User Account Information Provided

This is information that you provide to us through text fields, such as your name, contact information and payment information. The information we collect differs depending on whether you create an account, create a Fan Page, charge for your content or are just a manager or agent for a Content Creator.

• First and Last Name
• Email Address
• Mobile Phone Number
• Username
• Password
• State and Country of Residence

You may also sign up using a Facebook or Google account. We will ask for permission to access basic information from your Facebook or Google account, such as your name, email and profile picture. You can choose to stop sharing that information with us at any time by going to Facebook or Google to remove Swaray’s access to that account and your ability to log in.

You also have the option to add more information to your public profile, such as a location, social media links and an about section, which we store along with any comments or messages you submit on Swaray.

Users

A User is someone who joins the Swaray platform to view and purchase content from Content Creators, purchase NFT Lifetime Access Passes from Content Creators or make donations to Content Creators. As a User, in order to purchase Swaray points on the Swaray platform, you must provide your payment information to our payment processors. You can see the Privacy Policy for these payment processors on the PayPal and Stripe websites. Swaray does not receive your full card number at this time. Payment processors provide us with a token that represents your account, your card’s expiration date, card type and the last four digits of your card number. If you are required to provide your name and email address to the payment processor then they also provide us with that information.

We collect and process information about the content you purchase from Content Creators, the free content you search for and view, and how often you pay for content.

Content Creators and Athletes

A Content Creator is someone who creates and provides content for Users through the Swaray platform. To become a Content Creator, you must create a Fan Page that describes what content you are creating. To receive payouts you have to create an account with one of our payment partners: PayPal or Stripe. We may also require your bank account information to process payouts. You must also provide us with additional information for tax purposes. Depending on your location you may have to fill out a form with some combination of your:

• First and Last Name
• Address
• Social Security Number or Employer Identification Number
• Country of Citizenship
• Foreign Tax Identification Number
• Date of Birth
• Your Nonprofit Registration Number, if you are a nonprofit business
• Bank Account Information for Payouts
• Phone Number

NFTs

Content Creators who create a Fan Page and decide to mint an NFT All Access Pass on the Swaray platform are providing Users with a tradable, lifetime access pass to all of their content on the Swaray platform in exchange for a one-time purchase of the NFT All Access Pass.  In order to mint (do you need a wallet to mint?) or purchase an NFT All Access Pass, Content Creators and Users must link an external, non-custodial crypto wallet to their Swaray account. Swaray allows you to link to a number of different third-party non-custodial wallets through an integration with Wallet Connect, including, but not limited to Metamask, Crypto.com, Rainbow, Trust Wallet and Math Wallet.  Depending on which wallet you decide to link your Swaray account to, you may have to fill out a form with some combination of your:

• First and Last Name
• Address
• Social Security Number or Employer Identification Number
• Country of Citizenship
• Foreign Tax Identification Number
• Date of Birth
• Your Nonprofit Registration Number, if you are a nonprofit business
• Phone Number

What Information We Collect

You probably wonder what information we collect. This often depends on the exact nature of our relationship with you and how you choose to use Swaray, but we’ve described the most common examples below. We have broken these descriptions down into categories to make them clearer:

We collect account information

We collect information relating to your account. For example, we collect basic registration details like name, email address, phone number, birthday, and username and password when you create a Swaray account. You may be able to share other account-related information with us too, like if you choose to provide a profile photo or your interests. We collect some information about your friends when you invite or refer them to Swaray or import your contacts.

We collect usage information

We collect information about your interactions with Content Creators and Users and your actions on Swaray. For example, we collect information about how many Fan Pages you view, how long you participate in Live Events and who you chat with. If you purchase points or items, provide gifts of points or items or make donations, we collect information about what you purchase, gift or donate

When you participate in a Live Event, Fan Page Chat, Fan Page Q&A or Direct Message as User on Swaray, we collect the questions or comments you make as well as record how many times Users visit the application, a Fan Page or Live Event, their activity on the application/website, where Users have interacted or replied, with whom they’ve communicated or messaged, their IP addresses and from which location the User was last logged in.

Swaray uses this info to make the product better for you so you can focus on being present with Content Creators and other Users. We do the heavy lifting, utilizing tech to improve the experience.

We collect certain information when you link third party accounts or apps to Swaray

If you link social media accounts to Swaray, we collect certain social media account information. If you link your contacts, we collect information about your friends and other Users, like their phone numbers and addresses. If you link non-custodial, crypto currency wallets to Swaray, we collect certain information related to your usage and activity, but do not collect any account or login information.

We collect location information

For example, we may collect your zip code and state. Based on your IP address, we also derive location information.

We collect feedback information

We collect information that you give us when you complete a survey or participate in a contest or promotion. This includes when you write a review or make a suggestion.

We collect device information

We collect information about the browser or device you are using. We may look at what site you came from, or what site you visit when you leave us. We may also collect device identifiers. For example, this might include your operating system and hardware model. This may also include your mobile carrier.

Why We Collect Information

Now that you know what we collect, we want to tell you why and what we do with that information. Below we explain how we use information:

We use some information to communicate with you

We use information to respond to your questions, including questions about our services or your relationship with us, and to communicate with you about this policy or our Terms. We may also contact you about your feedback.

We just want to be able to be responsive to you, and occasionally reach out to hear how it’s going on Swaray, and make sure you have updates on what’s going on with us!

We use some information so you can participate in Swaray and to enhance your experience

We use information to process your registration and to empower you to use certain features. With your permission where required by law, for example, we use information to suggest other users with whom you may want to connect. We also use information so you can invite new people to join Swaray and to provide or suggest specific features.

We use some information so you can participate in Swaray and to enhance your experience

We use information to process your registration and to empower you to use certain features. With your permission where required by law, for example, we use information to suggest other users with whom you may want to connect. We also use information so you can invite new people to join Swaray and to provide or suggest specific features.

We help you find Content Creators, other Users and make connections. For example, we might suggest a Content Creator or User to you based on your common favorite Content Creators or Users.

We use some information to improve our products

We use information to make Swaray better, for example by saving certain preferences you choose, tracking events in Swaray, and recording other performance data. We use this information to customize your experience, analyze product trends, and to develop and improve our products and services.

We use some information for marketing purposes

We use your information to share updates about new products and special offers, including promotions, surveys, and contests, through email, via SMS text, on our app, or on social media platforms. We might also use this information to tell you about products and offers, new features, or updates. These might be our own offers or products or select third-party offers or products we think you might find interesting.

We use information to protect our company and users

We use information to protect our company and users, for example to identify fraud and secure, protect accounts, and protect Swaray. This includes looking into potentially prohibited or illegal activity.

We may also use push notifications in our mobile apps

We may send you push notifications about updates and other information we think you will find interesting, for example to let you know when a favorite Content Creator or User is online.

Our basis for processing European information

Our basis for processing your information for the reasons described above is typically to perform a contract, including responding to your requests. For example, this includes providing customer service. Where this applies, if you choose not to provide information, we may be unable to perform the contract or respond to your request. We also process information based on your consent. Where you have provided consent, you have the right to withdraw it. We also use information about you when we have a legitimate purpose in doing so. For example, this includes helping secure and improve Swaray.

We also use information as otherwise permitted by law.

How We Collect Information

Like many other companies, there are different ways that we collect information, which we’ve outlined below:

We collect information directly from you

We use tracking tools to collect information from you passively. These tools include things like browser cookies and web beacons. We use these on our sites and in emails that we send to you. We collect this information about users over time when you download and use our app.  Please see our Cookie Policy for more information on our use of cookies on Swaray.

The information we gather helps us give you the best experience on Swaray.

We get information about you from third parties

Social media platforms and third-party apps may give us information about you. We may also collect information about you from other Users. This might include your name, phone number, or email address if they invite or refer you to our app or if they have linked their contacts to their Swaray account.

What social platforms are we talking about? We might get information, for example, from Facebook if you choose to link your Swaray account with a third-party platform. Information they share with us includes certain details from your profile.

We combine information

Swaray is an integrated social media platform, which means we may combine information that we have collected across devices, such as computers and mobile devices. We may also combine information we get from a third party with information we already have and combine information that we have collected from other third-party sites.

When We Share Information

Swaray is part of the digital community, and as part of our business there are times that we share information with third parties. You can find out more about that here:

Sharing on Swaray

Swaray is designed to let you join video chats with not only your favorite Content Creators but also the favorites of others. If someone who is not your direct connection joins your video chat session you will get a notice. Your public profile is available to both Content Creators and other Users. Other Users may also be able to view your name, username, and your Favorites (i.e., who you speak to most often). Favorites can see a list of some of your other Favorites and receive a notice when you go online and are in a Live Event.

Swaray exists to help you connect with the people (Content Creators and Users) you care about most. When you connect with Content Creators and other Users, they can see some of the profile information you’ve created on Swaray.

Information we share with Content Creators

By favoriting or purchasing content from a Content Creator, you agree to have the following information shared with that Content Creator:

• Your name, phone number and email address, and other profile information you’ve provided
• Any messages you send Content Creators through Swaray
  Your physical address, city, state, and country (if provided for physical delivery of items)
• All information about your pay-per-view subscription, monthly subscription or NFT All Access Pass purchase including amount and start date but not your full payment card information
• Some aggregated and anonymized data about how you use Swaray that cannot be linked back to you or to any individual user

Content Creators agree to the terms of our Content Creator Agreement (CCA) when they create a Fan Page. The CCA is a creator’s promise to protect the privacy of Users during and beyond their relationship with any respective User. You can view a copy of the CCA here.

We share information with our vendors

We may share information with trusted third parties, including companies who serve as our vendors and help us deliver our services and social media partners if you elect to use social media integration features. We may also share some information with companies that help operate our app or run a promotion.

What can we say? We can’t do it alone. Sometimes we have to work with other companies to help us deliver a great Swaray experience.

We will share information if we think we have to in order to comply with the law or to protect ourselves

For example, we will share information to respond to a court order or subpoena or if a U.S. or non-U.S. law enforcement agency, government agency, or investigatory body requests it. We may also share information we collect when we investigate potential fraud, abuse, or other similar violations of Swaray rules and codes of conduct.

We may share information with any successor to all or part of our business

If all or part of our business is sold, we are part of a merger or acquisition, or there is a financing or bankruptcy, we may share information as part of that transaction.

We may also share information for other reasons we may describe to you or as permitted under law.

Your Rights

You have certain choices about how we use your information. Those are described here:

You can opt out of certain marketing

To stop receiving our promotional emails or communications follow the instructions in any promotional message you get from us. If you opt out of getting marketing messages, you will continue to receive non-marketing messages from us about your relationship with us where permitted by law.

You can control certain aspects of your interactions with others on Swaray

Swaray is meant to offer a fun way for people to interact with other people in ways similar to how you might in-person. However, your settings do give you certain controls over your video conversations and chats.

We believe in respecting social norms. You control who joins your Live Event.  Only those people that you or your friends in a particular Live Event invite are allowed to attend any given Liven Event. You can learn more about this in our Guidelines in the app.

You can control certain notifications about being online

If you don’t want other Users or Content Creators to know when you’ve launched the app, then you can select that option in the Notifications section of Settings on the Swaray app. You can also select online notification preferences for yourself in your notification settings. When you launch the app, you’re listed as active on the application and others may be able to immediately contact you or join you in a Live Event.

You can control cookies and tracking tools

Your browser may give you the ability to control cookies or other tracking tools. How you do so depends on the type of tool. Certain browsers can be set to reject browser cookies.

Our Do Not Track Policy

You may change your browser settings or take other steps to block, manage, or delete cookies. Not all of our websites and online services currently respond to browser “do not track” signals, so you will need to use your browser settings to effectively manage cookies. In some cases, blocking or disabling cookies may cause Swaray not to work as intended and some features may not be available.

You can control certain settings on your mobile device

For example, you can turn off the location services or push notifications on your phone. To modify the push notifications you get from us, you can change your preferences in Swaray settings. You also can modify app level permissions, such as location collection, through your device settings. The Digital Advertising Alliance also offers a tool for opting out of the collection of cross-app data on a mobile device for interest-based advertising. To exercise choice for companies participating in this tool, download the AppChoices app here. Choices you make are both browser and device specific.

Additional Rights

In some places laws grant residents certain additional rights. We have described those rights in the relevant sections here:

Read on to learn more about different rights we offer depending on your location. A lot of these rights have to do with your ability to ask us for more information. You can reach us using the contact information listed in the “contact us” section below.

European Residents

If you are an EEA, Swiss, or UK resident, you may have the right to access your information, the right to correct your information, the right to request deletion of your personal information, the right to request restricted processing of your personal information, the right to a portable copy of the personal information you have provided, and the right to object to processing of your personal information, such as for direct marketing. For more information about exercising these rights, send an email to info@swaraylabs.com. EEA and UK residents also have the right to lodge a complaint with a data protection authority if they have concerns about our handling of personal information.

Sale of information

We only use the personal information we collect to help provide, support, and improve Swaray as described in this policy, and we do not “sell” this information to third parties as that term is defined by applicable laws.

Establishing an Authorized Agent

You may designate an authorized agent to make a request on your behalf. In order to designate an authorized agent to make a request on your behalf, you must provide a valid power of attorney, the requester’s valid government ID and the authorized agent’s valid government ID. Please contact privacy@swaraylabs.com with your request. To protect your information from account takeover, we may decline access to or recovery of your account at our discretion.

Account Holders with Disabilities

Swaray is committed to accessibility for its account holders with disabilities. If you are having difficulty accessing your account, please email us at info@swaraylabs.com for assistance.

How We Protect Information

We maintain appropriate administrative, technical, and physical safeguards to protect your personal information from accidental, unlawful, or unauthorized destruction, loss, alteration, access, disclosure, or use and other unlawful forms of processing. You should keep your user credentials and password confidential and secure so that your information is protected.

We work hard to protect your data, but the Internet is not 100% secure. We encourage you to use caution online. This includes not sharing or reusing your passwords and not accepting friend requests from strangers.

Transfers of Information

Swaray is based in the United States, which means the information we collect may be processed and stored within the United States. If you live outside of the United States and choose to use Swaray, you understand that your information may be processed outside your country of residence, including in other jurisdictions (like the United States) that may have different data protection frameworks than your region. We keep personal information as long as it is necessary or relevant for the practices described in this policy and as otherwise required by law.

Information we transfer from Europe to the United States is subject to appropriate safeguards under applicable law.

Third-Party Sites

We may link to third-party sites or apps. Swaray may also include third-party content that collects information. We do not control these third parties. This policy does not apply to the privacy practices of these third-party websites or apps. Please read the privacy policies of other websites carefully. We are not responsible for the practices of these third-party sites or apps.

How To Contact Us

To learn more about our privacy practices or this policy, please contact us at info@swaraylabs.com or at

Swaray Inc.
Attn: Legal
627 Promontory Drive East
Newport Beach, CA 92660
USA

Updates

Things change. The world evolves. Here at Swaray, we want to keep current with the times. This might mean that our practices will change. We will notify you of any material changes to our policy as required by law. We will also post an updated copy on our website. Please check our site periodically for any updates.