Swapchain, Inc. and its wholly-owned subsidiaries (collectively "Swapchain") believe that privacy is important to the success and use of the Internet. This statement sets forth Swapchain’s policy and describes the practices that we will follow with respect to the privacy of the information of users of this site. Should you have any questions about this policy or our practices, please send an email to firstname.lastname@example.org or write to us at:
Attention: Privacy Officer
PO Box 1433 Scottsdale, AZ 85257
You can also call us at 909-572-0492.
Our Commitment to You:
As a Swapchain user, you have entrusted to your personal and financial data to our care. We recognize that your relationship with us is based on trust, and that you expect us to act responsibly and in your best interests. Because your personal and financial data are your private information, we hold ourselves to the highest standards in their safekeeping and use.
This means, most importantly, that we do not sell client or prospective client information—whether it is your personal information or the fact that you are or may become a Swapchain client—to anyone.
Instead, we use your information primarily to complete transactions that you request or to make you aware of other financial products and services that we offer or sponsor.
The Personal Information We Collect:
You provide personal information when you complete a Swapchain account application. (If you enter information in an online account application, we may store the information even if you don't complete or submit the application.) You also provide personal information when you request information or materials from us or otherwise interact with Swapchain or one of the Swapchain affiliated companies.
In addition to personal information you provide to us, we may receive information about you that you authorize third parties to provide to us. We also may obtain personal information from third-party service providers in order to verify your identity, to prevent fraud, or to help us identify products and services that may be of interest to you. Personal information collected from any source may include, among other things, your name and address, Social Security or taxpayer identification number, date of birth, assets, income, account balances, investment activity, and accounts at other institutions. The information we collect about you may be transferred to or stored by Swapchain or our service providers in the United States or elsewhere, as permitted by law.
We may combine the information collected on our website or through our mobile application with information collected from or about you in other contexts. This may include information collected online, such as through our email exchanges with you, or from offline sources, such as information that we collect when you establish your account with us or call customer service. We will treat such combined information in accordance with this policy. If you do not wish to provide information to Swapchain, we may be unable to provide certain products or services to you.
How We Handle Your Personal Information:
We do not sell personal information about current or former clients or their accounts to third parties. Nor do we share personal information about clients or prospective clients, except when needed to complete transactions at your request or to make you aware of financial products and services that we offer. Here are the details:
In order to complete certain transactions or account changes that you direct, it may be necessary to provide identifying information about you to companies, individuals, or groups that are not affiliated with Swapchain. For example, if you ask to transfer assets from another financial institution to Swapchain, we will need to provide certain information about you to that company to complete the transaction.
In order to alert you to other financial products and services that Swapchain offers or sponsors, we may share your information within the Swapchain family of affiliated companies, to the extent permitted by law. This would include, for example, sharing your information within Swapchain to make you aware of new Swapchain services.
In certain instances, we may contract with nonaffiliated companies to perform services for us. Where necessary, we will disclose information we have about you to these third parties. In all such cases, we provide the third party with only the personal information necessary to carry out its assigned responsibilities, and only for that purpose. And we require these third parties to treat your personal information with the same high degree of confidentiality that we do.
Finally, we will release information about you if you direct or authorize us to do so, if we are compelled by law to do so, or in other legally limited circumstances (for example, to prevent fraud).
Cookies, Web Beacons, and Online Privacy:
Our website and our mobile application use some of the most secure forms of online communication available, including data encryption, transmission encryption, user names and passwords, adaptive authentication techniques, and back-end fraud and account monitoring. These technologies provide a high level of security and privacy when you access your account information, initiate online transactions, or send secure messages.
We use a variety of online technologies, such as cookies, web beacons, and similar mechanisms, as described further below, to collect information that helps us understand how our website and our mobile application are used. Specifically, when you visit Swapchain online, we or our third-party service providers may automatically collect a variety of technical and navigational information about you via these technologies, including, as applicable: your computer or device type; operating system version; browser type and version; user agent string; internet connection type; mobile network provider; date and time of your visit; time since your last visit; pages you view; links you click; searches you conduct; the internet protocol (IP) address used to access our website or mobile application; your general geographic location (e.g., your city, state, or zip code); and the website visited before our site. We also may use similar tracking technologies in emails that we or third parties send to you, as further described below. This information may be used, for example, to alert you to software compatibility issues or to resolve technical or service problems. We also analyze this information, with the assistance of our service providers, to improve our website and mobile application design and functionality, to enhance our ability to serve you and your accounts, and to tailor our communications to you regarding our products and services.
A cookie is a small file of letters and numbers that is stored on your computer, tablet, mobile phone, or other device when you visit a website or a mobile application. Cookies contain information that is transferred to or read on your device and allow websites and mobile applications to recognize devices and store certain information, such as user preferences. Cookies are used to distinguish you from other users of our online services. This helps us to provide you with a useful experience when you browse and also allows us to improve our online services. We and our third-party service providers use session cookies, which link your actions during a particular online session and expire at the end of that session, as well as persistent cookies, which remain on your device and allow us to remember your actions or preferences across multiple browser sessions.
Our website, our mobile application, and the emails that you receive from Swapchain use an application known as a web beacon (also known as a pixel tag or clear gif). A web beacon is an electronic file that usually consists of a single-pixel image, embedded in a web or mobile application page or an email to measure usage and activity. In some cases, a web beacon triggers the placement of a persistent cookie on your device.
We and our service providers use web beacons and cookies to determine whether and when you receive and open our emails; these beacons and cookies may also capture information such as the type of device, operating system, email program, and web browser used to view the email, the IP address from which you opened the email, and whether you click any links in the email. These technologies enable us to gauge the effectiveness, relevance, and value of our email communications, as well as to target relevant advertising to you and to measure the impact of that advertising on your Swapchain relationships.
If you are a Swapchain user who has registered for secure online access to your Swapchain accounts, we are able to combine the information we collect about your usage of our website or mobile application during a secure (logged-on) session with other information we know about you, such as any account transactions you conduct during your session. We can also identify your computer or device on each online visit to Swapchain, even if you do not log on, and link information about that visit, as well as Swapchain ads that you may have viewed on other websites, to you. We may use this combined information to assess the appeal and usefulness of the information and tools offered on our website and in our mobile application and the effectiveness of our online advertising, as well as to identify Swapchain products and services that may be of interest to you.
Third-Party Analytics and Interest-Based Advertising:
We partner with third parties to collect the information discussed above to engage in analysis, auditing, research, and reporting. These third parties may set and access cookies on your computer or other device and may use web beacons to collect information about your activity on our website or our mobile application. In particular, our website and mobile application uses the services of Google Analytics, and may use other similar services, to collect and analyze statistical data about visitors to our website. We also use Google advertising services, including a remarketing function, and may use other similar services, to arrange for you to see Swapchain advertisements when you visit certain third party websites. These analytic and advertising services do not collect personally identifiable information. You may elect to opt out of the use of non-personally identifiable data by Google Analytics by downloading and installing an add-on to your web browser. You may find out more about how Google Analytics collects and processes data by visiting “How Google uses data when you use our partners’ sites or apps,” found here. You may also opt out of the Google AdWords service we use to serve ads, and which service also collects non-personally identifiable information, by visiting the Google Ad Settings page here.
We may use third-party service providers' technologies that enable us to establish connections among related devices (such as smartphones, tablets, and computers). This means that information about your interactions with our online services and online advertising through different devices may be combined. By making these connections, we may be able to better understand the relevance of our content and the impact of our advertising and to customize that content and advertising for you.
Although our website currently does not respond to "do not track" browser headers, you can limit tracking by taking the steps discussed above. The use of online tracking mechanisms by third parties is subject to those third parties' own privacy policies, and not this policy.
How We Safeguard Your Personal Information:
Within Swapchain, we restrict access to information about you to those Swapchain employees who need to know the information in order to perform their jobs, such as servicing your accounts, providing you with information you request, or notifying you of new products and services. To protect your personal information, we maintain physical, electronic, and procedural safeguards in keeping with industry standards and practices, and we review and adjust these safeguards regularly in response to advances in technology.
What You Can Do:
We Will Keep You Informed: