SWISH PRIVACY POLICY

Effective date: August 01, 2022

Swish Maintenance Limited ("Swish," "we," "our," or "us") is committed to protecting your privacy. This Privacy Policy (the “Policy”) explains how your personal information is collected, used, stored, processed, transferred and disclosed by Swish.

This Policy applies to our websites and brands, including www.swish.ca, charlotteproducts.com, and any other website, mobile application, or other online services that links to this Policy (collectively, the “Platforms” ).

By accessing, installing or using t the Platforms, you signify that you have read, understood, and agree to our collection, storage, use and disclosure of your personal information as described in this  Policy.  Please also see our Terms of Use.

1. WHAT PERSONAL INFORMATION DOES SWISH COLLECT ABOUT YOU AND HOW DO WE USE IT?

We collect personal information about you when you voluntarily submit information to us when you use the Platforms. This can include personal information you provide to us when you register for an account, purchase one of our products, post a review, send us messages, subscribe to our mailing lists, newsletters or other forms of marketing communications, participate in a survey, click on an ad, redeem a promotion or use some other feature of the Platforms .

We collect certain information automatically when you visit the Platforms , such as information about the pages you look at on the Platforms , the actions you take on the Platforms  or the device you use to access the Platforms. Information we collect automatically about you may be combined with other personal information we collect directly.

We may also collect information about you from third parties if they have your consent to provide us the information or otherwise as permitted by applicable law.

The categories of personal information we collect may include:

• Contact and profile information such as your name or alias, email address, phone number
• Comments, chat and opinions
• Financial information such as your shipping/billing address and credit card number
• General Location information (e.g. Province, City)
• Information provided by social networks
• Information provided by third parties
• Information about fraudulent or criminal activity related to your account

2. INFORMATION AUTOMATICALLY COLLECTED THROUGH COOKIES AND OTHER TRACKING
   
   TECHNOLOGY.

What are Cookies? 

When you use the Platforms, visit our branches, read our emails, or otherwise engage with us through a computer or mobile device, we and our third party partners (our “Partners”), automatically collect information about how you access and use the Service and information about the device you use to access the Platforms.

We use this information to enhance and personalize your user experience, to monitor and improve our websites and services, and for other internal purposes.

We typically collect this information through a variety of tracking technologies, including cookies, Flash objects, web beacons, tracking pixels, embedded scripts, location-identifying technologies, and similar technology (collectively, “tracking technologies”).

3. THIRD PARTY DATA COLLECTION AND INTEREST BASED ADVERTISING.
   
   

Interest Based Advertising

We participate in interest-based advertising and use third party advertising companies to serve you targeted advertisements based on your browsing history. We permit third party online advertising networks, social media companies and other third party services, to collect information about your use of our websites and mobile apps over time so that they may play or display ads on the Platforms ,  other websites, apps and/or devices you may use. Typically, though not always, the information used for interest-based advertising is collected through cookies or similar tracking technologies, which recognize the device you are using and collects information, including click stream information, browser type, time and date you visited the site and other information. We may share a common account identifier (such as an email address or user ID) with our third party advertising partners to help identify you across devices. We and our Partners  use this information to make the advertisements you see online more relevant to your interests, as well as to provide advertising-related services such as reporting, attribution, analytics and market research.

Social Media Widgets and Advertising

 The Platforms may include social media features, such as the Facebook Like button, Google Plus, LinkedIn, Snapchat, Instagram, Twitter or other widgets. These social media companies may recognize you and collect information about your visit to the Platforms, and they may set a cookie or employ other tracking technologies. Your interactions with those features are governed by the privacy policies of those companies.

We display targeted advertising to you through social media platforms, such as Facebook, Twitter, and others. These companies have interest-based advertising programs that allow us to direct advertisements to users who have shown interest in the Platforms while those users are on the social media platform, or to groups of other users who share similar traits, such as likely commercial interests and demographics. We may share a unique identifier, such as a user ID or hashed email address, with these platform providers or they may collect information from our website visitors through a first-party pixel, in order to direct targeted advertising to you or to a custom audience on the social media platform. These advertisements are governed by the privacy policies of those social media companies that provide them. If you do not want to receive targeted ads on your social networks, you can adjust your ad preferences through your settings on those networks. If you do not want to receive targeted ads on your social networks, you may be able to adjust your advertising preferences through your settings on those networks. For example:

• Facebook. To learn more about your advertising preferences on Facebook, click here.
• Twitter. To learn more about privacy controls for personalized ads on Twitter, click here.
• LinkedIn. To learn more about advertising preferences on LinkedIn, click here.
  
  

Cross-Device Linking

We, or our  Partners, may link your various devices so that content you see on one device can result in relevant advertising on another device. We do this by collecting information about each device you use when you are logged in to the Platforms. We may also work with Partners  who employ tracking technologies, or the application of statistical modeling tools, to determine if two or more devices are linked to a single user or household. We may share a common account identifier (such as an email address or user ID) with third party advertising partners to help recognize you across devices. We, and our partners, can use this cross-device linkage to serve interest-based advertising and other personalized content to you across your devices, to perform analytics and to measure the performance of our advertising campaigns.

Third party partners.

The following is a sample of the third party service partners we work with to provide cross-device linking and advertising services. We will strive to update this list if or when we work with new partners which offer you a choices about the collection of your information, but as partners change and new technologies become available, this list is likely to change over time and may not always reflect our current partners. We require any third party service partner to protect your personal information in a manner consistent with this Policy and to limit the use of such personal information only as relevant to the performance of services for Swish.

Google Analytics and Advertising. We use Google Analytics and Google Universal Analytics to recognize you and link the devices you use when you visit our site or Service on your browser or mobile device, login to your account on the Platforms, or otherwise engage with us. We share a unique identifier, like a user ID or hashed email address, with Google Universal Analytics to facilitate the service. Google Analytics allows us to better understand how our users interact with our Service and to tailor our advertisements and content to you. For information on how Google Analytics collects and processes data, as well as how you can control information sent to Google, review Google's site “How Google uses data when you use our partners' sites or apps” located at www.google.com/policies/privacy/partners/. You can learn about Google Analytics’ currently available opt-outs, including the Google Analytics Browser Ad-On here.

We may also utilize certain forms of display advertising and other advanced features through Google Analytics, such as Remarketing with Google Analytics, Google Display Network Impression Reporting, the DoubleClick Campaign Manager Integration, and Google Analytics Demographics and Interest Reporting. These features enable us to use first-party cookies (such as the Google Analytics cookie) and third-party cookies (such as the Doubleclick advertising cookie) or other third party cookies together to inform, optimize, and display ads based on your past visits to the Service. You may control your advertising preferences or opt-out of certain Google advertising products by visiting the Google Ads Preferences Manager, currently available at https://google.com/ads/preferences or by vising NAI’s online resources at http://www.networkadvertising.org/choices.

Google Advertising. To learn more about your ad settings through Google, click here.

Bing Ads. To learn more about Bing Ads, click here.

User Experience Information

On some of the Platforms, we use third party tools to monitor user experience information. These tools automatically collect usage information, including mouse clicks and movements, page scrolling and any text keyed into website forms. The information collected does not include passwords, payment details, or other sensitive personal data. We use this information for site analytics, optimization and to improve website usability. We do not permit this information to be shared with or used by third parties for their own purposes.

4. HOW WE SHARE YOUR INFORMATION
   
   

We may share your personal information in the instances described below. For further information on your choices regarding your information, see the “Control Over Your Information” section below.

We may share your personal information with the following parties:

• Our affiliates and companies in the same group of companies as us: our affiliates and subsidiaries (i.e., any organization or brand we own or control) or our ultimate holding companies (i.e., any organization that owns or controls us) and any subsidiaries it owns. These companies may use your personal information in the same way as we can under this  Policy.
• Third parties at your request: You may choose to share your activities on Swish with your friends through email, text or on various social media networks.
• Promotional partners: Third parties with whom we partner to provide contests and sweepstakes, or other promotional activities, which will usually be identified by name in the Official Rules of the contest or sweepstakes.
• Select third parties: Third parties, so that they can provide you with information and marketing messages about products or services that may interest you. To opt-out of our sharing your personal information with such companies, see Your Choices and Control Over Your Information, below.
• Service providers and advisors: Third party vendors and other service providers that perform services for us, on our behalf, which may include identifying and serving targeted advertisements, providing mailing or email services, tax and accounting services, product fulfillment, payments processing, data enhancement services, fraud prevention, web hosting, or providing analytic services.
• Product Suppliers: third party product suppliers who may have a legitimate business or legal interest in receiving such information. For example, personal information may be shared with product suppliers to fulfill warranty service obligations, product recalls or other product safety related matters, or transaction tracking regarding shipments or leases of supplier products.
• The public: When you provide feedback or post user content on our site. For example, if you post a product review on our website or a comment on our social media sites, your information, such as your first name, last initial, state of residence, and your comments, may be displayed on our website or on our social media pages.
• Purchasers and third parties in connection with a business transaction: Personal information may be disclosed to third parties in connection with a Swish-related transaction, such as a merger, sale of Swish assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another Swish or third party, or in the event of a bankruptcy or related or similar proceedings; and
• Law enforcement, regulators and other parties for legal reasons: Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to (a) comply with the law and the reasonable requests of law enforcement; (b) to enforce our Terms of Use or to protect the security or integrity of our Service; and/or (c) to exercise or protect the rights, property, or personal safety of Swish, our visitors, or others.
  
  

We may also share information with others in an aggregated or otherwise anonymized form that does not reasonably identify you.

Personal information relating to you may be transmitted outside the province of Ontario and/or Canada by us and our group of companies, our business partners and our service providers consistent with the purposes disclosed in this Policy. While outside of Canada, your personal information may be subject to the laws of that foreign jurisdiction and may be accessible to law enforcement and other authorities in the foreign jurisdiction.

5. YOUR CHOICES AND CONTROL OVER YOUR PERSONAL INFORMATION
   
   

By submitting personal information to Swish, visiting or using the Platforms , you acknowledge and agree that you have consented to the collection, use, and sharing practices set forth in this Policy as they relate to your personal information. You may withdraw your consent by following the instructions set forth in this  Policy. You may also contact Swish’s Privacy Officer as set forth below. However, withdrawing your consent may limit your ability to use the Platforms and access our web content. You may not have the full functionality of the Platforms , and Swish may not be able to offer you some of the personalized products and services that depend on this type of information to function.

Profile and data sharing settings: You may update your profile information, such as your user name, address, or billing information, and may change some of your data sharing preferences on your Account Page, click here.

How to control your email preferences: You can opt out from  receiving promotional email communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of service-related communications (e.g., account verification, transactional communications, changes/updates to features of the Service, technical, safety, and security notices).

Accessing, modifying or deleting your information: If you have any questions about accessing, reviewing, modifying, or deleting your information, or if you want to remove your name or comments from our website or publicly displayed content, you can contact us directly by submitting a request to our portal here. We may not be able to provide you with access to or to modify or delete your information in all circumstances due to legal or contractual restrictions, and access to your personal information may be subject to legal exemptions recognized in applicable law.

Cookies, tracking and interest-based advertising preferences:

• Cookies and Flash cookies. Most browsers allow you to adjust your browser settings to: (i) notify you when you receive a cookie, which lets you choose whether or not to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies.
  
  Blocking or deleting cookies may negatively impact your experience using the Platforms , as some features and services on the Platforms may not be accessible.
  
  Deleting cookies does not delete Local Storage Objects (LSOs) such as Flash objects and HTML5. To manage Flash cookie settings and preferences, you must use the settings manager on Adobe’s website or by clicking here. If you choose to delete Flash objects from our Service, then you may not be able to access and use all or part of the Service or benefit from the information and services offered.

• Interest-based advertising. To learn about interest-based advertising and how you may be able to opt-out of some of this advertising, you may wish to visit the Network Advertising Initiative’s online resources, at http://www.networkadvertising.org/choices, and/or the DAA’s resources at www.aboutads.info/choices.

• Cross-device linking. Please note that opting-out of receiving interest-based advertising through the NAI’s and DAA’s online resources will only opt-out a user from receiving interest-based ads on that specific browser or device, but the user may still receive interest-based ads on his or her other devices. You must perform the opt-out on each browser or device you use.

• Mobile advertising. You may also be able to limit interest-based advertising through the settings on your mobile device by selecting “limit ad tracking” (iOS) or “opt-out of interest based ads” (Android). You may also be able to opt-out of some – but not all – interest-based ads served by mobile ad networks by visiting http://youradchoices.com/appchoices and downloading the mobile AppChoices app.
• Some of these opt-outs may not be effective unless your browser is set to accept cookies. If you delete cookies, change your browser settings, switch browsers or computers, or use another operating system, you may need to opt-out again.
  
  

6. HOW WE STORE AND PROTECT YOUR INFORMATION
   
   

Data storage and transfer: Your information collected through our website may be stored and processed in the United States or any other country in which Swish or its affiliates or service providers maintain facilities. If you are located in Canada or the European Union or other regions with laws governing data collection and use that may differ from U.S. law, please note that we may transfer information, including personal information, to a country and jurisdiction that does not have the same data protection laws as your jurisdiction, and you consent to the transfer of information to the U.S. or any other country in which Swish or its parent, subsidiaries, affiliates, or service providers maintain facilities and the use and disclosure of information about you as described in this Policy. While in a foreign jurisdiction, your personal information may be subject to the laws of that jurisdiction and may be accessible to law enforcement or other authorities.

Keeping your information safe: The protection  of your personal information is very important to us, and we have put in place safeguards to preserve the integrity and security of the personal information we collect and that we share with our service providers. However, even with the security measures, we cannot guarantee the security of your personal information. By using our Platforms, you acknowledge and agree that we make no such guarantee and that you use the Platforms at your own risk. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and, where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

7. LINKS TO OTHER WEB SITES AND SERVICES
   
   

The Platforms may contain links to and from third party websites of our business partners, advertisers, and social media sites and our users may post links to third party websites. If you follow a link to any of these websites, please note that these websites have their own privacy policies and that we do not accept any responsibility or liability for their policies. We strongly recommend that you read their privacy policies and terms and conditions of use to understand how they collect, use, and share information. We are not responsible for the privacy practices or the content on the websites of third party websites.

    8. HOW TO CONTACT US

If you have any questions about this Privacy Policy or the website, please contact our Privacy Officer at the following address:

Privacy Officer, Swish
2060 Fisher Drive, Peterborough, Ontario K9J 6X6
[email protected]

If you wish to make a request to access, edit, or delete your personal information, please click here to submit your request via our portal. The portal requires limited information about you that is needed to process your request.

9. CHANGES TO OUR PRIVACY POLICY
   
   

We may modify or update this  Policy from time to time to reflect the changes in our business and practices, and you should review this page periodically. We will update the ‘last modified’ date at the bottom of this page when we post changes to this Policy. If you object to any changes, you may close your account. Continuing to use our Services after we publish changes to this  Policy means that you are consenting to the changes.

This privacy policy was last modified on 08/2022