Effective Date: 2017-06-08

SWAPSY, Inc., a Delaware corporation (“SWAPSY”), takes your privacy very seriously. This Privacy Policy applies to SWAPSY’s websites (for purposes of this Privacy Policy, "websites" includes www.theswapsy.com and any associated mobile websites) and the services associated with it (the “Service"). Terms used but not defined in this Privacy Policy have the meanings assigned to them in our SWAPSY, Inc. Terms of Use.

We are committed to protecting our customers' privacy and security. This Privacy Policy explains what personal information we collect about you, with whom we share it, and how you (the user of the Service) can direct us not to share certain information with certain parties. "Personal Information" refers to information that can be used to identify or contact an individual. You should read this Privacy Policy in its entirety. Certain sections may apply differently to residents of different jurisdictions.

Information we collect:

We may collect the following information about you in connection with your use of the Services, which may include non-public Personal Information:

Your name, mailing address, email address, telephone number(s), bank account number, credit or debit card number, date of birth and social security number (or other government issues identification numbers);

We may also collect information about your usage of the Services, including your Transaction history, how you use the Services to send or receive Transactions;

Information that we lawfully obtain from third parties, such as identity verification services, electronic database services, and credit reporting agencies;

Information that we indirectly obtain from you, such as information about the device, hardware and software you use when accessing the Services, your IP address, the pages you access on our websites, and other websites that you visit prior to accessing the Services. We may combine this automatically collected log information with other information we collect about you. We do this for fraud prevention, to improve our Services, and to improve our marketing, analytics, or website functionality;

Recordings of your communications with our Customer Service department, including telephone calls and electronic communications; and

Type of device you use, operating system version, and the device identifier.

We may occasionally send you push notifications through our mobile applications to send you marketing messages and other Services or Transaction-related notifications that may be of importance to you. You may at any time opt-out from receiving these types of communications by turning them off at the device level through your settings or through the mobile application settings.

We and our third-party service providers, including our marketing partners and analytics providers, may also use cookies, web beacons, tags, scripts and similar technology ("Cookies"). Cookies are small data files that are placed on your computer or mobile device to, among other things, administer the website, track and analyze trends in your use of our websites, remember your preferences when you return to the website and gather information about our users as a whole. The information we store in the Cookies we place may include your email address in addition to non-Personal Information. We may receive reports from third-party service providers based on their use of Cookies about our users on an individual or aggregated basis.

You are free to decline the Cookies we place if your browser permits, but doing so may interfere with your use of the Services. The use of Cookies by our third-party service providers is not covered by this Privacy Policy. You are free to decline these Cookies if your browser permits. We do not have access or control over these Cookies. In addition, some of our third party advertising vendors or partners show our ads on sites across the Internet. These vendors or partners may use Cookies to gather information about your activities on our website and other websites in order to serve you advertising based on your browsing activities. We do not necessarily have access to or control over the Cookies they use, but you may be able to opt-out of some of their practices by visiting: http://preferences-mgr.truste.com/ or http://www.networkadvertising.org/managing/opt_out.asp. Please note that opting out does not prevent the display of advertisements to you.

As is true of most websites, we gather certain information automatically and store it in log files. This information may include your internet protocol (IP) address, browser type, internet service provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. From time to time, we may combine this automatically collected data to other information we collect about you for reasons such as analysis, security, content generation or marketing.

We may use mobile analytics software to allow us to better understand the functionality of our mobile software on your mobile device. This software may record information such as how often you use the mobile applications, the events that occur within the mobile applications, aggregated usage, performance data, and from where the mobile application was downloaded. We may link the information we store within the analytics software to any Personal Information you submit within the mobile applications.

We currently do not recognize "do-not-track" signals from your browser. We engage third parties, such as marketing or analytics partners, who may collect information about

your online activities over time and across different websites when you use our websites. We use local storage objects, such as Flash Cookies ("LSOs") and Local Storage, such as HTML5, to prevent unauthorized or fraudulent sign ups. Third parties, with whom we partner to provide certain features on our websites or to display advertising based upon your Web browsing activity also use Flash Cookies and HTML5 to collect and store information. Various browsers may offer their own management tools for removing HTML5 LSOs. To manage Flash LSOs please click here: http://www.macromedia.com/support/documentation/en /flashplayer/help/settings_mana ger07.html. Disabling LSOs may affect the performance of our Services.

Why we collect information
We collect information for the following purposes:

We will retain your account information, including but not limited to your payment source information and Personal Information about you, as needed to provide you Services, as required by applicable law, to resolve disputes and to enforce our agreements. SWAPSY abides by strict security standards, but if you wish to cancel your account and stop using SWAPSY’s Services, contact us at hello@theswapsy.com. We will continue to retain your account information after your account is cancelled as required under applicable law, regulations, and rules.

How we share information with others

Our website may offer publicly accessible blogs. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. Please do not post any information you prefer to keep private, including but not limited to your email address, mailing address, or SWAPSY Transaction information.

Access to your information

If your personal information changes, or if you no longer wish to use our Services, you can access, modify, delete or update your Personal Information submitted on our websites by logging into your account and changing your preferences or by contacting SWAPSY Customer Service at hello@theswapsy.com. We will respond to your request within a reasonable timeframe.


We employ industry-accepted standards in protecting the information you submit to us on our websites. We have put in place SSL [Secure Socket Layer] encryption technology to protect your sensitive information transmitted on our websites. We also require a username and password from each user who wants to access his or her information on our websites. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, we cannot guarantee its absolute security.

Choices you can make about our use of your information

Federal and state laws allow you to restrict the sharing of your Personal Information in certain instances. However, these laws also state that you cannot restrict other types of sharing.

If, after giving us your permission to share your Personal Information with third parties with whom we market our jointly offered products, you later decide that you no longer want us to share such information, you may contact us by email at hello@theswapsy.com; or by mail at SWAPSY Customer Service, 7703 Cullen Street, San Diego, CA 92111, U.S.

You may also opt-out from promotional email messages to you or your blog subscription by accessing your Email Preferences under "My Account" or selecting the "Unsubscribe" function present in each promotional or blog email message we send out and providing the required information.


If you have a complaint, first contact SWAPSY Customer Service at hello@theswapsy.com.

Third party sites

Our websites contain links to other websites. We are not responsible for the privacy practices or the content of these other websites. We encourage you to familiarize yourself with the privacy practices of these other websites prior to engaging with them or submitting your Personal Information to them.


If you choose to use our Refer a Friend program to tell a friend about our Services, we will ask you for your friend's name and email address. We will automatically send your friend a one-time email inviting him or her to visit the websites. We store this information for the sole purpose of sending this one-time email and tracking the success of our Refer a Friend program. Your friend may request removal from our Refer a Friend program by following the instructions in the promotional email message we send out and providing the required information.

Import contacts

You can import contacts from your Outlook or other email account address book in connection with using our Services. We collect the username and password for the email account from which you import your contacts and will only use it for that purpose. We may also collect the name, mailing address, email address, and telephone number(s) of any contacts that you import in order to facilitate the Services.

Changes to this policy; Transfer of Information

We may amend this policy at any time, and shall notify you by posting a revised version on our websites. Should we make a substantial change to the manner in which we collect, use, or store Personal Information about you, we shall provide prior notice on our websites, or by email.

If we are involved in a reorganization, merger, acquisition or sale of our assets, your information may be transferred as part of that deal. We will notify you (for example, via a message to the email address associated with your account) of any such deal and outline your choices in that event.


You can contact us with any questions or concerns at: SWAPSY Customer Service, 4250 Executive Square #200, La Jolla, CA 92037, U.S. or by email: support@theswapsy.com