Privacy Policy

Swift Bunny Privacy Policy

Swift Bunny, LLC. (“us”, “we”, or “our”) operates SwiftBunny.com and the Ingage™ Feedback System application. This Privacy Policy applies to all the products, services, websites and applications offered by us. We refer to our products, services, websites, and applications collectively as the “Service” in this policy. References to "data" in this Privacy Policy will refer to whatever data you use our services to collect, whether it be survey responses, data collected in a form, or data inserted on a site hosted by us. Data Controller means the natural or legal person who determines the purposes for which and the manner in which any personal information are, or are to be, processed. For the purpose of this Privacy Policy, we are a Data Controller of your Personal Data. Data Processor and Service Provider means any natural or legal person who processes the data on behalf of the Data Controller. We may use the services of various Service Providers in order to process your data more effectively. Data Subject, that means you the user, is any living individual who is using our Service and is the subject of Personal Data.

This page informs you of our policies regarding the collection, use and disclosure of personal data when you use our Service and the choices you have associated with that data. We use your data to provide and improve the Service. By using the Service, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, the terms used in this Privacy Policy have the same meanings as in our Terms and Conditions and Terms of Service.

Information We Collect and Use

We collect several different types of information for various purposes to provide and improve our Service to you.

Personal Data

While using our Service(s), we may ask you to provide us with certain personally identifiable information used in the voluntary surveys we provide as well as data that can be used to contact or identify you (“Personal Data”). Depending upon the particular service, personally identifiable information may include, but is not limited to the following items:

• First name, middle name and last name
• Email address
• Phone number
• Zip/Postal code
• Name of your Company/Employer
• Employment or property location
• Employment position
• Employment ID
• Employment status
• Employment or residence start date
• Employment or residence separation date
• Employment Supervisor

You can contact us at support@swiftbunny.com to get complete list of data we collect. For clarity, you shall retain ownership in your user submissions. We have a license to use the data to support our services. You may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at support@swiftbunny.com.

Usage Data

We may also collect information that your browser sends whenever you visit our Service or when you access any Swift Bunny Service (“Usage Data”). This Usage Data may include information such as your computer’s Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the data entered into any of our Services, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data. When you access the Service with a mobile device, this Usage Data may include information such as the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

Cookies

We and our partners use cookies and similar technologies on our websites. We use certain cookies, for legitimate interests of delivering and optimizing our services. Cookies are small bits of data we store on the device you use to access our services so we can recognize repeat users. Each cookie expires after a certain period, depending on what we use it for. We use cookies and similar technologies for several reasons:

• To gather metrics about your survey taking experience. For example, we will collect data about the number of clicks it took Respondents to complete a survey, whether they left and returned to a survey, whether they skipped parts of a survey and how long it took to complete the survey and other details about the survey taking. However, this information is collated and kept at an aggregated and anonymized level only.
• For security reasons. We use cookies to authenticate your identity and confirm whether you are currently logged into Swift Bunny or determine if an incident impacts you.
• To provide you with personalized content. We store user preferences, your default language, device and browser information, your profile information which includes, the level of usage of service and the web-pages on our site which you visit, so we can identify you across devices and personalize the content you see.
• To improve our services. We use cookies to measure your usage of our websites and track referral data, as well as to occasionally display different versions of content to you. This information helps us to develop and improve our services (it helps us focus on the parts of the service you seem most interested in) and optimize the content we display to you (which may include marketing content).
• To advertise to you. We, or our service providers and other third parties we work with, place cookies when you visit our website and other websites or when you open emails that we send you, in order to provide you with more tailored marketing content (about our services or other services), and to evaluate whether this content is useful or effective. If you don’t want to receive ads that are tailored to you based on your online activity, you may “opt out” of many of the companies that are involved in such tailoring by going to https://preferences-mgr.truste.com or, if you’re located in the European Union, at https://www.youronlinechoices.eu. Opting out in this way does not mean you will not receive any ads; it just means that you will not receive ads from such companies that have been tailored to you based on your activities and inferred preferences.
• Google Analytics. In addition to the above, we have implemented on our websites and other services certain Google Analytics features that support Display Advertising, including re-targeting. Visitors to our websites may opt out of certain types of Google Analytics tracking, customize the Google Display Network ads by using the Google Ad Preferences Manager and learn more about how Google serves ads by viewing its Customer Ads Help Center. If you do not wish to participate in Google Analytics, you may also download the Google Analytics opt-out browser add-on.

You can choose to remove or disable cookies via your browser settings. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some portions of our Service.

How your data is used

Swift Bunny, LLC. uses the collected data for various purposes:

• To provide and maintain our Service
• To notify you about changes to our Service
• To provide customer support
• To gather analysis or valuable information so that we can improve our Service
• To personalize our Service and make recommendations
• To monitor the usage of our Service
• To detect, prevent and address technical issues
• To share with our vendors and contractors
• To provide you and others with news, special offers, advertisements and general information about other goods, services and events offered by us and others which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information

Swift Bunny, LLC.’s legal basis for collecting and using the personal information described in this Privacy Policy depends on the Personal Data we collect and the specific context in which we collect it. Swift Bunny, LLC. may process your Personal Data because:

• We need to perform a contract with you
• You have given us permission to do so
• The processing is in our legally compliant interests and not in conflict with your rights
• To comply with the law

Retention of Data

Swift Bunny, LLC. will retain Data for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations. For example, we are required to retain your data to comply with applicable laws, resolve disputes and enforce our legal agreements and policies. Swift Bunny, LLC. will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period, except when this data is used to strengthen the security or to improve the functionality of our Service, or we are legally obligated to retain this data for longer periods.

Data Transfer

Your information, including Personal Data, may be transferred to and maintained on computers located outside of your state, province, country, or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside the United States and choose to provide information to us, please note that we transfer the data, including Personal Data, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer. Swift Bunny, LLC. will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

Disclosure of Data

If Swift Bunny, LLC. is involved in a merger, acquisition or asset sale, your Personal Data may be transferred. We will provide notice before your Personal Data is transferred and becomes subject to a different Privacy Policy.

Disclosure for Law Enforcement

Under certain circumstances, Swift Bunny, LLC. may be required to disclose your Personal Data if required to do so by law or in response to valid requests by public authorities, e.g. a court or a government agency.

Legal Requirements

Swift Bunny, LLC. may disclose your Personal Data in the good faith belief that such action is necessary to:

• To comply with a legal obligation
• To protect and defend the rights or property of Swift Bunny, LLC.
• To prevent or investigate possible wrongdoing in connection with the Service
• To protect the personal safety of users of the Service or the public
• To protect against legal liability

Disclosure of Survey Personal Data

Under certain circumstances, Swift Bunny, LLC. may be requested to disclose your Personal Data to your Employer. Swift Bunny LLC will only provide this information where the subject individual has provided express consent to share their Personal Data, or where the surveyed individual did not select to complete the survey confidentially or notwithstanding anything contained in this Privacy Notice, Swift Bunny LLC may disclose any Confidential Information if, in the opinion of the disclosing Swift Bunny 's legal counsel: (a) such disclosure is legally required to be made in a judicial, administrative or governmental proceeding pursuant to a valid subpoena or other applicable order. Prior to any disclosure of Confidential Information, the disclosing Swift Bunny shall give the Participant at least ten (10) days prior written notice (unless less time is permitted by such rules, regulations or proceeding) and, in making such disclosure, the disclosing Swift Bunny shall disclose only that portion of Confidential Information required to be disclosed and shall take all reasonable steps to preserve the confidentiality thereof, including, without limitation, obtaining protective orders and supporting the Participant in intervention in any such proceeding. That said, it is it is not the responsibility of Swift Bunny LLC to notify a client of any sensitive comments we see in their survey results.

Swift Bunny LLC is aware that it is daunting for an employee to report any form of harassment, discrimination or misconduct in the workplace. Harassment is unwelcome conduct that is based on race, color, religion, sex (including pregnancy), national origin, age (40 or older), disability or genetic information. Harassment becomes unlawful where enduring the offensive conduct becomes a condition of continued employment, or the conduct is severe or pervasive enough to create a work environment that a reasonable person would consider intimidating, hostile, or abusive. Anti-discrimination laws also prohibit harassment against individuals in retaliation for filing a discrimination charge, testifying, or participating in any way in an investigation, proceeding, or lawsuit under these laws; or opposing employment practices that they reasonably believe discriminate against individuals, in violation of these laws.

While employers have made strides in addressing harassment, discrimination or misconduct in the workplace, the fear of retaliation for speaking up persists among many employees. With respect to addressing harassment, discrimination or misconduct in the workplace, the Swift Bunny service is not the proper place for such reporting. Under US law, the responsibility falls on the employer to establish an internal reporting procedure that will encourage employees to report misconduct without the fear of retaliation. Harassment is a form of employment discrimination that violates Title VII of the Civil Rights Act of 1964, the Age Discrimination in Employment Act of 1967, (ADEA), and the Americans with Disabilities Act of 1990, (ADA). See, https://www.eeoc.gov/harassment which requires that employers provide a safe and hostile-free work environment for their employees.

Data Security

While we strive to use commercially acceptable means to protect your Personal Data, we cannot guarantee its absolute security because no method of transmission over the Internet or method of electronic storage is guaranteed to be secure.

Your Rights under the General Data Protection Regulation (GDPR)

Some of you, i.e., European users and those whose information we receive under the EU-U.S. Privacy Shield or under new Standard Contractual Clauses (SCCs) released by the European Data Protection Board (EDPB) in November 2020 have certain legal rights to obtain information about whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request).

European users have the following data protection rights:

• The right to access, update or delete the information we have collected about you. Whenever made possible, you can access, update or request deletion of your Personal Data directly within your account settings section. If you are unable to perform these actions yourself, please contact us to assist you.
• The right of rectification. You have the right to have your information rectified if that information is inaccurate or incomplete.
• The right to object. You have the right to object to our processing of your Personal Data.
• The right of restriction. You have the right to request that we restrict the processing of your personal information.
• The right to data portability. You have the right to be provided with a copy of the information we have on you in a structured, machine-readable and commonly used format.
• The right to withdraw consent. You also have the right to withdraw your consent at any time where Swift Bunny, LLC. relied on your consent to process your personal information.

Please note that we may ask you to verify your identity before responding to such requests. You have the right to complain to a Data Protection Authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority in the European Economic Area (EEA).

Your Rights under the California Consumer Privacy Act

After January 1, 2020, users in the state of California and those whose information we receive from our Service running in California have certain legal rights to obtain information about whether we hold personal information about them, to access personal information we hold about them, and to obtain its correction, update, amendment, or deletion in appropriate circumstances. Some of these rights may be subject to some exceptions or limitations. We will respond to your request to exercise these rights within a reasonable time (and in all cases within 30 days of receiving a request).

Californian users have the following data protection rights:

• the right to know, through a general privacy policy and with more specifics available upon request, what personal information a business has collected about them, where it was sourced from, what it is being used for, whether it is being disclosed or sold, and to whom it is being disclosed or sold;
• the right to “opt out” of allowing anyone to sell their personal information to third parties (or, for consumers who are under 16 years old, the right not to have their personal information sold absent their, or their parent’s, opt-in);
• the right to have Swift Bunny delete their personal information, with some exceptions; and
• the right to receive equal service and pricing from Swift Bunny, even if they exercise their privacy rights under the Act.

On Nov. 3, 2020, California passed the California Privacy Rights and Enforcement Act (CPRA). The CPRA replaces the California Consumer Privacy Act (CCPA). The CPRA will go into effect on Jan. 1, 2023. We will amend our service and privacy policy to comply with CPRA when required to do so.

Please note that we may ask you to verify your identity before responding to such requests.

Your Rights under the Telephone Communication and Privacy Act (TCPA): SMS and Text Messages

By registering with Swift Bunny, you consent to receive text message-based surveys sent through an automatic telephone dialing system. You can choose to “opt out” and disable the sending of text message-based surveys. However, if you do choose to “opt out” and disable the sending of text message-based surveys, you may not be able to use some portions of our Service.

In compliance with the TCPA, you can “opt-out” at any time. When you send STOP, STOPALL, UNSUBSCRIBE, CANCEL, END or QUIT to SMS shortcode numbers, this will prevent you from receiving any additional messages:

"You have successfully been unsubscribed. You will not receive any more messages from this number. Reply START to resubscribe."

When and if you choose to re subscribe, you will receive the following message:

"You have successfully been re subscribed to messages from this number. Reply HELP for help. Reply STOP to unsubscribe. Message and Data Rates May Apply."

Per the TCPA requirements, text message-based surveys will only be sent between 8 a.m. and 9 p.m. in the time zone you are in. Again, you may opt out of receiving any, or all, of these communications from us by following the unsubscribe link or instructions provided in any email we send or by contacting us at support@swiftbunny.com. Please note that we may ask you to verify your identity before responding to such requests.

Your Rights under the Controlling the Assault of Non-Solicited Pornography and Marketing (CAN-SPAM) Act of 2003

The CAN-SPAM Act is a law that sets the rules for commercial email, establishes requirements for commercial messages, gives recipients the right to have emails stopped from being sent to them, and spells out tough penalties for violations. Swift Bunny (Swift Bunny) is committed to permission-based email practices, and in support thereof, has established this no-tolerance Anti-Spam Policy. Swift Bunny may update this policy and provide notice of any changes on its home page. Your use of this website constitutes your acceptance of the terms and conditions of our Anti-Spam Policy.

Spam is commercial email or unsolicited bulk email, including junk mail, which has not been requested by the recipient. Spam is the opposite of permission-based email. Spam is not an accepted promotion technique and Swift Bunny does not condone or engage in Spam and does not tolerate Spam of any sort. Swift Bunny, its Affiliates, Joint Venture Partners and Customers are strictly forbidden to advertise or promote Swift Bunny, products, or services, via any form of Spam. Swift Bunny, its Affiliates, Joint Venture Partners and Customers agree to comply with this Anti-Spam Policy. Swift Bunny reserves the right to determine in its sole discretion what constitutes Spam. Swift Bunny , its Affiliates, Joint Venture Partners and Customers found to be using Swift Bunny programs, products or services to engage in Spam may, at Swift Bunny’s discretion, be immediately cut off from use of all Swift Bunny programs, products and services. Swift Bunny will take any steps it deems necessary to prevent it from being involved in Spam and will legally pursue any person(s) or organization(s) that involve it in Spam allegations. If damages of any kind are levied against Swift Bunny, it will pursue full legal recourse against the offending person(s) and/or organization(s) under any and all applicable laws.

If you believe that you have received Spam connected to Swift Bunny in any way, send a complaint including the unsolicited email, to support@swiftbunny.com.You may also provide any other information that you believe may help an investigation. Swift Bunny does not investigate or take any action based on anonymous Spam complaints.

Service Providers

We may employ third party companies and individuals to facilitate our Service (“Service Providers”), provide the Service on our behalf, perform Service-related services or assist us in analyzing how our Service is used. These third parties have access to your Personal Data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

Analytics

We may use third-party Service Providers to monitor and analyze the use of our Service.

• Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of our Service. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.
• For more information on the privacy practices of Google, please visit the Google Privacy & Terms web page: https://policies.google.com/privacy?hl=en

Links to Other Sites

Our Service may contain links to other sites that are not operated by us. If you click a third-party link, you will be directed to that third party’s site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

Children’s Privacy

Our Service does not address anyone under the age of 18 (“Children”). We do not knowingly collect personally identifiable information from anyone under the age of 18. If you are a parent or guardian and you are aware that your Child has provided us with Personal Data, please contact us. If we become aware that we have collected Personal Data from children without verification of parental consent, we take steps to remove that information from our servers.

Changes to This Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

Contact

If you have any questions about this Privacy Policy, please contact us:

• By email: support@swiftbunny.com