Privacy Policy

Effective Date: 10/25/2023 Date Last Updated: 10/25/2023 This Privacy Policy (“Policy”) describes how Swai, its brands, affiliates, and subsidiaries (“Swai,” “we,” “our,” and “us”) collects, uses, discloses, and otherwise process personal information described in this Policy. Except as otherwise indicated, this Policy applies to the personal information collected when you visit our website – (our “Site”) or use our swai mobile application (our “App”) (collectively the “Services”). By using our Services, you agree that your personal information will be handled as described in this Policy. Your use of our Services and any dispute over privacy is subject to this Policy and our Terms of Use, available at, including their applicable terms governing limitations on damages and the resolution of disputes.

Table of Contents

Personal Information We Collect

As further described below, we may collect personal information directly from you, from third-party sources, and automatically through your use of our Services.

A. Personal Information We Collect Directly from You

We primarily collect personal information directly from you, including the following.
  • Contact Information. We collect information such as first and last name, username, company name and address, and business contact information, including your phone number and email address.
  • Account Information. When you create an account with us, we collect information such as your username and password.
  • Message Contents. If you communicate with us, such as through Services or email, we collect your contact information, message contents, and any other information you may choose to provide.
  • Preferences. We also may collect information about your preferences, including communications preference and other preferences you provide when interacting with us or the Services.

B. Personal Information Collected from Third Parties

We may collect personal information about you from third party sources, such as public databases, joint marketing partners, social media platforms or other third parties.
  • We may receive personal data about you from your employer or other organization that subscribes to our Services. For example, your employer may provide us with your name and contact information in order to provide you with access to the Services.

C. Personal Information Collected Automatically

In addition, we may automatically collect or derive personal information about you related to your use of and interactions with our Site, including through the use of cookies, pixel tags, and other similar technologies, as well as information we derive about you and your use of the Services. To the extent permitted by applicable law, we may combine Device Identifiers and Network and Activity Information (described below) with other information we collect, including personal information. The personal information we may automatically collect includes:
  • Device Identifiers. When you interact with us, we automatically collect information such as IP addresses, unique device identifiers, operating system, and other information related to the device used to interact with our Services.
  • Network and Activity Information. We may collect information related to how you interact with our Services, including referring and exit web pages and URLs, browsing history, links clicked, searches, features used, time spent within the Services, crashes or service incidents, time spent logged in to the Services, and your interactions with others within the Services. As described below in the “Our Use of Cookies” section, we may use analytics providers and technologies, including cookies and similar tools, to collect this information.
  • Audio Recordings. We offer a specialized real-time transcription service to sales managers in the automobile [and other] industries. Our service allows sales managers to gain insights into their sales representatives’ interactions with customers. When an App user enables access to their device’s microphone, our App provides audio transcription and analysis of sales representatives’ conversations with customers. This real-time transcription service is designed to identify objections raised during the conversation and analyze the responses of the sales representatives. We may use sales interaction transcripts to train and improve our sales training algorithms. App users have the ability to enable or disable the App’s access to their device’s microphone at any time, giving them full control over the transcription feature.
  • Location Information. With your permission, we use App users’ geolocation information to limit the App’s features to times where the App user is proximate to their workplace (i.e., when an automobile sales representative is at or close to the automobile dealership where they work). App users may turn off geolocation information sharing through their mobile device’s settings, however doing so will disable the App’s audio recording capabilities. If the user disables geolocation information sharing, the App software may notify the user’s manager (as the App will no longer be able to transcribe and analyze sales interactions).

How We Use Personal Information

We may collect, use, disclose and otherwise process the personal information we collect for the following purposes:
  • Services and support. To provide and operate our Services, communicate with you about your use of the Services, provide troubleshooting and technical support, respond to your inquiries, fulfill your orders and requests, process your payments, and for similar service and support purposes.
  • Analytics and improvement. To better understand how users access and use the Services and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our Services and business operations, to develop services and features and new products, and for internal quality control and training purposes. As noted above, we may use sales interaction transcripts to train and improve our sales training algorithms.
  • Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
  • Marketing and advertising. For marketing and advertising purposes. For example, to send you information about our Services, such as offers, promotions, newsletters, and other marketing content, [including about third-party products and services we think may interest you,] as well as any other information that you sign up to receive. We also may use certain information we collect to manage and improve our advertising campaigns so that we can better reach people with relevant content.
  • Planning and managing events. For event planning and management, including registration, attendance, connecting you with other event attendees, and contacting you about relevant events and Services.
  • Research and surveys. To administer surveys and questionnaires, such as for market research or user satisfaction purposes.
  • Security and protection of rights. To protect the Services and our business operations; to protect our rights or those of our stakeholders; to prevent and detect fraud, unauthorized activities and access, and other misuse; where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or other agreements we have entered into with you or your employer/organization.
  • Compliance and legal process. To comply with the law and our legal obligations, to respond to legal process and related to legal proceedings.
  • General business and operational support. To consider and implement mergers, acquisitions, reorganizations, bankruptcies, and other business transactions such as financings, and related to the administration of our general business, accounting, auditing, compliance, recordkeeping, and legal functions.

How We Disclose Personal Information

We may disclose the personal information we collect for the purposes described above, with the following recipients:
  • Vendors and Service Providers. We may disclose the personal information we collect to our service providers, vendors, contractors, or agents who perform functions on our behalf. This includes entities that host our Services, perform research and development, process payments, verify identity, and assist us in performing analytics.
  • Users’ Employers. We disclose information we collect about users of our App to their respective employers, who are our clients. This may include information about users’ customer interactions and how users may use the App.
  • Affiliates and Subsidiaries. We may disclose the personal information we collect to our corporate affiliates and subsidiaries.
  • Third party platforms, providers, and networks. We may disclose or make available personal information to third party platforms and providers that we use to provide or make available certain features or portions of the Services, or as necessary to respond to your requests. We may also make certain information that includes personal information available to third parties in support of our marketing, analytics, advertising, and campaign management (see Cookies, Targeting and Analytics for more information).
We also may disclose personal information in the following circumstances:
  • In Support of Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company; or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the personal information we have collected about you to the other company. As part of the business transfer process, we may share certain personal information with lenders, auditors, and advisors, including attorneys and consultants.
  • In Response to Legal Process. We may disclose personal information to comply with the law, a judicial proceeding, court order, law enforcement request, or other legal process, such as in response to a court order or a subpoena.
  • To Protect Us and Others. We may disclose personal information when we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our terms of use or this Policy, or as evidence in litigation in which we are involved.
  • Aggregate and Deidentified Information. Notwithstanding anything else in this Policy, we may use, disclose, and otherwise process aggregate or deidentified information related to our business or the Services with third parties for quality control, analytics, research, development, and other purposes.
  • With Permission. We may disclose personal information in ways not described above. If we do so, we will notify you, and if necessary, obtain consent.

Our Use of Cookies

We and our providers use cookies, pixel tags, and other similar tracking mechanisms to automatically collect information about browsing activity, type of device, and similar information within our Services. We use this information to, for example, analyze and understand how you access, use, and interact with us through our Services, to identify and resolve bugs and errors in our Services, to assess, secure, protect, optimize, and improve the performance of our Services, for marketing and advertising purposes, analytics purposes, and to personalize content on our Services. We may also aggregate such information to analyze trends, administer our Services, and gather broad demographic information. Cookies. “Cookies” are alphanumeric identifiers we transfer to your device’s hard drive through your web browser for tracking purposes. Some cookies allow us to make it easier for you to navigate our Site, while others are used to enable a faster log-in process, support the security and performance of the Site, or allow us to track activity and usage data within the Site. Pixel Tags. Pixel tags (sometime called web beacons or clear GIFs) are tiny graphics with a unique identifier, similar in function to cookies. While cookies are stored locally on your device, pixel tags are embedded invisibly within web pages and online content. We may use these, in connection with our Services to, among other things, track the activities of users, and help us manage content and compile usage statistics. We may also use these in our emails to let us know when they have been opened or forwarded, so we can track response rates and gauge the effectiveness of our communications. Do Not Track. Currently, our Site does not recognize “Do-Not-Track” requests. You may, however, disable certain tracking as discussed below (e.g., by disabling cookies). Third-Party Analytics and Tools. We use third party tools, such as Google Analytics, which are operated by third party companies. These third-party analytics companies may collect usage data (using cookies, pixels, and similar tools) about our Services to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at Targeted Advertising. We work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to personalize content and display advertising, as well as to manage our advertising on third-party sites, mobile apps, and online services. We may share certain information with these third-party ad companies, and we and them may use cookies, pixels tags, and other tools to collect usage and browsing information within our Site, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies use this information to provide you with more relevant ads and content on third-party sites and apps, and to evaluate the success of such ads and content.

Your Privacy Choices

We make available several ways for you to manage choices about your personal information, including preferences regarding cookies, advertising, whether you want to receive marketing and promotional emails from us, and choices regarding your account and profile information.
  • Cookie Settings. To prevent cookies from tracking your activity on our Site, you can set your browser to block certain cookies or notify you when a cookie is set; you can also delete cookies. The “Help” portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to delete cookies. Note, visitors to our Site who disable cookies will be able to browse the Site, but some features may not function.
  • Industry ad choice programs. You can control how participating third-party ad companies use the information that they collect about your visits to our Site, and those of third parties, to display more relevant targeted advertising to you. If you are in the U.S., you can obtain more information and opt out of receiving targeted ads from participating third-party ad networks at (Digital Advertising Alliance). You may also download the DAA AppChoices tool ( in order to help control interest-based advertising on apps on your mobile device. Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or ‘contextual’ ads on websites you visit or apps you use. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
  • Marketing Communications. You can opt out of receiving marketing emails from us by using the unsubscribe feature in any such email we send you.
  • Account and Profile Information. If you have an account with us, you may access, review, and update your account and profile information, such as your name, email address, contact information, preferences, and other profile information by logging in and accessing the information directly within your account.

Information Regarding Children

Our Services are not designed for children. We do not knowingly collect personal information from children under the age of 13 without parental consent. If we become aware that we have collected information from a child under 13 years old without parental consent, we will delete such information from our records. If you are a parent or legal guardian and believe your child has given us information and you did not provide consent, please contact us using the information provided in the “Contact Us” section below.


We have implemented safeguards intended to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security. There are also certain steps you can take to better protect against unauthorized access to your personal data. For example, you should choose a strong password for your that is unique to the Services; you should not reuse passwords across multiple sites and services or share your password with others.


We retain the personal information we collect only as reasonably necessary for the purposes described above or otherwise disclosed to you at the time of collection. For example, we will retain your personal information and account data for as long as you have an active account with us, for as long as necessary to comply with our tax, accounting and recordkeeping, and other legal obligations, and for research, development and safety purposes, as well as an additional period of time as necessary to protect, defend or establish our rights, defend against potential claims, and comply with legal obligations. Our Services may contain links to unaffiliated websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those websites. We are not responsible for the information practices of such websites.

Updates to This Policy

This Policy is current as of the date set forth above. We may change, update, or modify this Policy from time to time, so please be sure to check back periodically. We will post any updates to this Policy here. If we make any changes to this Policy that materially affect our practices regarding our use of the personal information, we have previously collected from you, we will endeavor to provide you with notice, such as by emailing you or by posting prominent notice on our Services and obtain your consent where required by applicable law.

Contact Us

If you have any questions or concerns regarding this Policy or our privacy practices, you may contact us at: