Privacy Policy

I. OUR COMMITMENT TO PRIVACY 

Swap Xf LLC (together, the “Platform”) respect the privacy rights of our users.  This privacy policy (“Privacy Policy”) applies to this website and the platform operated by the Platform, as expressly indicated by the Platform such as through a link or other display of this Privacy Policy (collectively, the “Site”) and the services offered via the Site (collectively, the “Services”).  This Privacy Policy does not apply to websites, applications, or services that do not display or link to this notice or that display or link to different privacy statements.  If you object to the collection, use, and sharing practices described in this notice, you may not use our Site or Services.  

II. THE PERSONAL INFORMATION WE COLLECT AND USE 

a. Information You Provide to Us 

  • You may choose voluntarily to provide certain personal information to us.  “Personal Information” is information that is defined by applicable law that can be used to identify you, such as your name, address, email address, phone number, or billing information. 

  • For example, you may decide to share your Personal Information when you create an account to log in to our Site (“Account”).  We need this information to set up your Account, verify your identity, and provide you with our Services. 

  • When you use our Site or Services, we may collect all information necessary to complete any transaction and provide you with the Services, including your name, address, email address, phone number, billing information, and records of your orders. 

  • If you provide us feedback or contact us via email, we will collect your name and email address, as well as any other content provided in the email, in order to send you a reply, provide customer and technical support, improve and optimize our Services, satisfy our legal obligations, enforce our contracts, and address any existing or anticipated disputes. 

  • When you express interest in or participate in any transaction through the Site or Services (each, an “Order” and, collectively, “Orders”), other participants in the Order (each, an “Authorized Trader”) will be able to see the information you selected if required for the Service or Order. 

  • If you tell us where you are, we may store and use that information to verify your eligibility to enter certain Orders, to comply with relevant laws, and for fraud prevention purposes. 

b. Information Collected via Technology 

  • Information Collected by Our Services.  In order to improve, personalize, and optimize our Site and Services and meet our legal obligations, we may automatically track certain information about your visits to and usage of our Site and Services, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to your device when you use the Internet, which may vary from session to session), device identifier, domain name, clickstream data, referring/existing pages, geolocation, and a date/time stamp for your visit.  We also use this information to analyze trends, administer the Site and Services, gather demographic information about our user base, deliver advertising, perform research, provide technical and customer support, inform our product development efforts, protect our legal rights, address disputes, and prevent our Services from being used to commit harmful or unlawful activities, including fraud.  Some of this information may also be collected so that when you use the Site or Services again, we will be able to recognize you and optimize your experience accordingly. 

  • Device Information.  We may collect information about the devices you use to access our Site and Services, including the hardware models, operating systems and versions, software, file names and versions, preferred languages, unique device identifiers, advertising identifiers, serial numbers, device motion information, and mobile network information.  This information is generally used to help us deliver relevant information to you.  

  • Cookies.  We may use cookies, log files, and other technologies to collect certain information about visitors to our website, use of our online features, and interactions with our e–mails and online advertisements.  For example, through these means, we may collect your browser type and operating system, viewed web pages, links that are clicked, IP address, sites visited before coming to our website, and emails we send that you open or forward or click through to our website.  Collecting the foregoing information and linking it with other information that you may provide helps us to best tailor our website to you and enhance your online experience by saving your preferences while you are visiting a particular page, and helps us identify website features and offers that may be of particular interest to you. 

  • Pixel Tags.  In addition, we may use “pixel tags” (also referred to as clear gifs, web beacons, or web bugs).  Pixel tags are tiny graphic images with a unique identifier, similar in function to cookies, that are used to track online movements of web users.  In contrast to cookies, which are stored on a computer’s hard drive or web browser, pixel tags are embedded invisibly in web pages.  Pixel tags often are used in combination with cookies, trigger the placing of cookies, and transmit information to us or our service providers.  This enables two websites to share information.  The resulting connection can include information such as a device’s IP address, the time a person viewed the pixel, an identifier associated with the browser or device, the type of browser being used, and the URL of the web page from which the pixel was viewed.  Pixel tags also allow us to send email messages in a format that users can read, tell us whether emails have been opened, and help to ensure we are sending only messages that may be of interest to our users.  We may also use this information to reduce or eliminate messages sent to a user. 

  • Threat Detection.  We use certain service providers to provide threat detection, user authentication, and fraud prevention services.  These service providers may automatically collect certain information about your visits to the Site, as well as the device you use to connect to our Services, in order to monitor for potential threats or bad actors.  This information may include, among other things, your IP address and your device’s unique identifiers.  

  • Third-Party Analytics.  We may use a number of service providers, such as [insert provider or anticipated provider], to help analyze how people use our Services (“Analytics Companies”).  Analytics Companies use cookies and similar technologies to collect information pertaining to how people use our Site and Services, what pages they visit, and what other sites they may have used prior to using our Services.  We use the information we get from Analytics Companies to improve and optimize our Site and Services. 

  • Location Information.  We may collect your location information, including your geolocation records, for purposes of verifying whether you are eligible to participate in an Order or to determine if you are otherwise permitted to use our Services.  We may also use such information to comply with our legal obligations, to protect our legal rights, and to address existing or anticipated disputes. 

III. INTERACTION WITH THIRD-PARTY SITES AND SERVICES 

Certain products, services, or other materials displayed on the Site and Services may integrate, be integrated into, or be provided in connection with certain third-party services and content.  We do not control those services and content and our Terms of Use and this Privacy Policy do not apply to those services and content.  You should read the terms of use agreements and privacy policies that apply to such services and content.  The Platform is not responsible for the practices used by any third-party websites or services linked to or from our Site, including, without limitation, the information or content contained within them.  By using our Site or Services, you acknowledge and agree that we are not responsible for and do not have control over any third-party services and content.  If you are using a third-party website or service and allow it to access your Personal Information, you do so at your own risk. 

IV. ADDITIONAL USES OF PERSONAL INFORMATION 

  • Creation of Aggregated Data.  We may create aggregated and de-identified data (i.e., data that is not reasonably capable of being associated with or linked to you) from Personal Information we collected from or about you.  We use such data to analyze request and usage patterns, so that we may improve, optimize, or enhance our Services and improve our users’ experience with and ability to navigate our Site.  We reserve the right to use such aggregated and de-identified data for any purpose and disclose it to third parties for any reason. 

  • Consent.  If you have provided your consent for us to use Personal Information, we will use your Personal Information for the purposes set forth in the consent.  You can withdraw your consent by contacting the Platform in accordance with the Contact Us section below. 

V. ADDITIONAL DISCLOSURES OF PERSONAL INFORMATION 

In addition to the sharing practices discussed above, we may disclose your Personal Information as follows: 

  • Parties You Share With.  When you use the Site or Services, the Personal Information you openly provide with others will be shared with parties you allow to receive such information or who need to access it to complete the Order or transactions.  

  • Service Providers.  We may share your Personal Information with certain service providers to: provide you the Services we offer through our Site; conduct quality assurance testing; facilitate the creation of accounts; provide account authentication and user verification services; provide technical and customer support; geolocate users; personalize, customize, and improve your use and experience of the Services; process financial transactions; send email and push notifications; enable security support and technical maintenance; send you messages and materials related the Services; verify your identity; prevent harmful or unlawful uses of our Services, including fraud; monitor the health and performance of code on users’ devices; request user feedback; monitor the health of our servers; manage search engine optimization, and; improve and optimize the performance of our Services. 

  • Professional Financial and Legal Advisers.  From time to time, we may also need to share your information with professional advisers, including lawyers, auditors, bankers, insurers, and consultants, in order to obtain advice or other professional services from them.  Such advisers are bound by legal and/or contractual duties of confidentiality and other prohibitions against disclosure of Personal Information. 

  • Corporate Affiliates.  We may share some or all of your Personal Information with our corporate affiliates, including, without limitation, our subsidiaries, joint ventures, and other companies under a common control (“Affiliates”), in which case we will require our Affiliates to respect this notice. 

  • Corporate Restructuring.  We may share some or all of your Personal Information in connection with or during negotiation of any merger, financing, acquisition, corporate divestiture, dissolution transaction, or other proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.  In the event of an insolvency, bankruptcy, or receivership, your Personal Information may also be transferred as a business asset. 

  • Other Disclosures.  Regardless of the choices you make regarding your Personal Information (as described below), the Platform may disclose Personal Information if it in good faith believes that such disclosure is necessary (i) to comply with relevant laws or to respond to discovery requests, court orders, or warrants served on the Platform; (ii) in connection with any legal investigation; (iii) to protect or defend the rights or property of the Platform, or users of the Site or Services; (iv) to investigate or assist in preventing any violation or potential violation of law, this notice, or our Terms of Use; or (v) if we believe that an emergency involving the danger of death or serious physical injury to any person requires or justifies disclosure of information. 

VI. SECURITY AND RETENTION OF PERSONAL INFORMATION 

The security of your Personal Information is a priority.  We seek to protect this information by implementing and maintaining reasonable administrative, technical, and organizational security measures and safeguards designed to protect Personal Information within our organization.  We provide employee training in the proper handling of Personal Information.  Unfortunately, no data transmission over the Internet or wireless network or data storage system can be guaranteed to be 100% secure.  If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately contact us in accordance with the Contact Us section below. 

VII. YOUR CHOICES REGARDING PERSONAL INFORMATION 

As a user of the Platform, you will be able to set email contact preferences within your profile.  At any time, you can easily indicate your preference to stop receiving certain communications from us by modifyingAs a user of the Platform, you will be able to set email contact preferences within your profile.  At any time, you can easily indicate your preference to stop receiving certain communications from us by modifying your email preferences [or by: -insert alternative method, if applicable].  Despite your indicated email preferences, we may send you service relatedDespite your indicated email preferences, we may send you service related communications, including notices of any updates to our Terms of Use and this privacy notice. 

VIII. HOW WE RESPOND TO DO NOT TRACK SIGNALS 

Some browsers have a “Do Not Track” feature that lets you tell websites that you do not want to have your online activities tracked.  At this time, we do respond to browser “Do Not Track” signals. 

IX. AGE TO ACCESS THE PLATFORM 

Natural persons accessing the Platform must be at least the age of majority in the state where they reside.  The Platform does not knowingly collect or maintain Personal Information from anyone under the age of majority through the Site.  If the Platform becomes aware that an individual under the age of majority in their respective state has provided the Platform with Personal Information through the Site or Services, the Platform will delete the information from its files.  If you are the parent or legal guardian of a child under the age of majority who you believe has provided Personal Information to the Platform through the Site or Services, please contact us in accordance with the Contact Us section below.  

X. Additional Disclosure for California Residents 

“Shine the Light” Law.  California Civil Code Section 1798.83 permits you to request information regarding the disclosure of your Personal Information by the Platform to its Affiliates and/or third parties for their direct marketing purposes.  To make such a request, please [insert contact method].  Please include your first name, last name, mailing address, email address, telephone number, and “California Privacy Rights” in your message. 

XI. HOW TO CONTACT US 

Any inquiries or comments regarding your Personal Information and privacy rights or this Privacy Policy should be via email at privacy@swapxf.com. 

XII. CHANGES AND UPDATES TO THIS PRIVACY POLICY 

We may change this Privacy Policy from time to time.  When we do, we will post the revised Privacy Policy on this page with a new effective date.  Any changes will become effective when we post the revised Privacy Policy on the Site.  Your use of the Sites/Services following these changes means that you accept the revised Privacy Policy.