General Privacy Policy

Information Use at Swizzle

This policy is effective as of October 29, 2012.

Keep Holdings ("Company", "we", "our", or "us") provides this Privacy Policy to inform you of our policies and procedures regarding the collection, use and disclosure of information we receive via our theSwizzle.com Service. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms of Service, accessible at http://www.theswizzle.com/terms.

Information Use at Swizzle
Our Collection and Use of Personally Identifiable Information (PII)

For the purposes of this Privacy Policy, "PII" means information that can be used to uniquely identify you, such as your e-mail address.

When you interact with us, we collect PII that you voluntarily provide. For example, when you create an account with us, update your account data on our Service, or otherwise use certain aspects of our Service, we may ask you to provide PII. We mainly use your PII, either alone or in combination with other information, so that we can provide, enhance and personalize our Service and related content, products, and marketing efforts.

Service Registration

No registration is required to use certain aspects of the Service. However, in order to take advantage of personalized features that make the Service most useful, visitors will have to register. As part of the account registration process, you will minimally be asked to provide a username, password and email address. This information may be used to validate your registration and to send useful information to you as part of, and related to, your account and the Service.

We collect PII when you register to join the Service (or choose to refresh your account data) by logging into an account that you already have with a third party social networking platform ("SNP") via our Service. For example, our Service allows you to create an account and login to the Service using your Facebook account credentials through Facebook Connect. If you create a user account by logging into the SNP via the Service, you are using the information you have already provided to the SNP (such as your "real" name, e-mail address, and other information you make available via the SNP) to create your account on our Service. Accordingly, if you use Facebook Connect to join the Service, you are allowing us to access the PII in your Facebook account pursuant to Facebook's terms and conditions governing your use of the Service via Facebook. The information we receive from an SNP may depend on the privacy settings you have with the SNP, so please check the SNP's privacy and data practices.

Swizzle Sweeper Program

The Service includes a Swizzle Sweeper program that scans the contents of user e-mail accounts with third party services, and allows users to take certain actions (such as unsubscribe from third party mailing lists).

The Swizzle Sweeper program on the Service identifies and stores (i) page requests and associated parameters, (ii) any errors generated during your use of the program, (iii) an encrypted hash of email addresses entered by users, (iv) IP addresses of visitors, and (v) certain parts of scanned email messages. Those parts of scanned messages are:

  • A random subject line from bulk mail senders to help more easily identify bulk messages.
  • The sender name and email address from bulk mail message senders.
  • A link and/or email address from the bulk mail message for use in unsubscribing.

We do not retain your e-mail account passwords for any third party e-mail accounts you submit to the Inbox Manager program. If you submit this information, we use it only to access and use your third party e-mail account on your behalf. After the session is closed, our software "forgets" your password. (You may notice the effect of this if you run multiple scans of your third party e-mail account and need to provide your password to us each time.)

If you use the Service in connection with your account on Gmail and/or Google apps, we use a process called OAuth to obtain a special token (with your permission) that allows us to access and use your Gmail account. We do not permanently store this token.

For further information regarding the Inbox Manager program, please review the FAQs on the Website.

General Use of PII

The following are examples of a variety of ways that we may use your PII. We may use your PII:

  • to provide you with the best user experience possible;
  • to respond to your questions and comments;
  • to communicate with you regarding Service updates, offers, and promotions;
  • to help us develop, customize, deliver, support and improve our Service, content, and advertising;
  • to help authenticate any account you create with us;
  • to protect the rights or property of Keep Holdings or our users, and prevent fraud and other prohibited or illegal activities;
  • to protect the security of our Service and business;
  • for our internal purposes (such as auditing, data analysis, and research to improve our products, services, and communications); and
  • otherwise, as disclosed to you at the point of collection.

Should you contact us requesting information, as a client, job applicant, or with a request for information about our Service or technical support or to opt-in to receive emails, newsletters or other communications from us via newsfeeds or other communication media that may become available to us, you may be asked to provide us with a first and last name and your email address, as well as other PII needed to fulfill your request. The information we ask you to provide may vary based on the nature of your request. In these cases, this PII is retained and used for the purpose for which it was provided. This PII will be stored on our servers within the United States or that of a trusted partner in the United States who may use specialized software to manage PII. In the case of our use of a third party, we ensure that their contractual obligations to use such PII meet our requirements to have your data secure pursuant to our own policies. See "Information Sharing with Third Parties" below for further details about when we may share your information with third parties.

We may track usage of the Service in order to better understand visitors’ usage of the Service and provide better services or more beneficial personalized experiences. For example, we may collect information on which deals you view, what brands you follow, comments you make on various pages of the Website and content you upload or link to or through the Service. In this effort we may combine your PII with aggregated or anonymous data and use such combined data either in a re-aggregated form or as specifically connected to a user in order to deliver improved services to such user.

We may use email software, newsfeed software or similar software to send you information that you have agreed to receive through email, a newsreader or other means that may become available. Besides these information channels potentially having advertisements of their own, we may use so-called "beacon" technology in these information flows. Beacons are most often small graphics which are identifiable to us and allow us to understand which communications were used and therefore what might be seen as useful to our users. This helps us provide increasingly valuable products.

We may receive additional PII from third parties. We may use this PII to enhance other information we have about you to help us better understand you and to otherwise enhance the Service for you.

We may use your PII, either independently or in conjunction with third parties, to provide you coupons or deals that we determine based on your use of the Service would be relevant or interesting to you.

We may use your PII in the process of tracking the redemption or use of an offer or coupon, or in the process of coordinating with third parties to fulfill a user request for such action.

We may use your PII to send you advertisements or deals via the Service, through emails, tweets, or other methods of communications.

Our Collection and Use of Non-Personally identifiable information
Product Usage Tracking & IP Addresses

We may collect, use, transfer, and disclose information in a form that does not personally identify you for any purpose using a variety of technologies. For example, in order to know what features, functions and services of the Service are providing value to you, we will track aggregated, non-personalized data regarding usage of Service-related features, functions and services. These aggregated reports will be summaries of usage by many users and will not contain any personalized data. Through our own computer servers or third party usage tracking services, we may collect various pieces of "log" data including but not limited to your browser type, the webpages visited immediately prior to arriving on the Website, the pages of the Website you visit and your Internet Protocol (IP) address ("Log Data"). IP addresses are labels that allow computers on the Internet to identify each other and send information back and forth. These numbers are non-personal in that they may identify machines, not people. The Log Data may be considered "partially personally identifiable" by some, and may be connected with your registration information, some of which is personally identifiable.

Use of Cookies

The Website and the Service use cookies. A "cookie" is a small text file stored by your Internet browser software that has a group of text characters. These characters may allow us to recognize that you're using the Service and thus provide you with personalized services. In addition to third party cookies (described below), the Service may include two types of cookies from us:

  • Persistent Cookie: This type of cookie remains as part of your web browser's cookie collection after you've stopped using your web browser. This way, when you use your browser again, the cookie will still be useful to you.
  • Session Cookie: This cookie is in use only during the time that you have your browser in use. It disappears when you close it. Cookies like this might be used to just keep track of some task you’re doing, (such as filling out a form), in order to complete some action or provide some temporary feature.

Identifiers in these Cookies are non-personal in that they are meaningless to any entity other than us and do not tie back to any of your PII until you return to the Service.

Cookie Behavior

Cookies are stored by your browser when your browser comes across elements on the Internet that have our codes attached to them. It could be that you've deleted cookies from us and perhaps all of your cookies, and later found a new cookie from us. This happens when you come across a new element on the Internet, both on our Website and otherwise, that has a Company code. Users always have control over their browsers and may use their browsers or other tools to opt out of cookies from a particular website or all websites. It's important to understand that if you delete these cookies many websites, including our Website, will most often not be able to provide you with all of their services. Our Service in particular will not perform all of its functions for you without cookies being enabled for the Service.

Information Sharing with Third Parties

From time to time, we may use third parties to provide services either to the Company or to users or collect information on our behalf. In these cases, we may provide your PII to such entities; however such third parties must use similarly respectful policies and security procedures to our own in order to be authorized to work with us.

We may be compelled to disclose certain PII if required to do so by law; such as subpoenas or warrants or to defend the Company in litigation or other proceedings.

We may disclose information about you that is not PII. For example, we may provide our business partners or other third parties with reports that contain aggregated and statistical data about our users.

We may supply business partners (such as marketers who have opted to participate in our Service) with anonymous, aggregated data regarding usage of our Service (such as Log Data), as well as certain PII.

We may sell, transfer or otherwise disclose some or all of our assets, including your PII, in connection with a merger, acquisition, reorganization or sale of assets or in the event of bankruptcy.

We do not directly provide PII to third parties absent a specific understanding between ourselves and such third parties, including their commitment to be respectful of user privacy.

We, or our partners or other third parties, may send you communications that are from and related to us directly, may be from us but related to, or on behalf of, partners or third parties, or may be from partners or third parties as a result of your registration with, and use of, the Service. The default setting of the Service may be to include users into such communications; however, you may manage preferences related to such communications through the Website, including electing to opt-out of some, or all, such communications.

We may share certain PII you provide to us with the SNPs you use to connect to the Service. In such case, once transferred, the use of such information will be governed by the policies of those third party SNPs.

We may provide certain third parties your PII in connection with contests, referrals or other programs in which you have elected to participate. For example, if you access the Service in connection with a contest we may exchange your PII with the other sponsor(s) of the contest in order to validate your participation, etc.

Third Party Cookies on the theswizzle.com Site

We display content sourced from a variety of third parties. Some of these third parties use their own cookies or otherwise add tracking information or tools on their content (such as advertisements) to collect information about your use of the content, and possibly also used in order to serve you more relevant content on other websites. These resulting targeted materials, such as advertisements, may appear on our Website or on other sites that you visit. The information may be collected through the use of a pixel tag, which is industry standard technology used by most major web sites. You may configure your web-browser to disable the automated tracking of such information. For more information about third-party advertising networks and opting out of tracking, see: here

Please note that opting out of third party networks could impact use of the Service.

Public Account Information

You should be aware that all user profiles in the Service are public by nature. Accordingly, some of the PII you provide to us when registering or otherwise utilizing the Service will be available to other registered users of the Service and other users of the Internet. In addition to your name, location and other provided information being displayed, some of your activity in the Service may also be displayed publicly, such as the brands or items you choose to "follow," advertisements you choose to "keep," comments and posts you make on the Website, etc. We strongly suggest that users guard their sensitive information sufficiently and review our Terms of Service for more detailed information.

Data Transfer

Your PII may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to provide information to us, please be aware that we collect and keep your information on United States-based servers and processes it in the United States. By using the Service you are consenting to our transfer of your PII as per above.

Changing or Deleting Your Information

You may review, update, correct or delete the information in your profile by editing the relevant part of your profile. If you would like us to delete your PII from our system, please contact us at privacy@theswizzle.com and we will attempt to accommodate your request provided we do not have a legal obligation or business reason to retain such PII. Please note we may retain server/ backup copies of all PII and non-identifying information.

Links to Other Sites

Our Service contains links to other websites. The fact that we link to a website, or display a banner ad or other type of advertisement is not an endorsement, authorization or representation of our affiliation with any of those third parties, nor is it an endorsement of their privacy or information security policies or practices. We do not exercise control over third party websites. These other websites may place their own cookies or other files on your computer, collect data or solicit PII from you. Other websites follow different rules regarding the use or disclosure of the PII you submit to them. We encourage you to read the privacy policies or statements of the other websites you visit.

Our Policy Toward Children

We do not knowingly collect PII from children under 13. If a parent or guardian becomes aware that his or her child has provided us with PII without their consent, he or she should contact us at info@theswizzle.com. If we become aware that a child under 13 has provided us with PII, we will delete such information from our files.

Information Confidentiality and Security

We have implemented generally accepted industry standards to protect against the unauthorized access to both personal and non-personal data, including retention of, and disclosure of data, misuse or alteration. Any employees who as part of their job may have access to user PII are made aware of our commitment to these standards. Their accountability in this regard has been made clear. We undertake physical, electronic, and management activities required to protect data integrity, access, and use. Data stored on our computer servers is treated as confidential. At the same time, no information transfer though out the Internet can be wholly guaranteed as secure and we cannot guarantee absolute security and will not be held liable for security breaches by third parties.

We will make any legally required disclosures of any breach of the security, confidentiality, or integrity of your unencrypted electronically stored "personal data" (as defined in applicable state statutes on security breach notification) to you via email or conspicuous posting on our Website in the most expedient time possible and without unreasonable delay, insofar as consistent with (i) the legitimate needs of law enforcement or (ii) any measures necessary to determine the scope of the breach and restore the reasonable integrity of the data system.

Changes to this Privacy Policy

Over time we may add new products, features or services which may require us to update this policy. If any such changes are substantive in how we collect or use personally identifiable or non-personally identifiable information on the Service, we will notify you via clear and obvious notices on the Service and in this policy. Your use of the Service following posting of a revised Privacy Policy will signify and constitute your assent to and acceptance of such revised Privacy Policy.

Changes in Ownership

If the Company is sold, in whole or in part, merges or otherwise changes its corporate structure, your PII may be transferred to this new entity. The Company will take reasonable steps to ensure any such information is used consistent to the purpose for which it was collected.

Contact Us

If you have questions about our Privacy Policy or how this web site uses PII, please contact us at privacy@theswizzle.com.

Our main offices are located at:

Keep Holdings
443 Park Avenue South
New York, NY 10016