Last updated: January 20, 2025.

We value your privacy. This privacy policy (“Policy”) describes how we and our affiliates (together, “we”, “us”, “our”) processes Personal Data (asdefined below) which we receive or collect in relation to your access and use of our website, https://www.swifter.io/ (“Website”), our applications,products and services that we provide and offer (together with our Website, our “Services”), as part of our marketing practices and from ourbusiness contacts (such as representatives of customers and suppliers) and other third parties who provide us with Personal Data. Any undefinedterms in this Policy, shall have the its meaning in our Terms, as provided here.

The term, “Personal Data”, as used in this Policy means information relating to an identified or identifiable natural person.

The term, “processing”, as used in this Policy means any action taken in respect of Personal Data.

We may change this Policy from time to time in order to keep you apprised of our data collection and use practices. We encourage you to regularlyvisit and review this Policy to stay informed of such practices.

Table of contents

1. The personal data we collect and how we use it

1.1.  When you visit our website (automatically collected data)

1.2. When you call us or contact us through our website or ask for a demo

2. How (and with whom) we share personal data

2.1. Cloud and hosting services

2.2. Law enforcement or other government entities

2.3. With your consent

2.4. Disputes

2.5. Mergers and acquisitions

2.6. Affiliates

2.7. Additional information on our service providers

3. How long we retain personal data

4. Your GDPR rights

5. Transfers of personal data to other countries outside the EU or EEA

6. Your California privacy rights

6.1. Disclosure of direct marketing practices (“Shine the light”)

6.2. Removal of public information of minors

7. California do not track notice

8. Personal data of children

9. Third party websites, services & data collection

10. Anonymous information

11. Our contact information

1. The personal data we collect and how we use itWe collect and receive Personal Data from outside our company and affiliates, such as from users of our products and services as described inthe table below. Certain Personal Data is collected automatically, while other Personal Data is provided by you voluntarily, for example, when youcontact us. The description in the table may be supplemented by additional information in other parts of this Policy. For example, you may find formore information on third-parties to whom your information may be transferred in Section ‎2 below.

1.1. When you visit our website (automatically collected data):

Type of personal data we collect:

Placement of cookies, including third party cookies

IP address

Purposes of processing the data:

Analysis of Website activity

Protecting the security of the Site

Enable site functionality

Track user activity on the site

Providing the Service

Retention period (how long we store the data)*:

24 months

Legal basis under the GDPR:

Your consent

Legitimate interest (e.g. essential cookies)

Third parties with whom we share your personal data**:

Google

Consequences of not providing the personal data:

Depending on the cookie type you may not be able to access or use the Website. For more information, please review our Cookie Policy

1.2. When you contact us through a website or ask for a demo:

Type of personal data we collect:

Full name

Phone number

Work email address

Company name

Job title

Information about your request or inquiry, and any other information you provide

Our phone call with you

Purposes of processing the data:

Verify your identity, process your request and respond to or contact you regarding your request or inquiry

Present this information to you as part of your account history

Display and contact you with information that is relevant to you in the future, and to assist you with further requests for support

Improve our customer support and communication practices

Retention period (how long we store the data)*:

24 months

Legal basis under the GDPR:

The performance of our contract with you (if you are a customer)

Your Consent

Our legitimate interest

Third parties with whom we share your personal data**:

Webflow

Hubspot

Google

LinkedIn

Consequences of not providing the personal data:

We may not be able to provide you support or respond to your request

* – Please see Section 3 for more information on how long we retain data we collect.

** – Please see Section 2 below for more information about our use of service providers. Section ‎‎2.7 provides for more information about thirdparties listed above.

2. How (and with whom) we share personal data

In addition to any methods or third parties with whom we may share your Personal Data described above, we share Personal Data in the followingmanner:

2.1. Cloud and hosting services

We use cloud storage providers to host the Services and store all information we collect. We currently engage Wix (or one of its affiliates), forsuch services and in addition to the third parties listed in Section ‎1 above, copies of all data we collect are stored on their servers.

2.2. Law enforcement or other government entities

Where required by law or government or court order, we will disclose Personal Data relating to you to the extent we believe we are required by law.

2.3. With your consent

In the event that you have requested or have consented to the transfer of Personal Data relating to you to a third party (such as by checking abox to signify your agreement) we will transfer Personal Data to the relevant third party.

2.4. Disputes and legal advice

In case of any dispute or request with, by or concerning you, we may disclose Personal Data relating to you with our legal counsel, professionaladvisors and service providers, the relevant court or other tribunal and other third parties as needed in order to resolve the dispute, defendourselves against any claims, or enforce our rights.

2.5. Mergers and acquisitions

In the event that we, or a part of our business, are sold to a third party, or if we are merged with another entity, or in the event of bankruptcy or asimilar event, we will transfer information about the relevant portions of our business as well as relevant customers and users and other personaldata, to the purchaser or the entity with which we are merged. We may also transfer personal data to a potential acquirer, their legal counsel orservice providers as part of an evaluation or due diligence review of our company in anticipation of an investment, acquisition or merger, thoughsuch transfers do not typically include personal data and are subject to obligations of confidentiality.

2.6. Affiliates and business partners

We share personal data with our affiliates, who assist us in processing personal data and providing our Services or with insurance companies andagencies (“Business Partners”) to provide you with our support and security Services.

2.7. Additional information on our service providers (listed in section 1)

To help you understand where data about you is transferred, here is more information about the service providers listed above whom we engageto process Personal Data that we collect. Where such service providers have made available information about their data security or processingpractices which we think is relevant to you, we have provided links to such information. We take no responsibility for information found on theirwebsites, including, without limitation, whether it is accurate or up-to-date.

Please note that the listing of these service providers in this Policy is not a guarantee or undertaking that only these service providers will beused. We may change service providers or add news ones. We make commercial reasonable efforts to update this Policy to reflect thesechanges.

3. How long we retain personal dataWe may store Personal Data for longer periods of time than stated in Section ‎1 above: (i) where we believe we are required to do so to comply withlaws or in connection with legal proceedings; (ii) to resolve disputes; (iii) to enforce agreements between us and others; (iv) when the informationis related to a potential or actual legal dispute.

Please note that if we receive Personal Data relating to you in multiple contexts, such as if you have separately provided information or we haveanother basis to use it, then we may keep such information for the longer of the periods listed in this Policy. For example, you are a customer orare a representative of a customer who has subscribe to receive our newsletter but late unsubscribes, then we will retain such information forthe period listed in connection with customer or business contact information as described in this Policy, even if we remove you from theapplicable email list.

4. Your GDPR rightsSubject to certain exceptions and exclusions, the following rights apply to individuals who are located in an EU member state or otherwiseprotected by the EU General Data Protection Regulation (“GDPR”), as further described below. If you are such a person, then:

Right of access. You may request that we confirm to you whether or not we store Personal Data about you and to receive a copy of the PersonalData we maintain about you and information about: (a) the purposes of the processing of the Personal Data; (b) the categories of Personal Databeing processed; (c) the names of the recipients or the categories of recipients to whom the Personal Data have been or will be disclosed, inparticular recipients in third countries or international organizations; (d) if possible, the period we believe we will store the Personal Data, or thecriteria we use to determine that period; (e) the sources of the Personal Data, if not collected from you; and (f) whether we use automateddecision-making, including profiling, and meaningful information about the logic involved, as well as the significance and the envisagedconsequences of such processing for you.

Right to rectify. You may request that we correct any Personal Data about you that we maintain that is incorrect. Depending on the purpose forwhich the data is used, you may also request to complete incomplete Personal Data we maintain.

Right to erasure (“Right to be Forgotten”). You may request that we erase or suppress Personal Data that relates to you in the following cases: thedata is no longer needed by us; the data was collected and is used on the basis of your consent and you withdraw that consent; when you have aright to object to our use of the data (as described below under, “Right to Object”); we are not lawfully processing the data; or we are otherwiserequired by law to delete the data. However, there may be circumstances in which we may retain your data or we may refuse your request, forexample, when we review the data to defend ourselves or make legal claims or exercise are own rights. In addition, this right may not apply to thedisplay or access of your Personal Data outside of the European Union.

Right to restrict processing. You may request that we restrict our use or processing of your Personal Data if: you claim the Personal Data isinaccurate, during the time we investigate your claim; our processing of the Personal Data was unlawful; we no longer require the Personal Data;we processed the Personal Data for our legitimate interests and you object to this use (as you are permitted to do under Article 21(1) of theGDPR), during the time that we investigate whether our legitimate interests override your request. However, there may be circumstances in whichwe are legally entitled to refuse your request.

Right to data portability. You may request that we provide you with your Personal Data that we process based on your consent or to fulfill acontract with you or that we process using automated means, in a structured, commonly used and machine-readable format, and to transferyour Personal Data to another entity or have us transfer it directly to such entity.

Right to object. You may, based on reasons specifically relating to you, object to our processing of your Personal Data, when: (i) the data is usedfor our legitimate interests and our interests in processing the data does not override your interests, rights and freedoms and we do not requireuse of the data for the establishment, exercise or defense of our legal claims or rights; and (ii) we use the data for direct marketing purposes orprofiling for direct marketing purposes.

Right to object to automated decision making. You may request that you not to be subject to a decision based solely on automated processing,including profiling, when the decision produces legal effects concerning you or significantly affects you.

Right to withdraw consent. Where we process Personal Data relating to you based on your consent (such as by clicking a check box adjacent to astatement of consent), you may withdraw your consent and request that we cease using your Personal Data for the purpose for which you haveyour consent, or altogether, depending on the situation.

Right to make a complaint. You may file a complaint regarding our practices with the data protection authority in your place of habitual residence,place or work, or the place of the alleged infringement. For a list of data protection authorities in the European Economic Area, please see here:https://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.

You can exercise your rights that apply to us by contacting us by email at info@swifter.io. We may be permitted by law (including the GDPR andlocal national laws) to refuse or limit the extent to which we comply with your request. We may also require additional information in order tocomply with your request, including information needed to locate the information requested or to verify your identity or the legality of yourrequest. To the extent permitted by applicable law, we may charge an appropriate fee to comply with your request.

5. Transfers of personal data to other countries outside the EU or EEAWe transfer Personal Data we receive in or from the European Union (and other locations) to the following countries outside the EU and EuropeanEconomic Area. If Personal Data from the EU is transferred outside the EU to our affiliates or to third-party service providers, to countries whichthe European Commission has not determined to adequately protect Personal Data, we take steps to ensure that such Personal Data receives thesame level of protection as if it remained within the EU. This includes entering into data transfer agreements and using the European Commissionapproved Standard Contractual Clauses.

The United States, where our Business Partners Wix, Google, Facebook, HubSpot and LinkedIn are located. As of the date of this Policy, theEuropean Commission has determined that the United States adequately protects Personal Data. (A list of countries which the EuropeanCommission has determined to adequately protect Personal Date can be found, as of the date of this Policy, here:https://ec.europa.eu/info/law/law-topic/data-protection/data-transfers-outside-eu/adequacy-protection-personal-data-non-eu-countries_en).

If you are an individual protected by the GDPR, you may contact us in order to obtain additional information regarding the basis for the transfer ofPersonal Data relating to you to countries outside the European Economic Area. Please note that information or copies of documents we mayprovide to you in connection with such requests may be limited or redacted in order to protect the rights of third parties or to comply withcontractual obligations we may have (such as obligations of confidentiality).

6. Your California privacy rightsIf you are a California resident you have the right under California law to make certain requests in connection with our use of Personal Datarelating to you, as described below. To make such a request, please contact us by email at info@swifter.io. Please note that certain exceptionsmay apply.

6.1. Disclosure of direct marketing practices (“Shine the light”)

Under California Civil Code Section 1798.83, one time per year you may request the following information regarding our disclosure of your PersonalData to third parties for their direct marketing purposes: a list of the categories of the personal information disclosed to such parties during thepreceding calendar year, the names and addresses of such third parties, and if the nature of the parties’ businesses is not clear from theirnames, examples of the products or services marketed by such third parties. This right only applies if our relationship is primarily for yourpersonal, family or household purposes and related to the purchase of our products and services.

6.2. Removal of public information of minors

If you are under the age of 18 and have an account with us, under California Business and Professions Code Section 22581, you may request theremoval of content or information you have publicly posted on our services that is identified with you or your account. Please be aware thatcertain exceptions may apply and we may not be able to completely remove all such information

7. California do not track noticeWe do not track individuals’ online activities over time and across third-party web sites or online services (though we do receive informationabout the webpage you visited prior to access our websites, products and services such as our Website, social media accounts, andadvertisement landing pages). We do permit third-parties to track individuals’ online activities on our Site and App, including Google and Facebookwhich provide us with the analytics and tracking services described above. We do not respond to Web browser “do not track” signals or similarmechanisms. You can find out more information about do not track signals at: http://www.allaboutdnt.com/.

8. Third party websites, services & data collectionOur Services may contain links to other websites, products or services offered by third parties and Business Partners (“Third Party Services”). ThisPolicy does not apply to data collected by or on behalf of such third parties, whose privacy practices may differ from ours and who are not underour control. We are not responsible for the actions of such third parties or their data practices. Please review the privacy policies of any suchthird parties before you interact with them or provide them with Personal Data.

Furthermore, we are not responsible for the accuracy of information contained on Third Party Services linked to in this Policy or from our Services.We refer to such websites for your convenience only.

9. Personal data of childrenOur Services are not intended for, and we do not knowingly collect Personal Data from persons under the age of eighteen (18). If you believe that aperson under the age of eighteen (18) has provided us with Personal Data, or if we have received the Personal Data of such person, pleasecontact us at info@swifter.io.

10. Anonymous informationWe do not treat information we collect or receive which is not or cannot reasonably be connected to any particular person or which isanonymized or aggregated such that it can no longer be connected to or used to identify any particular person as “Personal Data”, even if it wasoriginally linked to or stored with Personal Data. Such anonymous information is not subject to this Policy and we may use it for a variety ofpurposes, may share it with third parties or even publish it for any reason.

UK: 125 Kingsway, London, WC2B 6NH, UK

U.S. 136 Madison Avenue, New York, New York, 10016, United States.

Email: info@swifter.ioPrivacy policy

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