Privacy Policy
Published on February 9th, 2024
Skwash Inc. (“we,” “us,” or “Skwash”) is committed to letting you know how we will collect, use, store, share and protect your personal information when you transact with us. You accept this privacy policy (the “Privacy Policy”) whenever you access or use Skwash products, services, features, and technologies including the Skwash mobile app (the “Skwash Services”). Please read this Privacy Policy carefully. If you are a resident of California, you may have additional rights described in our California Privacy Rights Notice/ Notice at Collection section.
This Privacy Policy does not apply to information submitted or collected through websites maintained by other companies or organizations to which we may link or who may link to us. We are not responsible for the actions and privacy policies of third-party websites.
1. What type of information does Skwash collect?
We collect two basic types of information from you in conjunction with your use of the Skwash Services (collectively, your “personal information”): (1) personally identifiable information; and (2) non-personally identifiable information.
Personally Identifiable Information is any information that can identify you.
Examples include your name, e-mail address, telephone number, postal address, device identifiers, IP addresses, geolocation information.
We may also collect personally identifiable information about you from third parties such as data vendors.
Aggregate and/or de-identified information is not considered personally identifiable information.
Non-personally identifiable information is information that does not identify you directly, but may be linkable to you.
Examples include demographic information and general location information.
If non-personally identifiable information is directly linked to personally identifiable information, it will be considered personally identifiable information while it is linked. For example, if your payment history and transaction history are linked to your name, then that information will be considered personally identifiable information and subject to heightened privacy and security restrictions, as reflected in this Privacy Policy.
2. How does Skwash Collect Information?
We collect information about you through:
Your interactions with or use of the Skwash Services, including both information you give us, as well as information we derive from your usage;
Your contact with our customer support team and other communications with us;
Third parties, such as data vendors, consumer reporting agencies, your bank or merchants you perform a transaction with;
Through our websites and mobile applications, using cookies, Clear GIFs, web beacons, mobile application plug-ins, browser extension and similar technologies.
Cookies are small files that are stored on your computer or device when you use the Skwash Services. Cookies record your preferences and the actions you take on your computer or device. We may also use web beacons and mobile application plug-ins, such as software development kits, application programming interfaces and similar technologies. We use these and other similar technologies for security, to monitor traffic, improve the Skwash Services, and make the Skwash Services easier to use and more relevant to you. We may also use these technologies to personalize your experience, deliver advertisements, and for research and marketing.
Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web pages. We may use clear GIFs (a.k.a. web beacons, web bugs or pixel tags), in connection with the Skwash Services to, among other things, track the activities of Site visitors, help us manage content, and compile statistics about usage of Skwash Services.
Third Party Analytics We may use automated devices and applications provided by third parties to evaluate usage of the Skwash Services. We use these tools to help us improve the Skwash Services, performance and user experiences. These entities may use cookies and other tracking technologies to perform their services.
Sometimes when you communicate with us, or utilize our services we use third party service providers. In some cases these service providers may monitor and record mouse movements, clicks, and keystrokes so that we can better understand how our products are utilized, and in some cases they may provide interfaces that allow you to communicate with us, for example through a chat window. In these cases, we maintain contracts with these third parties and they are required to keep your information confidential. By utilizing the Skwash Services you consent to our use of service providers for these purposes.
3. How do we use the personal information we collect?
We may use your personal information to:
Provide the Skwash Services and customer support.
Process transactions and send notices about your transactions.
Resolve disputes and collect payments and/or fees.
Verify the accuracy of and authenticate your information.
Detect, investigate and prevent potentially prohibited or illegal activities, such as fraud.
Communicate about accounts or transactions and send information about features and enhancements.
Contact you, for example by phone, text (SMS) or email.
Communicate changes to our policies.
Personalize content and experiences, including providing recommendations based on your preferences.
Publish product and merchant reviews that you submit.
Send offers or promotions for the Skwash Services.
Provide advertising, including advertising based on your use of the Skwash Services or third-party websites.
Improve and develop Skwash Services and new products and services.
Perform statistical, demographic and marketing analyses of users of the Skwash Services and their purchasing patterns.
Conduct any other legitimate business activities not otherwise prohibited by law.
4. How do we share personal information?
We will only share your personal information with third parties as described in this Privacy Policy. We may share your personal information with:
Service providers, affiliates and commercial partners who help with our business operations including but not limited to, fraud prevention, account maintenance, customer service, marketing and technology services.
Consumer reporting agencies, fraud detection companies and collection agencies, as permitted by law.
Merchants you order goods or services from using the Skwash Services.
Marketing or media companies.
Analytics companies.
Companies that we plan to merge with or be acquired by or to whom we may sell or transfer our assets, including as part of a reorganization or bankruptcy proceeding.
Other third parties with your consent or at your direction to do so.
Third parties for any legitimate business purpose not otherwise prohibited by law.
We will only share your Personal Information with third parties as described in this Privacy Policy, as otherwise notified to you at the time of collection (for example as set forth in an agreement you have entered into with us) or with your consent.
5. How do we protect personal information?
We use reasonable security measures to protect your personal information from unauthorized access and use in compliance with applicable law. These measures include computer safeguards and encrypted, secured files and buildings. We also maintain other physical, technical, administrative, and procedural safeguards to protect personal information. Please be aware that despite our efforts, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared computer, choosing a robust password that nobody else knows or can easily guess, and keeping your log-in and password private. We are not responsible for any lost, stolen, or compromised passwords or for any activity on your account via unauthorized password activity.
6. How can you restrict us from sharing your personal information?
Personally Identifiable Information: You may choose not to provide your personally identifiable information to us; however, you will not be able to use the Skwash Services.
You can also limit our use and sharing of your personal information in other ways, such as:
You may unsubscribe from marketing emails by clicking the “Unsubscribe” link in the email footer or by contacting Skwash Customer Service (but we will still be permitted to contact you for servicing and account-related purposes).
You can modify browser settings to decline cookies, but certain features of Skwash Services may not function properly or may be unavailable if you do. For more information on cookies and how to disable them, you can consult the information provided by the Interactive Advertising Bureau at www.allaboutcookies.org
For your mobile device, you can understand which third parties have currently enabled cookies on your mobile device and how to opt-out of some of those cookies by accessing the Network Advertising Initiative's website at www.networkadvertising.org/mobile-choices your mobile device. On your mobile device you may also select “Limit Ad Tracking” (on iOS devices) or “Opt out of Interest-Based Ads” (on Android). Even if you disable tracking, keep in mind that you may still receive interest-based advertising, including from third parties with whom your information had been previously disclosed and that you may still receive advertising from third parties, although such advertising may not be based on your interests and preferences.
We use the information provided by Google Analytics to improve the Skwash Services. For more information regarding how Google collects, uses, and shares your information and how to opt out of certain uses please visit www.google.com/policies/privacy/partners and tools.google.com/dlpage/gaoptout
Your browser or device may include “Do Not Track” functionality. Note that our information collection and disclosure practices, and the choices that we provide to customers, will continue to operate as described in this Privacy Policy whether or not a Do Not Track signal is received.
7. Third-Party Links
The Skwash Services may contain links to third-party websites, including social media sites and merchant sites. By including a link to a third-party website, we do not endorse or recommend any products or services offered or information contained at the third-party website. Any access to and use of such linked websites is not governed by this Privacy Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites. If you decide to visit a third-party website via a link contained in or by the Skwash Services, you do so at your risk.
8. Children Under 13
Our products and services are not designed for children under 13. If we discover that a child under 13 has provided us with personal information, we will delete such information from our systems.
California Erasure Law: If you are a resident of California, under 13 and a registered user of the Skwash Services, you may ask us to remove content or information that you have posted through the Skwash Services by contacting contact@skwash.me. Please note that your request does not ensure complete or comprehensive removal of the content or information, as, for example, some of your content may have been reposted by another user.
9. Governing Law and Notice to Non-US/Non-EU Users
The Skwash Services are directed to organizations and individuals located in the United States or in European Union, and our policies are directed at compliance with those laws. If you are both located outside the United States and outside European Union, you should NOT submit personal information to us. If you voluntarily submit personal information to us, you thereby consent to the general use of such information as provided in this Privacy Policy and to the transfer of that information to, and/or storage of that information in, the United States.
10. Accessing, Correcting or Deleting Your Information
You may request to know, access, correct, or delete personal information that you have provided to us. You will not be permitted to examine the personal information of any other person or entity and may be required to provide us with personal information to verify your identity prior to accessing any records containing information about you. Depending on where you live and the type of information you have provided to us, you may have different rights and choices for managing your personal data. For example, certain state laws do not apply to personal data collected, processed, or disclosed by a financial institution according to federal or state laws, such as the Gramm-Leach-Bliley Act and the California Financial Information Privacy Act. Accordingly, the ability to know, access, correct, or delete data is not absolute, and is subject to our internal policies. We must adhere to certain legal obligations preventing us from immediately deleting some of your personal information. For example, we may not accommodate a request to change or delete personal information if we believe doing so would violate any law or legal requirement or cause the information to be incorrect. To submit a request, email contact@skwash.me.
11. Changes to this Policy
This Privacy Policy is current as of the “Published On” date set forth above. We may change this Privacy Policy from time to time, so please be sure to check back periodically. We will post any changes to this Privacy Policy on the Skwash Services. If we make any changes to this Privacy Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will aim to provide you with notice in advance of such change by highlighting the change on our website.
12. California Privacy Rights Notice/ Notice at Collection
The California Consumer Privacy Act (CCPA) provides California residents with additional rights related to their personal information. These rights do not apply, however, to any information we collect that is exempt from the CCPA, such as non-public personal information that we collect or disclose in providing a financial product or service for personal, family or household use or that is subject to certain state and federal privacy laws, such as the Gramm Leach Bliley Act, the Fair Credit Reporting Act or the California Financial Information Privacy Act. While this California Privacy Rights Notice does not apply to information that is exempt from the CCPA, in the interest of transparency, we have identified certain categories of personal information that overlap with these categories of exempted data.
For the purpose of this Section 12, the terms "personal information," "sensitive personal information," "consumer," "business purpose," "commercial purpose," "third party," "service provider," "share," "sell," and "sold" have the same meaning as provided in the CCPA.
California Shine the Light law provides California residents that have a direct business relationship with a business to request certain information regarding personal information disclosed by that to third parties for their direct marketing purposes. We do not disclose your personal information to third parties for their direct marketing purposes.
12.1 Your Rights as a California Resident
If you are a California resident, you have the following rights regarding your personal information that is subject to the CCPA (and not exempted as noted above):
Right to opt-out of the sale and sharing of your Personal Information - A common understanding of “selling” information is that it involves a company taking information it has learned about you and exchanging that information with an unrelated third party for money, who will then use that data for a new purpose that you did not intend. We do not do this.
However, California law has a much broader definition of “sell” which encompasses activities beyond the traditional common understanding of “selling” for money, such as disclosing, disseminating, making available, transferring or otherwise communicating by electronic or other means, a consumer’s personal information for money or other “valuable” consideration.
There are certain activities we perform that do fall under the very broad definition of “sale.” You have the right to opt-out of the sale of your personal information. Please note that your right to opt-out does not apply to our sharing of data with service providers, who are parties who are engaged to perform a function on our behalf and are contractually obligated to use the data only for that function.
Additionally, California law provides for a right to opt out of having your information “shared” for the purpose of delivering cross-context behavioral advertising. We also do this. We do not have actual knowledge that we have sold or shared the personal information of a California resident under 16 years of age.Request to Know – You have the right to know what personal information we have collected about you, including the categories of personal information, the categories of sources from which the personal information is collected, the business or commercial purpose for collecting, selling, or sharing your personal information, the categories of third parties to whom we disclose your personal information, and the specific pieces of personal information we have collected about you.
Request to Delete – You have the right to request in certain circumstances that we delete any personal information that we have collected directly from you, subject to certain exceptions.
Request to Correct – You have the right to request us to correct inaccurate Personal Information that we maintain about you.
Request to limit use or disclosure of Sensitive Personal Information – While we may collect pieces of sensitive personal information as defined by the CCPA, such information is either exempt from the CCPA or is only used or disclosed to provide the Skwash Services or for other purposes permitted by the CCPA. Therefore, we have no obligation to provide you the right to limit the use or disclosure of sensitive personal information under the CCPA.
Use of an Authorized Agent – You may exercise your rights under the CCPA through an authorized agent. Your authorized agent can submit a request by emailing contact@skwash.me. If you use an authorized agent to submit a request to delete, request to correct, or a request to know, we may require the authorized agent to provide proof that the you gave the agent signed permission to submit the request We may also require you to do either of the following: (1) verify your own identity directly with us or (2) Directly confirm with us that you provided the authorized agent permission to submit the request. You or the authorized agent can submit a power of attorney that complies with the California Probate Code as evidence of such authorization.
Right to not receive discriminatory treatment – If you choose to exercise any of your rights under the CCPA, you have the right to not receive discriminatory treatment by us. We will not discriminate against you because you exercise any of the rights as described in this section.
12.2 Exercising Your California Privacy Rights
To protect our customers’ personal information, we are required to verify your identity before we can take action on your requests. To do so we may ask you to verify information about you that we already have on file, for example your mailing address, email address, telephone number or details about a purchase you have made with us. We may have a reason under the law why we do not have to respond to your request, or respond to it in a more limited way than you anticipated. If we do, we will explain that to you in our response.
To submit a request, email contact@skwash.me.
12.3 Personal Information We Collect, and How it is Used
You have a right to receive notice of how we have handled personal information in the prior 12 months. Specifically: the categories of personal information we collected, the business or commercial purposes for which the personal information is collected, the sources of the personal information, the categories of personal information that we have disclosed to third parties (including the categories sold or shared as those terms are defined in the CCPA), the categories of the third parties that we have disclosed personal information and the purposes for those disclosures.
12.3.1 Categories of Personal Information We Collect
We collect personal information as part of our business. The personal information we collect depends on your relationship with us and which of the Skwash Services you have used (or not used). We collect the following categories of personal information from consumers to deliver the Skwash Services. These are also the categories of personal information we have collected in the prior 12 months.
Personal Identifiers - For example, your name, phone number, contact address and email address, IP address and Device ID.
California Customer Records (Cal. Civ. Code § 1798.80(e)) - For example, your address, telephone number, credit card, debit card, and bank account information.
Protected Classifications - For example, your date of birth from which we can derive your age, or your military status.
Commercial Information - For example, actual or considered transactions, information about your income, information in a credit report, preferences or opinions.
Biometric Information - For example, a facial geometry scan or “faceprint.”
Internet or other electronic network activity information - For example, browser or device information; interactions with specific websites and advertisements, use of specific services in our mobile application, or internet browsing history, cookies, web beacons, pixel tags, and clickstream or other traffic data.
Geolocation Information - For example, the geolocation of your personal device.
Audio, electronic, visual, thermal, olfactory, or similar information - For example, audio recordings or email and chat communications.
Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics - For example, profiles reflecting your preferences, such as interests, hobbies, characteristic tendencies, behaviors, attitudes or aptitudes, including inferences drawn from personal information like browsing information and clickstream or other website traffic data.
12.3.2 Categories of Sources of Personal Information
We have collected personal information about consumers from the following sources:
Your interactions with, or use of the Skwash Services including both information you give us, as well as information we derive from your usage;
Your contact with our customer support team and other communications with us;
Third parties, such as data vendors, marketing and media companies, consumer reporting agencies, your bank or merchants you perform a transaction with;
Through our websites and mobile applications, using cookies, Clear GIFs, web beacons, mobile application plug-ins, browser extension and similar technologies.
12.3.3 Purposes for Collection and Disclosure of Personal Information
We collect personal information about consumers for the following business and commercial purposes. We may collect information about you for additional purposes that are disclosed to you at the time of collection.
In some circumstances, we will disclose personal information about you to third parties as described in this notice. In those cases, the disclosure is done for the following business and commercial purposes as well.
Online Auditing: Auditing related to an interaction with a consumer and a concurrent transaction, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with standards that may apply.
Detecting and Protecting: Detecting and protecting against security incidents and malicious, deceptive, fraudulent, or illegal activity.
Debugging: Activities to identify and repair errors in technological functionality.
Short-term, Transient Use: Data collected, but not retained, other than to facilitate a one-time transaction or non-personalized advertising shown as part of a consumer's current interaction with the business when information is not disclosed to another third party or used to build a profile or to alter consumer experience outside of the current interaction with the business.
Providing the Skwash Services: Issuing and servicing of Skwash products and services, including but not limited to: customer service; processing or fulfilling orders and transactions; verifying customer information; responding to consumer requests; applications; underwriting; processing payments; transactions; providing IT infrastructure, storage, analytics and similar services.
Analytic Activities: Analysis to improve Skwash marketing, advertising, websites, mobile app, products, and services; to complete behavioral research; and to do other research, reporting, or evaluation.
Research & Strategic Development: Business, product, strategy, and technological development, excluding marketing and advertising activities.
Marketing and Advertising of Skwash and its Products and Services: Advertising and marketing Skwash products and services, personalize an individual's Skwash website or mobile app experience, and to deliver content or product and service offerings relevant to an individual's interests, including targeted ads and promotional offers.
Marketing and Advertising of Skwash and Our Products and Services through Cross-Context Behavioral Advertising and Similar Methods: Advertising and marketing our products and services, and to deliver content or product and service offerings relevant to an individual's interests, including targeted ads and promotional offers through cross context behavioral advertising and similar methods.
Marketing and Advertising of Our Partners and Their Products and Services: Offering our partner’s products and services, personalizing an individual's Skwash website or mobile app experience, and delivering content or product and service offerings relevant to an individual's interests, including targeted ads and promotional offers.
Legal/Compliance/Regulatory purposes: Satisfying internal and regulatory compliance requirements, responding to regulatory exams, conducting internal and external audits, responding to subpoenas and other law enforcement requests, record keeping, and enforcing or defending our rights and property.
12.3.4 Categories of Personal Information that have Sold or Shared
We have sold/shared the following categories of personal information in the prior 12 months. In each case, the information was sold/shared with Marketing or Media companies and Analytics companies for marketing and advertising of Skwash and our products and services through cross-context behavioral advertising and similar methods as well as Online Auditing.
Personal Identifiers - Specifically email addresses, Device IDs and IP addresses
Sold: No; Shared: No
Internet or other electronic network activity information - Specifically information about your use of the Skwash Services, for example how you have used the Skwash mobile app.
Sold: No; Shared: No
12.3.5 Categories of Personal Information Disclosed
In the preceding 12 months, we have disclosed personal information for a business or commercial purpose, as permitted or required by law or as otherwise set forth in this Policy. When we disclose personal information to a service provider, we enter into a contract that describes our business purpose for disclosing and requires the service provider to keep personal information confidential and to use it only for purposes consistent with the contract between us.
We may disclose all categories of your personal information for a business or commercial purpose to the following third parties:
Service providers, affiliates and commercial partners who help with our business operations, including but not limited to, fraud prevention, account maintenance, customer service, marketing and technology services.
Consumer reporting agencies, fraud detection companies and collection agencies, as permitted by law.
Merchants you order goods or services from using the Skwash Services.
Marketing or media companies.
Analytics companies.
Governmental authorities and law enforcement.
Parties to whom you have directed or authorized our disclosure.
12.3.6 Retaining Your Personal Information
We have policies and practices requiring the secure deletion of personal information when there is no applicable regulatory retention requirement and we no longer have a business need to use the information for a purpose that is compatible with our disclosed purposes of collection. Personal information that has been aggregated or deidentified so that it cannot reasonably be used to infer information about you or otherwise be linked to you may be retained indefinitely.
12.4 Additional Questions?
If you have any additional questions about the privacy aspects of the Skwash Services please email contact@skwash.me.