Privacy Policy

Effective Date: March 12, 2021​ LLC (“”, “we”, “our”) respects your privacy.  This Privacy Policy describes the types of personal data we collect from individuals visiting the website, how we use the personal data, and with whom we share it.  We also describe the rights you may have and how you can contact us about our privacy practices. is responsible for the use of your personal data for the purposes described in this Privacy Policy - our contact information can be found in the “How to Contact Us” section.

If you are a California consumer, for more information about your privacy rights, please see the section of this Privacy Policy called “California Consumer Privacy Statement.”

For further information on how we process your personal data, please use the links below to jump to the listed section:

  1. Personal Data We Collect
  2. How We Use the Personal Data We Collect
  3. How We Share Personal Data
  4. How We Protect Personal Data
  5. Your Rights and Choices
  6. Cookies
  7. Updates to Our Privacy Policy
  8. How to Contact Us

1. Personal Data We Collect

If you wish to receive services from, we may collect certain of your personal data, including your:

  • Name;
  • Email address;
  • Account details, including password;
  • Postal address;
  • Phone number; or
  • Company.

2. How We Use the Personal Data We Collect

We use the personal data that we collect in order to set up and maintain user accounts, for user authentication and security purposes, and to create a usage report and log for each user.  We process personal data for these purposes because we are required to do so in order to provide subscription services to users.

We also process personal data for the following business purposes because we have a legitimate interest in doing so:

  • Maintaining user subscription and account records, in order to administer our business;
  • Maintaining records relating to our users, in order to administer our business;
  • Managing our user relationships and communicating with our users, in order to administer our business and to update our users about new features and services that we may offer;
  • Complaint handling and dispute resolution, in order to resolve any complaints raised by our users;
  • Monitoring compliance with applicable policies and procedures relating to our services, in order to ensure the security of our services and compliance with our Terms of Use;
  • Carrying out analytics, in order to identify potential improvements to our services and to measure engagement with our advertising campaigns.

In addition to the purposes above, we also process personal data when we are required to do so by law, for example in order to maintain regulatory records.

If we plan to use the personal data that you provide for other purposes, we will provide an additional privacy policy to you to describe the purposes for which we will use the personal data.

3. How We Share Personal Data

We may share your personal data with third party service providers.  Such third party service providers will not be authorized to use the data for purposes beyond providing services to swXtch.  We may share your personal data with affiliates of swXtch for the purposes described in this Privacy Policy.

In addition, we may disclose personal data about you (i) if we are required or permitted to do so by law or legal process, for example due to a court order or a request from a law enforcement agency, (ii) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, (iii) in connection with an investigation of suspected or actual fraudulent or other illegal activity, and (iv) in the event we sell or transfer all or a portion of our business or assets (including in the event of a reorganization, dissolution, or liquidation).

4. How We Protect Personal Data

swXtch maintains administrative, technical, and physical safeguards designed to protect personal data against accidental, unlawful, or unauthorized access, destruction, loss, alteration, disclosure, or use.

5. Your Rights and Choices

We offer you certain choices in connection with the personal data we obtain about you.  To update your preferences or limit the communications you receive from us, please respond to the emails you receive, or contact us as specified in the How to Contact Us section of this Privacy Policy.


Information That We Collect Automatically

When you use our website, we or our third-party service providers may collect certain information by automated means, using technologies such as cookies, web server logs, web beacons (including tags and pixels), and JavaScript.

Cookies are files that websites send to your computer or other Internet-connected device to uniquely identify your browser or to store information or settings on your device. Your browser may tell you how to be notified when you receive certain types of cookies and how to restrict or disable certain cookies. Please note, however, that without cookies you may not be able to use all of the features of our website.

In conjunction with gathering information through cookies, our web servers may log information such as your operating system type, browser type, domain, and other system settings, as well as the language your system uses and the country and time zone where your device is located. The web server logs may also record information such as the address of the web page that referred you to our website and the IP address of the device you use to connect to the Internet. They may also log information about your interaction with our website, such as which pages you visit.

This website is not designed to respond to “do not track” signals received from browsers.

Categories Of Cookies And Other Automated Technologies

Strictly Necessary Cookies

These cookies are necessary for certain parts of our website to operate properly and facilitate your use of its features. Without these cookies, certain services cannot be provided. These cookies help us understand information, such as your session ID and other server authentication information. If this category of cookies is blocked or disabled, we cannot guarantee your security or predict how certain parts of our website will perform during your visit.

Analytics Cookies​

We may use these cookies to collect information about how visitors interact with our website, such as what pages you visit and if any errors have occurred. The information is used to improve how our website functions. These cookies don’t collect information that identifies you but generate statistical data about your use of our website. We may use different services to analyze these cookies, including Google Analytics and LinkedIn Analytics. The services register a unique ID that is used to generate statistical data on how visitors use our website. If you want to opt out of our use of Google Analytics please click here.

Advertising Pixels​

We may use cookies, pixels or similar tracking technologies on our website to help us deliver our content and advertising, and measure the effectiveness of our advertising campaigns on third party websites. They can also be used to limit the number of times users see an advertisement. We and our third-party vendors may collect information about our visitors’ online activities, over time and across third-party websites. You can opt out of receiving interest-based advertising on our website by blocking these cookies as described below.

Functional Cookies

These cookies allow our website to remember choices you make and provide enhanced and more personal features. They can also be used to remember changes made to parts of our website that you can customize.​

Your Choices

You can manage cookies through your web browser. Most browsers will tell you how to stop accepting new cookies, how to be notified when you receive a new cookie, and how to disable existing cookies. You can find out how to do this for your particular browser by clicking “help” on your browser’s menu or by visiting  Please note, however, that without cookies you may not be able to take full advantage of all our website features.

The following external links will explain how to manage cookies for the most common browsers:

In addition to the browser-based controls, you can manage third party cookies by visiting

7. Updates To Our Privacy Policy​

This Privacy Policy may be updated periodically to reflect changes in our personal data practices.  We will post a notice on our website to notify you of any significant changes to our Privacy Policy and indicate at the top of the Privacy Policy when it was most recently updated.

8.How to Contact Us

If you have questions about how handles your personal data, please reach out by emailing or writing to us at: LLC

3 World Trade Center, 58th Floor

New York, NY 10007

Attention: Legal


Effective: March 12, 2021

This California Consumer Privacy Statement supplements the Privacy Policy.  It applies solely to California consumers and addresses personal information we collect online and offline.

This Statement does not apply to (i) personnel or job applicants seeking opportunities at or (ii) personnel working on behalf of business partners with whom we are conducting business.

This California Consumer Privacy Statement uses certain terms that have the meaning given to them in the California Consumer Privacy Act of 2018 and its implementing regulations (the “CCPA”).

1. Notice of Collection and Use of Personal Information

We may collect the following categories of personal information about you:

  • Identifiers: identifiers such as a real name, alias, postal address, unique personal identifier (such as a device identifier; cookies, beacons, pixel tags, mobile ad identifiers and similar technology; unique pseudonym, or user alias; telephone number and other forms of persistent or probabilistic identifiers), online identifier, internet protocol address, email address, account name, and other similar identifiers;
  • Online Activity: Internet and other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with websites, applications or advertisements;
  • Employment Information: professional or employment-related information;
  • Inferences: inferences drawn from any of the information identified above to create a profile about you reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

We may use the categories of personal information listed above for the purposes described in the Privacy Policy.  In addition, we may use these categories of personal information for certain business purposes specified in the CCPA, as described in this table:

2. Our Prior Collection, Use and Disclosure of Personal Information

We may have collected and used your personal information, as described in section 1 above, during the 12-month period prior to the effective date of this California Consumer Privacy Statement.  For the personal information collected during that timeframe, we describe below: (a) the categories of sources from which we may have obtained the personal information, (b) the categories of third parties with whom we may have shared the information, and (c) the categories of personal information we may have disclosed for a business purpose.

a. Sources of Personal Information

We may have obtained personal information about you from various sources, as described below:

b. Sharing of Personal Information

We may have shared your personal information with certain categories of third parties, as described below.

​​​​​​c. Sale of Personal Information

We do not sell your personal information.

d. Disclosure of Personal Information for a Business Purpose

We may have disclosed to third parties for a business purpose all of the categories of personal information about you listed in Section 1 above.

3. California Consumer Privacy Rights

You have certain choices regarding your personal information, as described below.

Access: You have the right to request, twice in a 12-month period, that we disclose to you the personal information we have collected, used, disclosed and sold about you during the past 12 months.

Deletion: You have the right to request that we delete certain personal information we have collected from you.

How to Submit a Request: To submit an access or deletion request, email us at or call us at 646-343-2000.

Verifying Requests: To help protect your privacy and maintain security, we will take steps to verify your identity before granting you access to your personal information or complying with your request.  If you have an account with us, we may verify your identity by requiring you to sign in to your account.  If you do not have an account with us and you request access to or deletion of your personal information, we may require you to provide any of the following information: name, email address, or other relevant pieces of data.  In addition, if you do not have an account and you ask us to provide you with specific pieces of personal information, we will require you to sign a declaration under penalty of perjury that you are the consumer whose personal information is the subject of the request. If you designate an authorized agent to make an access, deletion or opt-out of sale request on your behalf (a) we may require you to provide the authorized agent written permission to do so, and (b) for access and deletion requests, we may require you to verify your own identity directly with us (as described above).

Additional Information: If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us.  To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.