Beamm limited (“Swayy,” “we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy (“Policy”) explains our practices regarding the collection, use, disclosure, and protection of information that is collected through our mobile app and our website (collectively, our “Service”), as well as your choices regarding the collection and use of information. Capitalized terms that are not defined in this Policy have the meaning given them in our Terms of Service.

By using or otherwise accessing our Service, you acknowledge the applicability of the terms of this Policy and the collection, use, processing and disclosure of your information in accordance with this Policy. If you do not agree to this Policy, do not download, use, or access the Service. We may update this Policy from time to time and will post updates to this Policy on this web page, including the policy’s effective date. By continuing to use or otherwise access the Service, you are confirming that you have read and understand the applicability of the latest version of this Policy.

A Note to Users Outside of the United Kingdom: If you are a non U.K user of the Service, by visiting website or using the Service and providing us with personal information, you acknowledge and agree that your personal information may be processed for the purposes identified in this Policy. In addition, your personal information may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. By providing your data, you consent to such transfer.

We are obsessed with our users’ privacy, and we’ve armed you with choice in our Service. We explain more below, but we adhere to these privacy principles:

• To be friends with another user on Swayy, and to see each other’s general proximity, you must both agree to it;
• You control your settings and can decide when you no longer want to share your general location;
• You can turn off notifications at any time;

Overview of this Privacy Policy

The Information We Collect

How We Use the Information We Collect

Sharing of Your Information

Analytics and Interest-Based Advertising

How We Protect Your Information

Your Choices

GDPR Information: For Residents of the European Union and EEA Countries

Children’s Privacy

Links to Other Web Sites and Services

Changes to Our Privacy Policy

Your California Privacy Rights

How to Contact Us

1. The Information We Collect

We collect the following types of information about you:

Information you provide directly to us.

We collect information you provide directly to us. For example, you may provide us with information through your:

• Use of the Service;
• Requests or questions you submit to us via online forms, email, or otherwise;
• Account registration and administration of your account;
• Uploading or posting of User Content;
• Requests for customer support and/or technical assistance;
• Registration for any contest, sweepstakes, or other events we may sponsor;
• Application for a job, internship, or fellowship;
• Participation in surveys we may make available;
• Provision of recommendations or reviews of merchants or locations; or
• Provision of other information to us within or outside of the Service.

The types of data we collect directly from you include:

• Registration and Profile Information. When you create an account, we may collect your personal information, such as your username, first and last name, email address, mobile phone number and a photo, if you choose to have one associated with your account. Your profile and associated information will only be visible to friends you have invited who have accepted your invitation and vice versa.
• Recommendations. You may provide additional information about yourself through any recommendations or reviews you provide, such as recommendations or reviews of restaurants, hotels, and parks.
• Messages and User Content. We collect information when you message us or your friends through use of the Service, including which friends you contact and the frequency and time and date of messages. We may retain any messages you send to us or through use of the Service. We use this information to operate, maintain, and provide to you the features and functionality of the Service, including customer support.
• Information about others. If you invite another person to download our app or otherwise use the Service, we may collect contact information to send an invitation to your selected recipient.

Information from third parties

When you interact with us through social media, such as when you like us on Facebook or post a comment to our Facebook page, we may receive information from the social network such as your profile information, profile picture, gender, user name, user ID associated with your social media account, age range, language, country, friends list, and any other information you permit the social network to share with third parties. The data we receive is dependent upon your privacy settings with the social network. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to Swayy’s website or Service more generally.

We may also collect information about you from non-affiliated third parties for fraud or safety protection purposes, or for marketing purposes. We likewise may combine information that we collect from you through the Service with information that we obtain from such third parties and information derived from any other products or services we provide.

Information we collect automatically through the use of technology

• Cookies and other tracking technologies

When you visit our website or use our mobile app, we and our business partners may collect certain information about your computer or device through technology such as cookies, web beacons, log files, or other tracking/recording tools. The information we collect through the use of tracking technologies includes, but is not limited to, IP address, browser information, referring/exit pages and URLs, click stream data and information about how you interact with links on the website, mobile app, or Service, domain names, landing pages, page views, cookie data that allows us to uniquely identify your browser and track your behaviour on our site, mobile device type, mobile device IDs or other persistent identifiers, and location data collected from your mobile device. Some or all of this data may be combined with other information described above. When you access our Service by or through a mobile device, we may receive or collect and store a unique identification numbers associated with your device or our mobile application (including, for example, a UDID, Unique ID for Advertisers (“IDFA”), Google Ad ID, or Windows Advertising ID or other identifier), mobile carrier, device type, model and manufacturer, mobile device operating system brand and model, phone number, and, depending on your mobile device settings, your geographical location data, including GPS coordinates (e.g. latitude and/or longitude), WiFi location or similar information regarding the location of your mobile device.

• Analytics Data

We may also collect analytics data, or use third-party analytics tools, to help us measure traffic and usage trends for the Service. These tools collect information sent by your browser or mobile device, including the pages you visit, your use of third party applications, and other information that assists us in analyzing and improving the Service.

• Geolocation

If you install our mobile app, we ask you to grant us access to your mobile device’s geolocation data, which enables use of the features of the Service. If you grant us access, we collect your unique user identifier and your location through GPS, WiFi, or wireless network triangulation in order to obtain your location for the purposes of providing and improving our Service. Other users do not have access to your exact location; only that you are within a certain distance (selected by you). We collect your location and locations you’re planning to visit to provide alerts when friends are, or are planning to be, within your specified proximity distance. If you turn off our application, we will not share your location with friends. We maintain location information only so long as is reasonable to provide the Service and then delete location data tied to your personal information. We may maintain aggregated or anonymized location information in order to analyze aggregate trends and metrics. Please see “Your Choices” below to learn more.

2. How We Use The Information We Collect

We may use the information we collect, alone or in combination, for various purposes, including, but not limited to providing the Service as well as the following:

• Fulfill the purposes for which you provided it (such as to provide you general location information from your connected friends);
• Remember information so that you will not have to re-enter it during your visit or the next time you visit the site or mobile app;
• Administer, troubleshoot and improve the Service, and develop new features and services;
• Provide customer support;
• Maintain internal records;
• Keep track of your preferences and provide custom, personalized content and information, including advertising;
• Monitor your location in accordance with the geolocation permissions you’ve granted us;
• Monitor the effectiveness of our Service and our marketing campaigns;
• Monitor aggregate metrics such as total number of visitors, users, traffic, and demographic patterns;
• Communicate with you, including to send you updates, newsletters and other information that may be of interest to you;
• Create or maintain aggregated, anonymized or de-identified information, which we may use and disclose without restriction;
• Investigate, prevent, or take action regarding unlawful or harmful activities, including potential threats to physical safety, potential fraud, and violations of our Terms of Service;
• Process any job applications you may submit; and
• Diagnose or fix technology problems reported by our Users or engineers that are associated with certain IP addresses or User IDs, and update our mobile application on your system and related devices, including automatically.

3. Sharing of Your Information

We may share your information with third parties outside Swayy and our controlled subsidiaries and affiliates in some circumstances, including:

• With your friends. We share your profile information and location and planning information that you provide for sharing through the Service (e.g., presence within the proximity distance selected by you, destination and timing of trips you are planning) with your friends. We share messages that you transmit through the Service with their designated recipients.
• With your consent. We may disclose your information when we have your consent.
• With our business partners. We may share your information on a confidential basis with our third-party business partners, vendors and consultants who perform services on our behalf or who help us provide our Service, such as accounting, managerial, technical, marketing or analytic services, so they can perform such services.
• To third parties offering features through the Service. We may offer various features through a third party service provider. When you use these services, you would be providing information directly to the provider of these services, and the provision of such information would be subject to such party’s own privacy policy. We are not responsible for any information you provide to these parties directly, and we encourage you to become familiar with their practices before disclosing information directly to such third parties with which you come into contact.
• Aggregated or anonymized information. We may also share with third parties—such as advertisers—aggregated or anonymized information.
• With third parties as part of a merger or acquisition. We may share your information in connection with, or during the negotiation of, any merger, acquisition, asset sale, financing, liquidation or bankruptcy.
• With third parties for legal reasons. We may collect, use, preserve and disclose your information if we believe in good faith:

• that we are required to do so in connection with any legal investigation, or by law or regulation, including in response to a court order, subpoena or other legal demand or request; or
• that it is reasonably necessary to protect the protect the rights, property, or personal safety of any person, to address fraud, security or technical issues, to protect Swayy’s rights or property, and/or to investigate or assist in preventing any violation or potential violation of the law, this Privacy Policy, or our Terms of Service.

4. Analytics and Interest-Based Advertising

• Interest-Based or “Personalized” Advertising

We and our third-party vendors may use device IDs and other automated technologies (including cookie identifiers on our website), along with other collected information, to tailor ads or deliver content when you are on our Service or on other devices, apps or websites. These ads may be based, for instance, on the types of websites that you visit over time, the types of apps you have on your device, or de-identified information about you and your likely interests, based on your activities off of our Service.

Ad partners that we or others work with to generate the above ads and content may track your activities over time (including across different apps or websites) by collecting information through automated means, and they may use this information, and other information they receive from us or other sources, to deliver advertisements to you.

• Opting Out of Interest-Based Advertising

You can learn more about interest-based advertising on the web, or opt out of receiving those ads, by visiting (i) the Network Advertising Initiative’s Consumer Opt-Out link or (ii) the Digital Advertising Alliance’s Consumer Opt-Out link to opt-out of receiving tailored advertising from companies that participate in those programs. To opt out of Google Analytics for display advertising or customize Google display network ads, you can visit the Google Ads Settings page.

Please note that to the extent advertising technology is integrated into our Service, you may still receive advertisements even if you opt-out. In that case, the advertising will not be tailored to your interests. Also, we do not control any of the above opt-out links or whether any particular company chooses to participate in these opt-out programs.

• Do Not Track

We do not respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.

5. How We Protect Your Information

Swayy cares about the security of your information and uses physical, administrative, and technological safeguards (including encryption of data in transit and at rest) to preserve the integrity and security of all information we collect and that we share with our service providers. However, no security system is impenetrable and we cannot guarantee the absolute security of our systems. In the event that any information under our control is compromised as a result of a breach of security, we will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

6. Your Choices

You may decline to submit any personal information through the Service, in which case Swayy may not be able to provide its Service to you.

Modifying Your Account Information and Settings:

You may modify your account information or update or amend certain of your information, at any time by logging in to your account. You can decline promotional communications at the point information is requested or, by following the unsubscribe instructions on communications sent to you.

You can control your receipt of email, text or push alerts within the mobile app. We may also send you Service-related emails or notice (e.g., account verification, order confirmations, changes or updates to features of the Service, technical and security notices). You may not opt-out of Service-related e-mails or notices.

Delete Your Account and Personal Information:

We generally retain information for so long as it is needed to provide the Service and in compliance with applicable law. To dispose of any personal data, we may anonymize it, delete it or take other appropriate steps. Information may persist in copies made for backup and business continuity purposes for an additional period of time.

If you wish to cancel your account, you can click the “delete my account” button within the application or delete our application from your phone. We may retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements. Please remember that when you delete your account, it does not affect the information other users have relating to you, such as their copy of the messages you sent them.

7. GDPR Information: For Residents of the European Union and EEA Countries

• Our Legal Bases for Use of Your Information

Under applicable European law (for instance, the GDPR), Swayy is considered the “data controller” of the personal data we handle under this Privacy Policy. In other words, Swayy is responsible for deciding how to collect, use and disclose this data, subject to applicable law. Our contact information appears at the end of this Policy.

European privacy laws require data controllers to tell you about the legal ground that they rely on for using, sharing, or disclosing of your information. To the extent those laws apply, our legal grounds are as follows:

• Contractual Commitments: We may use, share, or disclose information to honor our contractual commitments to you.
• With Your Consent: Where required by law, and in some other cases, we use, share, or disclose information on the basis of your consent.
• Legitimate Interests: In many cases, we use, share, or disclose information on the ground that it furthers our legitimate business interests in ways that are not overridden by the interests or fundamental rights and freedoms of the affected individuals, such as customer service, certain promotional activities, analyzing and improving our business, providing security for our Service, preventing fraud, and managing legal issues.
• Legal Compliance: We need to use, share, and disclose information in certain ways to comply with our legal obligations.

• Your Rights Under European Privacy Law

European privacy laws also generally permit you to request that we:

• provide access to and/or a copy of certain information we hold about you;
• prevent the processing of your information for direct-marketing purposes (including any direct marketing processing based on profiling);
• update information which is out of date or incorrect;
• delete certain information that we are holding about you;
• restrict the way that we process and disclose certain of your information;
• transfer your information to a third-party provider of services; and
• revoke your consent for the processing of your information.

Please note, however, that certain information may be exempt from such requests in some circumstances, which may include needing to continue processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.

To exercise any of these rights, please contact us as described in the “How to Contact Us” section below. In addition to those rights, you have the right to lodge a complaint with the relevant supervisory authority. However, we encourage you to contact us first, and we will do our very best to resolve your concern.

8. Children’s Privacy

The Service is not directed to persons under 16 and we do not knowingly collect personal information from children under 16. If you become aware that your child has provided us with personal information, please contact us as described in the “How to Contact Us” section below. If we become aware that a child under 16 has provided us with personal information, we take steps to remove such information and terminate the child’s account. We also comply with other age restrictions and requirements in accordance with applicable local laws.

9. Links to Other Web Sites and Services

We are not responsible for the practices employed by websites or services linked to or from the Service, nor the information or content contained therein. Please remember that when you use a link to go from the Service to another website, our Privacy Policy does not apply to third-party websites or services. Your browsing and interaction on any third-party website or service, including those that have a link on our website, are subject to that third party’s own rules and policies. Please read over those rules and policies before proceeding.

10. Changes to Our Privacy Policy

Swayy may, in its sole discretion, modify or update this Policy from time to time, and so you should review this page periodically. When we change the Policy, we will indicate the ‘last modified’ date at the top of this page. If there are material changes to this Policy, we will notify you in accordance with applicable law.

11. How to Contact Us

If you have any questions about this Policy or Swayy’s data practices, please contact us at info@swayy.app.