In addition, if you opt out through the NAI and later delete your cookies, use a different browser or buy a new computer, you will need to renew your opt-out choice. Additional options for opting out of target advertising include, without limitation:
- FACEBOOK - https://www.facebook.com/settings/?tab=ads
- TWITTER - https://help.twitter.com/en/safety-and-security/privacy-controls-for-tailored-ads
- GOOGLE - https://www.google.com/settings/ads/anonymous
- BING - https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads
- Digital Advertising Alliance - http://optout.aboutads.info/
For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page. To learn more about how Google collects and uses data, click here. To opt out of Google Analytics Advertising Features please use Google Ad Settings. To opt out of Google Analytics entirely please use this link.
•Nevada Residents. Nevada law permits our users who are Nevada consumers to request that their personal data (as defined under applicable Nevada law) not be sold, even if their personal data is not currently being sold. Requests may be sent to email@example.com and are free of charge.
1. Information that You Disclose to Third Parties
Our Site, including any of our newsletters or e-mail messages, may contain links or access to websites or platforms operated by third parties that are beyond our control. Links or access to third parties from our Site is not an endorsement by us of such third parties, or their respective websites, applications, products, platforms or practices. We are not responsible for the privacy policies, terms and conditions, practices or the content of such third parties. All information that you disclose to such third parties will be subject to the privacy policies and practices of such third parties. You should review the privacy policies and practices of such third parties prior to disclosing information to them. If you have any questions about how these third parties use Your Information, you should review their policies and contact them directly.
1. Operation of our Site in the United States
1. Contacting Us
If you have any questions, suggestions or complaints regarding our use or disclosure of the information we collect from you or wish to contact us to make a request regarding such information (including Your Information), please contact us at firstname.lastname@example.org or in writing at:
Attn: Privacy Request
SWIFT RESPONSE, LLC
2690 WESTON ROAD
WESTON, FL 33331
In contacting us, you must include the reference to our “Privacy Request” on the subject line and in the body of the message and include the email address or mailing address, as applicable, for us to send our response. We reserve the right not to respond to inquiries submitted other than to the address specified above.
1. Privacy Notice for California Residents
Additional Detail on the Information We Collect:
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver's license number, passport number, or other similar identifiers.||YES|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||NO|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||YES|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.||NO|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer's interaction with a website, application, or advertisement.||YES|
|G. Geolocation data.||Physical location or movements.||YES|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||YES|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||YES|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.||NO|
|K. Inferences drawn from other personal information.||Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||YES|
Additional Restriction on Our Use of Your Information:
Additional Detail on Our Disclosure of Your Information:
In the preceding twelve (12) months, we have disclosed the following categories of Your Information for a business purpose:
• [Category A: Identifiers.]
• [Category B: California Customer Records personal information categories.]
• [Category C: Protected classification characteristics under California or federal law.]
• [Category D: Commercial information.]
• [Category E: Biometric information.]
• [Category F: Internet or other similar network activity.]
• [Category G: Geolocation data.]
• [Category H: Sensory data.]
• [Category I: Professional or employment-related information.]
• [Category J: Non-public education information.]
• [Category K: Inferences drawn from other personal information]
Your Additional Rights and Choices under the CCPA:
The CCPA provides California residents (consumers) with specific rights regarding their personal information.
Access to Specific Information and Data Portability Rights. You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you (also called a data portability request).
• If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
• sales, identifying the personal information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Deletion Request Rights. You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information's deletion may likely render impossible or seriously impair the research's achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided.
Exercising Your Access, Data Portability, and Deletion Rights:
How to Exercise. To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request to us by emailing us at email@example.com or making a request through your account profile. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.
General Requirements. You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative. It must also describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you. Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.
Response Timing and Format. We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing. If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information's value and contain written terms that describe the program's material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.
Other California Privacy Rights:
California's “Shine the Light” law permits users of our Site that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to firstname.lastname@example.org or write us at:
Attn: Privacy Request
SWIFT RESPONSE, LLC
2690 WESTON ROAD, SUITE 200
WESTON, FL 33331