This Privacy Policy (“Policy”) discloses the privacy practices for swivl.tech (including all sub-domains, the “Sites”), which are owned and operated by Work Order Management, LLC (“Swivl,” “our,” “we,” or “us”) as well as the use of any mobile device application created by Swivl (each, the “Mobile App”) and our web-based business management applications for contractors (collectively, the “Web App”). The “Sites,” “Mobile App,” and “Web App” may be referred to collectively as our “Services.” This Privacy Policy applies to our collection, use, and disclosure of your information from our Services, including, without limitation, visitors to the Sites and unpaid users of the Services. This Policy is incorporated into our Terms of Service.
1. Acceptance
By accessing or using the Services, you warrant and represent that you accept the data practices and terms detailed in this Policy. If you do not agree with this Policy, please discontinue your access or use of the Services immediately. Please note that this Privacy Policy does not address the privacy practices of third parties, including those with whom we may share information as set forth below. Please review the privacy policies of any third parties before you disclose information to them.
2. Changes to This Privacy Policy
We may revise this Privacy Policy from time to time and without prior notice to you. Changes may apply to any personal information we already hold about you, except as otherwise set forth in this Privacy Policy, and any new personal information collected after the Policy is modified. If we make changes, we will notify you by revising the “Last Modified” date at the top of this Policy, which will always be at https://swivl.tech/privacy-policy. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.
In addition, we may provide you with “just-in-time” disclosures or additional information about the data handling practices of specific parts of our Services. Such notices may supplement this Policy or provide you with additional choices about how we process your personal information.
3. Our Relationship to You
To understand Swivl’s data protection obligations and your rights to your personal information under this Policy, it is important that you identify which relationship(s) you have with Swivl.
- “Contractors” or “Pros” refers to the registered users of the “Swivl Services,” including Contractors with both paid and free or trial accounts, on whose behalf Swivl provides contractor business management services. Authorized users of a Contractor’s Swivl paid, free, and/or demo accounts are collectively and individually referred to as “Contractor Users.” Swivl has a service provider relationship with Contractors and acts as a “data processor” when it stores, processes, transmits, or otherwise shares the consumer data it collects on behalf of the Contractor. Swivl is in a “data controller” or direct relationship with Contractor Users.
- “End Customers” refers to individuals doing business with a Contractor utilizing “Swivl Services” to provide estimates and otherwise service their accounts. If you are an End Customer, Swivl will collect and share your Personal Information solely on behalf of a Contractor, and solely based on the instructions provided by the Contractor.
- “Visitors” refers to any individual accessing the “Sites,” as well as to any individual submitting Personal Information via the Sites for any reason, including but not limited to submitting a “contact us” or other online inquiry form, subscribing to a newsletter or blog, registering for a demo or webinar, or completing an online survey. Swivl is in a “data controller” or direct relationship with Visitors.
Hereinafter we may refer to Contractors, End Customers, and Visitors individually and collectively as “you.”
4. Collection of Personal Information
For purposes of this Policy, “Personal Information” refers to any information about an identified or identifiable individual, including financial account information, and any device information that may be linked with an identifiable individual. Any information that is anonymized or aggregated is no longer Personal Information, and we may use it and share it for any reason.
We collect Personal Information from and about Visitors to our Sites; we collect Personal Information from and about Contractors and Contractor Users through our Sites and Services; and we collect Personal Information from and about End Customers and other individuals who do business with Contractors that use our Services.
Parts of our Sites are public, such as our blog, and any information that is disclosed on such public parts of our Sites may appear on search engines or other publicly available platforms. Please do not post any information that you do not want to reveal publicly.
In all cases where we share Personal Information with third parties, we will use a “minimum necessary” standard to disclose only that information required for satisfying the purpose of or performing the service for which the information is disclosed.
Information from Visitors to the Sites
Information we collect from Visitors and when we collect it:
- Information You Provide to Us: We collect the Personal Information you provide to us when you submit a “contact us” or other online inquiry form, when you comment on a blog, or when you email, call, write, fax, or otherwise initiate contact with Swivl. We record your contact information in our CRM system.
- Performance and Log Data: When you visit the “Sites,” our servers automatically record information created by your use of our Sites, which may include your IP address, browser type, operating system, the referring web page, pages visited, location, device and application IDs, and search terms.
- Cookies and Similar Tracking Technologies: We use technologies like cookies, web beacons, pixel tags, and other similar tracking technologies to gather information about how you are interacting with the Sites and Services. User sessions originating from an EU IP address are provided the opportunity to opt out of accepting all non-essential cookies.
How we use the information we collect from Visitors:
- To Provide Customer Service: When you contact us with information requests, questions, concerns, disputes, feedback, or any other reason, we use your Personal Information to respond to you.
- To Engage in Marketing and Promotional Activities: We may share your Personal Information with our current or future affiliated entities, subsidiaries, and parent companies (“Affiliates”). You can opt out of our marketing activities at any time.
- For Research and Development: We use information collected via Automated Data Collection Technologies for functional purposes, to improve the performance and usability of our Sites, and to analyze how users interact with the Services.
- For Security Purposes: We process your Personal Information to enhance the security of our Services and to combat spam, malware, or other security risks.
How we share the information we collect from Visitors:
- Consent: When we have your consent to do so, we share your Personal Information as you have agreed.
- Referral Partners: When you complete an online inquiry form to which you were referred by a third party, any information collected may be shared with the referring party.
- Marketing Partners: We share your Personal Information with third parties for marketing or advertising purposes, as permitted by law.
- Service Providers: We share your Personal Information with our trusted service providers who provide certain services on our behalf.
- Business Transfers: If we are involved in a merger or acquisition, any Personal Information we possess may be a part of the assets transferred.
- Compliance, Safety, and Protection: Personal Information may be shared with law enforcement, public authorities, or other third parties for purposes of compliance with the law or in response to subpoenas.
From Contractors and Contractor Users
Information we collect from Contractors and Contractor Users:
- Account Information: We collect certain information when you register for an account, including your name, business name, phone number, e-mail address, and business industry. For paid accounts, we collect additional information including billing information.
- Financial Information: We collect information about your payment methods, such as credit or debit card numbers, bank account numbers, and billing address.
- Third Party Public Databases, Credit Bureaus & ID Verification Partners: We may obtain information about you from public databases, credit bureaus, and ID verification partners.
- Transaction Information: We collect information when you engage in transactions via our Services.
- Contractor User Information: We collect Personal Information for authorized users including name, phone number, email address, and position.
- End Customer Information: We collect information about your customers when you enter it into our systems as part of using the Services.
- Device Information & Geolocation Data: We may collect device type, unique device ID, IP address, mobile operating system information, and with your permission, precise location data.
How we use the information we collect from Contractors and Contractor Users:
- To Provide You with the Services: We process your Personal Information to configure user accounts, provide location services, generate estimates and invoices, provision payment processing, and other system-related functions.
- To Qualify and Underwrite for Payment Processing: We use your Personal Information to verify your identity, perform credit checks, and qualify you to use Swivl’s paid services.
- For Payment Processing: We use billing and financial information to collect subscription fees and facilitate payments. Swivl does not store any bank account or credit card information in its own systems.
- To Enhance Your Experience: We process your Personal Information to provide you with a personalized experience on our Services.
- To Enforce Our Terms: We process your Personal Information to monitor, investigate, prevent, and mitigate prohibited or illegal activities.
- To Maintain Legal/Regulatory Compliance: We process your Personal Information to comply with legal obligations and prevent fraud.
- For Security Purposes: We process your Personal Information to enhance security and verify your identity and access to the Services.
From End Customers
Any Personal Information we collect about a consumer, whether entered directly by the consumer as an End Customer or entered by an authorized Contractor User, is used solely for the purpose of providing our Services and is not shared with third parties for any reason other than providing our Services, unless otherwise set forth herein.
- Transaction/Order Information: We collect information necessary to process transactions, including your name, address, email, phone number, and payment information. Swivl does not store any bank account or credit card information in its own systems.
- Geolocation Data: With your permission, we may collect precise location data.
- Information You Provide: If you contact Swivl directly, we collect the information you provide.
5. Automated Data Collection Technologies
When you access the Site or Services, we may automatically record certain information from your system by using cookies and other types of click-stream tracking technologies. This “automatically collected” information may include IP Address, a unique user ID, device type, device identifiers, browser types and language, referring and exit pages, platform type, version of software installed, system type, the content and pages that you access, the number of clicks, the amount of time spent on pages, the dates and times that you visit the Sites, and other similar information.
6. Cookies and Similar Technologies
Certain portions of our Services may collect information via cookies, web beacons, pixel tags, and similar digital tracking technologies. Swivl utilizes only strictly necessary and functional cookies as part of its application Services. Other cookies including analytics and marketing related cookies are utilized on our public-facing websites. User sessions originating from an EU or UK IP address are provided the opportunity to opt-out of these analytics and marketing cookies.
7. Third-Party Integrated Payments Services
Swivl provides the ability to integrate the Services with select third party systems for payment processing (“Payments Service”). When a Contractor elects to establish a Swivl integration with a Payments Service, all data in the Contractor account may be shared with the Payments Service. Swivl does not control the policies or procedures of these Payments Services.
Any third-party vendors who are selected to provide a Payments Service integration with Swivl are contractually required to maintain compliance with the PCI DSS and to adhere to all NACHA rules for ACH payment processing.
8. How We Share Information
Except as otherwise set forth in this Privacy Policy, Swivl does not sell, share, or in any other way transmit Personal Information submitted by End Customers to any persons or companies other than the Contractor on whose behalf the data was obtained. We reserve the right to use and disclose anonymous information to third parties at our discretion.
In all cases where we share Personal Information with third parties, we will use a “minimum necessary” standard to disclose only that information required to perform the service for which the information is disclosed.
9. Data Retention
We will retain Personal Information for Contractors and Contractor Users as long as you remain an active user of our Services and for a reasonable time thereafter.
- End Customer Personal Information: We may store on behalf of Contractors, for as long as a valid business reason exists, which may be indefinitely.
- Your Interactions on Our Services: We may store interaction information for a period after account closure, which may be indefinitely where a valid business reason exists.
- Marketing: We store information used for marketing purposes indefinitely until you unsubscribe.
- Cookie Data: We retain any personal information collected via cookies up to one year from expiry of the cookie or the date of collection.
- Telephone Records: Telephone calls may be kept for a period of up to six years.
- Anonymized and Aggregate Data: We may retain anonymized and aggregate data indefinitely.
10. Security
Swivl has implemented measures designed to secure your Personal Information from accidental loss and from unauthorized access, use, alteration, and disclosure. All information you provide to us is stored on our third party vendor’s servers which utilize industry standard security practices.
Swivl does not directly store, process, or transmit bank account and credit card information. All payment processing is accomplished via integration with third-party Payments Services providers who are contractually required to maintain compliance with the PCI DSS.
If you believe that you have experienced unauthorized access or use of your account, please contact us immediately at account-services@swivl.tech.
11. Choices and Opt-Outs
You may opt-out of receiving marketing communications from us by following the opt-out instructions we include in such communications. Any communications from us that are not Service-related or transactional in nature will offer you an “unsubscribe” option.
You may opt-out of all information collection from your mobile device by uninstalling the Mobile App.
12. Accessing, Correcting, and Deleting Your Information
Swivl acknowledges the right of individuals to access their Personal Information. Generally, you may access, correct, and/or delete your Personal Information as follows:
- Contractors and Contractor Users may access and modify Personal Information using the account settings page or by emailing account-services@swivl.tech.
- Contractors may close their Swivl account by contacting Swivl Customer Care at (404) 383-6112 or account-services@swivl.tech.
- To have Personal Information permanently deleted from Swivl systems, you must make an official request in writing by emailing account-services@swivl.tech.
- End Customers should contact the Contractor directly for access to their Personal Information.
13. California Privacy Rights
If you are a California resident, you may request from us a list of what personal information (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year. You may make such a request by emailing us at account-services@swivl.tech.
14. A Note About Children
We do not intentionally gather information about individuals who are under the age of 18 or the age of majority in the country where they reside. If you are under the age of 18, you should not use our Services.
15. Designated Countries Privacy Rights
This section only applies to users of our Services that are located in the European Economic Area, United Kingdom and/or Switzerland (collectively, the “Designated Countries”) at the time of data collection.
Swivl is a data controller with regard to any personal information directly collected from Visitors, Contractors, or Contractor Users. Swivl acts as a data processor with regard to any consumer Personal Information imported by Contractors into our systems.
Individual Rights
If you are located in the Designated Countries, you have the following rights:
- Right to Withdraw Consent – You have the right to withdraw your consent at any time for consent-based processing.
- Right of Access – Upon request, we will provide you with a copy of your personal information.
- Right to Rectification – You may request to correct or update your personal information.
- Right to Erasure – Upon request, we will erase personal information that is no longer necessary.
- Right to Restriction – You have the right to restrict processing in certain circumstances.
- Right to Object to Processing – You may object to our processing at any time.
- Right to Data Portability – You may request to receive your personal information in a structured, machine-readable format.
- Right to Lodge Complaint – You have the right to lodge a complaint with a competent supervisory authority.
To exercise your rights, please contact us at account-services@swivl.tech.
16. International Transfers
If you are accessing our Services from outside of the United States, any information provided will be transferred to us or our service providers in the United States. Such countries may have data protection laws that are less protective than the laws of the jurisdiction in which you reside. You consent to such transfer through your continued use of our Services.
17. Contact Us
Work Order Management, LLC dba Swivl
Attention: Data Protection Officer
2302 Parklake Drive Northeast Suite 550
Atlanta, GA 30345 United States
Telephone: 1 (404) 383-6112
Email: account-services@swivl.tech
