SWAPPY'S CONFIDENTIALITY AND ONLINE PRIVACY POLICY

 

  1. Online privacy policy
  2. Our guiding privacy principles
  3. Identifying the purpose of personal information
  4. Obtaining your consent
  5. Use of cookies
  6. Limiting collection, use, and disclosure of personal information
  7. Providing access and accuracy
  8. Responding to your privacy concerns

 

1. Online privacy policy


9589945 Canada Inc., with any and al its affiliates (collectively "SWAPPY") is aware of your legitimate concerns about privacy and is committed to maintaining the integrity, confidentiality, security, and accuracy of your Personal Information subject to the terms and conditions set forth herein and in SWAPPY's terms and conditions. To this end, we will deploy reasonable physical, technological, and administrative measures to protect your privacy in accordance with applicable privacy legislation and industry practices, the terms and conditions set forth herein and SWAPPY's terms and conditions..


We thought it would be useful to provide you with our Online Privacy Policy (the "Policy"). This Policy helps You understand the guiding principles applied by SWAPPY to the collection, use, disclosure, retention, and disposal of and access to Personal Information and other contact information You provided Us with. Because privacy concerns and legal and business requirements evolve continually, SWAPPY may have to change its Policy at any time without advance notice and therefore you are invited to review it regularly. Access to and use of the Site and our Services are also governed by SWAPPY's terms and conditions that you should review and must accept in advance of using any Services or the Site.

If you have any questions concerning SWAPPY's Policy, please feel free to contact us by email.

 

2. Our guiding privacy principles


Our Policy rests on the following 7 key privacy principles:

 

  • Identifying the purposes of Personal Information

SWAPPY will identify and inform you of the purposes for which the Personal Information is being collected.

  • Obtaining your Consent

SWAPPY will obtain your Consent before or when it collects, uses, or discloses Personal Information, and will give effect to your withdrawal of consent.

  • Limiting collection, use, and disclosure of personal information

SWAPPY will not, without your Consent, collect, use, or disclose Personal Information except for the purposes identified or for a use consistent with those purposes or as otherwise required or permitted by applicable law.

  • Safeguarding personal information

SWAPPY will implement appropriate physical, technological, and administrative measures to safeguard your Personal Information.

  • Providing access and accuracy

SWAPPY will respect your right of access to your Personal Information and take all reasonable steps to ensure the Personal Information used is accurate and complete for the purposes identified.

  • Responding to your privacy concerns

SWAPPY will respond to your questions and investigate diligently any complaints with respect to your Personal Information.

  • Complying with applicable privacy legislation.

Your and SWAPPY's rights and obligations regarding privacy are governed by applicable privacy legislation in Canada. The application and interpretation of this Policy and of our guiding privacy principles are subject to and will comply with such legislation, including the requirements, procedures, exemptions, and exclusions contained therein.

 

For purposes of this Policy, "Personal Information" means any information about an identifiable individual. Personal Information includes information relating to identity (including the name or other identifier assigned by SWAPPY to an individual), nationality, age, gender, address, passwords, telephone number, e-mail addresses, marital status, education, employment and health history, assets, liabilities, payment records, income and information relating to financial transactions as well as certain personal opinions or views of an individual.

 

3. Identifying the purposes of personal information


The nature and scope of the Personal Information we need depends to a great extent on which Services are of interest to You. SWAPPY will collect Personal Information only in relation to its operating programs or activities for business purposes, and will take special care to explain these purposes clearly. Below, we provide concrete examples of Personal Information associated with these purposes and explain why such information is necessary:

 

  • To identify you and support other members/users dealing with You

Personal Information such as your name, telephone number, personal address, date of birth, gender, and password helps us to identify and contact you, and to prevent impersonation. SWAPPY may monitor and review any communications between members/users using the Services, including in relation to any claims or disputes, and may elect, in its sole and entire discretion (and with no obligation or liability whatsoever), to participate in such exchanges and/or communicate to each (or to only one of the two) party relevant contact and other relevant and related information of the other party as SWAPPY deems appropriate.

  • To advise on our products, solutions and Services

SWAPPY will try to satisfy your request for advice on various matters and direct you towards appropriate products, solutions and Services whenever possible. 

  • To provide ongoing Services

Personal Information about you and your business allows us to communicate with you and respond adequately and promptly to your inquiries about applications or other online services.

  • To protect You, Us and other members and users against misbehavior, errors and fraud

All your activities and communications are electronically logged, so that SWAPPY can review them including in case of any suspicious activity. SWAPPY uses software to monitor site traffic and activities and to detect unauthorized attempts to upload, change information, or otherwise cause damage. The software receives and records the Internet Protocol (IP) addresses of the computers that have visited this site, including the date and time of visits, the pages that were viewed and downloaded, and the identifier attributed to any registered user who accesses restricted areas on this site. The software also captures information regarding the type of browser and operating system. SWAPPY does not attempt to link the IP addresses and the identifiers with the identity of users visiting this site unless there is an attempt to damage the site.

  • To promote our products, solutions and Services to You

We can contact You in relation to any and all Your dealings and use of the Site and the Services. Also, when you complete any online SWAPPY subscription or registration form or process and indicate that You wish your name to be added to a SWAPPY mailing list, SWAPPY will, from time to time, use your e-mail or regular mailing address to send You information on SWAPPY's products, solutions and Services, changing trends, business opportunities, or other topics of current interest. In order to do so, SWAPPY may also collect the information that You provided on the subscription or registration form or process, such as Your name and name of Your company (if applicable), Your address, telephone and fax numbers, and your language of preference.

  • To build with our third party providers rich data bases of user-related experiences

We – and the various third parties we use as subcontractors as well as third party tools and functionalities used in relation to SWAPPY – collect user-related experience and behavioral data for various purposes, including to monitor the utilization of SWAPPY and related systems, functionalities and services, optimize these, for targeted marketing and so forth.

 

4. Obtaining your consent

 

BY CLICKING AN “ENTER”, “I AGREE”, “I ACCEPT” OR ANY OTHER SIMILAR ICON OR BUTTON WHEN PROMPTED TO DO SO AT THE TIME OF JOINING SWAPPY OR AT ANY TIME THEREAFTER, OR BY ACTUALLY SIMPLY ACCESSING OR OTHERWISE USING THE SITE, SWAPPY OUR ANY SERVICES, YOU ARE AND SHALL BE DEEMED TO HAVE IRREVOCABLY AGREED TO BE BOUND BY ALL TERMS AND CONDITIONS OF THIS ONLINE PROVACY POLICY, INCLUDING ANY AMENDMENTS OR RESTATEMENTS THERETO. BEFORE USING SERVICES, YOU MUST READ THIS POLICY CAREFULLY. BY ACCESSING OR USING SWAPPY, THE SITE OR ANY SERVICES, YOU WARRANT THAT YOU ARE FULLY EMANCIPATED AND HAVE THE AGE OF MAJORITY IN YOUR JURISDICTION AND ARE CAPABLE OF FORMING LEGALLY BINDING CONTRACTS, AND YOU AGREE TO BE LEGALLY BOUND AND ABIDE BY THE TERMS AND CONDITIONS OF THIS ONLINE PROVACY POLICY AS DESCRIBED ABOVE AND BELOW. IF YOU DO NOT HAVE MAJORITY AGE IN YOUR JURISDICTION FOR ALL PURPOSES, OR OTHERWISE DO NOT HAVE FULL LEGAL CAPACITY, OR IF YOU DO NOT AGREE WITH ANY PART OF THIS POLICY, DO NOT USE OR ACCESS SWAPPY, THE SITE OR ANY OF THE SERVICES.

Your Consent can be expressed or implied ("Consent"). It can be expressed orally, in writing, or electronically when, for example, you authorize us to obtain, You provide or You exchange Personal Information. Your Consent can be implied through Your action or inaction. For instance, when you sign up for Services, we conclude that you have Consented to the collection, use, disclosure, disposal, etc. of the Personal Information We then collected for the intended purposes.


SWAPPY will make reasonable efforts to ensure that You understand the purposes for collecting Personal Information, and to obtain your Consent in a timely manner, given the nature and sensitivity of the information. Your Personal Information will be viewed by SWAPPY employees or representatives for the purpose of their work or for which it was given, as well as any and all Third Party Providers (as defined in SWAPPY's terms and conditions), their employees and representatives, in relation to their business and in accordance with their respective terms and conditions, with which You must be familiar and comfortable.


In some circumstances, SWAPPY will have to collect, use, or disclose Personal Information without your Consent for legal, security, or processing reasons, or when it is impossible to obtain your Consent in cases contemplated by applicable privacy legislation. Examples of such circumstances include compliance with applicable laws or court orders, the protection of the public interest, SWAPPY's rights, fraud detection and prevention, the use of Personal Information emanating from a third party, and the collection of overdue accounts.

You can withdraw your Consent at any time, provided SWAPPY is given reasonable notice and there are no legal or contractual requirements preventing this i.e. SWAPPY will comply with your request to be removed from their mailing list.

 

5. Use of cookies

A cookie is a small text file containing certain pieces of information that a website server creates and puts on your computer. SWAPPY uses persistent cookies to enable us to better serve you when you visit our Site. 

Persistent cookies are written or stored on your hard drive until the expiry date. SWAPPY's persistent cookies are used, for example, to retain information that you provided so that the SWAPPY Site can be personalized accordingly, or to determine if a certain user has previously completed one of our surveys, so that he/she will not be surveyed again.


The cookies used by SWAPPY are designed so they do not reveal any Personal Information on their own.

By accessing our Site, You consent to the use of cookies and agree to have Your browser set to accept cookies. If You want to access our Site but don't agree to receive cookies, You can do so by modifying the preferences of your browser. However, note that by not accepting cookies, You may not be able to use all the features of our Site.

 

6. Limiting collection, use, and disclosure of personal information

SWAPPY will generally collect Personal Information about You directly from You. With your Consent, SWAPPY may obtain Personal Information from third parties.


SWAPPY will limit the type and scope of Personal Information it collects for use and disclosure according to the identified purposes. Except as outlined in this Policy or SWAPPY's terms and conditions, SWAPPY will not disclose your Personal Information to anyone outside SWAPPY without Your Consent except as required or permitted by applicable law. 

As explained above, SWAPPY may transfer (or otherwise make available) Personal Information to third parties – including Third party Providers – who are services partners and/or provide services on our behalf. For example, we may use service providers to process Personal Information, authorize and process payments, or host our Site (See the reference to Third Party Providers in SWAPPY's terms and conditions).  Personal Information will be stored and processed outside of Canada, including in the United States, by our Third Party Providers. Our Third Party Providers have their own respective terms and conditions, with which You must be familiar and comfortable.

 

7. Providing access and accuracy

Subject to legal requirements provided by applicable Canadian and Quebec laws, SWAPPY will respect Your right of access to your Personal Information by informing You of its procedures and requirements for responding to your request for access.


You can challenge the accuracy of your Personal Information and request corrections if you believe there are errors or omissions. You may also require in certain circumstances an annotation be attached to your Personal Information reflecting any correction requested but not made, or that such annotation or correction be notified to certain individuals. SWAPPY will rely on you to inform it of any required corrections to Your Personal Information.

 

8. Responding to your privacy concerns

For questions or comments regarding this Policy, for additional information about the management of Personal Information at SWAPPY, or to consult or modify your Personal Information, contact us by email

Chat with us
Contact