Privacy Policy

This is the privacy policy (“Privacy Policy”) that governs how Swift Navigation, Inc. and our affiliated companies (“Swift”, “we”, “our” or “us”), use Personal Data (defined below) that we collect, receive and store about you in connection with your use of our: (i) website www.swiftnav.com and any other website that we operate (each, together with its sub-domains, content and services, a “Site”); or (ii) Skylark software-as-a-service, including all services and functionality offered therein; and (iii) any other app, widget, software, tool or online support services offered through our Site. Our “Platform”, together with our Site, is collectively defined as our “Service”.

You may choose whether or not to provide or disclose Personal Data in connection with your use of our Service. If you choose not to provide the Personal Data we request, you may still visit and use parts of our Service, but may be unable to access or use certain features, options, programs and services. Our Service may contain links to third-party websites and services that are not owned or controlled by Swift. We are not responsible for the privacy practices or the content of third-party websites, services and advertisements and you visit them at your own risk.

1. Introduction

We are committed to respecting the privacy and recognize the need for appropriate protection and management of any Personal Data that is shared with us as part of using our Service. As used in this Privacy Policy, “Personal Data” means any information that may be used, either alone or in combination with other information, to personally identify an individual.

2. Changes to Privacy Policy

We reserve the right, at our discretion, to change the terms of this Privacy Policy at any time. You can see when this Privacy Policy was last updated by reviewing the “Last Updated” legend on the top of this page. We may provide you with notice of material changes to the Privacy Policy as appropriate under the circumstances. UNLESS OTHERWISE INDICATED, ANY CHANGES TO THIS PRIVACY POLICY WILL APPLY IMMEDIATELY UPON POSTING TO OUR SERVICE.

3. Personal Data Collected

3.1. Personal Data You Provide To Us On Our Service

a) Types of Personal Data. We and our service providers collect the Personal Data set forth below in order to provide our Service to you or because we are legally required to do so. If you do not provide the Personal Data we request, we may not be able to provide you with our Service. The Personal Data we and our service providers collect includes but is not limited to:

Your name;
Email address;
Service username;
Address;
Payment information;
Phone;
Company name;
Communications you send to us.

b) When Personal Data is Collected. You may be required to provide us with certain information that may constitute Personal Data in the following ways:

CONTACT INFORMATION

In various areas of our Service and in printed materials, we provide you the opportunity to submit a form with basic contact information, such as your name, email or mailing address. With your permission, Swift uses such information to inform you of new products, technical information and services and upcoming events that may be of interest. If you no longer wish to receive these emails, the opt-out process is described in Section 7.2 of this Privacy Policy.
In addition, if you choose, you may participate in a Swift e-mail list server by subscribing within our Service or by contacting Swift staff directly. You may unsubscribe from these e-mail list servers by following the unsubscribe instructions found within the list email.

SERVICE LOGIN INFORMATION

We process your username and password to enable you to securely log into our Service and we process information regarding your role with Swift to appropriately control access to restricted content. Passwords are one-way hashed, so we do not have access to your plain text password.We process this Personal Data only as necessary to provide you services on our Service under our Terms and Conditions and to further our legitimate interests in protecting our Service and content.

PAYMENT INFORMATION

When you register for a subscription through our Service, third-party service providers acting on our behalf process your payment information, including payment card details and billing addresses. Any Personal Data collected by such third party will be subject to the third party’s privacy policy, rather than this Privacy Policy. We will retain the last four digits of your credit card number and credit card type for future use with our Services. A recurring subscription will be created at our payment gateway, which will store your billing information for as long as necessary to carry out the terms of your subscriptions.

INFORMATION COLLECTED THROUGH VARIOUS FORMS

We and our service providers may collect Personal Data in a variety of ways, including: (i) through your use of our Service, e.g., when you sign up for a newsletter, download a product, make online inquiries or register for a subscription; (ii) offline, such as when you attend one of our events or contact customer service; or (iii) from other sources, such as public databases, joint marketing partners, social media platforms (including from people with whom you are friends or otherwise connected) and from other third parties.

PERSONAL DATA YOU DISCLOSE RELATING TO OTHERS

If you disclose any Personal Data relating to other people to us or to our service providers in connection with our Service, you represent that you have the authority to do so and to permit us to use the information in accordance with this Privacy Policy.

SOCIAL MEDIA

You also may be able to link an account from a social networking service to an account through our Service. This may allow you to use your credentials from the other site or service to sign in to certain features on our Service. If you link your account from a third-party site or service, we may collect information from those third-party accounts and any information that we collect will be governed by this Privacy Policy.

3.2. Personal Data You Provide To Third Parties On Our Service. Please note that we use certain third-party service providers on our Service to enhance your experience or deliver certain services. These providers may collect Personal Data about you in performing their services and/or functions on our Service. Swift maintains Data Processing Agreements with all third parties that process Personal Data on our behalf. For more information on our third party service providers and their privacy practices, please see Appendix 1.

3.3. Information Collected Automatically. Certain information on our Service is collected automatically by means of various software tools. We have a legitimate interest in using such information to assist in log-in, systems administration purposes, information security and abuse prevention, to track user trends and to analyze the effectiveness of our Service. Alone or in combination with other information, such automatically collected information may constitute Personal Data. Some of our service providers (described in Section 5, below) may use cookies or other methods to gather information regarding your use of our Service. Such third parties may use these cookies or other tracking methods for their own purposes by relating information about your use of our Service with any Personal Data about you that they may have. The use of such information by a third party depends on the privacy policy of that third party.

a) Log Files On Our Service.

WEBSITE

The information inside the log files includes internet protocol (“IP”) addresses, type of browser, Internet Service Provider (“ISP”), date/time stamp, referring/exit pages, clicked pages and any other information your browser may send to us.

SKYLARK SOFTWARE-AS-A-SERVICE

The Skylark license management service captures username in an audit trail, which is used for security reviews and troubleshooting. The usage logs for Skylark Direct service also capture username for troubleshooting purposes. If advanced troubleshooting is required, you may be asked by Swift support to temporarily repoint your device to a Skylark endpoint that also logs rover position.

b) Cookies. We use cookies to make interactions with our Service easy and meaningful. When you visit our Service, our servers may send a cookie to your computer. Standing alone, cookies do not personally identify you; they merely recognize your web browser. Unless you choose to identify yourself to us, either by responding to a promotional offer, opening an account or filling out a web form, you remain anonymous to us.
We may use cookies that are session-based and persistent-based. Session cookies exist only during one session. They disappear from your computer when you close your browser software or turn off your computer. Persistent cookies remain on your computer after you close your browser or turn off your computer. Please note that if you disable your web browser’s ability to accept cookies, you will be able to navigate our Service but you may not be able to successfully use all of the features of our Service.
The following sets out how we may use different categories of cookies and your options for managing cookie settings:

Types of Cookies	Description	Managing Settings
Strictly Necessary Cookies	Required cookies enable you to navigate our Service and use its features, such as accessing secure areas of our Service and using our services. If you have chosen to identify yourself to us, we use cookies containing encrypted information to allow us to uniquely identify you. Each time you log into our Service, a cookie containing an encrypted, unique identifier that is tied to your account is placed on your browser. These cookies allow us to uniquely identify you when you are logged into our Service and to process your online transactions and requests.	Because required cookies are essential to operate our Service, there is no option to opt out of these cookies.
Performance Cookies	These cookies collect information about how you use our Service, including which pages you go to most often and if they receive error messages from certain pages. These cookies do not collect information that individually identifies you. All information these cookies collect is aggregated and anonymous. It is only used to improve how our Service functions and performs. From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit our Service. We may also utilize Flash cookies for these purposes.	You can opt out of performance cookies through your browser settings. To learn how to manage privacy and storage settings for Flash cookies click here.
Functionality Cookies	Functionality cookies allow our Service to remember information you have entered or choices you make (such as your username, language, or your region) and provide enhanced, more personal features. These cookies also enable you to optimize your use of our Service after logging in. These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customize. We may use local shared objects, also known as Flash cookies, to store your preferences or display content based upon what you view on our Service to personalize your visit.	You can opt out of performance cookies through your browser settings. To learn how to manage privacy and storage settings for Flash cookies click here.
Targeting or Advertising Cookies	From time-to-time, we may engage third parties to track and analyze usage and volume statistical information from individuals who visit our Service. We sometimes use cookies delivered by third parties to track the performance of our advertisements. For example, these cookies remember which browsers have visited our Service. The information provided to third parties does not include Personal Data, but this information may be re-associated with Personal Data after we receive it. By way of example, as you browse our Service, advertising cookies may be placed on your computer so that we can understand what you are interested in. Our advertising partners then enable us to present you with retargeted advertising on other sites based on your previous interaction with our Service. We also contract with third-party advertising networks and similar partners that collect IP addresses and other information from web beacons (see below) on our Service, from emails, and on third-party sites. Ad networks follow your online activities over time by collecting Site Navigational Information through automated means, including through the use of cookies. They use this information to provide advertisements about products and services tailored to your interests. You may see these advertisements on other websites. This process also helps us manage and track the effectiveness of our marketing efforts. Third parties, with whom we partner to provide certain features on our Service or to display advertising based upon your web browsing activity, use Flash cookies to collect and store information. Flash cookies are different from browser cookies because of the amount of, type of, and how data is stored.	To learn more about these and other advertising networks and their opt out instructions, click here. To learn how to manage privacy and storage settings for Flash cookies click here.

c) Other Tracking Technologies. When you visit our Service, we may collect your IP address for certain purposes such as, for example, to monitor the regions from which you navigate our Service. We may also use web beacons alone or in conjunction with cookies to compile information about your usage of our Service and interaction with emails from us. Web beacons are clear electronic images that can recognize certain types of information on your computer, such as cookies, when you viewed a particular site tied to the web beacon. For example, we may place web beacons in marketing emails that notify us when you click on a link in the email that directs you to our Service. We may use web beacons to operate and improve our Service and email communications.

d) Analytics Software Tools. We use Google Analytics on our Service to help us analyze the traffic on our Service. For more information on Google Analytics’ processing of Personal Data, please see http://www.google.com/policies/privacy/partners/. By using a browser plugin http://www.google.com/ads/preferences/plugin/ provided by Google, you can opt out of Google Analytics.

4. The Purposes For Which We Use Personal Data.

If you submit, or we collect, Personal Data through our Service, then such Personal Data may be used in the following ways: (i) to provide, analyze, administer, and improve our Service, (ii) to contact you in connection with our Service and certain services, notifications, events, programs or offerings that you may have registered for, (iii) to send you updates, newsletters and promotional materials that you have registered for, (iv) to identify and authenticate your access to the parts of our Service and services that you are authorized to access; (v) for recruiting and human resources administration purposes, (vi) to protect our rights and/or our property and to ensure the technical functionality and security of our Service; (vii) to customize any advertising and content you see on the Services; (viii) to compare and otherwise use data entered for any purpose including consulting, research, and marketing; and (ix) to improve the quality of experience when you interact with the Services.

5. How We Disclose Personal Data

We do not sell, lease, rent or otherwise disclose the Personal Data collected from our Service to third parties unless otherwise stated below or with your consent.

5.1. Our Third Party Providers. We transfer Personal Data to our third-party service providers to perform tasks on our behalf and to assist us in providing our Service, as more fully described in Section 3.2. We use commercially reasonable efforts to only engage or interact with third party service providers and partners that post a privacy policy governing their processing of Personal Data. Notwithstanding the foregoing, we will comply with applicable laws regarding Personal Data transfers as well as any transfer restriction that is specified in an agreement between Swift and a customer.

5.2. Related Entities. We may share some or all of your Personal Data with any parent company, subsidiary or companies under common control (collectively, “Related Entities”), in which case we will require our Related Entities to honor this Privacy Policy.

5.3. Business Partners. From time to time, we may partner with other companies in connection with the retail, resale, or general commercialization of our Service. In connection with such partnership, we may share Personal Data we have collected from you and which we have recorded in our customer contact lists and registries. We share Personal Data to allow our business partners to effectively contact you with unique offerings of our Service. We do not control our business partners’ use of Personal Data we collect, and their use of the information will be in accordance with their own privacy policies.

5.4. Advertising. We engage advertising services to assist us in advertising our brand and Service. From time to time, those services target advertisements on third-party websites based on cookies or other information indicating previous interaction with our Service.

5.5. In the Event of Merger, Sale, or Change of Control. We may transfer or assign this Privacy Policy and any Personal Data to a third party entity that acquires or is merged with us as part of a merger, acquisition, sale or other change of control.

5.6. Other Disclosures. We may disclose Personal Data about you if we have a good faith belief that disclosure of such information is helpful or reasonably necessary to: (i) comply with any applicable law, regulation, legal process or governmental request; (ii) enforce our terms of use, including investigations of potential violations thereof; (iii) detect, prevent, or otherwise address fraud or security issues; or (iv) protect against harm to the rights, property or safety of Swift, our users, or the public.

6. Retention of Personal Data

We reserve the right to retain any Personal Data as long as the Personal Data are needed to: (i) fulfill the purposes that are described in Section 4 (The Purposes For Which We Use Personal Data) and (ii) comply with applicable law.

7. Your Rights

7.1 Personal Data. If you have an account on our Service, to the extent we are legally required, we provide access to—and the ability to edit or delete—certain categories of Personal Data through the account.
If you would like to access, amend, erase, export (i.e., data portability), or object to or restrict the processing of Personal Data collected via our Service, you may submit a request via email to privacy[at]swift-nav[dot]com. We will promptly review all requests, and act in accordance with applicable laws.

Depending on where you live, you may have a right to lodge a complaint with a supervisory authority or other regulatory agency if you believe that we have violated any of the rights concerning Personal Data about you. We encourage you to first reach out to us at privacy[at]swift-nav[dot]com so we have an opportunity to address your concerns directly before you do so.

7.2. Opting-Out of Promotional Emails. You may choose not to receive future promotional or advertising emails from us by selecting an unsubscribe link at the bottom of each email that you receive from us or by responding to the emails directly and requesting removal if such a link is not available. Additionally, you may send a request specifying your communications preferences to privacy[at]swift-nav[dot]com. Customers cannot opt out of receiving transactional emails related to their account with us or our services. Please note that even if you opt out of receiving the foregoing emails, we may still send you a response to any "Contact Us" request as well as administrative, maintenance and operational emails (for example, in connection with a password reset request).

8. Personal Data Residency

Unless otherwise specified, Personal Data is stored in the US. To reduce latency, the Skylark license registry database is replicated in the US and EU.

9. Data Security

The security of Personal Data is important to us. We follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it. However, no method of transmission over the Internet, or method of electronic storage, is 100% secure. Therefore, while we strive to use commercially acceptable means to protect Personal Data, we cannot guarantee its absolute security.

10. Children's Privacy

Our Service is not intended for children under the age of 18. Accordingly, we do not intend to collect Personal Data from anyone we know to be under 18 years of age.

11. How We Respond to Do Not Track Signals

Swift does not track Site users over time and across third party websites to provide targeted advertising. Accordingly, we do not currently respond or take any action with respect to web browser "do not track" signals or other mechanisms that provide consumers the ability to exercise choice regarding the collection of Personal Data about an individual consumer's online activities over time and across third-party websites or online services.

12. For California Residents

If you are a California resident, California Civil Code Section 1798.83 permits you to request information regarding the disclosure of Personal Data about you by Swift to third parties for the third parties’ direct marketing purposes. To make such a request, you may send an email to privacy[at]swift-nav[dot]com.
Furthermore, California residents have the following rights with respect to Personal Data we may have collected about them:

(i) Requests to Know

You have the right to request that we disclose:

The categories of Personal Data we have collected about you;
The categories of Personal Data about you we have sold or disclosed for a business purpose;
The categories of sources from which we have collected Personal Data about you;
The business or commercial purposes for selling or collecting Personal Data about you;
The categories of Personal Data sold or shared about you, as well as the categories of third parties to whom the Personal Data was sold, by category of Personal Data for each party to whom Personal Data was sold; and
The specific pieces of Personal Data collected.

You may submit a request via email to privacy[at]swift-nav[dot]com. The delivery of our response may take place electronically or by mail. We are not required to respond to requests to know more than twice in a 12-month period.

(ii) Requests to Delete

You have the right to request that we delete any Personal Data about you that we have collected. Upon receiving a verified request to delete Personal Data, we will do so unless otherwise authorized by law. You may submit a request to delete Personal Data via email to privacy[at]swift-nav[dot]com

(iii) Authorized Agents

You may designate an authorized agent to make requests on your behalf. You must provide an authorized agent written permission to submit a request on your behalf, and we may require that you verify your identity directly with us. Alternatively, an authorized agent that has been provided power of attorney pursuant to Probate Code sections 4000-4465 may submit a request on your behalf.

(v) Methods for Submitting Consumer Requests and Our Response to Requests

You may submit a request to know and requests to delete Personal Data about you via email to privacy[at]swift-nav[dot]com

Upon receipt of a request and in order to protect your privacy and the security of Personal Data about you, we may ask you for additional information to verify your identity. Any additional information you provide will be used only to verify your identity and not for any other purpose. We will acknowledge the receipt of your request within ten (10) days of receipt. Subject to our ability to verify your identity, we will respond to your request within 45 days of receipt.

(vi) The Right to Non-Discrimination

You have the right not to be discriminated against for the exercise of your California privacy rights described above.

13. Contacting Us

Any comments, concerns, complaints, or questions regarding our Privacy Policy may be addressed to privacy[at]swift-nav[dot]com.

Appendix 1

Third Party Service Providers

Acquia, for website hosting. For more information on this service provider’s privacy practices, please review:https://www.acquia.com/about-us/legal/privacy-policy
Amazon Web Services, for Skylark software-as-a-service, including for license management-related emails, data storage and cloud infrastructure. For more information on this service provider’s privacy practices, please review: https://aws.amazon.com/privacy/
Bing, for web-based marketing solutions. For more information on this service provider’s privacy practices, please review: https://privacy.microsoft.com/en-us/privacystatement
Freshdesk, to support ticketing management. For more information on this service provider’s privacy practices, please review: https://www.freshworks.com/privacy/
DoubleClick, for advertising targeting. For more information on this service provider’s privacy practices, please review: https://policies.google.com/privacy
Drupal, for content management solutions. For more information on this service provider’s privacy practices, please review: https://drupal.org/privacy
Google Ad Words, for advertising targeting. For more information on this service provider’s privacy practices, please review: https://policies.google.com/privacy
Google Groups, for product/Q&A forum and community. For more information on this service provider’s privacy practices, please review: https://policies.google.com/privacy
Greenhouse, for job applicant and tracking management. For more information on this service provider’s privacy practices, please review: http://www.greenhouse.io/privacy-policy
LinkedIn, social link to internal business. For more information on this service provider’s privacy practices, please review: https://legal.linkedin.com/dpa
Lotame, for advertisement targeting and tracking. For more information on this service provider’s privacy practices, please review: https://www.lotame.com/about-lotame/privacy/
Mapbox, for mapping services. For more information on this service provider’s privacy practices, please review: https://www.mapbox.com/privacy/
Netsuite, for e-commerce solutions. For more information on this service provider’s privacy practices, please review: https://www.oracle.com/legal/privacy/index.html
Papertrail, for Skylark software-as-a-service monitoring and logging. For more information on this service provider’s privacy practices, please review: https://www.papertrail.io/privacy
Salesforce, for customer relationship management solutions. For more information on this service provider’s privacy practices, please review: https://www.salesforce.com/company/privacy
The Trade Desk, for programmatic buying and automated tracking. For more information on this service provider’s privacy practices, please review: https://www.thetradedesk.com/general/website-privacy-policy
Twitter, social link and profile build-out with Salesforce. For more information on this service provider’s privacy practices, please review: https://help.twitter.com/forms/privacy

Last Updated July 29, 2020