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    SwingCulture Privacy Policy

    Last Updated: March 27, 2019

    This Privacy Policy (the "Policy") explains how information is collected, used and disclosed by SwingCulture. With respect to your access and use of SwingCulture's services, whether through our websites (located at www.swingculture.com), SwingCulture's mobile applications (SwingCulture) or in connection with social networking services (together referred to below as "SwingCulture" or the "Service").
    We have prepared this Privacy Policy to describe to you our practices regarding the personal information that we collect from Users of the SwingCulture Services. This Privacy Policy is incorporated into and forms part of our Terms of Use , which outline the terms and conditions you agree to when accessing and using the SwingCulture Services. By accessing and using the SwingCulture Software and/or by registering and using the SwingCulture Services, you agree and consent to the collection, use and disclosure of your personal information as outlined in this Privacy Policy.

    1. What personal information do we collect?

    a) Information You Provide.  We may collect personal information from you when you voluntarily provide it to us through a number of features available on the SwingCulture Software. For example, when you register, use, pay to use or subscribe to any of our SwingCulture Services or take part in any interactive features of the SwingCulture Services (such as any contests, games, promotions, quizzes, surveys, research or other services or features), we collect a variety of personal information directly from you or when you authorize us to access certain personal information. This information includes your birth date, name, age, gender, photographs, lifestyle, physical appearance, relationship intentions, bio, religion, political views, dating gender preference, education, language, interests (movies, TV shows, books, etc.) and profile pictures, valid email address and phone number, and your choice of username and password when you register for a SwingCulture Account via email, etc. You may also be asked to validate your SwingCulture Account via email, SMS or photo with required posture. We retain passwords in hashed format only.

    b) We may also ask for other personal information as indicated on the relevant forms on the SwingCulture Services. Where possible, on these forms we will indicate which fields are required and which fields are optional.

    c) In addition, as you use the SwingCulture Services, you can from time to time enter or send to us personal information such as sending us feedback via email. Our primary purpose in collecting personal information from you is to provide you with a safe, smooth, efficient, and customized experience. This allows us to provide services and features that most likely meet your needs, and to customize our service to make your experience safer and easier. We only collect personal information about you that we consider necessary for achieving this purpose. Once registered, you are no longer anonymous to us and you can review and change certain personal information such as your bio and gender in the Edit Profile settings area.

    d) Information From Content You Post.  When you post photos or other content to the SwingCulture Services, we collect information such as the time and date the content was taken or uploaded. We reserve the right to collect data on how you use them, who views them or with whom you share.

    e) Geolocation Data.  When you use the SwingCulture Services, we will collect your location information to determine your distance from other Users (" Distance Information ") through GPS, Wi-Fi and other cellular technology in your mobile device or through an Internet Protocol (" IP address ") address (which is a number that is automatically assigned to your computer or mobile device when you use the Internet, which may vary from session to session). Your last known location is stored on our servers for the purpose of calculating Distance Information between you and other Users. We will also collect your mobile device's geographic location data (including GPS) or your computer's geographic location data while the SwingCulture Service is actively running.

    f) Information Automatically Collected.  When you access the SwingCulture Services, we automatically record information from your computer and/or mobile device and its software, such as your IP address, browser type, Internet service provider, platform type, the site from which you came and the site to which you are going when you leave, date and time stamp and one or more Cookies (as defined below) that may uniquely identify your browser or your SwingCulture Account. Your mobile device's unique device ID is unique to the mobile device on which you install the SwingCulture Services (" Device ID " and " Mobile Device ", respectively). For example, if you installed the SwingCulture app on an Apple Device, we store your identifier for vendor. We create a hashed version of your Device ID and use your hashed Device ID to log you into the SwingCulture Services. We store your Device ID and/or your hashed Device ID with other information we collect about you, including your SwingCulture Account and profile information and your Message information. We will also collect certain software and hardware information about your Mobile Device. When applicable, we will also receive or collect identification numbers associated with your Mobile Device (such as an Open UDID), mobile carrier, device type, firmware version and manufacturer and other diagnostic Mobile Device information.

    g) Information About How You Use The SwingCulture Services.  Additionally, we also automatically track certain personal information about you based upon your behaviour on the SwingCulture Services, including information about your computer or Mobile Device and your activities. We create a tracking ID unique to each SwingCulture Account for internal tracking purposes. We use this information to do internal research on our Users' demographics, interests, and behaviour to better understand, protect and serve you and our community. This may include information such as the pages and profiles you view, how you browse the SwingCulture Services, your SwingCulture Coin balance and purchases you make through the SwingCulture Services. It can also include the various functions and features that you use, such as Messages (as defined below), the connections you make, other friends or contacts you invite to the SwingCulture Services and profile searches you perform, or your general use of the SwingCulture Services.

    h) Log Files.  To make the SwingCulture Services more useful to you, our servers or analytic partners, when applicable, collect log files that contain personal information listed in Section 1(e) for diagnostic purposes. We reserve the right to also use Cookies (as described below) and URL information to gather information regarding the date and time of your visit and the information for which you searched and which you viewed. " Cookies " are tiny computer files that a website sends to your computer or Mobile Device while you are viewing a website. We may use Cookies to provide you with a more personal and interactive experience on the SwingCulture Services. If you choose to disable Cookies, some areas or features of the SwingCulture Services may not work properly.

    i) Messages.  When you send a message (which may include text, photos, audio or video) to other Users of the SwingCulture Services, we will retain the messages (" Messages ") as required by the operation of the SwingCulture Services.

    j) Surveys.  When you participate in one of our surveys (which may be provided by a third party service provider), we may collect additional personal information that you provide through the survey. The third party survey provider's privacy policy applies to its collection, use and disclosure of your personal information.

    k) Purchases.  If you purchase any of the Paid SwingCulture Services (as defined in our Terms of Use ) through your Google Play account and/or Apple iTunes account, SwingCulture will collect the iTunes unique transaction IDs and receipts data. SwingCulture does not receive or process credit card information and asks you to use your Apple iTunes account to purchase Paid SwingCulture Services on Apple devices. If you wish to use your Apple iTunes to purchase Paid SwingCulture Services, please review Apple's privacy policies at http://www.apple.com/privacy or as otherwise available to better understand Apple's privacy practices.

    l) Your Communications With Us And Other Users.  We collect communications you send to us (such as emails), comments that you post on the pages that we have on a third-party service such as our Instagram, Pinterest, Twitter and Facebook channels, and messages or communications you send to us directly through those services. We may also collect any comments, photos, messages or other content or communications you and other Users share on the SwingCulture Services. If you provide us feedback or contact us via email (e.g., for support), we will collect your name and email address, as well as any other content included in the email in order to send you a reply. If you contact us for support, we may also collect and retain certain technical diagnostic data (e.g., your Mobile Device model).

    m) Third-Party Social Networking Sites. When you have enabled the use of the SwingCulture Services through a third-party social networking site or similar site or mobile site or other application (a " Social Networking Site "), such as Facebook, Google+ or Twitter, you permit SwingCulture to access certain personal information about you that is made available to SwingCulture through or from that Social Networking Site. The personal information obtained by SwingCulture varies by Social Networking Site and may be affected by the privacy settings that you establish at that Social Networking Site, but can include information such as your name, profile picture, network, gender, username, user ID, age or birthday, language, location, country, interests, contacts list, friends lists or followers and other information. By accessing or using the SwingCulture Services through a Social Networking Site, you are authorizing SwingCulture to collect, use, store, and disclose, in accordance with this Privacy Policy, any and all of your information that SwingCulture has obtained from the Social Networking Site, including to create a profile and SwingCulture Account for you. Depending on the Social Networking Site and your privacy settings, SwingCulture may also post information to your Social Networking Site. SwingCulture is able to access this information when you click or otherwise agree to " accept " or " allow " or " go to " (or other similar terms) the SwingCulture Services on a Social Networking Site or otherwise permit the transfer of information to SwingCulture from such site. If there is information about your " friends " or people you are associated with in your Social Networking Site account, the information that we obtain about those persons may also depend on the privacy settings that such people have with the applicable Social Networking Site. You acknowledge and agree that SwingCulture is not responsible for, and has no control over, your Social Networking Site account or any applicable privacy settings on any Social Networking Sites (including any settings related to any messages or advertisements about SwingCulture that the Social Networking Site may send to you or your friends). You should always review, and if necessary, adjust your privacy settings on Social Networking Sites before getting or using applications such as ours or linking or connecting your Social Networking Site account to the SwingCulture Services. You may also unlink your Social Networking Site account from the SwingCulture Services by adjusting your settings on the Social Networking Site.

    n) Information Provided By Others.  We may be provided with information relating to you or your conduct on the SwingCulture Services by other Users of the SwingCulture Services. We also collect information that third-party organizations may provide to us, such as demographic information or fraud prevention information.

    2. How do we use the personal information that we collect?

    We use your personal information for the purposes described in this Privacy Policy or otherwise disclosed to you in connection with the SwingCulture Services. These purposes include:

    a) Providing the Requested SwingCulture Services:  We use your personal information to administer and maintain your SwingCulture Account and generally provide the functions and features that are part of the SwingCulture Services (including providing communications as described below).

    b) Analyzing and Develop Our Products and Services:  We use your personal information to develop, deliver, measure, monitor, analyze and improve the SwingCulture Services and develop new products and services.

    c) Communicate With You:  We use your personal information to respond to your comments and questions and provide customer service, to provide any messaging or communications associated with the functions and features of the SwingCulture Services (including by email), to keep you posted on our latest product or service announcements or updates, software updates, security alerts and any technical notices and to provide you with support and administrative messages. If you do not wish to receive email from SwingCulture you may opt-out by following the instructions included in each communication or by contacting SwingCulture support at support@swingculture.com

    d) Protect the SwingCulture Services and SwingCulture's Property:  We use your personal information to detect and prevent abusive, fraudulent, malicious or potentially illegal activities, and to protect the rights, safety or property of SwingCulture and our Users.

    e) Geographical Or GPS Location-Based Services:  We may use your personal information to provide features of the SwingCulture Services that may be relevant to you and your geographical location or GPS information.

    f) Additional Uses:  We may use your personal information to perform other functions as may otherwise be described to you at the time of collection or as enabled by you in relation to the SwingCulture Services.

    3. How do we disclose your personal information?

    The SwingCulture Services allow you to share personal information about yourself with other individuals and other companies, including other Users and potential Users of the SwingCulture Services. Please consider your own privacy and personal safety when sharing your information with anyone, including information you share through your profile. Profiles may include certain personal information that was provided at registration, and other information added by you (e.g., your bio), as well as information about your use of the SwingCulture Services (e.g., whether you were recently logged in to the SwingCulture Services).  for tips on using the SwingCulture Services.

    Please be advised that information on your profile, including any personal information, is viewable by other Users. We do not control who reads the information that you share or what others may do with this information, so we encourage you to use discretion and caution with respect to your personal information. Also, if you wish to share information about other Users, please consider their safety and privacy and get their consent before sharing.

    Except as described below, we do not sell, transfer or otherwise disclose to third parties the personal information we collect through the SwingCulture Services. At times we may share personal information with third parties as follows:

    1.    With third party vendors, consultants, business partners and other service providers (" Third Party Providers ") that perform services on our behalf, in order to carry out their work for us, which may include identifying and serving advertisements, providing fraud detection services or providing analytics services;

    2.    With Third Party Providers that offer a service to you jointly with us, for example, if we run a contest or promotion.

    Any Third Party Providers that have access to personal information are chosen carefully by us and are required to have privacy and security standards that meet our requirements. We use contracts and other measures with our Third Party Providers to maintain the confidentiality and security of Users' personal information and to prevent personal information from being used for any other purpose, including for any advertising or other commercial purposes. However, you should know that Third Party Providers performing services on our behalf may store, transfer and process personal information on servers located outside of United States, in jurisdictions (including Canada) whose data protection laws differ from those of The United States. As a result, personal information may be subject to access requests from governments, courts, or law enforcement in those jurisdictions according to laws in those jurisdictions. For example, information may be shared in response to valid demands or requests from government authorities, courts and law enforcement officials in those countries. Subject to applicable laws in such other jurisdictions, we will use reasonable efforts to ensure that appropriate protections are in place to require our Third Party Providers to maintain protections on personal information that are equivalent to those that apply in the United States of America.

    We also reserve the right to transfer any personal information we have about you in the event that we sell or transfer all or a portion of our business or assets to a third party, in connection with any company transaction, such as a merger, sale of assets or shares, reorganization, financing, change of control or acquisition of all or a portion of our business by another company or third party or in the event of bankruptcy, dissolution, divestiture or any related or similar proceedings.

    We may disclose your personal information for any other purpose to which you consent.

    We reserve the right to share aggregated information (not linked to your personal information) with others that is not personal information or that is in an aggregated or anonymous form that does not reasonably identify you directly as an individual.

    Note that the term " third party " does not include companies in the same group of companies as SwingCulture, which includes our subsidiaries (that is, any organization we own or control) or our ultimate holding company (that is, any organization that owns or controls us) and any subsidiaries that our holding company owns. Unless otherwise indicated, these companies will use your personal information as described under this Privacy Policy.

    4. Our retention of your personal information

    We retain personal information for only as long as required to fulfill the identified purposes for which it was collected, and for a reasonable time thereafter, or as required by law. SwingCulture has retention standards which meet these requirements. SwingCulture destroys your personal information following the end of our retention period, when it is no longer needed, or when we remove your name from the information. We assume no obligation or guarantee to archive any information and do not warrant that any archived information will later be made available to you.

    You may deactivate your SwingCulture Account at any time by accessing "Settings" and selecting deactivate account or by emailing our support team at support@swingculture.com with the subject line Please Deactivate My SwingCulture Account .


    For greater clarity, Messages, photos, videos, text, comments and certain other information sent to Users may remain on the SwingCulture Services after you deactivate your SwingCulture Account.

    5. Legal requests; emergencies; jurisdictions

    We cooperate with bona fide law enforcement inquiries and demands for information as required by law. We are also cognizant of the need to address emergencies. Therefore, we may disclose your personal information (a) to any governmental authority as part of an investigation to determine our compliance with any applicable law, rule, or regulation (including privacy laws, rules, and regulations); (b) in response to a court order, subpoena, discovery request, or other lawful judicial or administrative proceeding; (c) as otherwise required under any applicable law, rule, or regulation; (d) in good faith, to protect or defend our rights or property or those of other Users or investigate and defend ourselves against any third party claims or allegations; (e) enforce our Terms of Use, including the investigation of potential violations thereof; or (f) detect, prevent or otherwise address criminal (including fraud or stalking), security or technical issues.

    In some cases, personal information that we collect may be stored or processed by us outside of United States of America in jurisdictions whose data protection laws may differ from The United States of America. In such cases, we will continue to protect the information with appropriate safeguards through contract and otherwise use reasonable efforts to ensure that appropriate protections are in place, but you acknowledge that your personal information may be subject to the governments, courts, law enforcement officials, national security authorities and laws of those countries.

    6. Security

    SwingCulture takes your privacy concerns seriously and strives to protect your personal information against unauthorized access, disclosure, inappropriate alteration and misuse. For security we use the Secure Sockets Layer (SSL/TLS) protocol for any transactions that send personal information. This encryption process protects your information, by scrambling it before it is sent to us from your Mobile Device or computer. We also make reasonable effort to ensure the security of your personal information on our system using available protection technology. Unfortunately, no data transmission over the Internet can be guaranteed to be 100% secure. As a result, we make no representations or warranties as to the security of any information that you submit to us electronically in connection with the SwingCulture Services, which you do at your own risk.

    7. Advertising and Third Party Advertising Networks

    We may use or share certain information with online advertising networks or similar third party vendors that display ads through the SwingCulture Services, or to our Users. Typically, the information we share is provided through Cookies or similar technologies and is used to recognize the device or browser you are using. We or the online advertising networks use this information to make the advertisements you see online more relevant to your interests.

    8. Access to your information and account management

    You may access and change your SwingCulture Account information at any time by visiting the " Edit Profile " and " Settings " sections of your SwingCulture Account or the Social Networking Sites that you have connected to the SwingCulture Services. You may also contact us for assistance using the details below if you want to access or change your SwingCulture Account information or close your SwingCulture Account.

    9. Age restrictions

    We do not intentionally collect or maintain personal information from people under eighteen (18) years of age. If you become aware that personal information about a person under eighteen (18) years of age has been provided to us, please immediately click on the Report button located in the drop down menu on a User's profile or contact us using the details below.

    10. Links to third party websites

    Use of the SwingCulture Services may allow you to access links to websites or apps of our partner networks, advertisers, partner merchants, retailers or affiliates and/or to other sites that are independently owned and operated by third parties. They may have their own privacy policies and are not governed by this Privacy Policy. We are not responsible for the privacy practices or the content of any site(s) owned and operated by any such subsidiaries, affiliates or third parties and accept no responsibility or liability for their policies. Please always check the privacy policies that apply to a third party site before you provide any information to any third party site.



    We want you to be in control of your information, so we have provided you with the following tools:

    · Access / Update tools in the service. Tools and account settings that help you to access, rectify or delete information that you provided to us and that’s associated with your account directly within the service. If you have any question on those tools and settings, please contact our customer care team for help here.

    · Device permissions. Mobile platforms have permission systems for specific types of device data and notifications, such as phone book and location services as well as push notifications. You can change your settings on your device to either consent or oppose the collection of the corresponding information or the display of the corresponding notifications. Of course, if you do that, certain services may lose full functionality.

    · Deletion. You can delete your account by using the corresponding functionality directly on the service.

    We want you to be aware of your privacy rights. Here are a few key points to remember:

    · Reviewing your information. Applicable privacy laws may give you the right to review the personal information we keep about you (depending on the jurisdiction, this may be called right of access, right of portability or variations of those terms). You can request a copy of your personal information by sending us an email.

    · Updating your information. If you believe that the information we hold about you is inaccurate or that we are no longer entitled to use it and want to request its rectification, deletion or object to its processing, please contact us here.

    For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer the above requests.

    Keep in mind, we may reject requests for certain reasons, including if the request is unlawful or if it may infringe on trade secrets or intellectual property or the privacy of another user. If you wish to receive information relating to another user, such as a copy of any messages you received from him or her through our service, the other user will have to contact our Privacy Officer to provide their written consent before the information is released.

    Also, we may not be able to accommodate certain requests to object to the processing of personal information, notably where such requests would not allow us to provide our service to you anymore. For instance, we cannot provide our service if we do not have your date of birth.

    · Uninstall. You can stop all information collection by an app by uninstalling it using the standard uninstall process for your device. If you uninstall the app from your mobile device, the unique identifier associated with your device will continue to be stored. If you re-install the application on the same mobile device, we will be able to re-associate this identifier to your previous transactions and activities.

    · Accountability. In certain countries, including in the European Union, you have a right to lodge a complaint with the appropriate data protection authority if you have concerns about how we process your personal information. The data protection authority you can lodge a complaint with notably may be that of your habitual residence, where you work or where we are established.



    If you are a California resident, you can request a notice disclosing the categories of personal information about you that we have shared with third parties for their direct marketing purposes during the preceding calendar year. To request this notice, please submit your request here. Please allow 30 days for a response. For your protection and the protection of all of our users, we may ask you to provide proof of identity before we can answer such a request.



    We work hard to protect you from unauthorized access to or alteration, disclosure or destruction of your personal information. As with all technology companies, although we take steps to secure your information, we do not promise, and you should not expect, that your personal information will always remain secure.

    We regularly monitor our systems for possible vulnerabilities and attacks and regularly review our information collection, storage and processing practices to update our physical, technical and organizational security measures.

    We may suspend your use of all or part of the services without notice if we suspect or detect any breach of security. If you believe that your account or information is no longer secure, please notify us immediately here



    We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of six months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.

    In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window) or after two years of continuous inactivity, unless:

    1. we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);

    2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);

    3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or

    4. the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users' safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.

    Keep in mind that even though our systems are designed to carry out data deletion processes according to the above guidelines, we cannot promise that all data will be deleted within a specific timeframe due to technical constraints.


    15. Updates to this Privacy Policy

    This Privacy Policy is SwingCulture's privacy commitment to you with respect to the SwingCulture Services. If you have questions about this Privacy Policy, please contact our Privacy Officer as described in Section 12 below. SwingCulture reserves the right to change this Privacy Policy at any time without specific notice or obligation to you. If we make changes to this Privacy Policy, we will change the " Last Updated " date above and will post the updated Privacy Policy on this page. We may also provide other methods of notice or request your consent depending on the circumstances.

    Any changes will be effective immediately upon the posting of the revised Privacy Policy. Your continued access to, or use of, the SwingCulture Services after any such changes constitutes your acceptance of the Privacy Policy as revised.

    16. Contacting SwingCulture

    If you have questions about this Privacy Policy, or if you want us to remove your information from our database, please contact us at: support@swingculture.com

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