Privacy Policy

Last Updated: December 28, 2024

Swirly Sky Ventures LLC is committed to safeguarding your personal information and ensuring your privacy rights are respected. For inquiries or concerns about this policy or our data practices, please reach us through our Contact Us page here.

This Privacy Policy outlines the types of personal information Swirly Sky Ventures LLC and its affiliated businesses collect from you or your devices when you engage with our website, email communications, or related platforms. It explains how your information is used, shared, and the options available for controlling its use.

This Privacy Policy governs the privacy policies and practices of Swirly Sky Ventures LLC and its affiliated businesses and organizations (collectively, “Swirly Sky Ventures,” “we,” or “us”). It applies to all activities, offerings, and features provided by Swirly Sky Ventures LLC through our website (swirlyskyventures.com) and any related platforms, as well as any affiliated businesses or ventures that may operate under the Swirly Sky Ventures LLC group. These may include, but are not limited to, creative projects, content platforms, marketing activities, and product sales.

Affiliated Businesses:

Swirly Sky Ventures LLC operates as part of a group of businesses and ventures that may be owned, operated, or controlled by Swirly Sky Ventures LLC. These affiliated businesses may provide additional content, services, or products related to the Swirly Sky Ventures brand. Personal information collected by Swirly Sky Ventures LLC may be shared with its affiliated businesses to provide integrated services and features, subject to the terms of this Privacy Policy unless a separate privacy policy is provided by the affiliated business.

Third-Party Websites and Services:

Swirly Sky Ventures LLC is not responsible for the privacy practices of any third-party websites, applications, platforms, or services. This Privacy Policy does not govern third-party websites, applications, platforms, or services that may link to or from Swirly Sky Ventures LLC or its affiliated businesses. We encourage you to review the privacy policies of any third-party services to understand how they collect, use, and protect your personal information.

Table of Contents

• Personal Information Collected Through Our Services
• How We Use the Personal Information We Collect
• How We Disclose Personal Information
• Privacy Rights and Choices
• Security
• Children’s Privacy
• Retention of Personal Information
• Links to and from Other Sites and Services
• Job Applicants
• Changes to This Privacy Policy
• International Data Transfers
• How to Contact Us

Personal Information Collected Through Our Services

Information You Provide

We and our service providers, acting solely on our behalf, may collect personal information that you voluntarily provide when engaging in activities such as:

• Registering for an account, email newsletter, or updates provided by Swirly Sky Ventures.
• Signing up for events, tours, contests, giveaways, or sweepstakes we sponsor.
• Contacting us via email, message, or other communication tools.
• Participating in surveys or feedback sessions.
• Making a purchase of products or services through our website or affiliated platforms.
• Submitting user-generated content, such as comments, photos, essays, or other materials, to Swirly Sky Ventures.
• Applying for a job, internship, or collaboration opportunity with Swirly Sky Ventures LLC.
• Expressing interest in or completing a financial transaction for Swirly Sky Ventures’ offerings.
• Volunteering information to us or responding to requests for information through our website or platforms.

We may also request additional information for specific purposes, such as identity verification or compliance with legal obligations, which will be disclosed at the time of collection.

When you engage with our offerings, you may provide the following types of personal information:

• Contact details, profile, and account information: Your name, email address, postal address, telephone number, password, age, country of residence, and other details required for account setup or communication purposes.
• Payment information: Payment details, such as credit card numbers, billing addresses, and other transaction-related information. Payment details, such as credit card numbers, are securely processed by our payment providers. Swirly Sky Ventures only retains transaction identifiers, like the last four digits of your card.
• Communications and content preferences: Information you provide when contacting us with questions, feedback, or other communications, or when registering for newsletters or updates.
• Marketing data: Your preferences for receiving promotional communications, updates, or newsletters, and engagement details (e.g., email opens and clicks).
• Job applicant data: Employment history, educational background, and other information provided when applying for roles at Swirly Sky Ventures LLC.
• Event data: Information related to event registration, ticket purchases, or visitor screening (where applicable).
• Survey data: Information provided in surveys or polls, which may include demographic details like age, gender, employment, education level, geographic location, and other optional information. Where required by law, we will only process this data with your explicit consent.
• Contest data: Information submitted as part of contests, giveaways, or sweepstakes, including information about individuals involved in the submission or preparation of the entry.
• User-generated content: Materials such as comments, feedback, photos, or other content you upload or post through Swirly Sky Ventures’ website or platforms.
• Donation data: If you make a donation or financial contribution, we may collect and retain records of your name, contact information, donation amount, and related data, in accordance with this Privacy Policy.
• Other data: Any additional information you voluntarily provide, including unique cases such as custom submissions or special requests, which will only be used as outlined in this Privacy Policy or disclosed at the time of collection.

As a visitor to our website, you are not required to provide personal information. However, we collect information you choose to provide through activities such as signing up for newsletters, contacting us, making purchases, participating in surveys or contests, submitting user-generated content, or applying for opportunities with us.

Information Automatically Collected Through Technology

For visitors from jurisdictions requiring consent (e.g., EEA, UK, California), we obtain explicit consent before collecting data through cookies and similar technologies. Visitors can manage their cookie preferences using our cookie banner by clicking the cookie icon in the bottom-left corner of the webpage or via browser settings.

Subject to your cookie consent settings, we, along with our service providers and vendors, may automatically collect certain information about your computer or device and interactions with Swirly Sky Ventures through access logs, cookies, pixel tags, and other tracking technologies.

Depending on your interactions with our website and platforms, the information collected automatically may include:

• Internet Protocol (IP) Address: The IP address of your computer or device used to access our website or interact with our platforms.
• Domain Information: Details about your Internet Service Provider and associated domain.
• Referring and Exit Pages: The website, application, platform, or service you visited before and after accessing Swirly Sky Ventures.
• Search Terms: Search terms entered on our website or through a referring website.
• Geographic Location: Your approximate geographic location (derived from your IP address). More precise location data may be collected with your explicit consent where required by applicable law.
• Device Information: The make, model, carrier, and unique device identifier for your device, as well as information about your browser, operating system, settings, and software. For example, mobile advertising identifiers, such as Google Advertising ID or Apple IDFA, may be collected where you have consented.
• Interaction Details: Information about the dates, times, duration, and frequency of your interactions with our website and platforms.
• Navigation Path: Your navigation path through our website, including pages visited, content viewed, and patterns in your interactions.
• Download Data: Information about files you download, share, or interact with on our platforms.
• Time Spent: The amount of time spent on specific media files, pages, or other content.
• Error Logs: Information about any errors encountered during your use of our website or platforms.

Analytics and Tracking Technologies

We utilize third-party services, such as analytics and advertising platforms, to better understand user behavior and improve our website’s functionality and content. These services include but are not limited to:

• Google Analytics: Used to track and report website traffic, user interactions, and engagement. Google Analytics may use cookies, pixel tags, and similar technologies to collect and analyze data about your use of our website and provide insights into audience behavior. This data may be shared with other Google services, and Google may use the collected data to contextualize and personalize ads within its advertising network. Under CCPA, certain uses of Google Analytics may qualify as the ‘sale’ of personal information. Visitors can opt out by managing their cookie preferences. To learn more about how Google uses data, visit Google Privacy Policy.
• Cookies and Pixels: We use cookies, including first-party cookies (e.g., Google Analytics cookies) and third-party cookies (e.g., Remarketing with Google Analytics), to track and analyze user behavior, optimize content delivery, and serve targeted advertisements. These technologies may also be used to inform sponsorship credits and marketing messages based on your previous interactions with our website or other services.
• Affiliate Marketing Analytics: For certain affiliate marketing relationships, such as links to online retailers, we may use cookies to uniquely identify users who click on marketing messages or links within our content and later purchase related products or services on the third-party site. These cookies are used to measure the performance of marketing efforts and to calculate commissions.
• Aggregated Analytics Data: We may use geographic, demographic, and interest-based reporting to understand user preferences, improve content, and inform operational decisions.

Consent and Opt-Out Options

You can manage your consent preferences and opt out of certain tracking technologies:

• Cookie Consent Banner: Our cookie consent banner allows you to accept all cookies, reject non-essential cookies, or customize preferences for specific categories. We use cookies and similar tracking technologies to enhance your experience and analyze usage. Cookies are categorized as follows:
  • Essential Cookies: Necessary for website functionality.
  • Analytics Cookies: Help us understand user interactions to improve our services.
  • Advertising Cookies: Used to deliver personalized ads.
  • Consent: For visitors from the EEA, UK, or other jurisdictions requiring consent, our cookie banner allows you to accept or reject non-essential cookies. You can manage your preferences at any time through the cookie consent icon. To revisit your cookie consent preferences, click the cookie icon in the bottom-left corner of the webpage.
• Cookie Settings: Most browsers allow you to manage cookie settings or disable cookies entirely. Please note that disabling cookies may limit certain website functionality.
• Interest-Based Ads: To opt out of interest-based advertising and tracking, adjust your browser or device settings. Most browsers (e.g., Chrome, Firefox, Safari) allow you to block third-party cookies or enable ‘Do Not Track’ (DNT) requests. While our website does not currently respond to DNT signals, you can manage tracking preferences through the cookie consent banner or your browser/device settings.
• Modify Device Settings: On mobile devices, you can turn off ad tracking:
  • For iOS devices: Go to Settings > Privacy > Tracking and disable “Allow Apps to Request to Track.”
  • For Android devices: Go to Settings > Google > Ads and enable “Opt Out of Ads Personalization.”

What Happens After You Opt Out?

After opting out, you will still see ads online, but they will be generic or contextually relevant based on the content you visit.

Information We Obtain From Other Sources

Platform and Third-Party Single Sign-On Tools
Our services allow users to sign in using credentials from platforms such as Apple, Facebook, and Google, or from other partner organizations (each an “SSO Provider”). If you sign in through an SSO Provider, we may receive your email address and certain profile information from that SSO Provider based on their privacy policy and your account settings. The specific information collected will depend on the privacy settings you have configured with your SSO Provider. You can adjust these permissions through the settings provided by the SSO Provider. Please review the privacy policies and data settings of your chosen SSO Provider to understand what information may be shared. Similarly, if you use tools on our services that allow you to share content (e.g., stories, articles, or media) with your social media accounts or other platforms, the shared information will be subject to the privacy policies of those platforms.

Partner Organizations
Swirly Sky Ventures may obtain personal information from partner organizations to provide services on their behalf in accordance with their privacy policies or to deliver services to you as otherwise described in this Privacy Policy.

Other Third Parties
We may also obtain personal information from other third-party sources, such as marketing vendors, event organizers, publicly available databases, media partners, and data providers. The information collected from these sources will be handled in accordance with this Privacy Policy and used solely for purposes consistent with the scope of this document.

How We Use the Personal Information We Collect

We and our service providers and vendors collect and use personal information to provide you with a customized, interactive experience and to make our services more useful to you.

Swirly Sky Ventures LLC and its service providers and vendors may use the information collected through our services for the following purposes:

To Perform Contractual Obligations Under Our Terms of Use:

• To manage, administer, and deliver Swirly Sky Ventures services.
• To publish, broadcast, attribute, and otherwise use and license any user-generated materials you submit in accordance with our Terms of Use.
• To fulfill your product or service orders and other requests.
• To provide you with access to events, giveaways, or sweepstakes hosted by Swirly Sky Ventures.
• To manage contests, giveaways, and other promotional activities you choose to enter.

To Perform Legitimate Business Interests:

• To respond to your questions or messages.
• To provide you with personalized features and content based on your preferences and interactions with our website and platforms. For example, we may track your engagement with specific pages, resources, or products to better understand your interests and improve your user experience.
• To save and “remember” your registration information, settings, and preferences so you do not need to re-enter this information each time you visit our website or use our platforms.
• To analyze whether and when you read our email messages and click on links in those messages, allowing us to improve the effectiveness of our communications.
• To improve Swirly Sky Ventures’ offerings, platforms, and overall user experience.
• To process applications for job opportunities, collaborations, or partnerships with Swirly Sky Ventures.
• To contact you for surveys or other feedback opportunities, and to process your responses where applicable.
• To generate aggregated or anonymized data that is not reasonably linkable to you or your devices. This data may be used to improve our offerings, analyze trends, or create customized content. For example, we may work with service providers or vendors who assist in analyzing and improving our platforms or help us measure engagement with our content.

To Perform Marketing, Sponsorship, Analytics, and Operational Purposes:

We, our service providers, and our third-party sponsorship or marketing vendors may collect and use personal information for the following purposes, based on our legitimate business interests or your consent where required by law:

• To provide personalized, “interest-based,” or “cross-contextual” sponsorship credits and marketing messages tailored to your preferences and interactions.
• To recognize you as the same user across multiple devices, browsers, or platforms and deliver consistent content, marketing messages, and sponsorship credits.
• To send you newsletters and other communications, including promotional updates, marketing materials, and event-related information from Swirly Sky Ventures or its affiliated businesses.
• To manage the sequence and frequency of marketing messages and sponsorship credits you view or hear, ensuring a tailored and relevant experience based on your perceived interests.
• To conduct market or audience analysis, including attribution and conversion analysis, to evaluate the effectiveness of sponsorship credits, promotional campaigns, and other marketing messages.
• To measure and analyze user traffic, engagement, and usage patterns, enabling us to improve the quality and effectiveness of our content, marketing efforts, and overall platform experience.

For Perform Compliance and Protection Purposes:

Where we seek your consent, you may withdraw your consent at any time.

We use personal information for compliance and protection purposes based on our legitimate business interests, including the following:

• To prevent prohibited or illegal activities, comply with applicable laws, respond to lawful requests and legal processes, such as subpoenas or requests from government authorities.
• To enforce our Terms of Use and protect our legal rights.
• To safeguard the rights, privacy, safety, or property of Swirly Sky Ventures, its users, or others, including by initiating or defending legal claims.
• To audit internal processes and ensure compliance with legal, contractual, and policy obligations.

How We Disclose Personal Information

Swirly Sky Ventures is committed to maintaining your trust. We want you to understand when and with whom we and our service providers or vendors may share personal information about you that is collected through our platforms.

Swirly Sky Ventures LLC does not sell personal information, as defined under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA). If this practice changes in the future, we will update this Privacy Policy and provide you with appropriate opt-out options, as required by law.

The Public or Other Individuals
Any user-generated materials you submit through our contact forms, social media services, or similar features can be seen, collected, and used by us, as well as by others who have access to the applicable service. These materials may also be freely used and shared by Swirly Sky Ventures and its affiliated entities in accordance with our Terms of Use.

You may also choose to share content, such as stories or materials, with your friends and followers on social media platforms. If you use our platforms to email or text content to others, we may disclose your name to that person, along with the content you have directed us to send.

Affiliated Entities
Swirly Sky Ventures may share your name, email address, and other contact information, as well as details about your interactions, purchases, or preferences, with affiliated businesses or projects within the Swirly Sky Ventures group. These entities may use this information to provide integrated services, fulfill orders, or send you updates, newsletters, or promotional materials relevant to their specific offerings. When sharing information with affiliated entities, we ensure they adhere to similar policies regarding the use and protection of your personal information as outlined in this Privacy Policy. Such data sharing will be conducted only where it complies with applicable laws, and where required, your consent will be obtained.

Authorized Service Providers
We may share the personal information we collect with authorized service providers who help us operate and improve our platforms, provide customer support, and deliver our offerings. This includes, but is not limited to:

• Customer support services.
• Email deployment and subscription management.
• Account sign-in and authentication services.
• Payment processing and order fulfillment.
• Analytics and marketing tools.
• Sponsorship management and promotional services.
• Contest, giveaway, or sweepstakes management.

Sponsorship and Marketing Vendors

Subject to applicable law and your opt-out choices, and as we deem appropriate, we may share information with sponsorship and marketing vendors, including those who provide digital sponsorship credits and marketing messages for us, or allow them to directly collect information about your devices and your use of our Services. These vendors may use such information pursuant to their own respective privacy policies, which we do not control.

• Vendor Analysis and Improvement:
  We may share or authorize the collection of information by vendors that help us analyze and improve our Services, including sponsorship credits and marketing messages within our platforms. These vendors may also tailor sponsorship credits and marketing messages to your perceived interests by sharing information with other third parties, such as supply-side platforms or demand-side platforms working with us and sponsors.
• Performance Measurement for Marketing Campaigns:
  We work with third-party analytics services to set tracking cookies or pixels on browsers of users who click on marketing messages, or users who click on links to online retailers for merchandise, including affiliate marketing links. This tracking measures the performance of these marketing messages and helps calculate commissions when a purchase is made through such links.

Payment Processors
If you make a payment or receive a refund through our Services, your information will be collected and controlled by the payment processor, not by Swirly Sky Ventures LLC. The processing of this information will be subject to the payment service provider’s privacy policy and practices. We encourage you to review their policies to understand how your data is handled.

Professional Advisors
We may share your information with professional advisors such as lawyers, auditors, bankers, and insurers, as necessary, during the course of the professional services they provide to us.

Authorized Third-Party Applications
We may share information that you provide directly through our platforms or that is automatically collected, with your consent, by authorized third-party applications to deliver specific services or features. This information may include your name and other interaction data, such as usage or engagement activity.

Your use of third-party applications is subject to their respective privacy policies. Swirly Sky Ventures LLC is not responsible for the privacy practices of any third-party applications, platforms, or services. We recommend that you review their privacy policies to understand how your data is handled.

Business Transfers
In the event of a significant corporate transaction, such as the sale of Swirly Sky Ventures LLC, a merger, consolidation, asset sale, or in the unlikely event of bankruptcy, your information may be transferred as part of that transaction.

Legal Requirements
Swirly Sky Ventures LLC, along with service providers and vendors, may disclose collected information to comply with legal obligations. This may include responding to subpoenas, court orders, or other lawful requests from authorities, or as required to adhere to applicable laws and regulations.

Protect Our Services and Users
We, along with service providers and vendors, may disclose collected information to enforce our Terms of Use and to protect and defend the legal rights, interests, and safety of Swirly Sky Ventures LLC, its affiliated businesses, employees, agents, contractors, sponsors, users, members of the general public, or others.

Wireless Carriers and Automobile Manufacturers
Wireless carriers and automobile manufacturers may collect contact information, precise location data, and other details from users of our mobile services through processes that we do not control. We encourage you to review the privacy policies of your wireless carriers and automobile manufacturers for further information about their practices.

Content Producers
We may share aggregated or anonymized usage and interaction data with third-party content producers related to your engagement with their media files, such as podcasts or videos, that are distributed or linked through Swirly Sky Ventures platforms. This data will not personally identify you.

URL Shortening Services
Swirly Sky Ventures LLC may use services like Bitly to create shortened URLs for easier sharing of our content, particularly on social media platforms. Bitly collects data as shortened URLs are shared and clicked on, including IP addresses, general location information, timestamps, and the social media or other channels through which content is shared. If you have a separate account with Bitly, they may associate this information with other data they have about you, as governed by Bitly Privacy Policy. To share our content without using Bitly, you can copy and paste the full URL directly from your browser into your message or social media post.

Aggregated and Anonymous Information
Subject to applicable laws and your opt-out choices, we may share aggregated or other anonymized information with third parties, which cannot reasonably be linked to you or your devices. These third parties may use this information according to their own privacy policies, which we do not control. For example, we may share such information with service providers or vendors to help us analyze and improve our platforms, generate ratings or ranking data, or develop personalized content. Additionally, sponsors or their agencies may collect or use aggregated data to measure the impact of their sponsorship campaigns.

Privacy Rights and Choices

You have the following choices to update, correct, and limit the collection and use of information gathered through our website and services.

Opt-Out of Interest-Based Ads and Tracking
To opt out of receiving interest-based ads or tracking, you can take the following steps:

• Browser Settings: Adjust your browser settings to block third-party cookies or enable “Do Not Track” (DNT) signals. Note, however, that our website does not currently respond to DNT signals. While DNT signals are widely supported by browsers, there is no universal standard for interpreting these signals. Instead, we provide alternative tools for managing tracking preferences through our cookie consent banner.
• Cookie Preferences: Use the cookie consent icon or banner on our website to manage your preferences, including disabling non-essential cookies.
• Ad Settings: Modify your mobile device settings:
  • For iOS: Go to Settings > Privacy > Tracking and disable “Allow Apps to Request to Track.”
  • For Android: Go to Settings > Google > Ads and enable “Opt Out of Ads Personalization.”

Note: Even after opting out, you may still see ads online, but they will no longer be personalized to your interests.”

Update or delete registration information. You may contact us to update, correct, or delete any registration information you provided to Swirly Sky Ventures. If applicable, you can also request to cancel your account or registration with us by contacting us through our Contact Us page here.

Opt out of sharing information. If you do not wish for your information, such as your name, contact details, or usage data, to be shared with sponsorship vendors or other entities we work with, you can contact us through our Contact Us page here. to opt out. Please note that opting out may limit the personalized services and sponsorship content we can provide.

Opt out of sharing for newsletter sponsorship. To opt out of sharing your information with our newsletter sponsorship vendors for the delivery of interest-based sponsorship credits and marketing messages, please contact us through our Contact Us page here.

Opt out of marketing communications. You can stop receiving marketing emails, newsletters, or other promotional communications by following the unsubscribe instructions included in those communications. Please note that even if you opt out of marketing messages, you may still receive essential communications related to services or transactions you have requested.

Opt out of sharing precise location information. If you consent to our collection of precise location data through an app or service, you can withdraw your consent at any time. You can do this by adjusting the privacy settings on your mobile device or through the settings of the respective app.

We also offer you choices that affect how we handle the personal information that we control. Depending on the applicable law in your jurisdiction and the nature of your interactions with our services, you may request the following in relation to your personal information:

• Information about how we have collected and used personal information. This information is provided in this Privacy Policy to ensure transparency.
• Access to a copy of the personal information we have collected about you. Where applicable, we will provide this information in a portable, machine-readable, and readily usable format.
• Correction of personal information. You may request corrections to personal information that is inaccurate or out of date, as permitted under applicable law.
• Deletion of personal information. You may request the deletion of personal information that we no longer need to provide services or for other lawful purposes. Please note that certain information may be retained for legal, compliance, or security purposes as permitted by applicable law.
• Additional rights. Depending on your jurisdiction, you may have the right to object to or request that we restrict our use of your personal information.

To make a request, please email us through our Contact Us page here. We may request specific information from you to verify your identity. For your protection, we can only act on requests related to the data associated with the email address you use to submit your request. Additionally, we may ask you to verify your identity before processing your request.

We will attempt to fulfill your request as soon as reasonably practicable or as required by law. However, we may need to retain certain information for recordkeeping purposes or to complete any transactions initiated before your request. Depending on your location, you may have the right to authorize an “authorized agent” to submit requests on your behalf. We will require proof of the agent’s identity and authority, as mandated by applicable laws. You have the right to exercise these rights free from discrimination.

Please note that, in some cases, your choices may be limited. For example, fulfilling your request could affect the rights of others, hinder our ability to provide a service you have requested, or conflict with legal obligations or our ability to enforce our legal rights. If you are dissatisfied with how we address your request, you may submit a complaint or appeal by contacting us. Depending on your location—such as if you reside in the European Economic Area or the United Kingdom—you may also have the right to file a complaint with a data protection authority in your place of residence, work, or where you believe a violation occurred.

Your Privacy Rights by Region
The following table summarizes your privacy rights depending on your location:

To exercise your rights or learn more, email us through our Contact Us page here.

California residents have the following rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: Request specific details about the personal information we have collected, used, disclosed, or sold.
• Right to Delete: Request the deletion of personal information, subject to certain exceptions.
• Right to Opt-Out of Sale or Sharing: Opt out of the sale or sharing of your personal information.
• Right to Correct: Request corrections to inaccurate personal information.
• Right to Non-Discrimination: Exercise these rights without facing discrimination.
• California residents can submit a data rights request through our Contact Us page here.

Data Portability
Under GDPR, you have the right to request your personal information in a portable format that can be transferred to another service. To request your data in a machine-readable format, such as JSON, CSV, or XML, please email us through our Contact Us page here, with the following:

• Proof of Identity: Provide sufficient information to verify your identity, such as a notarized ID (e.g., passport or driver’s license) and a current utility bill with your name.
• Specific Request: Clearly specify the personal data you are requesting to be transferred.

We will respond to your request within 30 days of receiving the necessary documentation.

Please note that the portability right applies only to personal data you have provided to us, which is processed based on consent or contractual necessity. It does not extend to derived data or information processed under other legal bases.

If you are dissatisfied with our response to your request, you may file a complaint with your local data protection authority.

Automated Decision-Making
Swirly Sky Ventures LLC does not use automated decision-making or profiling that significantly affects users. If this practice changes, we will update this policy and provide mechanisms for you to object or opt-out, as required under GDPR Article 22. If automated decision-making practices are introduced in the future, users will be notified and provided with options to opt out, as required by law.

Under GDPR, we process personal information based on the following legal bases:

• Consent: When you provide consent for specific uses of your data (e.g., subscribing to newsletters or accepting cookies).
• Contractual Obligations: To fulfill our contractual obligations to you, such as processing purchases or providing requested services.
• Legitimate Interests: To improve our services, prevent fraud, and provide personalized experiences (when not overridden by your rights).
• Legal Obligations: To comply with applicable laws, such as tax and reporting requirements.

Security

Swirly Sky Ventures LLC takes the protection of your personal information seriously. We utilize Bluehost’s security infrastructure to safeguard your data and ensure secure interactions with our platforms. Bluehost employs advanced technologies and practices to protect your information, including:

• SiteLock Integration: Bluehost integrates with SiteLock, a service that performs daily automated scans of our website to detect and remove malware, vulnerabilities, and other potential threats.
• Malware Detection and Removal: Proactive scanning and removal of malicious code to ensure a secure website environment.
• Web Application Firewall (WAF): SiteLock’s WAF blocks harmful traffic and defends against common attacks, such as SQL injections and cross-site scripting.
• Vulnerability Scanning: Regular assessments to identify and address weaknesses in the website’s code and infrastructure.
• SSL Encryption: Bluehost provides SSL certificates, which encrypt data exchanged between our website and users, ensuring that sensitive information remains secure during transmission.
• Regular Backups: Bluehost supports automatic backups, enabling quick restoration of website data in case of a breach or data loss.
• Security Badge: Our website features a SiteLock security badge to reassure visitors that industry-standard security measures are in place.

While these measures are robust and designed to protect your data, no security system is entirely impenetrable. We encourage users to take precautions when sharing sensitive information online. If you have concerns or suspect a potential security issue, please contact us immediately at through our Contact Us page here.

Breach Notification
In the unlikely event of a data breach that compromises your personal information, we will notify affected users as required by applicable laws. Notifications will be sent via email or through a prominent notice on our website. If a data breach occurs that poses a high risk to your rights and freedoms, we will notify affected individuals within 72 hours, as required under GDPR.

Children’s Privacy

Swirly Sky Ventures LLC cares about protecting the privacy of children. Our website and services are not directed to children under 13 years of age. In accordance with the Children’s Online Privacy Protection Act (COPPA), we do not knowingly collect personal information from children under 13. If we become aware that personal information from a child under 13 has been collected, we will take appropriate steps to delete it. For users in the EU or UK, where GDPR applies, the minimum age for consent may differ and will be observed accordingly. If you believe we have inadvertently collected such information, please contact us through our Contact Us page here.

Retention of Personal Information

Swirly Sky Ventures LLC retains personal information only for as long as necessary to fulfill the purposes outlined in this Privacy Policy, to comply with legal and regulatory requirements, or to resolve disputes and enforce our agreements. Factors influencing retention include the type and sensitivity of the data, your consent (where applicable), and our legal or regulatory obligations (e.g., tax, fraud prevention, or accounting requirements).

Once the information is no longer required for these purposes, we securely delete, anonymize, or de-identify it in accordance with applicable laws and industry best practices. We periodically review our data retention policies to ensure compliance with evolving legal requirements and your privacy rights. You may also request the deletion of your personal information at any time, as outlined in the Privacy Rights and Choices section of this Privacy Policy.

Links to and from Other Sites and Services

Our website and platforms may contain links to third-party sites, applications, and services. These third-party services may have privacy policies that differ significantly from ours and operate outside our control. For example, clicking on a link to a sponsor’s page or third-party content may take you to a separate site or service that collects, uses, and shares information differently. Similarly, you may access Swirly Sky Ventures LLC content through third-party services that have their own privacy practices. We are not responsible for the privacy policies or practices of any third-party services, and we encourage you to familiarize yourself with their privacy policies before engaging with them.

Job Applicants

If you visit the Careers section of our website, we may collect information that you provide in connection with your application for a position, internship, or collaboration with Swirly Sky Ventures LLC. This may include, but is not limited to, personal and business contact information, professional credentials, educational and work history, and other information typically included in a resume.

We use this information for recruitment purposes, such as evaluating candidates, monitoring recruitment statistics, and responding to employment-related inquiries. Additionally, we may use this information:

• To comply with relevant laws, such as government reporting requirements.
• To respond to legal requests, subpoenas, or warrants.
• To protect and defend our rights or property or those of others.
• To investigate or prevent violations of the law, this Privacy Policy, or our Terms of Use.

Changes to This Privacy Policy

Swirly Sky Ventures LLC reserves the right to modify this Privacy Policy at any time. Material changes may include, but are not limited to, updates to how we collect, use, or share your personal information, as well as updates required by changes in applicable laws, regulations, or business practices.

We will notify you of material changes to this Privacy Policy via email or a prominent notice on our website at least 30 days before the changes take effect. If you continue to use our services after the updated Privacy Policy takes effect, you acknowledge and agree to the updated terms. For non-material changes (e.g., typographical corrections or clarifications), we may update this Privacy Policy without prior notice.

International Data Transfers

Swirly Sky Ventures LLC may transfer personal information to, and process and store it in, countries outside your country of residence, including the United States. These jurisdictions may have data protection laws that are less protective than those in your home country. Courts, law enforcement, or other authorities in these jurisdictions may access your personal information in certain circumstances.

Swirly Sky Ventures LLC uses Standard Contractual Clauses (SCCs) approved by the European Commission to ensure data transfers comply with GDPR. Where SCCs are not applicable, equivalent safeguards such as Binding Corporate Rules (BCRs) or reliance on adequacy decisions are applied.

For more information about our safeguards for international transfers or to request a copy, please contact us through our Contact Us page here.

How to Contact Us

If you have any questions or concerns about our policy or our practices regarding your personal information, please contact us through our Contact Us page here.