Sway

Sway Privacy Notice

Last updated: April 15, 2025

This Privacy Notice describes how Sway Networks, Inc., d/b/a Sway (“we”, “us”, “our”) collects, uses and discloses information about you when you use our website (www.sway.app), applications, services, tools and features, or otherwise interact with us (collectively, the “Services”). For the purposes of this Privacy Notice, “you” and “your” means you as a Supporter, Leader, or other user of the Services.

Please read this Privacy Notice carefully. By using any of the Services, you agree to the collection, use, and disclosure of your information as described in this Privacy Notice. If you do not understand or agree to this Privacy Notice, please do not use or access the Services.

Table of Contents

1. CHANGES TO THIS PRIVACY NOTICE

We may modify this Privacy Notice from time to time, in which case we will update the “Last Updated” date at the top of this Privacy Notice. If we make material changes to how we use or disclose information we collect, we will use reasonable efforts to notify you as required by applicable law. If you do not agree to any updates to this Privacy Notice, please do not continue using or accessing the Services.

2. COLLECTION AND USE OF INFORMATION

When you use or access the Services, we collect certain categories of information about you from a variety of sources. In addition to the specific uses discussed below, we may use this information to provide and improve the Services and to maintain our business relationship, including by enhancing the safety and security of our Services, providing customer support, complying with applicable legal obligations, enforcing any applicable terms of service, and protecting our rights and the rights of our employees, users or other individuals.


Information You Provide to Us.

Some features of the Services may require you to directly provide certain information, including information about yourself. You may elect not to provide this information, but doing so may prevent you from creating issue pages, voting on issues, or otherwise using or accessing certain features. Information that you directly submit through our Services includes:

  • Basic contact details and identifiers, such as name, address, phone number, email address, date of birth, and state issued ID, that you provide when you sign up for the Services as a Leader or Supporter. We use this information to create and maintain your account, verify your identity and voter registration / eligibility status, and provide the Services, and to communicate with you (including to tell you about products or services that may be of interest to you).

  • Account information, such as username, password, and passkeys. We use this information to provide the Services (including so you can create issue pages and vote on issues) and to maintain and secure your account with us (including through two-factor authentication). If you choose to register an account, you are responsible for keeping your account credentials safe. We recommend you do not share your access details with anyone else. If you believe your account has been compromised, please contact us immediately.

  • Profile information, such as your name, organization, headline, and photo (should you choose to provide it). We use this information to provide the Services, including so you can create issue pages as a Leader and vote on issues as a Supporter.

  • User-content, such as [issue/topic preferences, personal stances or slogans, and other issue-related information], submitted by you when you create and populate issue pages as a Leader. We or others may store, display, reproduce, publish, or otherwise use such content, and may or may not attribute it to you. Others may also have access to such content and may have the ability to share it with third parties. For example, if you choose to create an issue page, the issue page may be shared and accessed by anyone with a link to the page, including us.

  • Your interactions with the Services, including how you choose to vote on an issue as a Supporter (should you choose to vote on an issue and provide this information).

  • Any other information you choose to include in communications with us, for example, when sending a message through the Services.


Information Collected Automatically.

We and third parties may also use cookies, pixels or other tracking technologies to automatically collect certain information about your interactions with the Services. This information is collected and used to tailor your experience with the Services, run analytics, better understand user interactions with the Services, etc. Such information includes:

  • Device information, such as device type, operating system, unique device identifier, and internet protocol (IP) address.

  • Location information, such as approximate location / precise geolocation, if you choose to provide it.

  • Other information regarding your interaction with the Services, such as browser type, log data, date and time stamps, clickstream data, interactions with marketing emails, and ad impressions.

Most browsers accept cookies automatically, but you may be able to control the way in which your devices permit the use of cookies. If you so choose, you may block or delete certain of our cookies from your browser; however, blocking or deleting cookies may cause some of the Services, including any portal features and general functionality, to work incorrectly.

Your browser settings may also allow you to transmit a “Do Not Track” signal when you visit various websites. Like many websites, our website is not designed to respond to “Do Not Track” signals received from browsers.


Information Collected From Other Sources.

We may obtain information about you from outside sources, including information that we collect directly from third parties and information from third parties that you choose to share with us. Such information includes:

  • Analytics data we receive from analytics providers such as Google Analytics and Sentry.

  • Information about whether you are registered / eligible to vote we receive from third-party providers such as TargetSmart.

  • Information we receive when you choose to link any social media platforms to your account, such as Facebook or X, which we use to maintain your account and login information.

Any information we receive from outside sources will be treated in accordance with this Privacy Notice. We are not responsible for the accuracy of the information provided to us by third parties and are not responsible for any third party’s policies or practices. For more information, see the section below, Third-Party Websites and Links.


Deidentified Information.

Finally, we may deidentify or anonymize your information such that it cannot reasonably be used to infer information about you or otherwise be linked to you (or we may collect information that has already been deidentified/anonymized), and we may use such deidentified/anonymized information for any purpose.

3. DISCLOSURE OF INFORMATION

We may disclose your information for legitimate purposes subject to this Privacy Notice, including the following categories of third parties:

  • Vendors or other service providers who help us provide the Services, including for system administration, authentication, voter verification, ballot information, cloud storage and database provision, security, customer relationship management, and web analytics.

  • Third parties to whom you request or direct us to disclose information, such as through your use of social media widgets or login integration.

  • Professional advisors, such as auditors, law firms, or accounting firms.

  • Third parties in connection with or anticipation of an asset sale, merger, bankruptcy, or other business transaction.

We may also disclose your information as needed to comply with applicable law or any obligations thereunder or to cooperate with law enforcement, judicial orders, and regulatory inquiries, to enforce any applicable terms of service, and to ensure the safety and security of our business, employees, and users.

4. SOCIAL FEATURES

Certain features of the Services allow you to initiate interactions between the Services and third-party services or platforms, such as social networks (“Social Features”). Social Features may include features that allow you to access our pages on third-party platforms, and from there to “like” or “share” our content. Use of Social Features may allow a third party to collect and/or use your information. If you use Social Features, information you post or make accessible may be publicly displayed by the third-party service. Both we and the third party may have access to information about you and your use of both the Services and the third-party service. For more information, see the section, Third-Party Websites and Links.

5. THIRD-PARTY WEBSITES AND LINKS

We may provide links to third-party websites or platforms. If you follow links to sites or platforms that we do not control and are not affiliated with us, you should review the applicable privacy notice, policies and other terms. We are not responsible for the privacy or security of, or information found on, these sites or platforms. Information you provide on public or semi-public venues, such as third-party social networking platforms, may also be viewable by other users of the Services and/or users of those third-party platforms without limitation as to its use. Our inclusion of such links does not, by itself, imply any endorsement of the content on such platforms or of their owners or operators.

6. DATA SECURITY AND RETENTION

Despite our reasonable efforts to protect your information, no security measures are impenetrable, and we cannot guarantee “perfect security.” Any information you send to us electronically, while using the Services or otherwise interacting with us, may not be secure while in transit. We recommend that you do not use unsecure channels to send us sensitive or confidential information.
We retain your information for as long as is reasonably necessary for the purposes specified in this Privacy Notice. When determining the length of time to retain your information, we consider various criteria, including whether we need the information to continue to provide you the Services, resolve a dispute, enforce our contractual agreements, prevent harm, promote safety, security and integrity, or protect ourselves, including our rights, property or products.

7. PRIVACY RIGHTS

California residents under the age of 18 who have registered to use the Services and have posted content or information on the Services can request that such information be removed from the Services by contacting us at the email address below. Such request must state that the California resident personally posted such content or information and detail where the content or information is posted. We will make reasonable good faith efforts to remove the post or content from prospective public view or anonymize it so the minor cannot be individually identified. This removal process cannot ensure complete or comprehensive removal. For instance, third parties may have republished the post, and archived copies of it may be stored by search engines and others that we do not control.

8. HOW TO CONTACT US

Should you have any questions about our privacy practices or this Privacy Notice, please email us at privacy@sway.app