Privacy Policy
Swell Consulting Co, LLC. (“Swell Consulting Co,” “we,” “us” or “our“) is committed to maintaining your privacy and informing you of our privacy practices. This privacy policy and agreement (the “Privacy Policy“) covers how we collect, use, and treat personal information.
1. Scope of this Privacy Policy. Swell Consulting Co offers various services (the “Services“), which include: (i) operating the website located at www.swellconsulting.co (the “Website“); (ii) operating Swell Consulting Co’s cloud-based software (the “Swell Consulting Co Software“); (iii) managing relationships with social impact organizations; and (v) other related services. Our Privacy Policy applies to anyone who uses or accesses the Services, including (i) casual visitors of the Website or any Swell Consulting Co landing page who are not Registered Users (collectively, “Site Visitors“), and (ii) users who have registered in Swell Consulting Co’s Software (“Registered Users“) either by (a) agreeing to the Terms of Use, or (b) entering into a negotiated agreement with us in order to access and use our Services in Swell Consulting Co’s Software. If you are an employee of an entity that has entered into an agreement with us, then this Privacy Policy applies to you in your capacity as a representative of such entity. We use the term “you” to refer to Site Visitors and Registered Users (as the context permits). The Services may contain links to other websites for your convenience and reference. We are not responsible for the privacy practices or the content of those sites.
2. Navigating this Privacy Policy. To help you navigate our Privacy Policy, we have divided it into numbered sections and provided a set of definitions in Section 19 (Definitions) to allow easy reference to key concepts.
3. Your Consent to this Privacy Policy.
3.1 Consent by Site Visitor. By accessing and using our Website as a Site Visitor, you are acknowledging that you have read, understand, and consent to this Privacy Policy and agree to be legally bound by it.
3.2 Consent by Registered User. By either (a) agreeing to the Terms of Use, or (b) entering into a negotiated agreement with us in order to access and use our Services in the Swell Consulting Co Software and clicking a checkbox indicating that you have read this Privacy Policy, you are acknowledging that you have read, understand, and consent to this Privacy Policy and agree to be legally bound by it.
3.3 Consent by User Acting in a Representative Capacity. If you are agreeing to our Privacy Policy on behalf of a company or other legal entity (“Your Organization“), then (i) you represent and warrant that you have authority to act on behalf of, and to bind Your Organization, and (ii) for all purposes in this Privacy Policy, the term “you” means Your Organization on whose behalf you are acting.
3.4 Right to Withdraw Consent. You have the right to withdraw your consent at any time, in accordance with Section 12 (Your Right to Opt-Out; Object to Processing; Deleting Information), along with other opt-out rights for residents of California and Nevada per Section 15.
4. Information We Collect. To provide our Services, and to otherwise conduct our business via the Swell Consulting Co Software, we rely on information provided by, and collected from, you. This information consists of the following:
4.1 Information You Submit. We collect certain information from you as a Registered User that identifies you as an individual when you submit such information voluntarily. Such information may include the following: Your name and job title/role; Your phone number; Your email address; The agency or organization that you represent; The address of the agency or organization that you represent.
4.2 Information Gathered Automatically. We also automatically collect from you technical and device-related information that does not identify you as an individual but may reasonably be used to identify a particular user device. Such information may include the following: Device identifiers, such as cookies; Device information, such as hardware and software settings; Other characteristics of a user device, which, by themselves or taken in conjunction with other information, are sufficient to distinguish that user device over time from a population of other user devices; IP addresses and log information, such as your device’s name, the type and version of your web browser, and referrer addresses that can function to identify a user device; and Tracking information that we, or a third party collects.
4.3 Anonymous Information. We may engage service providers to collect, process, and provide us with information that does not identify you or your devices, by: (i) removing identifying fields and aggregating the information with other information so that individual subjects of the information cannot be re-identified, or (ii) anonymizing the information with techniques that remove or modify the identifying data so as to prevent re-identification of the anonymized information (collectively, “Anonymous Information“). We will use such Anonymous Information in order to provide Services to our clients. Information that meets these criteria might include, for example, demographic information, statistical information (e.g. page views and hit counts), and general tracking information.
4.4 Treatment of Combined Information. If we combine Anonymous Information with Personal Information (defined in Section 19 as including information covered by Sections 4.1 and 4.2 above), we treat the resulting combination as Personal Information.
5. How We Collect Information. We collect the above information through the following means and technologies:
5.1 Registration Information; User Names. In order to become a Registered User and thereby participate in our Services as a Registered User, we require that you use the process described in Section 3.2 (Consent by Registered User). After completing the process to become a Registered User, Registered Users may be provided with an email username and password, which allows them to gain access to password-protected portions of the Swell Consulting Co Software and to otherwise use certain functionality available in the Swell Consulting Co Software. This information is used by Swell Consulting Co in providing the Services, as further detailed below.
5.2 User-Generated Content. The Services may provide you with the ability (either directly or through a third party service) to engage with us and others in public exchanges, and these may include opportunities for you to provide comments, reviews, recommendations, information related to the Services, and other input via the Services (collectively, “User-Generated Content“). Please understand that anything you supply as User-Generated Content will be accessible to others to read, collect, re-publish, and otherwise freely use. We are not responsible for anything you decide to include in User-Generated Content, and we will only take down, remove, or edit User-Generated Content in our sole discretion, except as required by Applicable Law. If you include in your User-Generated Content any information relating to others, you represent that you have full permission and authority to do so.
5.3 Contacting Swell Consulting Co. You may have the ability to contact us via email or “live chat” functionality with questions, comments, or feedback concerning our Services. By communicating with us for these purposes, you may provide us with your email address and other Personal Information. In these instances, we may use any information you provide to us for the purposes for which you submit the information.
5.4 Newsletters and Bulletins. You may choose to sign up to receive communications from us including, for example, emails, mobile notifications, or “push” notifications with information related to our Services, including deals, news, and other events. If you provide us with Personal Information, then we may send you newsletters about Swell Consulting Co, our Services, and information about programs or events that we believe may be of interest to you.
5.5 Web Beacons and Tags. The Services may use certain data collection technologies that rely on (i) web beacons; (ii) pixel tags and object hyperlinking tags, and (iii) other means to link an object to an Internet address, a remote software application, a remote database, or other remote means of receiving or processing information. We may use these technologies to determine what parts of our Services have been accessed or to measure the effectiveness of our Services. These technologies also enable us to send email messages in a format users can efficiently read, to learn whether these email messages have been opened, and to help ensure, for example, that our messages are of interest to our users. These technologies provide us with Anonymous Information and, in certain instances, Personal Information.
5.6 Device Identifiers; Logs; IP Addresses. To determine whether your device is supported by our Services, we may collect certain information about your device and network, including your IP address, your operating system and browser, your device model, information about your use of the Services, as well as the presence of any software that our Services may require to operate with your device, or other third party software or mobile apps on your device. We automatically receive and record this information in log files.
5.7 Cookies. A cookie is a small amount of data that is sent to your browser from a website’s computer and stored on your computer’s hard drive. Cookies can be used to provide you with a tailored user experience and to make it easier for you to use a website upon a future visit. Our Services may include cookies and we may use them to recognize you when you return to access or use our Services. You may set your browser so that it does not accept cookies; however, you may need to enable cookies on your web browser if you wish to access certain personalized features of our Services.
5.8 Click-Throughs. We may send email messages or display links that use a “click-through URL” linked to our Services or to another resource. When you click one of these URLs, you pass through our web server before arriving at the destination website page or other resource. We may track this click-through data to help determine interest in particular topics and measure the effectiveness of our user communications.
5.9 Other Technologies and Data Sources. We may augment Personal Information with data from other third-party sources, such as privately-held marketing or analytics databases. For example, we may link your Personal Information with third-party demographic information (such as age, sex, household income, job industry, or job title).
5.10 Other Uses. In addition to the uses specifically identified in Section 5 (How We Collect this Information), there may be instances where you request information and Services from us that are not described in this Privacy Policy. We will use Personal Information in order to provide such information and Services.
6. How We Use Information. We use the information we collect or process, including Anonymous Information and Personal Information, as permitted under Applicable Law, including where the use is based on (i) the consent you provide to us at the point of collection; (ii) performance of our agreement to provide you with the Services; (iii) compliance with our legal obligations; and/or (iv) our Legitimate Interests, as well as a third party’s Legitimate Interests. More specifically, we use the information we collect for some or all of the following:
Our Use of the Information
To provide you with the Services you request and, specifically, to allow us to send you emails with information
Bases for Our Use for Residents of the EEA
Performance and management of our agreement with you
Our Use of the Information
To allow you to post User-Generated Content
Bases for Our Use for Residents of the EEA
Performance and management of our agreement with you
Your consent
Our Use of the Information
To respond to your inquiries
Bases for Our Use for Residents of the EEA
Performance and management of our agreement with you
Your consent
Our Use of the Information
To customize your use of the Services
Bases for Our Use for Residents of the EEA
Performance and management of our agreement with you
Our Legitimate Interests
Our Use of the Information
To determine which events, programs, and content (including marketing content) might interest you
Bases for Our Use for Residents of the EEA
Your consent
Our Legitimate Interests
Our Use of the Information
To inform you of events and programs that we think (or our marketing partners think) would be appealing to you; this includes information in the form of recommendations and endorsements that we might provide
Bases for Our Use for Residents of the EEA
Your consent
Our Legitimate Interests
Our Use of the Information
To track access to and use of our Services, and conduct data and other analyses, including anonymization and aggregation of Personal Information
Bases for Our Use for Residents of the EEA
Our Legitimate Interests
Our Use of the Information
To perform internal administration, auditing, operation, and troubleshooting for our Services
Bases for Our Use for Residents of the EEA
Our Legitimate Interests
Our Use of the Information
To determine, optimize, and track advertising campaign performance
Bases for Our Use for Residents of the EEA
Your consent
Our Legitimate Interests
Performance and management of our agreement with you
Our Use of the Information
To engage in the activities specified in Section 7 (How We Share this Information)
Bases for Our Use for Residents of the EEA
Our Legitimate Interests
Compliance with our legal obligations
Performance and management of our agreement with you
Our Use of the Information
To evaluate and improve our Services and our communications, and to develop and test new services and content
Bases for Our Use for Residents of the EEA
Our Legitimate Interests
Our Use of the Information
To comply with Applicable Law
Bases for Our Use for Residents of the EEA
Compliance with our legal obligations
Note that when determining the bases for our use of your information, we rely on what we consider to be the most appropriate basis, even if there are multiple bases available in connection with our use.
7. How We Share this Information. We value your privacy, and we share the information we collect only in the manner set out below.
7.1 Our Service Providers. We engage third parties to perform functions on our behalf, and these may include maintaining the Services, collecting information, responding to and sending email or other messages, and other functions useful to our business. In this capacity, we may provide service providers with Personal Information and Anonymous Information as applicable. The following are examples: We may use service providers: (i) to provide customer service (where applicable); (ii) to process and distribute emails; and (iii) to provide advertising services. These service providers may require access to, or may be required to collect, your Personal Information in order to perform these services. We may use analytics service providers to assist us in understanding and using information that we collect via the Services. A service we use in this regard is Google Analytics, and information concerning how Google uses the information is available at https://policies.google.com/privacy/partners, and opt-out options specific to Google Analytics are available at https://tools.google.com/dlpage/gaoptout. We may use marketing, communications, and contact management service providers to assist us in our efforts to communicate with you. If you no longer wish to receive email messages from us, you can opt out of this Service by either (i) following the “unsubscribe” instructions located near the bottom of any commercial email message, or (ii) contacting us at info@swellconsulting.co or as provided in Section 18 (Contact Us). We may use service providers to anonymize and aggregate Personal Information in order to generate Anonymous Information. We may use marketing, communications, and contact management service providers to assist us in our efforts to communicate with you. If you no longer wish to receive email messages from us, you can opt out of this Service by either (i) following the “unsubscribe” instructions located near the bottom of any commercial email message, or (ii) contacting us at info@swellconsulting.co or as provided in Section 18 (Contact Us). We may engage service providers to analyze the interests and attributes of our users and, using techniques based on Anonymous Information and/or Personal Information, identify others who might share those interests and attributes. We then use this information to reach out to relevant market segments to provide them information concerning the Services. We do not permit our service providers to use the information we give them for any purpose other than providing services to us.
7.2 Questions of Harm; Legal Process. We may disclose your Personal Information to third parties, including law enforcement agencies, attorneys, and private investigator organizations, where it is necessary, or where we have a good faith belief that it is necessary: To comply with legal process; To protect and defend our rights and property, including the Services and associated content; To protect against misuse or unauthorized use of our Services; To protect the personal safety or property of users of our Services or the public, including your personal safety or property (it being understood that we assume no duty to provide, or monitor the need for, such protections); and To cooperate with public and government authorities including, where required, authorities outside your jurisdiction. While you are not able to opt out of this use of information, we will take reasonable steps to limit such use, and disclose only the information we reasonably believe is necessary for the above purposes. If we receive legal process calling for the disclosure of your Personal Information, we will attempt to notify you within a reasonable amount of time, unless such notification is not permitted.
7.3 Transfer of the Services. We shall be entitled to transfer information that we collect (including Personal Information) to a third party in connection with or related to an actual or potential reorganization, merger, sale, joint venture, assignment, transfer or other disposition (including a disposition in connection with a bankruptcy or similar proceedings) of all or substantially all assets or stock of the business unit or division responsible for the information under this Privacy Policy; provided the acquiring third party has agreed to safeguard your Personal Information with protections that are compatible with those set out in this Privacy Policy.
7.4 Our Affiliates. We may choose to rely on and share the information we collect with our affiliates. By “affiliate” we mean an entity that is closely related to us, such as an entity that controls, is controlled by, or is under common control with Swell Consulting Co. Our affiliates will be bound by the terms of this Privacy Policy.
7.5 Third Party Advertising. While we do not sell or transfer your Personal Information to, and do not share, swap, or exchange your Personal Information with, any third party for such third party’s advertising or marketing purposes, we may use third parties, such as network advertisers, to display advertisements on our websites and to assist us in determining relevant advertising and placement on third party websites. Network advertisers are third parties that display advertisements based on your visits to our website as well as other websites. This enables us and these third parties to target advertisements by displaying ads for products and services in which you might be interested. Third party ad network providers, advertisers, sponsors and/or traffic measurement services may use cookies, JavaScript, web beacons (including clear GIFs), Flash LSOs and other technologies to measure the effectiveness of their ads and to personalize advertising content to you. These third-party cookies and other technologies are governed by each third party’s specific privacy policy, not this one. We may provide these third-party advertisers with information about your usage of our website and our services, as well as aggregate Anonymous Information about visitors to our website and users of our services. We also use services like Google Analytics and Google Customer Match to allow us to use information collected from your use of our site and other websites to customize the pages and advertisements that we present to you. The use of these services could also be in the form of an advertisement on the Google search results page, or a site in the Google Display Network. These services collect data about your use of our site and other websites through Google advertising cookies. In connection with our use of the Google Customer Match service, we may share your email with the Google Customer Match service. Any data collected or shared through the use of this service will be used in accordance with our own privacy policy and Google’s privacy policy. You can set preferences for how Google advertises to you using the Google Ad Preferences page. Google Ad Preferences page. Alternatively, you can opt out of a third-party vendor’s use of cookies by visiting the Network Advertising Initiative opt-out page. If you wish to prevent your data from being used by Google Analytics, you may use the opt–out browser add on available here. We do not honor browser requests not to be tracked. You may, however, opt–out of the collection of web viewing data over time and across unaffiliated website by Google and many third–party ad networks, including those operated by members of the Network Advertising Initiative (“NAI“) and the Digital Advertising Alliance (“DAA“). For more information regarding this practice by NAI members and DAA members, and your choices regarding having this information used by these companies, including how to opt–out of third–party ad networks operated by NAI and DAA members, please visit their respective websites: http://optout.networkadvertising.org/?c=1 (NAI) and www.aboutads.info/choices (DAA).
8. How We Safeguard the Information We Collect. We recognize the sensitivity of our users’ Personal Information and we have put in place security systems designed to help prevent unauthorized access to or disclosure of this information. Our security systems include physical, technical, and administrative information security controls, and we take commercially reasonable steps to secure and safeguard such Personal Information in accordance with Applicable Law. Please understand, however, that no online system is perfect or can guarantee that unauthorized access or theft might not occur.
9. Our Retention of Data. We retain information for the period of time necessary to fulfill the purposes for which we obtained the information and consistent with Applicable Law. We use the following criteria to set our retention periods: (i) the duration of our relationship with you; (ii) the existence of a legal obligation as to the retention period; and (iii) the advisability of retaining the information in light of our legal position (for example, in light of applicable statutes of limitations, litigation, or regulatory investigations).
10. Accuracy and Minimization of Data. We take reasonable steps (i) to maintain the accuracy of the Personal Information we process; and (ii) to limit the Personal Information that we process to that which is reasonably necessary for the purposes for which we obtained the information.
11. Accessing and Updating Your Information.
11.1 If you would like to review, correct, or update Personal Information we have collected about you, or if you would like to request an electronic copy of such information for purposes of transmitting it to another company (to the extent Applicable Law provides you with this right to data portability) you may make such requests as provided in Section 18 (Contact Us).
11.2 Your “CCPA” Access Rights. If you are a California consumer protected by the California Consumer Privacy Act (“CCPA“), you have the right to request in writing from a business, (i) a list of the categories of personal information, such as name, address, e–mail address, and the type of services provided to the customer, that a business has disclosed to third parties (including Independent Affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes, and (ii) the names and addresses of all such third parties.
12. Your Right to Opt-Out; Object to Processing; Deleting Information.
12.1 Unsubscribing to Email. If you no longer wish to receive email messages from us, you can opt out of this Service by either (i) following the “unsubscribe” instructions located near the bottom of any commercial email message, or (ii) contacting us at info@swellconsulting.co or as provided in Section 18 (Contact Us). NOTE: Unsubscribing generally applies to commercial messages. Unless you specifically choose to cease receiving account-related communications, you will continue to receive emails with important information about your account (billing, etc.) when you unsubscribe from commercial email communications.
12.2 Deleting Information. If you request, we will take reasonable steps to remove your name and email address from our databases, within the time frames (if any) set out in Applicable Law. Please understand, however, that if you request the deletion of your information, you will no longer be able to receive our Services. In addition, it may be impractical (or essentially impossible) to remove the requested information completely, due to requirements promulgated by Applicable Law, and/or data backups and records of deletions. As such, certain Personal Information may remain in our databases following the deletion of your account; we will continue to treat the remaining information (if an) in accordance with this Privacy Policy and Applicable Law.
12.3 Your “Right to be Forgotten.” If you are protected by the GDPR with respect to our use of your information, upon proper request, we will take the steps set out in the GDPR to erase your Personal Information, including information that may be publicly available via our Services, such as, for example, Personal Information made publicly available through User-Generated Content.
Your “CCPA” Deletion Rights. If you are a California consumer protected by the CCPA, you have the right to have your personal information deleted, unless the personal information is necessary for the business or service provider to: complete a transaction for which the personal information was collected, provide a good or service requested by the consumer or otherwise perform a contract between the business and the consumer; detect security incidents; protect against malicious, deceptive, fraudulent or illegal activity (or prosecute those responsible); debug to identify and repair functionality errors; exercise or ensure the right of another to exercise free speech or another legal right; comply with the California Electronic Communications Privacy Act, which compels the production of or access to electronic communication information or electronic device information with a search warrant; engage in research in the public interest (if the consumer has provided informed consent); to enable solely internal uses aligned with the consumer’s expectations given their relationship with the business; comply with a legal obligation; otherwise use the information internally in a lawful manner compatible with the context in which the consumer provided it.
12.3.1 Anonymous Information. We will not delete Anonymous Information from our database, and nothing in this Privacy Policy restricts our use of Anonymous Information.
12.4 Objections. If you object to our processing of your Personal Information, and a request for us to delete this Information is not, in your view, sufficient, please contact us as provided in Section 18 (Contact Us).
13. Advisory Regarding Participation by Children and Teens. WE DO NOT COLLECT OR STORE ANY PERSONALLY IDENTIFIABLE INFORMATION FROM INDIVIDUALS THAT WE KNOW ARE UNDER THE AGE OF 13. If we become aware that we have collected Personal Information relating to an individual under the age of 13, we will take steps to delete it immediately.
14. Relationship to Other Agreements; Incorporation of Other Agreements. This Privacy Policy must be read in conjunction with our other agreements (which may include: (i) the Website Terms of Use; (ii) the Swell Consulting Co Software Terms of Use; and/or (iii) a negotiated agreement with us to access use of the Swell Consulting Co Software or participate in our Services, as the case may be (collectively, the “Other Agreements“)), and the provisions of the Other Agreements are incorporated herein. To the extent the terms of the Other Agreements conflict with the terms of this Privacy Policy, the terms of this Privacy Policy will control.
15. Notice of Privacy Rights to California and Nevada Residents.
15.1.1. California. California residents have a number of rights under CCPA. Some of those rights are described above in Sections 11 and 12. In addition to those rights described in Sections 11 and 12, California residents have the right to opt-out of having their personal information sold. Swell Consulting Co does not sell personal information. Californians can exercise their privacy rights by contacting us per Section 18 (Contact Us) below.
15.1.2 Response Time. We will handle requests under Applicable Law in California. When a request is made, we may verify your identity to protect your privacy and security. We will respond to written rights requests within 30 days following receipt at the e–mail or mailing address stated above. If we receive your request at a different e–mail or mailing address, we will respond within a reasonable period of time, but not to exceed 150 days from the date received. Please note that we are only required to respond to each customer once per calendar year.
15.1.3. Nevada. Nevada law entitles you to request that we refrain from the sale of your Personal Information. We do not sell your Personal Information. For more information about how we handle Personal Information, please review this Privacy Policy, or contact us per Section 18 (Contact Us) below.
16. Complaints. We want your feedback. If you have a suggestion on how we can improve our Services or complaints you would like us to address, please contact us at the address set out in Section 18 (Contact Us). If you are a California resident, you may report complaints to the Complaint Assistance Unit of the Division of Consumer Services of the California Department of Consumer Affairs. Other states may provide similar avenues for lodging complaints. Please check with your state’s consumer protection authority. If you are protected by the GDPR with respect to our use of your information, you may lodge a complaint with a data protection authority for your country or region. A list of EU data protection authorities is available at http://ec.europa.eu/newsroom/article29/item-detail.cfm?item_id=612080.
17. Changes to this Privacy Policy. From time to time, we may change this Privacy Policy for our business purposes and to comply with changes in Applicable Law. In the event of any substantive or material changes, we will communicate these changes to you by posting the updated Privacy Policy in the Swell Consulting Co Software and Website and/or notifying you of the change via the Services, email, or other methods per Applicable Law. Your continued use of the Services following such notice constitutes your agreement to follow and be bound by the updated Privacy Policy.
18. Contact Us. If you have any questions about this Privacy Policy or the Services, please contact us. You may contact us, for any reason, at: info@swellconsulting.co
19. Definitions. Below are definitions applicable throughout this Privacy Policy. Additional terms are defined in context.
19.1 “Anonymous Information” has the meaning set out in Section 4.3 Anonymous Information). If you are protected by the GDPR with respect to our use of your information, the term “Anonymous Information” has the same meaning as information generated by a “pseudonymization” processes, as that term is defined under the GDPR.
19.2 “Applicable Law” means statutes, regulations, and any other laws that apply to the Services. For example, if you are protected by the GDPR with respect to our use of your information, the term “Applicable Law” includes the GDPR.
19.3 “GDPR” means the European Union General Data Protection Regulation, applicable to persons residing in the European Economic Area (“EEA“).
19.4 “Legitimate Interest” means, for purposes of the GDPR, that there is a good reason for processing your Personal Information, and that the processing is carried out in a way that minimizes impacts (if any) on your privacy rights and interests. The term “Legitimate interest” also refers to our use of information in ways that you would reasonably expect, based on your relationship to us. For example, there is a Legitimate Interest in collecting and processing your Personal Information: (i) to safeguard our Services, networks, content, and related information and resources; (ii) to administer and generally conduct our business; and (iii) to prevent fraud.
19.5 “Personal Information” means the information described in Sections 4.1 and 4.2; provided that, if you are protected by the GDPR with respect to our use of your information, the term “Personal Information” has the same meaning as the term “personal data” under the GDPR.
19.6 “Swell Consulting Co Software” has the meaning set out in the introductory paragraph.
19.7 “Swell Consulting Co Software Terms of Use” means the agreement that provides Registered Users with access to the Swell Consulting Co Software and related Services.
19.8 “Services” has the meaning set out in the introductory paragraph.
19.9 “Website” has the meaning set out in the introductory paragraph.
19.10 “Website Terms of Use” means the agreement located here, which provides the terms and conditions for access to the Website.
20. U.S. Website and Swell Consulting Co Software. Our business is located in the United States. By becoming a Site Visitor, you understand and agree that any information you submit or is gathered about you will be transmitted to and stored in the United States. You further consent to the use and disclosure of that information accordance with Applicable Law and this Privacy Policy.
21. Effective Date. The effective date of this Privacy Policy is August 1, 2022.
22. Copyright and Legal Notice. Copyright © 2022 Swell Consulting Co, LLC. All Rights Reserved.