Swish Privacy Policy


LAST UPDATED: JULY 2022

Swish OnO, is an application suite and an online platform published by the InMobi and/or its affiliates (collectively referred to "Swish", "InMobi", "us," "we," or "our"), that provides end users ("end users" or "you") a unique home screen guide helping you to consume and navigate dynamic content relevant to your interests. Swish’s offerings include Gaming, Sports, Shopping, Finance, Entertainment, News, and Weather apps published individually on the application stores such as Google Play Store, GetApps and in applications containing combinations of these apps. Features of these apps may also be accessible through the Swish Homescreen or Swish Folder on your device. We respect your privacy, and we are committed to protecting it. This Privacy Policy is designed to help you understand how we collect, use, process, and share your personal information and to help you understand and exercise your privacy rights.

  1. SCOPE
  2. PERSONAL INFORMATION WE COLLECT
  3. HOW WE USE YOUR INFORMATION
  4. HOW WE DISCLOSE YOUR INFORMATION
  5. YOUR PRIVACY CHOICES AND RIGHTS
  6. SECURITY OF YOUR INFORMATION
  7. INTERNATIONAL DATA TRANSFERS
  8. RETENTION OF PERSONAL INFORMATION
  9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS
  10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS
  11. CHILDREN’S INFORMATION
  12. OTHER PROVISIONS
  13. CONTACT US

1. SCOPE

This Privacy Policy applies to personal information processed by us, including on our websites, Swish and/or other related software made available to you through smart devices which may be preloaded on the devices, downloadable from Google Play Store, or made available through other digital media ("Services").

Important Note: This Privacy Policy does not apply to: (i) third party’s websites, applications, content, or landing pages ("Third Party Content"), that you may access through Swish, (ii) your interaction with Third Party Content; or (iii) information that you provide to or that is collected by any third party ("Third-party Data"). Third Party’s respective privacy policies govern their collection and use of your information may be available on the settings page of your smart device. Any questions or requests relating to Third-Party Data should be directed to the relevant third party. For the Application that is made available as a pre-loaded feature on a smart device, please note that, the carrier/provider of the device may incorporate relevant terms of this policy within their own privacy policies or provide for a different version of this privacy policy and make the same available to you. Please refer to the settings page of your smart device for the same.

We are the controller for the personal information we process, unless otherwise stated. For information on how to contact us, please refer to "CONTACT US" below.

2. PERSONAL INFORMATION WE COLLECT

The categories of personal information we collect depend on how you interact with us, our Services, and the requirements of applicable law. We collect information that you provide to us, information we obtain automatically when you use our Services, and information from other sources such as third-party services and organizations, as described below. Please note that you may interact with our customers, telecom partners, advertisers and media partners directly and their respective privacy policies govern their collection and use of your data.

  1. Information You Provide to Us Directly
  2. We may collect the following personal information that you provide to us:


  3. Information Collected Automatically
  4. We may collect personal information automatically when you use our Services:


  5. Information Collected from Other Sources
  6. We may obtain information about you from other sources, including through third-party services and organizations. For example, if you access our Services through a third-party application, such as an app store, a third-party login service, Third Party Content, or a social networking site, we may collect information about you from that third-party application that you have made available via your privacy settings.

3. HOW WE USE YOUR INFORMATION

We use your information for a variety of business purposes, including to provide our Services, for administrative purposes, and to market our products and Services, as described below.
  1. Provide Our Services
  2. We use your information to fulfill our contract with you and provide you with our Services and perform our contract with you, such as:


  3. Administrative Purposes
  4. We use your information in our legitimate interest, such as:


  5. Marketing and Advertising our Products and Services
  6. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law.

    Some of the ways we market to you include email campaigns, custom audiences advertising, and "interest-based" or "personalized advertising," including through cross-device tracking.

    If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time as set forth in "CONTACT US" below.

  7. With your Consent
  8. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.

  9. Other Purposes
  10. We also use your information for other purposes as requested by you or as permitted by applicable law.

4. HOW WE DISCLOSE YOUR INFORMATION

We disclose your information to third parties for a variety of business purposes, including to provide our Services, to protect us or others, or in the event of a major business transaction such as a merger, sale, or asset transfer, as described below.

  1. Disclosures to Provide our Services
  2. We may disclose your information to the third parties (as set out below) for a variety of business purposes, as described above, in accordance with applicable privacy laws and regulatory requirements:

  3. Disclosures to Protect Us or Others
  4. We may access, preserve, and disclose any information we store associated with you to external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement or national security requests and legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual illegal activity.

  5. Disclosure in the Event of Merger, Sale, or Other Asset Transfers
  6. If we are involved in a merger, acquisition, financing due diligence, reorganization, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.

5. YOUR PRIVACY CHOICES AND RIGHTS

The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these and learn more about targeted advertising and consumer choice and privacy by visiting the Network Advertising Initiative, the Digital Advertising Alliance,the European Digital Advertising Alliance, and the Digital Advertising Alliance of Canada.

Please note you must separately opt out on each device.

Your Privacy Rights. In accordance with applicable law, you may have the right to:

If you would like to exercise any of these rights, please contact us at dsr_swish@inmobi.com, with the subject line "Opt-out" and providing us with the email address of your account or your GAID. We will process such requests in accordance with applicable laws. We do not track users with cross-device identifiers, please keep in mind that every time you change your device, reset your identifier or reinstall the app a new request will need to be submitted.

6. SECURITY OF YOUR INFORMATION

We take steps to ensure that your information is treated securely and in accordance with this Privacy Policy. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable law, we do not accept liability for unauthorized disclosure.

By using our Services or providing personal information to us, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of our Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on our Services, by mail, or by sending an email to you.

7. INTERNATIONAL DATA TRANSFERS

All information processed by us may be transferred, processed, and stored anywhere in the world as described in this policy, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavor to safeguard your information consistent with the requirements of applicable laws.

8. RETENTION OF PERSONAL INFORMATION

We store the personal information we collect as described in this Privacy Policy for as long as you use our Services, or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws.

9. SUPPLEMENTAL NOTICE FOR CALIFORNIA RESIDENTS

This Supplemental Notice for California Residents only applies to our processing of personal information that is subject to the California Consumer Privacy Act of 2018 ("CCPA"). The CCPA provides California residents with the right to know what categories of personal information we have collected about them, and whether we disclosed that personal information for a business purpose (e.g., to a service provider) in the preceding 12 months. California residents can find this information below:

Category of Personal Information Collected by Swish

Category of Third Parties Information is Disclosed to for a Business Purpose

Identifiers. 

A real name, alias, unique personal identifier, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. 

  • Advertising networks, including the Group
  • Service providers
  • Other Users/Public (User Content)

 

Commercial information

Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.

  • Advertising networks, including the Group
  • Service providers

 

 

Internet or other electronic network activity

Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.

  • Advertising networks, including the Group
  • Service providers

 

 

Geolocation data

Precise location information when the consumer opts into its collection.

  • Service providers

Sensory data

Audio, electronic, visual, or similar information.

  • Service providers

Inferences drawn from other personal information to create a profile about a consumer

Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  • Service providers

 

 

The categories of sources from which we collect personal information and our business and commercial purposes for using personal information are set forth in "PERSONAL INFORMATION WE COLLECT" and "HOW WE USE YOUR PERSONAL INFORMATION" above, respectively.

"Sales" of Personal Information under the CCPA

California residents have the right to opt out of the "sale" of their personal information. Under the CCPA, "sale" is defined broadly and includes the transfer of personal information by a business to a third party for valuable consideration (even if there is no exchange of money).

We may "sell" personal information. The categories of personal information we have "sold" and the categories of third parties we have "sold" personal information to in the preceding twelve months are listed below:

Category of Personal Information Sold by Swish

Category of Third Parties  Personal Information is Sold to

Identifiers

A real name, alias, online identifier, Internet Protocol address, email address, account name, or other similar identifiers. 

  • Advertising networks including the Group
  • Data analytics providers including the Group channels

 

Internet or other electronic network activity

Browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement.

  • Advertising networks including the Group

 

Geolocation data

Precise geolocation information when opted in by consumer.

  • Service providers
  • Advertising networks including the Group

 

Sensory data

Audio, electronic, visual, or similar information.

  • Service providers
  • Advertising networks including the Group

 

Inferences drawn from other personal information to create a profile about a consumer

Profile reflecting a consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

  • Service providers
  • Advertising networks including the Group

 

Our business and commercial purposes for "selling" personal information can be found in "HOW WE USE YOUR INFORMATION" above. We do not have actual knowledge of any "sale" of personal information of minors under 16 years of age.

Opt-out of "Sales." California residents may opt-out of the "sale" of their personal information by contacting us at dsr_swish@inmobi.com.

Additional Privacy Rights for California Residents

Non-Discrimination. California residents have the right not to receive discriminatory treatment by us for the exercise of their rights conferred by the CCPA.

Authorized Agent. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. To designate an authorized agent, please contact us at dsr_swish@inmobi.com and provide written authorization signed by you and your designated agent.

Verification. To protect your privacy, we will take the following steps to verify your identity before fulfilling your request. When you make a request, we will ask you to provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include, but not limited to, asking you to answer questions regarding your account, device information and/or use of our Services.

If you are a California resident and would like to exercise any of your rights under the CCPA, please contact us as set forth in "CONTACT US" below. We will process such requests in accordance with applicable laws.

Accessibility. This Privacy Policy uses industry-standard technologies and was developed in line with the World Wide Web Consortium’s Web Content Accessibility Guidelines, version 2.1. If you wish to print this policy, please do so from your web browser or by saving the page as a PDF.

California Shine the Light. The California "Shine the Light" law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their personal information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties.

10. SUPPLEMENTAL NOTICE FOR NEVADA RESIDENTS

If you are a resident of Nevada, you have the right to opt-out of the sale of certain Personal Information to third parties who intend to license or sell that Personal Information. You can exercise this right by contacting us as described in "Contact Us" below with the subject line "Nevada Do Not Sell Request" and providing us with your name and the email address associated with your account.

11. CHILDREN’S INFORMATION

Protecting children’s privacy online is very important to us. Although our Services are designed for a general audience, for any Services that may appeal to children we limit personal information collection and sharing to only what is necessary to support the internal operations of our Services.

If you are a parent or guardian and believe your child has uploaded personal information to our site without your consent, you may contact us as described in "CONTACT US" below. If we become aware that a child has provided us with personal information in violation of applicable law, we will delete any personal information we have collected, unless we have a legal obligation to keep it, and terminate the child’s account, if applicable.

12. OTHER PROVISIONS

Third-Party Websites/Applications. The Services may contain links to other websites/applications and other websites/applications may reference or link to our Services. These third-party services are not controlled by us. We encourage our users to read the privacy policies of each website and application with which they interact. We do not endorse, screen, or approve, and are not responsible for, the privacy practices or content of such other websites or applications. Providing personal information to third-party websites or applications is at your own risk.

Supervisory Authority. If you are located in the European Economic Area, Switzerland, the United Kingdom, Columbia, Ecuador or Brazil, you have the right to lodge a complaint with a supervisory authority if you believe our processing of your personal information violates applicable law.

Changes to our Privacy Policy. We may revise this Privacy Policy from time to time in our sole discretion. If there are any material changes to this Privacy Policy, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Policy if you continue to use our Services after the new Privacy Policy takes effect.

13. CONTACT US

If you have any questions about our privacy practices or this Privacy Policy, or to exercise your rights as detailed in this Privacy Policy, please contact us at: dsr_swish@inmobi.com.