This is the privacy policy ("Privacy Policy") that governs how we, Swifto Inc., and our affiliates and subsidiaries (collectively, "Swifto", "we", "us" or "our"), use Personal Information (defined below) that we collect, receive and store about individuals who visit or use the website www.swifto.com (together with its subdomains, content and Services, the "Site").  This Privacy Policy forms part of our terms of use, available at www.swifto.com\agreement ("Terms of Use"). Capitalized terms used herein shall have the meaning ascribed thereto in the Terms of Use. 

1. 1.  Introduction

We are committed to respecting your online privacy and we recognize your need for the protection and management of any Personal Information that you share with us.  We provide this Privacy Policy to explain our online information practices and the choices you can make about the way your Personal Information is collected and used in connection with the Site.  "Personal Information" means any information that may be used, either alone or in combination with other information, to personally identify an individual, including, but not limited to, a first and last name, personal profile, a home or other physical address, an email address or other contact information.

2. Your Consent

By using this Site, you consent to the terms of our Privacy Policy and to Swifto's processing of Personal Information for the purposes stated herein.  If you do not agree to this Privacy Policy, then please do not use our Site.  We reserve the right, at our discretion, to modify this Privacy Policy at any time.  We will inform you regarding any modifications by either notifying you via your designated email address or by posting the changes on the Site. The modifications will become effective ten (10) days following whichever form of notification occurs first and will apply to any cause of action arising after the effective date of the change.

1. 3.  Receipt and Collection of Information

We do not currently require you to provide Personal Information in order to have general access to information available on our Site.  However, we may receive and/or collect information, including Personal Information, from you in the following ways:

3.1. Account.   In order to provide you with certain Services (defined below) that we offer through the Site, you must create an account (“Account”) by completing an online registration form or by importing certain details from your Facebook account or your account with another third party social network website that we designate on our Site (each a "Third Party Account").  Such information may include your Third Party Account user name, email address, profile picture, birthday, gender and preferences.  You may also be asked to provide us with certain mandatory information, such as your cell phone number and your address.  Please be aware that your Third Party Account user name (which may be your email address) and password may be used to create and log-in to your Account ("Log-In Details").  By linking your Account and your Third Party Account, you grant us authorization to collect the information that you make available to us from your Third Party Account.

3.2.  Dog Walking Services.   

(a) General.  We offer certain services through the Site ("Services").  Such Services include the "Dog Walking Service" which is an informative platform that enables registered Site users who are seeking a dog walker ("Seekers") to send and post requests for dog walking services through the Site, (each a "Service Request"), and enables dog walkers ("Dog Walkers") to respond through the Site to a Service Request with offers to provide said services.  We collect, receive and store Personal Information (such as your email address and cell phone number) in connection with the Services that we provide to you.  Your participation in any Services is optional and you at all times may choose whether to provide any related Personal Information.   

(b) Seekers.  If you are a Seeker then, in order to receive the full benefit of the Dog Walking Service, it may also be necessary to provide us with certain information about your Service Request, such as: your name, the consideration that you are willing to pay for the dog walk, the number of participating dogs, the duration of the dog walk and the location at which the service will take place. 

3.3. 'Contact Us' Information.  If you send us a "contact us" request we will receive and store a copy of your email address, as well as any other Personal Information you disclose.

3.4. Tell a Friend Service.  Any registered user of the Site may voluntarily participate in our Tell-A-Friend Service by forwarding a Service Request to his or her, as applicable, friend ("Friend") and/or posting the link to the Service Request on his or her Facebook page, Twitter page or another third party social network website that we designate on our Site. If a Friend responds to a Service Request by confirming his/her availability, you may be awarded points that will be displayed on your Profile.  We may also display on the Site the user name, profile picture and the number of points of the then-current top ten (10) users who have accumulated the highest number of points. If you do not want to have such information publicly displayed by us, please let us know by sending an email to contact@swifto.com.

3.5. Profile.  The Site enables you to build a profile in connection with your Account ("Profile").  The Profile information will be based on the information that you provide to us from your Third Party Account.   You may also choose to provide us with other information to use and display in connection with your Profile.  If you provide information about your references or any third party, please make sure you first obtain their consent to post and make information about them publicly available.

3.6.  Transactions. 

(a) The Dog Walking Service includes the option to purchase Dog Walking Services from a Dog Walker.  If you choose to purchase or provide Dog Walking Service, we will require sufficient information from you to complete the transaction.  If you are Seeker, such information could include a credit card number, related account and billing information, invoice related information, and other data required to process the order.  We may update such data should you grant us permission to bill you or your credit card for recurring charges, such as monthly or other types of periodic payments.  If you are a Dog Walker, we require you to open a PayPal account in order to facilitate the transaction and you acknowledge and agree to review and be bound by PayPal's terms of use and privacy policy.

(b) We may use the tools, software or services of third-party service providers to process transactions on our behalf, in which case you acknowledge and agree to review and be bound by the terms of use and privacy policy of said third-party service provider.  Except as set forth herein, we will not share your financial Personal Information with any third person or entity.

3.7. Log Files.  Like many other websites, this Site may make use of log files. The information inside the log files includes internet protocol (IP) addresses, type of browser, Internet Service Provider (ISP), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.  We may use such information to analyze trends, administer the Site, track user's movement around the Site, and/or gather demographic information. Such information is not linked to any information that is Personal Information, with the exception of the IP address which might be used to identify spamming attempts.

3.8.  Cookies and Other Tracking Technologies.  Some of our Site pages utilize "cookies" and other tracking technologies.  A "cookie" is a small text file that may be used, for example, to collect information about Site activity.  Some cookies and other technologies may serve to recall Personal Information previously indicated by a Site user.  Most browsers allow you to control cookies, including whether or not to accept and remove them.  You may set most browsers to notify you if you receive a cookie, or you may choose to block cookies with your browser.

1. 4.  Publicly Available Information

4.1.  General.  The Site may permit you and other Site users to post, publish and transmit information, video, image, data, text, documents, and other content onto public areas of the Site and to other Site users ("User Submissions").  You acknowledge and agree that certain User Submissions will become publicly published content and will be available to other Site users.  This is the case even if your User Submission contains Personal Information. Any information, photos, image, data, text, documents, or other content that you post onto a public area of the Site becomes publicly published content and will be available to all users of the Site even if such content contains Personal Information.  Please note that if you publish your contact information, you may receive unsolicited messages from users and visitors to the Site. We therefore encourage you to publish only information you are sure you want to be accessible to anyone.

4.2. User Submissions and Profile.  Any inquiries, responses, messages, and comments that you post onto public areas of the Site will be publicly available, and may include your Profile name and Profile picture (to the extent that you have posted a Profile picture).  You have the choice of deciding whether to make your inquiries, responses, messages, and comments generally available on a public area of the Site or to only send or post them to one or several Site users.  The notices and tools that we provide on the Site should help inform you who your User Submissions will visible to (for example, one or many other Site users).

5. Use of Personal Information

If you submit Personal Information to us through the Site, then such Personal Information may be used in the following ways:

5.1. We will use your Personal Information to provide and improve our Services to you, to contact you (including, for example, by email, SMS, and such other means as you may permit) in connection with the Site and Services (including for the purpose of notifying you about offers, products and/or services which are published via the Dog Walking Service) and to identify and authenticate your access to the Services that you are authorized to access.

5.2. We may use your Personal Information to contact you in response to a "contact us" request.

5.3. If you include Personal Information in an inquiry, response, message, or comment that you (i) send or post to another Site user, then such Personal Information will be disclosed to that Site user; or (ii) post to a public area of the Site, then such Personal Information will be generally publicly available.

5.4. Service Requests.  Depending on whether you are a Seeker or a Dog Walker, certain Personal Information shall be made available to other Site users in connection with your use of the Dog Walking Service, as follows:

(a) If you are a Seeker and you post a Service Request: certain information (but never your password), such as your name, postal code, and the time for the dog walk, will be made available to prospective Dog Walkers.  Your email address and phone number may also be sent to the Dog Walker that confirms, via the Site, his or her acceptance of the Service Request.

(b) If you are a Dog Walker and you approve a Service Request: certain information (but never your password), such as your Profile (including your name, age, picture, postal code) and other information that you disclose, will be made available to the Seeker.

5.5. We may transfer your Personal Information to our third-party service providers, but only for purposes of providing the Services on the Site to you. We may also provide Personal Information and non-personally-identifiable information to our subsidiaries, affiliated companies, or other businesses or persons for the purpose of processing or storing such information on our behalf.  Such transfers of Personal Information may be made to other countries around the world.  We require that these parties agree to process such information in compliance with our Privacy Policy, and we use reasonable efforts to limit their use of such information, as well as use other appropriate confidentiality and security measures.

5.6. We may disclose your Personal Information or any information you submit via the Site and its Services, if we have a good faith belief that disclosure of such information is helpful or reasonably necessary, to (i) comply with any applicable law, regulation, legal process or governmental request, (ii) enforce our Terms of Use including investigations of potential violations thereof, (iii) detect, prevent, or otherwise address fraud or security  issues, and/or (iv) protect against harm to the rights, property or safety of Swifto, its users, yourself or the public.

1. 6.  Use of Anonymous Information

We may use Anonymous Information or disclose it to third party service providers in order to improve our services and enhance your experience with the Site and its Services. We may also disclose Anonymous Information (with or without compensation) to third parties, including advertisers and partners, for purposes including, but not limited to, targeted advertisements. "Anonymous Information" means information which does not enable identification of an individual user, such as aggregated information about the use of our Site and Services.

1. 7.  Opt-out

We may use your email address to send updates, a newsletter or news regarding our Services.  You may choose not to receive future emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us.   If you no longer desire our Services or wish to delete or deactivate your Account, you can contact us at contact@swifto.com.

1. 8.  Changes to Your Personal Information

To the extent that you do provide us with Personal Information, please ensure that it remains accurate.  If your Personal Information changes, you may correct or update it by logging-in to your Account, which includes your Profile, and making the change(s), or by contacting us at contact@swifto.com. Notwithstanding the above, you may only change your Log-In Details through your Third Party Account.

9. Choice

At all times, you may choose whether or not to provide Personal Information to Swifto.  The notices that we provide on the Site in circumstances where we collect Personal Information should help you make this choice.  If you choose not to provide the Personal Information we request, you can still visit the Site, but you may be unable to access certain options, offers, and Services that involve our interaction with you.

10. Collection of Information by Third-Party Sites 

Our Site may use a reputable third party to present advertisements that you may see on our Site. These third party ad servers may use cookies, web beacons, clear gifs or similar technologies to help present such advertisements, and to help measure and research the advertisements' effectiveness. The use of these technologies by these third party ad servers is subject to their own privacy policies and is not covered by our Privacy Policy.

11. Links to Other Sites

Our Site may contain links to other sites. Other sites may also reference or link to our Site. We are not responsible for the privacy practices or the content of such other sites.

12. Children's Privacy

The Site is not intended for children under the age of 13 years old, and we do not intend to collect Personal Information from anyone we know to be under 13 years of age.

13. Security

The security of your Personal Information is important to us.  We follow generally accepted industry standards to protect the Personal Information submitted to us, both during transmission and once we receive it. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your Personal Information, We cannot guarantee absolute security. If you have any questions about security on the Site, you can contact us contact@swifto.com.

1. 14.  In the Event of Merger, Sale, or Bankruptcy

In the event that Swifto is acquired by or merged with a third party entity, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected from you and our users as part of such merger, acquisition, sale, or other change of control.  In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors' rights generally, we may not be able to control the manner in which your Personal Information is treated, transferred, or used.

15. Your California Privacy Rights.

California Civil Code Section 1798.83 permits customers of Swifto who are California residents to request certain information regarding its disclosure of Personal Information to third parties for their direct marketing purposes.  To make such a request, please send an e-mail to contact@swifto.com.  Please note that we are only required to respond to one request per customer each year.

16. Commitment

We are committed to protecting your privacy, and we are constantly modifying our Site to meet evolving demands.  If you have any comments or questions regarding our Privacy Policy, please contact us at contact@swifto.com. While we cannot guarantee privacy protection, we will address any issue to the best of our abilities as soon as possible.

Last modified: January 10, 2012