Privacy Policy

Privacy Policy for Swirl Social

Effective date: April 2024

Swirl Social, Inc. (“we”, “us” or “our”) values your privacy. In this Privacy Policy (“Policy”), we describe how we collect, use, and disclose information that we obtain about visitors to our website at swirlsocial.app (the “Site”) and the functionality available through our Site, including any mobile applications and browser extensions (collectively, the “Functionality”), and how we use and disclose that information.

By visiting the Site or using any of the Functionality, you agree that your user data (including your personal data and personally identifiable information ("personal information") will be handled as described in this Policy. Your use of the Site or the Functionality, and any dispute over privacy, is subject to this Policy (including any applicable changes) and an applicable Terms of Use, including its applicable limitations on damages and provisions for the resolution of disputes.

Overview

Privacy is core to Swirl Social’s mission and values. We take all appropriate steps to preserve user privacy and aim to be as transparent as possible with you regarding the treatment of any data we collect or that you provide to us (including your personal information).

Swirl Social does not require you to provide personally identifiable information or your personal data such as your name, email address, tax ID, or phone number to use the Site or the Functionality.

For even more privacy, users have the option to opt-out of our anonymous analytics.

This policy will be updated whenever there are material changes to Swirl Social’s privacy practices or applicable law.

The Information We Collect

We collect information about you directly from you and from third parties, as well as automatically through your use of our Site or Functionality Information.

Information We Collect Directly From You:

Publicly available data such as your digital asset wallet address and public blockchain data, which is only used to provide and improve the Functionality and to ensure compliance with applicable laws and regulations. Your contact information as well as other data and information related to your use of the Site and Functionality (to the extent that you provide it to us) in connection with survey responses or customer support queries. While not required to access the Site or Functionality, you may choose to provide us with your email address in order to participate in certain promotional activities or to receive additional information related to upcoming product launches or developments. Information We Collect Automatically:

Usage data, such as your browser type and operating system, the web pages that you connect your wallet to, the webpage that led you to our Site, and country-level location information. Swirl Social does not automatically collect or store personally identifying information such as your IP address. For additional information related to Swirl Social’s use of cookies and other tracking technology please see the section “Our Use of Cookies and Other Tracking Mechanisms” below for more information. How We Use The Information We Collect

We use the information we collect for the following purposes:

Provide our services. Provide personalized services. Improve and develop our services. Offer promotions. Other Uses. How We Share The Information We Collect

We may share the information we collect as follows:

Consent. Affiliates & Service Providers. Business Transfers. In Response to Legal Process. To Protect Us and Others. Aggregate and De-Identified Information. Our Use of Cookies and Other Tracking Mechanisms

We and our service providers use cookies and other tracking mechanisms to track information about your use of our Site and Functionality.

Personal Information

Security of My Personal Information

We have implemented commercially reasonable precautions to protect the information (including your personal information) we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction.

What Rights Do I Have Regarding My Personal Information

You may request access, a copy, modification or deletion of personal information that you have submitted to us by contacting us at [e-mail]

What Choices Do I Have Regarding Use of My Personal Information for Marketing

You may opt-out of receiving marketing communications from us by following the opt-out instructions provided in those communications.

Location of Information

Our Site and Functionality are offered from Canada . We store any information we collect in Canada.

Children Under 13

Our Site and Functionality are not directed to children under 13. If you learn that your child has provided us with personal information without your consent, please contact us.

Contact Us

If you have questions about our approach to privacy or would like to make a complaint, please contact us at [e-mail]

Changes to this Policy

This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time and will post any changes to this Policy on the Site.

CALIFORNIA PRIVACY NOTICE

In addition, under California Civil Code § 1798.83, California residents who have provided personal information to Swirl Social, Inc. may obtain information regarding Swirl Social, Inc.’s disclosures, if any, of personal information to third parties for third-party direct marketing purposes. Requests must be submitted to the following address: [insert contact email]. Within 30 days of receiving such a request, we will provide a California Privacy Disclosure, which will include a list of certain categories of personal information disclosed during the preceding calendar year to third parties for their direct marketing purposes, along with the names and addresses of the third parties. This request may be made no more than once per calendar year.