Effective Date: June 17, 2007

This website, located at www.swiftmailer.net (the "Site"), is owned and operated by Swiftmail ("we," "us"). Your privacy is important to Swiftmail. This Privacy Policy (the "Privacy Policy") outlines the types of Personally Identifiable Information (as defined below) that we gather while you are visiting the Site, as well as ways in which we process and disseminate such Personally Identifiable Information.

Swiftmail reserves the right to change, modify, add, or remove provisions of this Privacy Policy. Any changes to this Privacy Policy will be posted here, and we encourage you to check back from time to time to ensure continuing familiarity with the most current version of our Privacy Policy. You can determine whether the Privacy Policy has been revised since your previous visit to the Site by referring to the "Last Updated" legend at the top of this page. Please read this Privacy Policy carefully. Your use of this Site constitutes your acceptance to be bound by this Privacy Policy without limitation, qualification or change. If at any time you do not accept all the terms and conditions contained herein, you must immediately discontinue use of this Site.

This Site is governed by and operated in accordance with the laws of United States of America (USA). Swiftmail makes no representation that this Site is governed by or operated in accordance with the laws of other nations, or that the Site or any part thereof is appropriate or available for use in any particular jurisdiction. Those who choose to access the Site do so on their own initiative and at their own risk, and are responsible for complying with all local laws, rules and regulations. By using this Site and submitting any PII, visitors from outside of the USA acknowledge this Site is subject to USA law, consent to the transfer of PII to the USA, and waive any claims that may arise under their own national laws.

1. What Information We Collect

Swiftmail gathers two basic types of information through the Site: "Personally Identifiable Information (or "PII") and "Non-Personally Identifiable Information" (or "Non-PII"). Personally Identifiable Information is information that identifies or can identify you as an individual and Non-Personally Identifiable Information is aggregated information, demographic information, IP addresses and any other information that does not reveal your specific identity.

1. Non-Personally Identifiable Information When you visit and interact with the Site, Swiftmail may collect Non-PII (for example, a catalog of the Site pages you visit). Non-PII is generally collected through the Site from four different sources: IP protocol addresses and web logs; cookies; pixel tags and other similar technologies; and information that you voluntarily provide.
   
   
   1. IP Protocol Addresses and Web Logs This Site's web servers automatically collect the Internet Protocol (IP) addresses and log files of visitors. Your IP address is an identifying number that is automatically assigned to your computer by your Internet Service Provider (ISP). This number is identified and logged automatically in our server log files whenever you visit the Site, along with the time(s) of your visit(s) and the page(s) that you visited. We use your IP address, and the IP addresses of all users, for purposes such as calculating Site usage levels, helping diagnose problems with the Site's servers, and administering the Site. Collecting IP addresses is standard practice on the Internet and is done automatically by many websites.
   2. Cookies We and our service providers may use a standard technology called a "cookie" to collect information about how you use the Site. Cookies reside on your computer and help the Site recognize your computer's browser as a previous visitor. In addition, on occasion our Site may also set a "session cookie" which helps us administer the Site. The session cookie expires when you close your browser and does not retain any information about you after it expires. If you do not want information collected through the use of cookies, you should be able to modify your browser preference to provide you with choices relating to cookies. For example, if you use a standard browser, you should have the choice to accept all cookies, to be notified when a cookie is set or to reject all cookies. If you choose to reject cookies, you may be unable to use certain Site services (e.g., those services that require you to log on to the Site in order to participate). For more information on modifying your browser preference, please refer to the documentation accompanying your browser.
   3. Pixel Tags We and our service providers may also use so-called "pixel tags," "web beacons," "clear GIFs" or similar means (collectively, "Pixel Tags") in connection with some Site pages and HTML-formatted email messages to, among other things, compile aggregate statistics about Site usage and response rates. A Pixel Tag is an electronic image, often a single pixel (1x1), that is ordinarily not visible to Site visitors and may be associated with cookies on the visitors’ hard drives. Pixel Tags allow us to count users who have visited certain pages of the Site, to deliver branded services, and to help determine the effectiveness of promotional or advertising campaigns. When used in HTML-formatted email messages, Pixel Tags can tell the sender whether and when the email has been opened.
2. Personally Identifiable Information At this time, the only Personally Identifiable Information we collect are email addresses and names. We collect PII from you through the Site only when you voluntarily provide it. Your PII may also be collected by other websites that are clients of Swiftmail's services when you voluntarily provide it.

2. How Information We Collect Is Used

1. Non-Personally Identifiable Information Because Non-PII does not personally identify you, we may use such information for any purpose. For example, we may use Non-PII to measure the number of visits, average time spent on the Site and pages viewed as well as to diagnose problems with our servers and to administer the Site. We may then use this information to analyze and improve the features and functionality of this Site. We reserve the right to share such Non PII, which does not personally identify you, with third parties, for any purpose.
2. Personally Identifiable Information
   1. Communications: If you choose to opt-in through any of our partnering websites, we may use your PII to send you information specifically from that source. If at any time you change your mind and prefer to no longer receive such marketing communications from us, please see the "Opt-In Policy" section below.
   2. Administrative Matters: Swiftmail reserves the right to contact you in the event of a change in the Site's Terms of Use and/or this Privacy Policy, or to notify you of other administrative matters in connection with the Site (e.g., contacting you to facilitate, complete or confirm a transaction). Because this information may be important to your use of the Site, you may not opt-out of receiving such communications.
   3. Fulfillment of Requests: Swiftmail may use your PII to fulfill the purpose for which such PII was provided (e.g., to confirm your registration).
   4. "Forward This to a Friend": The Site may allow you to forward certain items posted on Site or links to Site features by email to other parties who you believe may be interested. If you wish to use this feature, you may provide us with such other party’s email address so that we can facilitate your sending of such message to such other party. To do so, any PII you provide in connection with sending such other party the message, such as your name and your email address, will, of course, be disclosed to such other party. While, due to technical restrictions, the recipient's email address may be retained in our log files, we do not knowingly share it with third parties (unless the recipient has already consented to such use of his/her PII).

3. How Personally Identifiable Information We Collect Is Disclosed

1. Compliance With Applicable Law: Swiftmail may also access and disclose PII as needed to: (1) comply with applicable laws; (2) respond to governmental inquiries or requests; (3) comply with valid legal process; (4) protect the rights, privacy, safety or property of Swiftmail, Site visitors or the public; (5) permit us to pursue available remedies or limit the damages that we may sustain; and (6) enforce our Terms of Use or other published guidelines.
   
   In the event that you encounter any Site user who you believe is improperly collecting or using information about you or other users, please contact us at privacy@swiftmailer.net to send us an email about such collection or use.
   
2. Assignment: We reserve the right to transfer any and all information that we collect from users of the Site to a third party in the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of Swiftmail's business, assets or stock (including without limitation in connection with any bankruptcy or similar proceedings).

4. Opt-In Policy

1. Swiftmail Communications When this Site or an affiliate, you may choose to disclose PII in order to sign up to a mailing list. If you do choose to opt-in to receive such communications, we may, from time to time, send you marketing communications on behalf of the partner from which you opted-in. If at any time you change your mind and no longer wish to receive marketing communications from us, you may opt-out of such marketing communications by either:
   1. Using the link provided in our newsletters or commercial email messages to opt-out of receiving further marketing communications from us; or
   2. Contacting us directly at privacy@swiftmailer.net.
   
   If you decide to unsubscribe, Swiftmail will implement this change in a reasonable time frame.

5. Use of This Site by Children The Site is not directed to individuals under the age of thirteen (13), and we request that such individuals do not provide PII through the Site.

6. Accessing, Updating or Deleting Information Collected About You This Site also gives you the opportunity to remove PII that you have provided to us by way of this Site or its affiliates. You may do so by modifying your password-protected registered user information on the Site. To the extent that such information is stored in our databases, we will respond to your changes as soon as reasonably practicable, although please understand that although this information, once deleted, is not available on the Site, that information may remain stored indefinitely in our backup and archival records. However, to the extent that such information is not stored in our databases, we cannot always ensure that these corrections or deletions will reach such other databases in a timely manner.

7. Security of Your PII Swiftmail employs reasonable security measures consistent with standard industry practice, for PII collected through this Site. Unfortunately, no data transmission over the Internet or method of storing data can be guaranteed to be 100% secure. As such, we cannot guarantee that PII supplied by users will not be accessed on our servers, or intercepted while being transmitted to us over the Internet. If you have reason to believe that there has been any breach of the security of the Site, please contact us at privacy@swiftmailer.net.

8. Offline vs. Online practices Please note that this Privacy Policy applies solely to our online information gathering and dissemination practices in connection with the Site, and does not apply to any of our practices conducted offline.

9. Contacting Swiftmail Regarding this Site If you have any questions concerning this privacy policy, you may send them by email to privacy@swiftmailer.net. Please note that email communications will not necessarily be secure. You must send any official correspondence via postal mail to:

Swiftmail
201 50th Avenue #25B
New York, NY 11101