SWEEBLE PRIVACY POLICY

Effective date: May 15, 2015

Sweeble (“Sweeble,” “we,” “us,” or “our,”) is a media sharing platform that lets you and friends share, comment, and like content and earn rewards.

Our Privacy Policy explains how we and some companies that we work with collect, use share, and protect information related to our mobile services, website and software with Sweeble services (collectively, the “Service”) and your choices about the collection and use of your information.

By registering for and using the Service, you understand and agree that we provide a platform for you to post content, including photos, video, comments, and other materials ("User Content"), to the Service and to share User Content publicly. This means that other Users may search for, see, use, or share any of your User Content that you make publicly available through the Service, consistent with the terms and conditions of this Privacy Policy and our Terms of Service.

This Privacy Policy applies to all visitors, users, and others who access the Service (“Users”). Click on the links below to jump to each section of this Policy:

Click on the links below to jump to each section of this Policy:

I. INFORMATION WE COLLECT

1.0 We collect the following types of information:

Your username, password, and e-mail address when you register for a Sweeble account.

Profile information that you provide for your user profile (e.g., first and last name, picture, phone number). This information allows us to help you or others be "found" on Sweeble.

User Content (e.g., photos, comments, and other materials) that you post to the Service.

Communications between you and Sweeble. For example, we may send you Service-related emails (e.g., account verification, changes/updates to features of the Service, technical and security notices). Note that you may not opt out of Service-related e-mails.

1.1 Finding your friends on Sweeble:

If you choose, you can use our "Find friends" feature to locate other people with Sweeble accounts either through (i) your contacts list, (ii) third-party social media sites or (iii) through a search of names and usernames on Sweeble.

If you choose to find your friends through (i) your device's contacts list, then Sweeble will access your contacts list to determine whether or not someone associated with your contact is using Sweeble and send a text or email invitation to Sweeble from your personal email or text account.

If you choose to find your friends through a (ii) third-party social media site, then you will be prompted to set up a link to the third-party service and you understand that any information that such service may provide to us will be governed by this Privacy Policy.

If you choose to find your friends through a search of names or usernames on Sweeble then simply enter a name to have us perform a search on our Service.

PLEASE NOTE: You understand and agree that you are responsible for any data or other charges that apply to communications sent from your device, and because these emails and texts are coming directly from your personal account. Sweeble does not have access to or control communications from your device.

1.2 Analytics information:

We use third-party analytics tools to help us measure traffic and usage trends for the Service. These tools collect information sent by your device or our Service, including the web pages you visit, add-ons, and other information that assists us in improving the Service. We collect and use this analytics information with analytics information from other Users so that it cannot reasonably be used to identify any particular individual User.

1.3 Cookies and similar technologies:

When you visit the Service, we may use cookies and similar technologies like pixels, web beacons, and local storage to collect information about how you use Sweeble and provide features to you.

We may ask advertisers or other partners to serve ads or services to your devices, which may use cookies or similar technologies placed by us or the third party.

More information is available in our About Cookies section below.

1.4 Log file information:

Log file information is automatically reported by your browser each time you make a request to access (i.e., visit) a web page or app. It can also be provided when the content of the webpage or app is downloaded to your browser or device.

When you use our Service, our servers automatically record certain log file information, including your web request, Internet Protocol ("IP") address, browser type, referring / exit pages and URLs, number of clicks and how you interact with links on the Service, domain names, landing pages, pages viewed, and other such information. We may also collect similar information from emails sent to our Users which then help us track which emails are opened and which links are clicked by recipients. The information allows for more accurate reporting and improvement of the Service.

1.5 Device identifiers:

When you use a mobile device like a tablet or phone to access our Service, we may access, collect, monitor, store on your device, and/or remotely store one or more "device identifiers." Device identifiers are small data files or similar data structures stored on or associated with your mobile device, which uniquely identify your mobile device. A device identifier may be data stored in connection with the device hardware, data stored in connection with the device's operating system or other software, or data sent to the device by Sweeble.

A device identifier may deliver information to us or to a third party partner about how you browse and use the Service and may help us or others provide reports or personalized content and ads. Some features of the Service may not function properly if use or availability of device identifiers is impaired or disabled.

1.6 Metadata:

Metadata is usually technical data that is associated with User Content. For example, Metadata can describe how, when and by whom a piece of User Content was collected and how that content is formatted.

Users can add or may have Metadata added to their User Content including a hashtag (e.g., to mark keywords when you post a photo). This makes your User Content more searchable by others and more interactive.

II. HOW WE USE YOUR INFORMATION

2.0 General Uses:

III. SHARING OF YOUR INFORMATION

3.0 We will not rent or sell your information to third parties outside Sweeble (or its parent or affiliated companies) without your consent, except as noted in this Policy.

3.1 Parties with whom we may share your information:

We may share User Content and your information (including but not limited to, information from cookies, log files, device identifiers, and usage data) with businesses that are, or may become, affiliated with Sweeble ("Affiliates"). Affiliates may use this information to help provide, understand, and improve the Service (including by providing analytics) and Affiliates' own services (including by providing you with better and more relevant experiences). But these Affiliates will honor the choices you make about who can see your photos.

We also may share your information as well as information from tools like cookies, log files, and device identifiers, with third-party organizations that help us provide the Service to you ("Service Providers"). Our Service Providers will be given access to your information as is reasonably necessary to provide the Service under reasonable confidentiality terms.

We may also share certain information such as cookie data with third-party advertising partners. This information would allow third-party ad networks to, among other things, deliver targeted advertisements that they believe will be of most interest to you.

We may remove parts of data that can identify you and share anonymized data with other parties. We may also combine your information with other information in a way that it is no longer associated with you and share that aggregated information.

3.2 Parties with whom you may choose to share your User Content:

Any information or content that you voluntarily disclose for posting to the Service, such as User Content, becomes available to the public, as controlled by any applicable privacy settings that you set. To change your privacy settings on the Service, please change your profile setting. Once you have shared User Content or made it public, that User Content may be re-shared by others.

Subject to your profile and privacy settings, any User Content that you make public is searchable by other Users and subject to use under our Sweeble API. Use of the Sweeble API is subject to the Terms of Service which incorporates the terms of this Privacy Policy.

If you remove information that you posted to the Service, copies may remain viewable in cached and archived pages of the Service, or if other Users or third parties using the Sweeble API have copied or saved that information.

3.3 What happens in the event of a change of control:

If we sell or otherwise transfer part or the whole of Sweeble or our assets to another organization (e.g., in the course of a transaction like a merger, acquisition, bankruptcy, dissolution, liquidation), your information such as name and email address, User Content and any other information collected through the Service may be among the items sold or transferred. You will continue to own your User Content. The buyer or transferee will have to honor the commitments we have made in this Privacy Policy.

3.5 Responding to legal requests and preventing harm:

We may access, preserve and share your information in response to a legal request (like a search warrant, court order or subpoena) if we have a good faith belief that the law requires us to do so. This may include responding to legal requests from jurisdictions outside of the United States where we have a good faith belief that the response is required by law in that jurisdiction, affects users in that jurisdiction, and is consistent with internationally recognized standards. We may also access, preserve and share information when we have a good faith belief it is necessary to: detect, prevent and address fraud and other illegal activity; to protect ourselves, you and others, including as part of investigations; and to prevent death or imminent bodily harm. Information we receive about you may be accessed, processed and retained for an extended period of time when it is the subject of a legal request or obligation, governmental investigation, or investigations concerning possible violations of our terms or policies, or otherwise to prevent harm.

IV. HOW WE STORE YOUR INFORMATION

4.0 Storage and Processing:

Your information collected through the Service may be stored and processed in the United States or any other country in which Sweeble, its Affiliates or Service Providers maintain facilities.

Sweeble, its Affiliates, or Service Providers may transfer information that we collect about you, including personal information across borders and from your country or jurisdiction to other countries or jurisdictions around the world. If you are located in 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.

By registering for and using the Service you consent to the transfer of information to the U.S. or to any other country in which Sweeble, its Affiliates or Service Providers maintain facilities and the use and disclosure of information about you as described in this Privacy Policy.

We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps (such as requesting a unique password) to verify your identity before granting you access to your account. However, Sweeble cannot ensure the security of any information you transmit to Sweeble or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.

Please do your part to help us. You are responsible for maintaining the secrecy of your unique password and account information, and for controlling access to emails between you and Sweeble, at all times. Your privacy settings may also be affected by changes the social media services you connect to Sweeble make to their services. We are not responsible for the functionality, privacy, or security measures of any other organization.

4.1 CALIFORNIA PRIVACY RIGHTS AND DO NOT TRACK DISCLOSURES.

Under California Civil Code Section 1798.83, California residents who have an established business relationship with us have the right to request that we provide certain information regarding the disclosure of their personal information to third parties for their direct marketing purposes during the immediately preceding calendar year. You may send your request for such information to info@sweebleapp.com. Requests shall only be accepted via this email address. We shall not be responsible for requests made over the telephone or by any other means.

4.2 Canadian and European Union Users

We do not intend to collect PII from Canadian and European Union users. If you are in Canada or the European Union, do not provide us with PII, use our Service, or use the Mobile App. If we learn that we have collected PII from a user in Canada or the European Union, we will promptly delete that information.

V. USE AND SHARING OF INFORMATION

5.0 We collect and store all PII that is volunteered through the use of Mobile App.

We use this PII to:

5.1 Third-Party Contractors.

We may share your information with third-party contractors who provide certain services to us or on our behalf, such as operating and supporting the Mobile App or otherwise responding to your customer service requests. These third-party contractors will only have access to the information needed to perform these limited functions on our behalf and are required to provide your information with at least the same level of protection and security as we use for the Mobile App.

5.2 Companies that Acquire Our Business or Assets.

If we become involved in a merger, acquisition, sale of assets, securities offering, bankruptcy, reorganization, dissolution, or other transaction or if the ownership of all or substantially all of our business otherwise changes, we may share or transfer your information to a third party or parties in connection with the applicable transaction.

5.3 Our Affiliates.

We may share some or all of your information with our parent company, subsidiaries and corporate affiliates, joint venturers, or other companies under common control with us. We will require these entities to comply with the terms of this Privacy Policy, as it may be amended, with regard to their use of your PII.

5.4 Other Users.

If you sign in to the Mobile App through your social media account, you consent to our sharing your PII with your social-media friends who are also users of the Service.

In addition, by uploading video content and/or posting messages or comments on the Mobile App, you consent to our sharing such video content, messages, or comments, along with your first name and first initial or your last name, with any user of the Service, whether or not the user is your social-media friend.

By clicking “share” on an uploaded video or posted message or comment, you consent to our causing the “shared” content to be posted to the timeline or status line on your social media account, where the content will be visible to any person who otherwise has access to view your social media profile.

5.5 Other Third Parties.

We may share your PII relating to your use of the Mobile App with affiliated or unaffiliated third parties on an individual or aggregate basis for marketing purposes.

5.6 Disclosures Permitted or Required by Law.

To the extent permitted by law, we may share your information with law enforcement, governmental agencies, or authorized third parties, in response to a verified request relating to a criminal investigation or alleged illegal activity or any other activity that may expose us, you, or any other Mobile App user to legal liability, or to protect our rights or property, or during emergencies when safety is at risk. We may also share your information in response to a warrant, court order, subpoena, or other legal process that we have a good-faith belief requires disclosure of the information.

VI. HOW WE PROTECT AND RETAIN YOUR INFORMATION

6.0 Restriction of Access to PII.

If we retain PII on our systems, we restrict internal access to PII to employees, contractors, and agents who need to know that information in order to operate, develop, or improve our Mobile App and Services. These individuals are bound by confidentiality obligations and may be subject to discipline, including termination, if they fail to meet these obligations.

6.1 Internet is Inherently Insecure.

The internet and mobile web are inherently insecure and so we are unable to guarantee that the security measures we take will not be penetrated or compromised or that your information will remain secure under all circumstances.

6.2 Retention of Information.

We retain information for active user accounts as long as it is necessary and relevant for our operations. In addition, we may retain information from closed accounts to comply with the law, prevent fraud, resolve disputes, troubleshoot problems, assist with any investigation, enforce the Terms of Service and take other actions permitted by law. The information we retain about you will be handled in accordance with this Privacy Policy.

VII. YOUR PRIVACY CHOICES

7.0 Mobile App.

You may visit the Mobile App and view video content and user comments and messages without sharing any PII while the Mobile App is open. In order to upload video content or to post comments or messages, you must log in to the Mobile App through your social media account, in which case you consent to our collection and use of your PII as described above.

7.2 Social Media.

We may engage with you on third-party social media sites like Facebook, if you engage with us. By doing so, you “opt in” to sharing your content with us. Be aware that such content (PII, images, captions and comments, etc.) that you submit (upload, post, comment, share, “like”, etc.) to third party social media sites (including any of our message boards or tweets) is publicly visible, not private and cannot be considered private PII. To manage social media notifications you receive, correct or delete your PII, or adjust your privacy settings, access the profile section of your social media accounts and follow the directions there. To learn more about social media privacy settings, follow these links:

Facebook: https://www.facebook.com/about/privacy/your-info-on-fb#!/about/privacy/

Twitter: https://support.twitter.com/groups/51-me

Sweeble: https://www.sweebleapp.com/terms-of-service

Vimeo: http://vimeo.com/privacy

7.3 Managing Email Communications.

We may communicate with you through your email address. You can choose not to receive email communications from us by following the “unsubscribe” instructions in any email communication you receive from us.

7.4 Choice of Law.

By using our Mobile App, you signify your consent to the data practices described in this Privacy Policy and agree that your visit and any dispute over privacy is subject to our Terms of Service, including without limitation, the terms regarding limitations on liability and application of the laws of the State of Delaware.

7.5 Questions?

If you have questions or concerns regarding our Mobile App, Privacy Policy or practices, please contact us at info@sweebleapp.com.