Privacy Policy

Swae is completely committed to protecting your personal privacy and organization’s data.

Information We Collect & How We Use It

Swae doesn’t make money from ads. So we don’t collect data in order to advertise to you. The tracking we do at Swae is to make our product work as well as possible.

In order to give you the best possible experience using Swae, we collect information from your interactions with our network. Some of this information, you actively tell us (such as your email address, which we use to track your account or communicate with you). Other information, we collect based on actions you take while using Swae, such as what pages you access and your interactions with our product features (like highlights, follows, and applause). This information includes records of those interactions, your Internet Protocol address, information about your device (such as device or browser type), and referral information.

We use this information to:

  • provide, test, improve, promote and personalize Swae Services
  • fight spam and other forms of abuse
  • generate aggregate, non-identifying information about how people use Swae Services

When you create your Swae account, and authenticate with a third-party service (like Twitter, Facebook or Google) we may collect, store, and periodically update information associated with that third-party account, such as your lists of friends or followers. We will never publish through your third-party account without your permission.

Information Disclosure

Swae won’t transfer information about you to third parties for the purpose of providing or facilitating third-party advertising to you. We won’t sell information about you.

We may share your account information with third parties in some circumstances, including: (1) with your consent; (2) to a service provider or partner who meets our data protection standards; (3) with academic or non-profit researchers, with aggregation, anonymization, or pseudonomization; (4) when we have a good faith belief it is required by law, such as pursuant to a subpoena or other legal process; (5) when we have a good faith belief that doing so will help prevent imminent harm to someone.

If we are going to share your information in response to legal process, we’ll give you notice so you can challenge it (for example by seeking court intervention), unless we’re prohibited by law or believe doing so may endanger others. We will object to requests for information about users of our services that we believe are improper.

Data Storage

Swae uses third-party vendors and hosting partners, such as Amazon, for hardware, software, networking, storage, and related technology we need to run Swae. We maintain two types of logs: server logs and event logs. By using Swae Services, you authorize Swae to transfer, store, and use your information in the United States and any other country where we operate.

Third-Party Embeds

Some of the content that you see displayed on Swae is not hosted by Swae. These “embeds” are hosted by a third-party and embedded in Swae. For example: YouTube or Vimeo videos, Imgur or Giphy gifs, SoundCloud audio files, Twitter tweets, GitHub code, or Scribd documents that appear within a Swae post. These files send data to the hosted site just as if you were visiting that site directly (for example, when you load a Swae post page with a YouTube video embedded in it, YouTube receives data about your activity). Swae does not control what data third parties collect in cases like this, or what they will do with it. So, third-party embeds on Swae are not covered by this privacy policy. They are covered by the privacy policy of the third-party service.

Some embeds may ask you for personal information, such as your email address, through a form. We do our best to keep bad actors off of Swae. However, if you choose to submit your information to a third party this way, we don’t know what they may do with it. As explained above, their actions are not covered by this Privacy Policy. So, please be careful when you see embedded forms on Swae asking for your email address or any other personal information. Make sure you understand who you are submitting your information to and what they say they plan to do with it. We suggest that you do not submit personal information to any third-party through an embedded form.

If you embed a form that allows submission of personal information by users, you must provide near the embedded form a prominent link to an applicable Privacy Policy that clearly states how to you intend to use any information collected. Failure to do so may lead Swae to disable the post or take other action to limit or disable your account.

Tracking & Cookies

We use browser cookies and similar technologies to recognize you when you return to our Services. We use them in various ways, for example to log you in, remember your preferences (such as default language), evaluate email effectiveness, allow our paywall and meter to function, and personalize content and other information.

Swae doesn’t track you across the Internet. We track only your interactions within the Swae network (which encompasses Swae.com and custom domains hosted by Swae).

Some third-party services that we use to provide the Swae Service, such as Google Analytics, may place their own cookies in your browser. This Privacy Policy covers use of cookies by Swae only and not the use of cookies by third parties.

Swae complies with the “Do Not Track” (“DNT”) standard recommended by the World Wide Web Consortium. For logged-out users browsing with DNT enabled, Swae’s analytics will not receive data about you, but we will do some first-party tracking in order to customize content and provide data to third-party service providers that enable Swae Services to work. When you use Swae while logged-in to your account, we cannot comply with DNT. 

Turning off / disallowing / disabling or deleting cookies in your browser
The majority of internet browsers will provide an option to disallow cookies. You can usually find how to do this in the help menu for your browser. Cookies can also be deleted by using your internet browser, but you must disallow cookies otherwise they will be reapplied the next time you visit a website.  If you disable cookies you may find that certain sections of our website will not work. For example, you may have difficulties logging-in or adding items to your basket. 

Your ability to control the cookies you accept depends on the type of browser you are currently using. For the best on-line experience, and for additional safety when browsing the internet, we recommend you install the latest version of whichever browser you choose to use. You can order your browser to accept all cookies or to alert you each time a cookie is offered. This way you can decide whether to accept one or not.

Internet Explorer 7.0 or 8.0
Choose Tools, then
Click Internet Options
Click then Privacy tab, and then, under Settings, move the slider to the top to block all cookies or to the bottom to allow all cookies, and then click OK.

Internet Explorer 9.0+
Choose Tools, then
Click Internet Options
Click Privacy Tab and click on the Advanced Button
Now, you can Allow or Block First-Party Cookies and Third-Party Cookies and then click OK

Firefox
Choose Tools, then
Options
Click the Privacy tab,
Use Custom settings for history
Check mark Accept cookies from sites to enable Cookies, and uncheck it to disable them
Choose how long cookies are allowed to be stored:
Keep until: they expire
Keep until: I close Firefox
Keep until: ask me every time
Click OK

Google Chrome:
Click the spanner icon on the browser toolbar
Select Options (Preferences on Mac and Linux; Settings on a Chromebook)
Click the Under the Bonnet tab
Click Content settings in the Privacy section
Click the Cookies tab in the Content Setting dialogue that appears

Safari:
From the Safari menu, click Preferences
From the Security dialogue box, from Accept Cookies, click to select Always
Click Close

Email Newsletter

In order to inform you, as a subscriber, about products and services supplied by this website. As a user, you will be able to subscribe through an online automated process – this will be at your own discretion.

Subscriptions will be taken in compliance with UK Spam Laws detailed in the Privacy and Electronic Communications Regulations 2003. All personal details relating to subscriptions will be held securely and in accordance with the Data Protection Act 2018.  No personal details will be passed on to third parties or shared with companies / people outside of Saker Lynd & Co.

Any email marketing campaigns published by this website or Saker Lynd & Co may contain tracking facilities within the actual email. Subscriber activity will be tracked and stored in a database for future analysis and evaluation. Such tracked activity may include; the opening of emails, forwarding of emails, the clicking of links within the email content, times, dates and frequency of activity.

This information is used to refine future email campaigns and supply you, the user, with more relevant content based around your activity.

In compliance with UK Spam Laws and the Privacy and Electronic Communications Regulations 2003, subscribers will be given the opportunity to unsubscribe at any time through an automated system. This process will be detailed at the footer of each email campaign. If an automated un-subscription system is unavailable clear instructions on how to un-subscribe will by detailed instead.

External Links

This website contains links to other websites operated by our partners and others.  Although we only look to include quality, safe and relevant external links, you are advised that by clicking any external link on this website, you do so at your own risk.

Saker Lynd & Co cannot guarantee or verify the contents of any externally linked website despite our best efforts. In addition, we cannot be held liable for any damages or implications caused by visiting any of the external links mentioned.  If you follow a link to any of these websites, please note that they will have their own privacy policies.  We don’t accept any responsibility or liability for these policies.  So, please check the policies before you submit any personal information to these websites.

Social Media Platforms

Communication, engagement and actions taken through external social media platforms that this website and Saker Lynd & Co participate on are subject to the terms and conditions as well as the privacy policies held by each of these social media platforms.

You are advised to use social media platforms wisely, communicating and engaging on them with caution so far as your own privacy and personal details are concerned. Neither this website nor Saker Lynd & Co will ever ask you for personal or sensitive information via social media platforms.  If you wish to discuss sensitive information, please contact us via telephone or email.

This website may use social sharing buttons which help share web content directly from web pages to the social media platform in question. You are advised that the use of such social sharing buttons is at your own discretion.  Please note that the social media platform may track and save your request to share a web page through your social media platform account.

Modifying or Deleting Your Personal Information

If you have a Swae account, you can access, modify or export your personal information, or delete your account here.

To protect information from accidental or malicious destruction, we may maintain residual copies for a brief time period. But, if you delete your account, your information and content will be unrecoverable after that time. Swae may preserve and maintain copies of your information when required to do so by law.

Data Security

We use encryption (HTTPS/TLS) to protect data transmitted to and from our site. However, no data transmission over the Internet is 100% secure, so we can’t guarantee security. You use the Service at your own risk, and you’re responsible for taking reasonable measures to secure your account.

Business Transfers

If we are involved in a merger, acquisition, bankruptcy, reorganization or sale of assets such that your information would be transferred or become subject to a different privacy policy, we’ll notify you in advance so you can opt out of any such new policy by deleting your account before transfer.

Email from Swae

Sometimes we’ll send you emails about your account, service changes or new policies. You can’t opt out of this type of “transactional” email (unless you delete your account). But, you can opt out of non-administrative emails such as digests, newsletters, and activity notifications through your account’s “Settings” page

When you interact with an email sent from Swae (such as opening an email or clicking on a particular link in an email), we may receive information about that interaction. We won’t email you to ask for your password or other account information. If you receive such an email, please send it to us so we can investigate.

Changes to this Policy

Swae may periodically update this Policy. It may change without notice.

Questions

We welcome feedback about this policy here

Data Protection Statement for European Union Users

Description of Processing Activity

Swae collects and stores personal information about its users to customize their reading experience and enable personalized distribution of content. It shares minimal data with its service providers.

Purposes of Processing

  • Provide, test, promote, and improve the services
  • Gather usage statistics of services
  • Provide customized reading experience
  • Publish and distribute user-generated content
  • Provide access to paid content
  • Pay authors in Partnership Program for certain content
  • Fight spam, fraud, and other abuse of services

Legal Bases

In order to provide the services, Swae collects and stores personal data about its users on the legal basis of consent given when you create an account and agree to the Privacy Policy.

Swae also pursues its legitimate interests by collecting minimal data of logged out users to provide the services, as outlined above.

Where Swae collects and stores personal data about non-users, it does so under performance of contract obligations with users who use the services to publish content on web sites hosted by Swae. In such cases, users authoring such content containing personal data of third parties are responsible for that content. Swae will consider related complaints in compliance with the General Data Protection Regulation’s rights of the data subject, as well as rights of expression and access to information.

Public Nature of Personal Data

Logged-in users may choose to interact publicly with the Swae Services in the form of clapping for a post, highlighting parts of a post, following other user accounts, sharing links on connected social media accounts, or writing original posts. Where such personal data may reveal special category protected data, it is processed on the basis that it is manifestly made public by the user. Additional information on potential consequences of such processing can be found below. If you do not agree to this public usage, do not create an account or use these features of Swae Services.

Categories of Personal Data Collected

Logged out users

  • Reading history
  • IP address
  • Browser information
  • DNT status

Logged in users:

  • Username
  • Display name
  • Bio
  • Avatar image
  • Email address (non-public)
  • Session activity (security)
  • Linked social media accounts (optional)
  • IP address
  • Browser information
  • Reading history 
  • Network interactions (recommends, follows, etc.)
  • Posts, responses, or series published by user

Members:

  • Billing information and history

Partner authors:

  • Bank account for payments
  • Business information, if applicable

Categories of Recipients

Swae shares minimal personal data with third-party processors in order to provide the Services. These processors offer at least the same level of data protection as that set out in this statement. This includes the following categories of recipients:

  • Hosting, Storage, & Other Infrastructure
  • Security
  • Analytics
  • Communication & Support
  • Payment Processors

Search engines will index user profiles, public interactions, and any user-generated content. Users may also share links to your content on social media.

Payment Processors

Swae provides Services in conjunction with several payment processors, including: Stripe, Paypal, Google Play, and Apple Pay, through which users may pay for Swae memberships or receive payment based on participation in our Partner program. Those companies acting as payment processors may collect and store personal data related to your billing information and history in order to provide their services, and may collect and store personal data and business data to prevent fraud and other abuse.

When you delete your Swae account, Swae deletes your personal data as outlined in this document. However, to delete your payment or billing information, you will need to do so with your payment provider, as Swae only has minimal secure access to those records as needed to provide the services.

Embedded Content

Swae posts may contain third-party embeds, which may in some cases collect and store personal data. The use of personal data by embedded content providers is not covered by this statement, but by the privacy policies of those sites or services.

Existence of Automated Decision-making

Swae collects and stores personal data about its users to customize reading. This includes automated decision-making to promote content tailored to the preferences and interests indicated by the user, and to their browsing history and network interactions.

Swae also filters content for the purposes of fighting and preventing spam, fraud, and other forms of abuse.

Potential Consequences of Processing

By creating an account on Swae, users may make certain personal data about themselves public and accessible to others on their profile and through network interactions. This may in some cases constitute special category protected data which is considered manifestly made public by the user.

Due to the public nature of information posted to Swae, it may be possible for third parties to derive identifying personal data from posts, whether by reading, inference, supplemental research, or automated extraction and analysis.

Users are free to use their real name and information, or a pseudonym of their choosing, for their account. Users may also choose to use the service without posting data or engaging in network interactions. However, if you do not agree with and accept the risks of such usage, you may not use the services.

Cross-border Transfers

Swae is hosted in the United States. By using Swae Services, you authorize Swae to transfer, store, and use your information in the United States & Canada and any other country where we operate. Where your data is disclosed to our processors, it is subject by contract to at least the same level of data protection as that set out in this statement.

Retention

Swae retains personal data associated with your account for the lifetime of your account. If you would like to delete your personal information, you can delete your account at any time. Deleted account profile pages will yield an error 404 “file not found” page, immediately upon initiating deletion, and will become unrecoverable in our system after a period of fourteen days. It may take several additional days for your personal data to be de-indexed from search engines, depending on those search engines’ practices, over which Swae may have limited or no control.

To delete your payment or billing information, you will need to do so with your payment provider, as Swae only has minimal secure access to those records as needed to provide the services.

Rights of Data Subjects

  1. If you sign up for a Swae account, you may at any time request an export of your personal information from the Settings page.
  2. You may correct information associated with your account from the Settings page, and the Customize Your Interests page to update your interests.
  3. You may withdraw consent by deleting your account at any time through the Settings page, which will erase your personal information completely within 14 days (except to the extent Swae is prevented by law from deleting your information).
  4. You may object at any time to the use of your personal data by contacting us here. If your complaint relates to alleged misuse of your personal data by a third party, it may result in suspension of that post or account in keeping with relevant law, public interest, our contractual obligations, and the rights of expression and access to information of others.
  5. You may at any time lodge a complaint regarding the processing of your personal data by Swae with the Supervisory Authority of your EU member state.
Soushiant Zanganehpour Founder & CEO

Soushiant is a social scientist, entrepreneur and Founder of Swae.io, an AI-powered platform for smarter organizational decisions and 21st century governance. Swae helps companies, cities and organizations of all sizes benefit from the collective intelligence of their employees, stakeholders and citizens helping source innovative ideas, program and product feedback, and policy, budget, and strategy suggestions, at a fraction of the cost. Stakeholders and AI build compelling proposals together from the bottom-up that are crowd-vetted and the best move to a decision-round for implementation, creating a bi-directional pathway for governance. Soushiant is a recognized global practitioner in the fields of business innovation, impact investing, social entrepreneurship, and sustainability having spoken at numerous international conferences and published in The Guardian, The Financial Times, Bloomberg Business Week, and Entrepreneur magazines. He is on Harvard Business Review's Advisory Council, and a board advisor of Biocarbon Engineering, a reforestation startup using drones to replant a billion trees per year.
Soushiant earned his BA (PoliSci & IR) from the University of British Columbia, a Diplôme in International Affairs from Sciences-po Paris, an MPP (Public Policy & Economics) from the University of London’s School of Oriental and African Studies (SOAS), and attended Singularity University’s Global Solutions Program as a Google Scholar. He was awarded a full scholarship by the UK's Foreign Office as one of four Canadian Chevening Scholars for his Masters. .

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