Last updated on January 31st, 2025.
https://www.swaddle.info (the “Website”) and the Swaddle Mobile Application (“App”) are operated by Swaddle Inc. Throughout this privacy policy (the “Privacy Policy”), the terms “Swaddle”, “we”, “us” and “our” refer to Swaddle Inc. This Privacy Policy applies to the Website and the App.
Swaddle is the controller of your personal information, and is responsible for the collection, processing and disclosure of your personal information as described in this Privacy Policy, unless expressly specified otherwise. If you have any questions about this Privacy Policy or want to exercise your rights hereunder, please write to us at contact@swaddle.info
Swaddle is committed to protecting and respecting your privacy, and will only use any personal information submitted in conformity with all applicable laws and regulations, and in accordance with this Privacy Policy.
We reserve the right to modify this Privacy Policy at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on our Website and App. If we make material changes to this Privacy Policy, we will notify you that it has been updated, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
By continuing to use our Website or App, you agree to the revised Privacy Policy to the fullest extent permitted by applicable law.
1. Processing Activities Covered
This Privacy Policy applies to the following processing activities:
- Visiting our Website and accessing our Website or the App, which display or link through to this Privacy Policy;
- Creating an account on the App;
- Requesting, purchasing and/or using services on the Website or the App;
- Communicating with us to report a problem or to submit queries, concerns or comments regarding the Website or the App;
- Communicating with us via the Website, the App, email, social media, Swaddle’s AI Chatbot, text message and/or phone call;
- Receiving email communications from us;
- Receiving SMS text messages from us;
- Receiving push notifications from us.
2. Personal Information We Collect
We only collect the personal information that is necessary to carry out our business, provide the services you requested and keep you informed of the latest news about us and our services.
Subject to certain exceptions and limitations, personal information is any information which relates to a natural person and directly or indirectly allows that person to be identified.
The personal information that we collect directly from you may include the following:
- Personal identifiers, which may include, without limitation, your email address, name, gender, ethnicity, marital status, job title, address, telephone number, social insurance number, medicare number and picture, passport number and picture, driver’s license number and picture, credit card number, debit card number, or any other financial information;
- Commercial information, which may include your billing information and purchase history;
- Internet or other electronic network activity information, which may include, without limitation, browsing history, search history, and information regarding interaction with an internet website, application or advertisement;
- Geolocation data, which may include, without limitation, current and historical physical location including the country, state, city, zip code, address and/or location over time; and
- Inferences we make, which may include your likelihood of retention.
3. Personal Information of Children
We understand the importance of protecting children’s privacy online. The Website and App are not intended for use by children under the age of 14 without the consent of their parent or legal guardian. If we learn that we have collected personal information from someone under the age of 14, we will delete that information as quickly as possible. If you believe we have collected information from your child in error or have questions or concerns about our practices relating to children, please notify us, and we will promptly respond.
We do collect information about children under the age of 14 from their parents, guardians, and/or caregivers. The personal information collected from you regarding a child in your care may include:
- Their name, gender and address;
- Their social insurance number, social security number, medicare number and passport number
- Their medical history, including but not limited to any dietary restrictions, medications, serious allergies, or physical, developmental and/or learning disabilities.
- Information concerning their education, including but not limited to the name of the educational institution the child frequents, their grade level, their grades and behavioral reports.
4. Device and Usage Data
We use common information-gathering tools, such as log files, cookies, web beacons, and similar technologies to automatically collect information, which may contain personal information, from your computer or mobile device as you navigate our Website or App or interact with emails we have sent to you.
As is true of most websites and mobile applications, we gather certain information automatically via log files. This collected information may include your Internet Protocol (IP) address (or proxy server), device and application identification numbers, your location, your browser type, your Internet service provider and/or mobile carrier, the pages and files you viewed, your searches, your operating system and system configuration information, and date/time stamps associated with your usage.
This information is used to comply with data contracts, treaties, national laws, and regulations, analyze overall trends to help us provide and improve our Website and App, and to guarantee their security and continued proper functioning. We also collect IP addresses from users when they log into the services as part of the Website’s and App’s security features.
We use cookies and similar technologies such as web beacons, tags, and Javascript alone or in conjunction with cookies to compile information about usage of our Website and App, and interaction with emails from us.
When you visit our Website or use our App, our servers or an authorized third party may place a cookie on your browser, which can collect information, including personal information, about your online activities over time and across different sites. Cookies help us ensure our Website and App are not misused by bots and prevent account login information sharing.
We use both session-based and persistent cookies. Session cookies exist only during one session and disappear from your computer or device when you close your browser software or turn off your computer. Persistent cookies remain on your computer or device after you close your browser or turn off your computer or device. Most web and mobile device browsers automatically accept cookies but, if you prefer, you can change your browser to prevent that or to notify you each time a cookie is set by using the opt-out tool at https://optout.networkadvertising.org/. You can also learn more about cookies by visiting https://allaboutcookies.org/, which includes additional useful information on cookies and how to block cookies using different types of browsers or mobile devices. Please note, however, that by blocking or deleting cookies used by us, you may not be able to take full advantage of the Website or App. We partner with a third-party ad network to either display advertising on our Website or App or to manage our advertising on other sites. Our ad network partner uses cookies and Web beacons to collect non-personal information about your activities on the Website and App and other websites to provide you targeted advertising based upon your interests, which is called online behavioural advertising. If you wish to not have this information used for the purpose of serving you targeted ads, you may opt-out by using the specific opt-out mechanism at https://optout.networkadvertising.org/. Please note this does not opt you out of being served advertising. You will continue to receive generic ads.
Some Internet browsers may be configured to send “Do Not Track” signals to the online services that you visit. There is no consensus among industry participants as to what “Do Not Track” means in this context. Like many websites and online services, Swaddle does not currently alter our practices when we receive a “Do Not Track” signal from a visitor’s browser except as specifically required by law. For information about “do not track” from The Future of Privacy Forum, click here.
5. Third Parties and Social Media Features
Third parties with whom we work may also provide us with information about you. We may combine the information you have given to us with additional information made available by external sources. For example, depending on your settings or the privacy policies for social media and messaging services like Facebook or Instagram, you may give us permission to access information from those accounts or services. Please verify the privacy policies of these third parties before submitting your personal information to them.
Conversely, Swaddle may use social media features, such as the Facebook and Instagram “like” button and other sharing widgets (“Social Media Features”). You may be given the option by such Social Media Features to post information about your activities on a website to a profile page of yours that is provided by a third-party social media network in order to share with others within your network. Social Media Features are either hosted by the respective social media network or hosted directly on our website. To the extent the Social Media Features are hosted by the respective social media networks, the latter may receive information that you have visited our Website or used our App from your IP address. If you are logged into your social media account, it is possible that the respective social media network can link your visit of our website with your social media profile. Your interactions with Social Media Features are governed by the privacy policies of the companies providing the relevant Social Media Features.
This Privacy Policy only addresses the collection, use and disclosure of personal information by Swaddle. Other websites that may be accessible through Swaddle’s Website or App have their own privacy policies and data collection, use and disclosure practices. We encourage you to familiarize yourself with the privacy statements provided by all third parties prior to providing them with information or taking advantage of an offer or promotion.
6. SMS Text Program
We operate a text message program (“Text Program”) as it is necessary to keep you informed of your bookings and allow us to provide the services requested by you. The Text Program is subject to this Privacy Policy, as applicable.
By opting into the Text Program, you consent to be sent periodic text messages to the telephone number you provided. By providing a telephone number to us, you confirm that you have the authority to grant us the right to send text messages to that telephone number.
You may opt out of receiving messages at any time by replying “STOP” to any message you receive. After this, you will no longer receive messages. Please note that opting out of the Text Program may result in you not receiving notifications regarding your bookings in a timely manner and prevent us from delivering our services to you. You understand and acknowledge that you are solely responsible for any consequences, outcomes or losses resulting from your opting out of the Text Program. You can receive assistance or obtain more information at any time by contacting us at contact@swaddle.info
While the Text Program is free, your wireless carrier’s normal messaging, data and other fees may apply. Swaddle is not liable for delayed or undelivered messages. Please contact your wireless carrier for information about your messaging plan.
7. Push Notifications
We may display push notifications on your mobile device to keep you informed of your bookings and allow us to provide the services requested by you.
You may, in most cases, opt out of receiving push notifications by going to your device “Settings” and clicking on “Notifications,” and then changing the settings for the App. Different device configurations or updates to devices may affect or change how these settings work. Please note, however, that by opting out of receiving push notifications, you may not be able to take full advantage of the App or receive updates regarding your booking and other services you requested in a timely manner. Your choice to opt-out will not affect notifications placed by any other organization.
8. Purposes and Legal Basis
We collect and process your personal information for the purposes and on the legal basis identified below:
- Providing our services and performing contracts: We use your personal information to enable us to operate and administer our Website and the App and to perform any contract with you for the services you request or provide according to any applicable terms of service. This includes sending you SMS updates with regard to your request for our service, to the extent you have provided your consent;
- Managing user registrations: We will process your personal information by managing your user account for the purpose of performing the contract with you according to any applicable terms of service, and relevant national laws and regulations;
- Handling contact and user support requests: If you contact us by any available means, we will process your personal information to the extent it is necessary to fulfill your request and communicate with you;
- Developing and improving our Website, App and services: We will process your personal information to analyze trends and track your usage of our Website and App, and interactions with emails to the extent this is necessary for us to develop and improve our Website and App, conduct market research, and provide our users with more relevant content;
- Sending communications: We will process your personal information to send you the latest updates about us, including information about our services, to the extent you have provided your prior separate consent by email or SMS text message to the extent you have provided your prior separate consent;
- Complying with legal obligations: We will process your personal information when cooperating with public and government authorities, courts, or regulators in accordance with our legal obligations under applicable laws to the extent this requires the processing or disclosure of personal information to protect our rights, and is necessary for our legitimate interests to protect against misuse or abuse of data hosted on our Website and App, our data, our Website, our App, to protect personal property or safety, to pursue remedies available to us and limit our damages, to comply with judicial proceedings, court order, or legal process, and/or to respond to lawful requests. Where we need to collect and process personal information by law, or under a contract we have entered into with you and you fail to provide that required personal information when requested, we may not be able to perform the contract.
9. Service Providers
Your personal information may be collected, transferred to, and stored by us in the United States of America. We will use reasonable means to ensure that personal information is protected regardless of where your personal information may be located.
We may transfer personal information to non-affiliated service providers in providing the services, such as IT and system administration and hosting, research and analytics, marketing, account management, technical operations, credit card processing and email service providers to send out emails on our behalf, pursuant to agreements that prohibit the service providers from using or disclosing the personal information other than for the purpose of processing and which impose security safeguards appropriate to the sensitivity of the information.
The names, addresses and contact information of our contracted service providers are reproduced below:
| Service Providers | Contact Information |
|---|---|
| Agora (Video conference calls with Swaddlers) | Agora Lab, Inc. privacy@agora.io 2804 Mission College Blvd. Santa Clara, CA, USA 95054 |
| Amazon Cloud Services (Hosting) | Amazon Web Services Canada, Inc. https://aws.amazon.com/contact-us/ 120 Bremner Blvd 26th Floor, Toronto, ON M5J 0A1, Canada |
| Firebase (Backend Cloud Computing) | Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA |
| Google Analytics (Website analytics) | Google LLC 1600 Amphitheatre Parkway Mountain View, CA 94043, USA |
| Stripe (Payment processing) | Stripe Inc. 510 Townsend Street San Francisco, CA 94103, USA Attention: Stripe Legal privacy@stripe.com. |
| Trustii (Identity verification) | Trustii Technologies Inc. Trustii Privacy Officer privacy@trustii.co 465 McGill St. #700 Montréal, Québec, H2Y 1H1 |
| Twilio (Video conference calls with Swaddlers) | Twilio Inc. Data Protection Officer privacy@twilio.com 101 Spear Street, 5th Floor San Francisco CA 94105 |
We may disclose aggregate statistics about our users in order to describe our business to prospective partners, advertisers, sponsors and other reputable third parties and for other lawful purposes, but these statistics will be anonymized and include no personally identifiable information. We may disclose your personal information to any of our affiliates (including but not limited to Swaddle LLC, a Delaware limited liability company), or to our agents or contractors who assist us in providing our services, processing transactions, receiving and sending communications, updating marketing lists, analyzing data, providing IT and other support services, or in other tasks, from time to time. Our agents and contractors will only use your information to the extent necessary to perform their functions. In the event of a sale of all or substantially all of our business or another similar transaction, we may transfer or disclose your personal information to a purchaser or prospective purchaser, who may collect, use and disclose such information for the purposes of evaluating the proposed transaction or operating and managing the affairs of the acquired business, or for other purposes identified in this Privacy Policy.
We reserve the right to disclose your personal information as required by law, and as necessary to protect the property, interests and rights of Swaddle.
In individual cases, we may also share personal information with professional advisers acting as processors or joint controllers including lawyers, bankers, auditors, and insurers based in countries in which we operate, who provide consultancy, banking, legal, insurance, and accounting services.
10. Retention of Personal Information
We will keep your personal information only as long as is reasonably necessary for the time consistent with the original purpose of collection or such longer period as may be required by applicable law. We determine the appropriate retention period for personal information on the basis of the amount, nature, and sensitivity of your personal information, the potential risk of harm from unauthorized use or disclosure, and whether we can achieve the purposes of the processing through other means. Personal information that is no longer required to fulfil the identified purposes will be promptly and securely destroyed, erased, or made anonymous.
11. Your Access and Control Over Your Personal Information
You may exercise any of the rights described below by contacting us at contact@swaddle.info. Please note that we may ask you to verify your identity before taking further action on your request. The verification methods we use may include requests to disclose your first name, last name, email address, location information, security question answer and other information. We will process your request within thirty (30) days of receipt.
a) Managing Your Information
You are responsible for keeping your personal information up-to-date. You can also ask us to correct inaccurate or incomplete personal information concerning you that you cannot update yourself.
b) Access to Your Information
You have the right to request information about the personal information we hold on you at any time. You can contact us via email at contact@swaddle.info and we will provide you with your personal information via email. If you require additional copies, we may need to charge a reasonable fee.
c) Right to Erasure
If you no longer want us to use your information to provide you with the latest news about our services and/or other helpful information, you can request that we erase your personal information by contacting us at contact@swaddle.info
Please note, however, that we may retain some of your personal information as necessary for our legitimate interests, such as fraud detection and enhancing security. We may also retain and use your personal information to the extent necessary to comply with our legal obligations, such as keeping information for tax, legal reporting and auditing obligations, as well as professional obligations. Information you have shared with others (e.g. comments, community postings) may continue to be publicly visible. Additionally, some copies of your information (e.g. log records) may remain in our database, but are disassociated from personal identifiers. Residual copies may also be kept in our backup systems. If we have shared your personal information with service providers, we will let them know about the erasure where possible.
d) Right to Object to Direct Marketing
If we rely on your consent as our legal basis for processing your personal information, you have the right to withdraw that consent at any time. If you have already given your consent but you prefer not to receive promotional information from us, you may unsubscribe by using the unsubscribe link situated at the bottom of any promotional message you receive from us, or by contacting us at contact@swaddle.info
To the best of its knowledge, Swaddle is in material compliance with applicable anti-spam Laws, including the Canadian Anti-Spam Law.
e) Restriction of Processing
You can ask us to block or suppress the processing of your personal information in certain circumstances, such as where you contest the accuracy of that personal information or you object to us processing it, and we have no legitimate grounds that override yours. Such request alone does not stop us from storing your personal information.
f) Right to Portability
Whenever we process your personal information by automated means based on your consent or based on an agreement, you have the right to get a copy of your personal information transferred to you or to another party. This only includes the personal information you have provided to us.
g) Automated Decision-Making
You have the right to elect not to be subject to a decision based solely on automated processing, including profiling (“Automated Decision-Making“). Our Website and App do not currently use Automated Decision-Making.
h) Consent Withdrawal
To the extent we base the collection, processing, and sharing of your personal information on your consent, you have the right to withdraw your consent at any time, without affecting the lawfulness of the processing based on such consent before its withdrawal.
k) Questions or Complaints
If you have any queries or would like to make any complaint in relation to this Privacy Policy and our privacy practices, you may contact us by email at contact@swaddle.info or at the following address:
SWADDLE INC. PRIVACY OFFICER
237 rue Baffin, Dollard-des-Ormeaux (Québec) H9G 2X4, Canada.
If, however, you believe that we have not been able to assist with your complaint or concern, you have the right to lodge a complaint with the competent supervisory authority.
12. Personal Information Security
We take reasonable precautions to ensure the protection of personal information collected, used or disclosed by us using appropriate physical, organizational and technological measures. We use industry-standard encryption technologies to receive sensitive data submitted by you on our Website and App.
In case of a personal data breach that is likely to result in a high risk to your rights and freedoms, we will notify you and the proper authority as soon as feasible following becoming aware of the breach and without undue delay. Notification may be delayed where requested by law
enforcement for the purpose of an active criminal investigation, but notification will still be provided in the most expedient time and manner possible subject to the circumstances. While we follow generally accepted standards to protect personal information, no method of storage or transmission is 100% secure. If you have any questions about the security of our Website or App, please contact us using the contact information in the “Questions or Complaints” section above.
