Privacy Policy
Last updated: March 5th, 2025
About Us
Swivvy, Inc. ("Swivvy," "we," "our," or "us") is a financial technology company that provides technology and related services to enable financial institutions ("Banks") to offer banking services through digital channels. Swivvy acts as a service provider to Banks and the Program Partners that Banks work with directly, facilitating the online offering of banking services.
About This Notice
Privacy and security are of utmost importance to us. This Privacy Policy ("Policy") also incorporates the Privacy Policy for California Residents (below). This Policy describes how we collect, use, and share information to operate our business, develop and improve our products and services, and as otherwise outlined herein. We encourage you to read this Policy carefully.
References to "you" or "your" in this Policy pertain to individuals or entities who visit our Website or use our Services (both defined below), including Website visitors ("Website Users"), current or prospective customers of Swivvy (collectively, "Program Partners"), and end customers of Program Partners and Banks ("End Users").
This Policy details the ways we collect, use, and share information in connection with your use of Swivvy's Services, including but not limited to Swivvy's website available at www.Swivvy.co ("Website"), and, to the extent applicable, both sandbox and production environments for the following: Swivvy dashboard, Swivvy-developed user interface ("White-Label UI"), application programming interfaces ("API"), software development kits ("SDKs," together with the dashboard, White-Label UI, and API, the "Platform"), and the products and services offered, operated, or made available by Swivvy through the Website, Platform, and, to the extent applicable, web and mobile applications (collectively, the "Services").
This Policy covers information concerning Program Partners ("Program Partner Information"), End Users ("End User Information"), Website Users, and other users or potential users of our Services ("User Information"). Please note that this Policy only covers information that Swivvy collects, uses, and shares. It does not cover any websites, products, or services provided by Banks and/or Program Partners or other third parties, including any third-party websites, applications, or services that may be accessed through Swivvy's Website and Services.
By using the Website and Services, you accept and agree to this Policy. If you do not agree to this Policy, please refrain from using or continuing to use the Website or Services.
Program Partner, End User, and User Information Collection and Use
How We Collect Information from Program Partners, End Users, and Website Users
We collect information from or about you in various ways, depending on how you interact with the Website and our Services, including:
Directly from you: Swivvy collects certain information from you directly, including, but not limited to, information you share when you:
- Complete our "contact us" form to set up a demo or create a developer account for the Swivvy sandbox environment
- Request customer support through our "Help" or other customer support link, email, or widget
- Complete our due diligence or banking services application
- Log in to our developer portal or Platform
- Contact us directly
Automatically when you visit our Website or use our Services: We may collect location information, device information, online or mobile activity information, and other information about you when you visit, use, or interact with our Website or Services using online tracking tools or technologies, as explained in more detail in the "How We Use Online Tracking Tools or Technologies" section of this Policy.
From other sources: We may also collect information about you from additional sources, including, without limitation, from our Banks, publicly available sources, commercially available third-party sources, other members of your company, or vendors that help us identify new Program Partners. We may combine this information with personal and other information we collect about you under this Policy.
Information We Collect from Program Partners and Website Users
When you visit our Website or use the Services, we may collect certain information about or from you, depending on how you interact with the Website and our Services. For example, to the extent applicable:
When you request to use our Services: We may collect:
- Personal Identifiers (e.g., your name, email address, phone number, username, or other additional information we may ask you to provide or you choose to provide)
- Professional Information (e.g., your company's legal name, title, employer identification number ("EIN"), or other information relating to your business or beneficial owners, which may include Personal Identifiers described above or other additional information we may ask you to provide or you choose to provide)
- Financial Information (e.g., financial account name and number, balance, transaction history, information to verify financial condition and creditworthiness, or other additional information we may ask you to provide or you choose to provide)
- Inferences we derive from the information we collect
When you browse, visit, use, or interact with our Website and/or Services: We may also collect:
- Location Information (e.g., your time zone setting and device location)
- Device Information (e.g., your device type or model, web browser type and version, and operating system type and version)
- Online or Mobile Activity Information (e.g., your Internet Protocol ("IP") address, the domain name of your Internet service provider, your browser data, search history, and information about how and when you use or interact with our Services)
- Inferences we derive from the information we collect (e.g., we may derive location information from your IP address)
From other third parties, including our Program Partners and Banks, in connection with the services we provide to them. We may collect contact information and similar data to assist in providing services to our Banks and Program Partners.
How We Use the Information We Collect from Program Partners and Website Users
We may use the information we collect from Program Partners and Website Users for various purposes, including, but not limited to:
- Provide Services: To operate, provide, and maintain our Website and Services
- Improve Existing Services: To enhance, modify, add to, and further develop our Website and Services
- Develop New Services: To create new products and services
- Verify Identity: To confirm your identity and the identities of other members of your company
- Provide Support: To respond to your comments, questions, inquiries, and customer service requests
- Marketing: To advertise and market our products and services to you
- For Analytics: To conduct analytics and research
- Prevent Fraud: To detect and prevent fraud, malicious activity, and other illegal activities
- Protect Against Security Risks: To protect against security risks
- Investigate Misuse or Misconduct: To investigate any misuse of our Website and Services
- For Legal Purposes: To comply with applicable laws and legal processes
How We Use Online Tracking Tools or Technologies
We and our vendors may use various online tracking tools or technologies, such as cookies, web beacons, and similar technologies, to collect information automatically when you interact with our Website and Services.
How We Share Information
We may share the information we collect as follows:
- With Banks and Program Partners
- With Service Providers
- For Legal Reasons
- In Business Transfers
Your Choices and Rights
Depending on your location, you may have certain rights regarding your personal information. To exercise these rights, please contact us at contact@Swivvy.co.
Data Security
We implement appropriate technical and organizational measures to protect your personal information.
Data Retention
We retain your personal information for as long as necessary to fulfill the purposes outlined in this Policy.
Children's Privacy
Our Website and Services are not directed to individuals under the age of 18.
Changes to This Privacy Policy
We may update this Policy from time to time. We will notify you of any material changes by posting the new Policy on our Website.
Contact Us
If you have any questions or concerns about this Policy or our privacy practices, please contact us at:
Swivvy Finance, Inc.
contact@Swivvy.co