This privacy notice describes how Sway As Limited ("Sway.ly", "we", "us", "our") collects, uses, shares, and protects your personal data as “user”, whether you are a parent or a child over 13, when you use our services via our website (www.Sway.ly) or our apps (we’ve referred to both as our “Site” in this policy). We are committed to protecting your privacy and ensuring the security of your personal data.
Want a simpler version of this policy? Our Privacy FAQ for Teens [here] sets out a summary of this policy in a friendly format; you can read this yourself, or your parents can use it to explain things to you.
At Sway.ly, the privacy of our users is paramount. We are committed to protecting the privacy of our service users and website visitors. This Privacy Policy sets out how we collect and look after your personal information and your rights in relation to the manner in which we use your personal information.
The most important things to know are that:
We do urge you however, to read this Privacy Policy so you understand how we collect, process and use your personal information.
The Controller is Sway As Limited, doing business as Sway.ly, a company registered in the United Kingdom with address at 3 Walden Road, Chislehurst, Kent BR7 5DH. For any questions, suggestions, or complaints regarding your personal data, or exercise your rights, contact our Data Protection Officer at support@Sway.ly.
Account Creation, Set-up and Registration data. We will collect the following personal data about you when you create your user account or otherwise register to our services: name, surname, nickname, username(s), password(s), family relationships, email address, age, gender, mobile telephone number. This information is required to enable Sway.ly to provide you the services.
Payments. We collect payment related details including billing name, billing contact details (street addresses, email addresses), and payment instrument details. This information is required to provide you the services. Paddle is our current payment provider, but we can contact additional payment processors. Any payment data they collect directly may be processed according to their terms and privacy policy, which is provided to you during the payment process.
Communications and submissions. We collect data when you communicate with us (e.g. via email or our Site) or submit information, for example when you sign up to our beta-release through our Site, contact us for queries, comments or out of curiosity, respond to surveys, provide feedback or participate in promotions.
Social Media username and password. To enable our services to analyse your Social Media Data, you will need to authenticate by entering your login credentials (username and password) directly in the App. We therefore process your social media account username and password in that context. This information is required to provide you the services.
Social Media Data: Information of your social media accounts and the social media posts and accounts you interact with or social media accounts that interact with your account (like, comment, repost or reshare, watch, save, subscribe, follow, favourites, or scroll through) and time spend on social media, based on the Hypertext Transfer Protocol, other technology or as otherwise provided by you to us. This information is required to provide you the services.
Device Information: Details of the device used to access the services such as operating system, browser type or version, the address of a referring site (if any) and your activity on our Sites such as what pages were visited and what links were clicked. We also collect or store Your IP address, social media applications installed (only those that can be added to our service) and screen time configuration through our app.
Analysis Results: Insights generated through AI processing and data analytics of your account’s use of our services. This information is required to provide you with those services.
Service Customisation Data: Personalised recommendations of information resources.
Preference information: Your marketing preferences, if you are over 18, including any consents you have given us.
If you choose not provide us the information required to provide you the services, as previously described, we may be unable to do so.
We collect personal data directly from you and may also process:
We collect and use your personal data to provide our services and comply with the law. In some places, like the European Economic Area (“EEU”) and the United Kingdom (“UK”), we may need a specific legal reason to use your information. This Section describes how we use your information, and, if applicable, the legal basis for collecting your information. If we need to collect any other information from you, we'll explain why when we collect it.
The table below sets out why we process your data and to the extent European Economic Area and the United Kingdom law is applicable, the lawful basis for the processing:
| Purpose | Legal Basis |
|---|---|
| To fulfil our contractual obligations with you, which includes setting up and managing your Sway.ly Account, communicating with you, billing administration activities, process payments and otherwise providing our services, as well as sending newsletters and promotions, if so requested by you. | Performance and preparation of a contract with you or to take steps at the request of the data subject prior to entering into a contract. Necessary for our legitimate interest in running our business and providing you with our services. |
| Managing our services, which includes: Analytics results and service customisation data. Improving navigation, maintenance and support, fraud prevention and implementing security measures. Promoting, measuring, improving and securing our services, as well as their functionalities. To troubleshoot and support our services. Recommendation and satisfaction surveys | Performance and preparation of a contract with you or to take steps at the request of the data subject prior to entering a contract. Necessary for our legitimate interest in running our business and promoting, measuring, improving and securing our services, as well as its functionalities. |
| Use information provided by social media platforms or trusted third parties to complement, analyse and combine your collected data through the services in order to provide such services. | Necessary for our legitimate interest in running our business and promoting, measuring, improving and securing our services, as well as their functionalities. Necessary to comply with a legal obligation. |
| Comply with a legal or regulatory obligation, for compliance with a legal or regulatory obligation that we are subject to. | Necessary to comply with a legal obligation. |
| To communicate with users, prospective users and people who contact us. | Performance and preparation of a contract with you or to take steps at the request of the data subject prior to entering a contract. Necessary for our legitimate interest in running our business. |
| To send you marketing promotions, offers, competitions and events by email (subject to your preferences). Please see the section below on Marketing for more information. | Processing based on your consent for direct marketing purposes. |
| To generate anonymized and aggregated reports for internal analysis, statistics and publications. These reports will not identify individual users. | Necessary for our legitimate interest in running our business and promoting, measuring, improving and securing our services, as well as their functionalities. |
If other laws require us to obtain your consent before processing your personal data for the described purposes, we will do so in accordance with those laws.
Our services are designed for users 13 years and older. We do not intentionally collect personal information directly from children under 13. In line with the UK’s laws on processing children’s personal data, children over the age of 13 will be asked to give their own consent, except as otherwise required by law. We never use children’s data for marketing purposes.
With additional users under your Sway.ly account
For account holders and other adult users: we share the following analysis results with the other users of your Sway.ly account: your time spent on social media platforms you connect to our services and your overall “Trust” score.
For teens: we share the following analysis results with the main account holder: dashboard, content alerts, “traffic light” page (information on the negative content category you’ve been overexposed to), weekly report and the time spent on the social media platforms you’ve connected our services to.
With Third Parties
Personal data will also be shared with third party service providers, who will process it on behalf of Sway.ly so that we can provide our services to you. Such third parties include providers of website hosting and maintenance, customer support service providers, payment providers. We also have AI processing partners that generate insights required for the services, which are exclusively of publicly available data of social media end users public posts, as such provided to us by third-party sources. Our agreements with such third parties only allow them to process data for purposes related to providing us services and in accordance with our instructions.
We do not transfer data outside the UK.
In the event that the business is sold or integrated with another business, your details will be disclosed to our advisers and any prospective purchaser’s adviser and will be passed to the new owners of the business.
We retain personal data:
Retention periods are determined by the following criteria:
If you grant us access to information of your YouTube, Instagram, Facebook, or TikTok accounts, we may automatically retrieve Social Media Data, as previously defined. We utilize this Social Media Data, along with data from other sources, to provide our Services. Please carefully review the terms and conditions and privacy policies of your respective social media platforms, as they govern, among other relevant terms, the information of your social media use that is collected and processed and, if applicable, shared with us and other businesses, and the purposes for which it is shared.
Please note that our services contain links to other websites or services (chats, helplines, etc.), which have their own privacy policies. Sway.ly is not responsible for the privacy practices of those external sites, and we encourage you to review their privacy policies.
As a data subject, you have the following rights under applicable data protection laws:
To exercise these rights, please contact us at support@Sway.ly where we will provide you with information on the procedure on how to exercise them.
If you've shared your contact information with us, we may send you our newsletter and marketing emails about our services and other updates about Sway.ly. If you don’t want to receive these emails, you can check the appropriate box when you sign up for our services simply click the 'unsubscribe' link in any email we send or contact us at the email address in the final section of this Policy. Remember, unsubscribing from newsletter and marketing emails won't stop important service-related messages.
We prioritise the security of all your personal data. In compliance with applicable laws, we implement security provisions to safeguard your information. This includes but is not limited to, encryption, access controls, tokenisations and data masking.
Sway.ly stores your personal data only for as long as needed to provide services or while your account remains active. We also retain data when legally required or for legitimate purposes. Please note that our backup systems may temporarily store residual copies per our disaster recovery plans.
We use cookies and other tracking technologies on our Website. To find out more, please consult our policy on trackers available here.
This Policy may be amended or revised from time to time at the discretion of Sway.ly. Changes to this Policy will be posted on our website https://www.Sway.ly/privacy and, where appropriate, notified to you by email. If we propose to make any material changes, we will provide notice on this page prior to the change becoming effective. We encourage you to periodically review this Policy for the latest information on our privacy practices.
If you believe we have not complied with data protection laws, you can lodge a complaint with the applicable data protection authority, including with:
For any privacy-related questions, please contact: support@Sway.ly.