Privacy and Cookie Policy 

Except as explicitly provided herein, Swoop will never share or sell your account email address to any third party without your explicit consent. 

Account information is password-protected. Keep your password safe. If you are using a shared computer, please be sure you logout from the Website and close the browser to avoid misuse of your sign-in information. 

Employees, contractors, and consultants at Swoop will have access to your information to troubleshoot issues, archive data from time to time, administer and maintain our Website. Employees, contractors, and consultants are trained and kept up to date on privacy practices. 

Swoop may disclose information about its users if required to do so by law or in the good faith belief that such disclosure is reasonably necessary to respond to subpoenas, court orders, or other legal processes. 

Swoop may also disclose information about its users to law enforcement officers or others, in the good faith belief that such disclosure is reasonably necessary to enforce our Terms of Use, respond to claims that any posting or other content violates the rights of third-parties, or protect the rights, property, or safety of Swoop, its employees, owners, users or the general public. 

Swoop may use your email address to communicate with you from time to time about our services, upcoming enhancements and new features, newsletter about your contact and network updates or any other information that might be of interest to you. In any case, we do not disclose your account email to any third parties without your explicit consent. 

Our company is subject to the investigatory and enforcement powers of the Federal Trade Commission (FTC). 

META DATA 

When visiting our website, you transmit data to our web server (due to technical necessity) via your internet browser. The following data is recorded during an ongoing connection for communication between your internet browser and our web server: Date and time of the request, Name of the requested file, Page from which the file was requested, Access status (file transferred, file not found, etc.), 

Web browser and operating system used, complete IP address of the requesting computer, amount of data transferred. 

For reasons of technical security, specifically to defend against attempted attacks on our web server, this data is stored by us for a short period of time. It is not possible for us to draw conclusions about individual persons based on this data. 

PROFILE DATA 

Some features of Swoop operate by collecting, searching, and organizing data publicly available on the Internet, which may not be accurate or complete, while other features of the Service operate by applying analytical tools to the Customer’s data. Swoop is not responsible or liable for the accuracy of any such data, of any the Customer’s data, or the results of the Service’s analysis of either.   

Our customers may access and use data publicly available on the internet using our system, and that data may be transferred onward to third party systems via a variety of electronic means.  We are not liable for this data which is publicly available.  We do not onward forward any data which is not publicly available on the internet.  We are not liable for the onward transfer to third parties of any data which is publicly available.  We call publicly available data "profile data", which we treat separately from "user data". 

USER DATA 

We collect and store various information provided by you explicitly during the registration process. To complete the registration process we require you to provide us with certain personal information (e.g. email address, first name, last name, location, password etc...). We do not share or forward this information except when legally obligated to do so. 

Swoop does not store credit card information. Credit card transactions are transmitted to a financial gateway provider, and we endeavor to protect the security of your payment information during transmission by using Secure Sockets Layer (SSL) technology 

Swoop and its partners, agents, and advertisers are not responsible for any personal or sensitive information posted in comments, feedback sections or forums, or for data from other sources which is publicly available. 

You may access your profile and/or user data by requesting a copy from privacy@swooptalent.com. You may also request that you be removed (deleted) from the database using the same contact method, which will prevent any data about you (even publicly available data) from being shared, forwarded, or accessed by any user.  Should you make that request, we will provide you with details on the sources of the publicly available data gathered about you so that you may contact those sources to edit or delete publicly available data from the source/s.  Unless you do remove the source data from public sources, we cannot guarantee that your profile information will not be collected again by our system as it will be publicly available data and our system automatically collects such data. 

We will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, the data processed by us will be deleted or restricted in their processing in accordance with this Privacy and Cookie Policy. If the data is not deleted because they are required for other and legally permissible purposes, their processing is restricted. This means that the data is blocked and not processed for other purposes. This applies, for example, to data that must be retained for commercial or tax law reasons. 

All the information provided by you and information collected by us automatically is stored in our databases, and file systems. This information is archived on periodic basis. This information is still available in our database, file system, and archives even after deletion. 

You must be at least 18 years or older to register with Swoop. Swoop does not knowingly collect any information from persons under the age of 18. If Swoop learns that we have collected information from a child under age 18 we will quickly act to delete that information as soon as possible 

By visiting our Website and providing us with information, you acknowledge and agree that due to the international dimension of Swoop we may use the data collected in the course of our relationship for the purposes identified in this policy or in our other communications with you, including the transmission of information outside your resident jurisdiction. In addition, please understand that such data may be stored on servers located in the United States. By providing us with your information, you consent to the transfer of such information. 

If you are a California resident, Californian Privacy Law provides you with additional rights regarding our use and processing of your personal information. To learn more about your California Privacy Rights, visit the CCPA (California Consumer Privacy Act) Notice. 

THE CONTROLLER  

We are the data “controller”, which means we are responsible for deciding how and why your personal information is used. We are also responsible for making sure it is kept safe, secure, and handled legally.  

SPECIAL CATEGORIES DATA (Art. 9 para. 1 GDPR) 

No special categories data is processed. 

AUTOMATED DECISION-MAKING AND PROFILING (Art.22 GDPR) 

We do not use automation for decision-making and profiling.  

WHAT ARE THE PURPOSES FOR PROCESSING? 

Provision of the online offer, its contents and shop functions. 

Provision of contractual services, service, and customer care. 

Answering contact enquiries and communication with users. 

Marketing, advertising, and market research. 

Security measures. 

WHAT ARE THE RELEVANT LEGAL BASES FOR PROCESSING YOUR DATA? 

In accordance with Art. 13 GDPR the following informs you about the legal basis of us processing your data and unless the legal basis is not specifically mentioned, the following applies:  

Consent 

This is where we have asked you to provide explicit permission to process your data for a particular purpose. (Art. 6 Para. 1 lit. a and Art. 7 GDPR) 

Contract 

This is where we process your information to fulfil a contractual arrangement we have made with you. (Art. 6 Para. 1 lit. b GDPR) 

Answering your business enquiries  

This is where we process your information to reply to your messages, e-mails, posts, calls, etc. (Art. 6 Para. 1 lit. b GDPR) 

Legitimate Interests 

This is where we rely on our interests as a reason for processing, generally this is to provide you with the best products and service in the most secure and appropriate way. (Art. 6 Para. 1 lit. f GDPR). Of course, before relying on any of those legitimate interests we balance them against your interests and make sure they are compelling enough and will not cause any unwarranted harm. 

Legal Obligation 

This is where we have a statutory or other legal obligation to process the information, such as for the investigation of crime. (Art. 6 Para. 1 lit. b GDPR) 

Vital interests 

This is where we process your information for communications about security, privacy, and performance improvements of our services. Or for establishing, exercising or defending our legal rights. (Art. 6 para. 1 lit. d GDPR) 

YOUR RIGHTS UNDER THE GDPR 

You have a number of ‘Data Subject Rights’ below is some information on what they are and how you can exercise them.  

• information about the processing of your personal data. 
• obtain access to the personal data held about you. 
• ask for incorrect, inaccurate, or incomplete personal data to be corrected. 
• request that personal data be erased when it’s no longer needed or if processing it is unlawful. 

• object to the processing of your personal data for marketing purposes or on grounds relating to your particular situation. 
• request the restriction of the processing of your personal data in specific cases. 
• receive your personal data in a machine-readable format and send it to another controller (‘data portability’). 
• request that decisions based on automated processing concerning you or significantly affecting you and based on your personal data are made by natural persons, not only by computers.  
• You also have the right in this case to express your point of view and to contest the decision. 

• Where the processing of your personal information is based on consent, you have the right to withdraw that consent without detriment at any time through our contact form. 

The above rights may be limited in some circumstances, for example, if fulfilling your request would reveal personal information about another person, if you ask us to delete information which we must have by law, or if we have compelling legitimate interests to keep it. We will let you know if that is the case and will then only use your information for these purposes. You may also be unable to continue using our services if you want us to stop processing your personal information. 

GENERAL TECHNICAL ORGANISATIONAL MEASURES 

Swoop has taken a variety of security measures to protect personal information to an appropriate extent and adequately. All information held by Swoop is protected by physical, technical, and procedural measures that limit access to the information to specifically authorized persons in accordance with this Privacy and Cookie Policy. 

This Cookie Policy describes and informs you about our use of cookies and other tracking technologies such as flash cookies, server logs, web beacons or pixel gifs. 

Please note that third party websites, which may be linked to the Site, are not covered by this Cookie Policy. 

If you do not agree to our use of cookies and similar tracking technologies in this way, you should set your cookie preferences or browser settings accordingly. You will always be able to withdraw your consent and change your choice by amending your cookie preferences or browser settings in the future. If you disable cookies that we use, some parts of the Site may not work properly and some functionalities of the Site may be unavailable, depending on the type of cookie you have disabled. 

WHAT ARE COOKIES? 

Cookies are small text files sent to your device by the Site. Cookies are uploaded onto your device, thus allowing the Site to recognize you and store certain information concerning you, in order to permit or improve the service offered. A cookie will usually contain the name of the website from which the cookie has come from, the "lifetime" of the cookie (i.e. how long the cookie will remain on your device), and a value, which is usually a randomly generated unique number. 

As regards the lifetime of cookies, two types of cookies may be used, "session cookies" and "persistent cookies". Session cookies are automatically deleted at the end of your browsing session. Persistent cookies remain longer on your device, for the duration of each specific cookie, and will remain valid until its set expiry date (unless deleted by the user before the expiry date). 

Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website. Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 

We also use other types of tracking technologies, such as flash cookies, server logs, web beacons or pixel gifs in connection with our Website and services. These technologies are similar to cookies in that they are stored on your device and can be used to maintain information about your activities and preferences. 

WHAT TYPES OF COOKIES DOES THE SITE USE AND WHAT ARE THEY FOR? 

We may use different types of cookies. We may use what we call "required" cookies to enable core site functionalities, such as logging-in and completing an Order for Products. These cookies do not collect personal information for marketing purposes and cannot be disabled. 

FUNCTIONAL COOKIES  

"Functional" cookies provide more advanced functions, such as remembering log-in details, remembering what is in your shopping cart and remembering your preferences such as language and country, analyzing Site usage to measure and improve performance. Also these cookies do not collect information that can identify users.  

ADVERTISING COOKIES  

"Advertising" cookies may be finally used to keep record of certain behaviours or preferences expressed by you, so as to present content that is more relevant to your interests, in compliance with the applicable data protection and privacy laws and upon collection of your express consent if required by law.  

Cookies commonly used on this Site are listed below. From time to time, we may also use additional cookies and tracking technologies not listed in this table. In any event, you can always manage all cookies and other tracking technologies used on this Site through our cookie preference tool. 

COOKIE LIST 

Below are the cookies that require prior consent from users to be installed: 

Cookie (AddThis): uid; ouid; 

Cookie (AppNexus): anj; uuid2; 

Cookie (Facebook): _fbp; fr; 

Cookie (Google Analytics): _gid; _ga; 

Cookie (Google Doubleclick): IDE; 

Cookie (OpenX): i; 

Cookie (Segment Platform): ajs_group_id; ajs_user_id; ajs_anonymous_id; 

Cookie (Twitter): personalization_id; 

Cookie (Yahoo): B; 

Third Party Cookies 

When you visit the Site, you may receive cookies from third party websites or domains. We do not control the placing of these cookies and you should check the relevant third party's website for more information about these cookies. The relevant third party is responsible for providing you with information regarding the cookies they place and obtaining your consent before placing cookies on your device. 

How can you control the use of cookies? 

YOUR COOKIE PREFERENCES 

By clicking the "cookie preferences" button on the Site's Cookie Banner, you may choose whether the Site will use "Functional" cookies and/or "Advertising" cookies, as described  above. 

The "cookie preferences" function available on the Site's Cookie Banner will inform you of which functionalities are available to you or not depending on the types of cookies you choose to authorize the Site to use. 

BROWSER SETTINGS 

If you wish to withdraw your consent to our use of cookies on this Site, or if you wish to delete or control the placing of cookies on your computer, you can also change your browser settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings at: Internet Explorer ,  Chrome,  Firefox, Safari 

If you disable the cookies that the Site uses, this may impact your experience while on the Site. 

You can also delete cookies already stored on your computer. Again, doing this may have a negative impact on the usability of many websites. 

This Cookie Policy describes and informs you about our use of cookies and other tracking technologies such as flash cookies, server logs, web beacons or pixel gifs. 

Please note that third party websites, which may be linked to the Site, are not covered by this Cookie Policy. 

If you do not agree to our use of cookies and similar tracking technologies in this way, you should set your cookie preferences or browser settings accordingly. You will always be able to withdraw your consent and change your choice by amending your cookie preferences or browser settings in the future. If you disable cookies that we use, some parts of the Site may not work properly and some functionalities of the Site may be unavailable, depending on the type of cookie you have disabled. 

WHAT ARE COOKIES? 

Cookies are small text files sent to your device by the Site. Cookies are uploaded onto your device, thus allowing the Site to recognize you and store certain information concerning you, in order to permit or improve the service offered. A cookie will usually contain the name of the website from which the cookie has come from, the "lifetime" of the cookie (i.e. how long the cookie will remain on your device), and a value, which is usually a randomly generated unique number. 

As regards the lifetime of cookies, two types of cookies may be used, "session cookies" and "persistent cookies". Session cookies are automatically deleted at the end of your browsing session. Persistent cookies remain longer on your device, for the duration of each specific cookie, and will remain valid until its set expiry date (unless deleted by the user before the expiry date). 

Cookies can be used by web servers to identify and track users as they navigate different pages on a website and identify users returning to a website. Cookies do not contain any information that personally identifies you, but personal information that we store about you may be linked to the information stored in and obtained from cookies. 

We also use other types of tracking technologies, such as flash cookies, server logs, web beacons or pixel gifs in connection with our Website and services. These technologies are similar to cookies in that they are stored on your device and can be used to maintain information about your activities and preferences. 

WHAT TYPES OF COOKIES DOES THE SITE USE AND WHAT ARE THEY FOR? 

We may use different types of cookies. We may use what we call "required" cookies to enable core site functionalities, such as logging-in and completing an Order for Products. These cookies do not collect personal information for marketing purposes and cannot be disabled. 

FUNCTIONAL COOKIES  

"Functional" cookies provide more advanced functions, such as remembering log-in details, remembering what is in your shopping cart and remembering your preferences such as language and country, analyzing Site usage to measure and improve performance. Also these cookies do not collect information that can identify users.  

ADVERTISING COOKIES  

"Advertising" cookies may be finally used to keep record of certain behaviours or preferences expressed by you, so as to present content that is more relevant to your interests, in compliance with the applicable data protection and privacy laws and upon collection of your express consent if required by law.  

Cookies commonly used on this Site are listed below. From time to time, we may also use additional cookies and tracking technologies not listed in this table. In any event, you can always manage all cookies and other tracking technologies used on this Site through our cookie preference tool. 

COOKIE LIST 

Below are the cookies that require prior consent from users to be installed: 

Cookie (AddThis): uid; ouid; 

Cookie (AppNexus): anj; uuid2; 

Cookie (Facebook): _fbp; fr; 

Cookie (Google Analytics): _gid; _ga; 

Cookie (Google Doubleclick): IDE; 

Cookie (OpenX): i; 

Cookie (Segment Platform): ajs_group_id; ajs_user_id; ajs_anonymous_id; 

Cookie (Twitter): personalization_id; 

Cookie (Yahoo): B; 

Third Party Cookies 

When you visit the Site, you may receive cookies from third party websites or domains. We do not control the placing of these cookies and you should check the relevant third party's website for more information about these cookies. The relevant third party is responsible for providing you with information regarding the cookies they place and obtaining your consent before placing cookies on your device. 

How can you control the use of cookies? 

YOUR COOKIE PREFERENCES 

By clicking the "cookie preferences" button on the Site's Cookie Banner, you may choose whether the Site will use "Functional" cookies and/or "Advertising" cookies, as described  above. 

The "cookie preferences" function available on the Site's Cookie Banner will inform you of which functionalities are available to you or not depending on the types of cookies you choose to authorize the Site to use. 

BROWSER SETTINGS 

If you wish to withdraw your consent to our use of cookies on this Site, or if you wish to delete or control the placing of cookies on your computer, you can also change your browser settings to block cookies or to alert you when cookies are being sent to your device. There are a number of ways to manage cookies. Please refer to your browser instructions or help screen to learn more about how to adjust or modify your browser settings at: Internet Explorer ,  Chrome,  Firefox, Safari 

If you disable the cookies that the Site uses, this may impact your experience while on the Site. 

You can also delete cookies already stored on your computer. Again, doing this may have a negative impact on the usability of many websites. 

COMMERCIAL PARTNERS 

Individual(s) or companies that have been approved by us as a recipient of organizational PII and from which Swoop has received confirmation of their data protection practices conformance with the requirements of this policy. Commercial Partners include all external providers of services to Swoop and include proposed Commercial Partners. No PII information can be transmitted to any vendor in any method unless the vendor has been pre-certified for the receipt of such information. 

PII TRAINING 

All new hires entering Swoop who may have access to PII are provided with introductory training regarding the provisions of this policy, a copy of this policy and implementing procedures for the department to which they are assigned. Employees in positions with regular ongoing access to PII or those transferred into such positions are provided with training reinforcing this policy and procedures for the maintenance of PII data and shall receive annual training regarding the security and protection of PII data and company proprietary data 

PII AUDIT(S) 

Swoop conducts audits of PII information maintained by Swoop in conjunction with fiscal year closing activities to ensure that this policy remains strictly enforced and to ascertain the necessity for the continued retention of PII information. Where the need no longer exists, PII information will be destroyed in accordance with protocols for destruction of such records and logs maintained for the dates of destruction. 

DATA BREACHES/NOTIFICATION 

Databases or data sets that include PII may be breached inadvertently or through wrongful intrusion. Upon becoming aware of a data breach, Swoop will notify all affected individuals whose PII data may have been compromised, and the notice will be accompanied by a description of action being taken to reconcile any damage as a result of the data breach. 

CONFIRMATION OF CONFIDENTIALITY  

All company employees must maintain the confidentiality of PII as well as company proprietary data to which they may have access and understand that that such PII is to be restricted to only those with a business need to know. Employees with ongoing access to such data will sign acknowledgement reminders annually attesting to their understanding of this company requirement. 

VIOLATIONS OF PII POLICIES AND PROCEDURES 

Swoop views the protection of PII data to be of the utmost importance. Infractions of this policy or its procedures will result in disciplinary actions under Swoop’s discipline policy and may include suspension or termination in the case of severe or repeat violations. PII violations and disciplinary actions are incorporated in Swoop’s PII onboarding and refresher training to reinforce Swoop’s continuing commitment to ensuring that this data is protected by the highest standards.