SwitchUp Privacy Policy
This Privacy Notice was last modified on Feb 12th, 2019. DebunkMe Inc., dba "SwitchUp", ("us", "we", or "our") operates switchup.org (the "Site"). This Privacy Notice provides you with information regarding the collection, use and disclosure of data, including personal information . This Privacy Notice explains how we use data collected from our Site, products and services (collectively the “Services”), you, and third-party sources. This Privacy Notice does not apply to third-party websites, products, services or databases that we do not control.
SITE VISITORS AND SERVICES USERS
We respect the privacy of our users. As a visitor to our Site, or otherwise as a user of the Services provided by us, this Privacy Notice is intended to describe for you: the information we collect about you; how that information may be used; with whom it may be shared; and and your choices about such uses and disclosures. We encourage you to read this Privacy Notice carefully when using our Services or transacting business with us. SwitchUp’s servers, which are used to store and process the information, are located in the United States and other countries around the world. By using our Services, including our Site, you are accepting the practices described in this Privacy Notice. If you have any questions about our privacy practices, please refer to the end of this Privacy Notice for information on how to contact us.
INFORMATION WE COLLECT ABOUT YOU
We collect information about you in order to effectively provide useful Services to you and others. We also use this information to improve the quality of those Services.
1. What kind of information do we collect?
We collect information such as:
(a) Contact and demographic data. We may collect any information you enter on our Site or provide to us in any manner, including personally identifying information (such as your name, home or mailing address, e-mail address, and telephone number). We may also collect information about you from third parties. We may partner with third parties to sponsor sweepstakes or other contests and receive any information you provide to our third-party partners and consent to sharing with us. Such shared information may include your name, e-mail address, street address, zip code, telephone numbers (including cell phone numbers and carriers), SMS messaging details (e.g. date, time and content of the SMS message), birth date, gender, salary range, education, marital status, occupation, industry of employment, personal and online interests, and such other information as you may have provided to the third-party partner (together, "Third Party List Information").
(b) Account credentials. We collect passwords and similar security information used for authentication and account access.
(c) Usage data. We collect information about how you use the Services. This includes data such as the search terms you enter, the pages you visit (inbound and outbound clicks), and the items you purchase. We may also collect information about your device such as Internet Protocol (IP) address, device identifiers, and data about the network, operating system, or software you use to connect to the Site. We also automatically collect information from your browser when you visit the Site, including your IP address, your browser type and language, access times, the content of any undeleted cookies that your browser previously accepted from us, and the referring website address. However, we utilizes IP Anonymization through Google Analytics to remove the personal identifying portion of your IP address.
(d) Cookies; Web Beacons; Pixels. When you visit the Site, we may assign your computer one or more cookies, to facilitate access to the Site, to personalize your online experience, and to record information about your visit to the Site. Through the use of a cookie, we also may automatically collect information about your online activity on the Site, such as the web pages you visit, the links or advertisements you click, or the other actions you conduct while on the Site. Most browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies. If you choose to decline cookies, please note that you may not be able to sign in or use some of the features offered on our Site. We may use standard Internet technology, such as web beacons, pixels, and other similar technologies, to track your use on the Site; if you are accessing our Site from a European Economic Area or Switzerland (collectively “EU”) based IP address, we will only do so with your consent. We also may include web beacons in promotional e-mail messages or newsletters to determine whether messages have been opened and acted upon. The information we obtain in this manner enables us to customize the Services we offer our Site visitors to deliver targeted advertisements and to measure the overall effectiveness of our online advertising, content, programming or other activities.
We may allow third parties, including our authorized service providers, advertising companies, and ad networks, to display advertisements on our site. If you click on such an advertisement, these companies may use tracking technologies, such as cookies, beacons, and pixels, to collect information about users who interact with these advertisements and connect to advertiser websites. This Privacy Notice does not apply to information that may be collected by those third parties if you click on a third party advertisement. Our Site does not provide any personal information to these third parties.
When you are asked to provide personal information, you may decline. But if you choose not to provide personal information that is necessary to provide Services, you may not be able to use some features or Services.
2. How do we collect information?
We collect information directly from you and from your use of our Site as described above. We also may obtain information about you from third party sources, including surveys or questionnaires, data licensors, public records, affiliated entities, marketing companies, and other customers, including business users, who use our Services.
If you are a user, the information we collect depends on the Services that you use. You provide some information directly, such as when you create an account, submit a search query on the Site, or contact us for support. Other information is automatically collected as described in the 1.(c) Usage data and 1.(d) Cookies; Web Beacons; Pixels sections above.
3. How do we use the information we collect?
We use the information to provide useful Services and customer support to our users. We also use the information to perform research and analysis about use of, and interest in, our Services, or services or content offered by others, to help us analyze the usage and effectiveness of our Services, and to improve our Services.
If you are a registered user who has consented to email communications, we may also use the information to send you communications, including promotional communications by e-mail, postal mail, telephone and/or mobile devices, or to serve advertising to you.
We also use the information to verify your eligibility and deliver prizes in connection with promotions, contests, and sweepstakes, to verify your identity, to protect against or identify possible fraudulent transactions, to resolve disputes and enforce our agreements, and as otherwise needed to manage our business.
We may combine the information we collect with information from third-party sources for these purposes.
4. Do we share information we collect and why?
We share the information as necessary to complete any transaction or provide any service you have requested or authorized. For example, we use collected email addresses to create an “exclusion list” to exclude users on our mailing list from advertising campaigns on Facebook, Google AdWords, and Adroll.
With your consent, we may also republish user reviews on third-party sites such as Quora, Medium, and Facebook.
We may share information with companies working on our behalf, such as sponsorship partners so they may analyze how users utilize our Services for us.
We may disclose and sell information as part of a corporate transaction such as a bankruptcy, merger, acquisition, or sale of assets.
We also share information when doing so is necessary to comply with applicable law.
Finally, as described in more detail below we may provide access to third parties to collect information so that they can deliver relevant online and mobile advertising to you.
5.Who do we share information with?
We may share personal information with:
(a) Authorized service providers. We may share your information with our authorized service providers that perform certain services on our behalf in connection with your request for Services. These service providers may include marketing and customer services firms, ISPs, credit card payment processors, as well as companies that support contests, sweepstakes, surveys, or other features offered through our Site, or that provide business analysis or website support. Our contracts with these service providers, require them to take adequate precautions to keep personal information safe and confidential, limit their access to only personal information needed to perform their functions, and prohibit them from sharing or using such personal information for any other purposes.
(b) Business partners. When you express interest in products, services, promotions, offered through our Services, we will share your personal information with the businesses with which we partner to offer you those products, services, promotions, contests and/or sweepstakes only upon your consent.
(c) Third parties. We will sell or transfer personal information to third parties as allowed by law or for any legally permissible purpose. We may also sell or transfer your personal information to third parties in accordance with your authorization or upon your consent.
(d) Legal compliance. We may share information in response to a subpoena or similar investigative demand, a court order, or a request for cooperation from a law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion. When we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our website terms and conditions or other agreements or policies. In connection with a corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.
Other situations and information we may share:
Aggregated Anonymous Information. We may share anonymous aggregated information (i.e., information about you and other customers collectively, which has been anonymized and cannot be combined with other data to identify you). We may also share aggregated anonymous information with third parties to display advertising on our Site and on websites of third parties. We also may share aggregated anonymous information with third parties, including advisors, advertisers and investors, for the purpose of conducting general business analysis. For example, we may tell our advertisers the number of visitors to the Site and the most popular features or Services accessed. This information does not contain any personal information and may be used to develop Site content and Services that we hope you and other users will find of interest and to target content and advertising.
Third-Party Links and Websites. There are a number of places on the Site where you may click on a link to access other websites that do not operate under this Privacy Notice. For example, if you click on an advertisement or a search result on the Site, you may be taken to a website that we do not control. These third-party websites may independently solicit and collect information, including personal information, from you and, in some instances, provide us with personal information about your activities on those websites. We recommend that you consult the privacy statements and terms and conditions of all third-party websites you visit by clicking on the links typically located at the bottom of the webpage you are visiting.
Third-Party Cookies. Third parties, such as Google, Facebook, and Adroll, may collect information using cookies, web beacons, or tracking pixels. Third parties may collect information in order to deliver relevant online and mobile advertising to you both on and off our Site and for their own business purposes. Collection and use of information for advertising and business purposes of the third party companies is subject to the privacy policies of the third party companies with whom we work, such as the privacy policy of Facebook or Google or Adroll. Accordingly, please review those policies for specific information. If you prefer not to have your information collected and analyzed by Google, you may install the Google Analytics Opt-out Browser Add-on.
6. How do we protect the information we collect?
We take security measures (including physical, electronic and procedural measures) to help safeguard your information from unauthorized access and disclosure. We want you to feel confident using our Services to transact business. However, no system can be completely secure. Therefore, although we take steps to secure your personal information, we do not promise, and you should not expect, that your personal information will always remain secure. Users should also take care with how they handle and disclose their personal information.
If you are a user, you should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer/phone, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in credentials and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized activity.
YOUR CHOICES ABOUT COLLECTION AND USE OF YOUR INFORMATION
You can choose not to provide us with certain information, but that may result in you being unable to use certain features of our Services, including the Site.
You may use your account to access, correct, or change information that you have provided to us or that is associated with your account. You may also email us at info {at} switchup {dot} org to request amendment, correction, or deletion of your information.
Under our Do Not Call policy you may instruct us not to call you for marketing purposes by emailing us at info {at} switchup {dot} org. We will implement your instructions within 30 days. Please note that we may still need to call you for customer service or other non-marketing purposes.
If you do not want us to send you e-mail or postal mail for marketing purposes, you may remove your name from current and future e-mail and postal mailing lists by contacting us at info {at} switchup {dot} org.
We may also grant advertising clients and email services providers' access to an individual's e-mail address to verify the origin of the individual information collected.
YOUR OPT-OUT RIGHTS
You may opt-out of receiving communications from us and or our third-party partners by not submitting your information. During registration and/or when you submit personally identifiable information to us at the Site, you may opt-in or request that we share your personal information with third parties to receive marketing communications. When contacted by any of these companies or third parties, you should notify them directly of your choices regarding their use and sharing of your information. As noted, we use personal information to provide promotional offers by e-mail to our website users. We may maintain separate e-mail lists for different purposes. If e-mail recipients wish to end their e-mail subscription from a particular list, they need to follow the instructions at the end of each e-mail message to unsubscribe from the particular list. To opt-out from receiving any additional email communications regarding the Site, please send your request in writing via email to info {at} switchup {dot} org.
Nevada residents may also submit their opt-out request to the following designated email address: info {at} switchup {dot} org.
CALIFORNIA PRIVACY RIGHTS NOTICE
Companies that collect personally identifiable information ("PII") from California residents and disclose such information to third parties (including affiliated entities) for marketing purposes must, in response to a request by a consumer, either (1) provide a list detailing the categories of information shared and the entities to which such information was provided, or (2) provide a mechanism by which a consumer may opt-out of having their information shared with third parties. We have elected the second option and you may request that your PII not be shared with third parties by sending your request, including your full name, email address and postal address to: switchup.org, 123 Lake Street Suite B-1 Kirkland, WA. In accordance with California Civil Code Sec. 1789.3, California resident users are entitled to know that they may file grievances and complaints with California Department of Consumer Affairs, 400 R Street, Suite 1080, Sacramento, CA 95814; or by phone at 916-445-1254 or 800-952-5210; or by email to dca@dca.ca.gov. We may provide this information in a standardized format that is not specific to you. The designated e-mail address for these requests is info {at} switchup.org.
EUROPEAN PRIVACY NOTICE
Scope. This section applies when the processing of your personal data is governed by the EU General Data Protection Regulation (“GDPR”).
Information we collect. The personal data we collect is described in more detail above in section 1. How we collect the personal data is described in more detail above in section 2.
Information use and sharing. How we use the personal data we collect is described in more detail above in section 3. How we share or disclose the personal data we collect is described in more detail above in sections 4 and 5.
Lawful grounds. The lawful basis for us to process your personal data under the GDPR is the processing necessary for our performance of our contract with you to provide Services. We also rely on our legitimate interest in understanding how our users interact with our Site and Services and in promoting and improving our Services. We rely on your consent to send you marketing and other communications about our partners and our partners’ services. We also rely on your consent to implement non-essential cookies, pixels and other technology.
Security. How we protect your personal data is described in more detail above in section 6.
Transfer to the United States. We are located in the United States. By submitting your personal data via our Site or Services, the data will be transferred to the United States for our performance of our contract with you to provide Services.
Individual rights and requests. You may use your account to access, correct, or change any personal data that you have provided to us and that is associated with your account. You may also contact us at info {at} switchup {dot} org to request access to, transfer of, and rectification or erasure of your personal data, or restriction of processing, or to object to processing of your personal data. Please specify the nature of your request and the information that is the subject of your request. We may require you to submit additional information necessary to verify your identity and status as an EU data subject. We will respond to your request within 30 days.
If we are processing your personal data based upon the lawful ground of your consent, you have the right to withdraw your consent for such processing at anytime without affecting the lawfulness of processing based on consent before it is withdrawn. To withdraw your consent, email us at info {at} switchup {dot} org.
Retention. We retain your personal data for as long as necessary for the purpose in which it was collected to either perform a contract, or for our or a third party’s legitimate interest, or for the purpose for which you consented.
CHILDREN'S PRIVACY
Our websites are general audience sites, and we do not knowingly, and do not intend to collect personal information from children under the age of 13. Individuals under eighteen (18) years of age are not permitted to obtain products and/or services from any of our websites. No information should be submitted to, or posted at, any of our websites by visitors under eighteen (18) years of age without first obtaining the prior consent of their parent or guardian. We encourage parents and guardians to spend time online with their children and to participate and monitor the interactive activities of their children.
VISITING OUR WEBSITES FROM OUTSIDE THE UNITED STATES
If you are visiting our Site from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States where our servers are located and our central database is operated. The data protection and other laws of the United States and other countries might not be as comprehensive as those in your country. By using our Services, you understand that your information may be transferred to our facilities and those third parties with whom we share it as described in this Privacy Notice.
NO RIGHTS OF THIRD PARTIES
This Privacy Notice does not create rights enforceable by third parties or require disclosure of any personal information relating to users of our Services.
CHANGES TO THIS PRIVACY POLICY
PLEASE NOTE: OUR PRIVACY NOTICE CHANGES FROM TIME TO TIME AND CHANGES ARE EFFECTIVE UPON POSTING. PLEASE CHECK BACK FREQUENTLY FOR UPDATES AS IT IS YOUR SOLE RESPONSIBILITY TO BE AWARE OF CHANGES. WWW.SWITCHUP.ORG DOES NOT PROVIDE NOTICES OF CHANGES IN ANY MANNER OTHER THAN BY POSTING THE CHANGES AT THE SITE. IF YOU DO NOT AGREE WITH THE TERMS OF THIS PRIVACY NOTICE PLEASE DO NOT PROVIDE ANY INFORMATION TO THE SITE OR USE ANY OF THE SERVICES OFFERED OR PROVIDED BY US.
GRAMM-LEACH-BLILEY ACT, CALIFORNIA FINANCIAL PRIVACY ACT AND VERMONT PRIVACY PROTECTION ACT NOTICE
For purposes of compliance with the Gramm-Leach-Bliley Financial Modernization Act of 1999, 15 U.S.C. 6802 (the "GLB Act"), the California Financial Privacy Act, Calif. Fin. Code § 4050 et. seq. ("CFPA") and the Vermont Consumer Protection Act, 8 V.S.A. 10202 ("VCPA"), this Privacy Policy shall serve as both your initial customer relationship and annual "Privacy Notice" as defined under the GLB Act, CFPA and VCPA.
CALIFORNIA RESIDENTS
Please see our California Privacy Policy here.
HOW TO CONTACT US
If you have any questions about this Privacy Notice or our information-handling practices, or if you would like to request information about our disclosure of personal information to third parties for their direct marketing purposes, please contact us by e-mail or postal mail as follows:
switchup.org
123 Lake Street
Suite B-1
Kirkland, WA
Info {at} switchup {dot} org
