Privacy Policy Overview

This policy (collectively, the “Privacy Policy”) tells you how Swivl ("Swivl", "we" or "us") uses personal information collected through the Swivl Recap™ Services that you access on this site or the Recap app (collectively the “site” or “website”).

Swivl is a Privacy Pledge Signatory and works to safeguard student privacy regarding the collection, maintenance, and use of student personal information.

This site is a service intended for users in educational settings with terms and policies aimed to protect children and student records. This policy is similar in intent, but has some important differences, to the privacy policy of our separate education service offering, Swivl Cloud. This policy is separate and unique to our company website The main purpose of is marketing. It is not intended for use or by users in educational settings and thus does not gather student data When you click on a link from Swivl Cloud to one of our other sites, you are going to a separate site and your use will be governed by the terms of that site and no longer be governed by the terms of this site. Please refer to the posted policies of each site for more information.

Please read this Privacy Policy before using the site or submitting any personal information. When you sign up to start using the site, you are accepting the practices described in this Privacy Policy. We may revise and update this Privacy Policy from time to time. We will provide notice and require consent for any material changes to this policy before using.

Privacy Policy

Updated August 8th, 2016.

Use of Cookies/Do Not Track. Swivl Recap™ Services uses cookies to store visitors’ preferences and to record session information, for purposes of managing and improving the services. We do not link the information we store in cookies to any personal information you submit while on our site. You may be able to configure your browser to accept or reject all or some cookies, or notify you when a cookie is set, so check the "Help” menu of your browser to learn how to change your cookie preferences. We do not respond to "do-not-track" signals or other mechanisms that allow users to signal their preferences on the collection of their personal information over time and across third-party web sites or online services.

Collection, Use and Disclosure of Non-Personal information. For each visitor to our websites, we collect non-personally-identifiable information including IP address, profile information, aggregate user data, preferences, technical session information, browser type ("non-personal information”). If you arrived at our website via a link from another webpage, we also may receive aggregate or otherwise anonymous statistical information about your visit to our site. We also use information collected from cookies and other anonymous identifiers to improve your user experience and the quality of our services. If you give us personal information, we may remove the identifiers and aggregate it, in which case it also becomes non-personal information. We will not use non-personal information for any reason other than the purpose for which it was collected or authorized for use. We may use or share aggregate non-personal information for any reason.

Collection of Personal information. We collect personal information ("personal information”), like names, postal addresses, email addresses, comments, images and videos of your likeness etc., only when voluntarily submitted by you or your authorized users. This information may be provided in the form of videos, comments, photos or forms that contain personal information. We may offer some services on or in collaboration with other Internet web sites, or through third party applications such as gadgets or extensions. Personal information that you provide to those third-party sites may be sent to us so that we can deliver the requested service. We process such information under this Privacy Policy. Any information collected when you enable a third party application on our site is processed under our Privacy Policy. However the use of that information by the third party application provider to whom it is given is governed by their privacy policies.

We also may collect and store personal information about other people that you provide to us. If you use our website to send others information that may interest them or messages through our system, we may store your personal information, and the personal information of each such recipient. Similarly, if you use our website to share and/or distribute content (including videos, comments or other submissions), and such content contains personal information about others, such information may be stored in order to allow for such uploading, sharing and/or distribution.

Use of Personal Information. We only use or process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized for use. We may use personal information we collect to provide the service or transaction you requested, and importantly, to maintain and improve the services we provide, including for example by providing you with a better user experience when accessing our services. We may use your personal information to respond to your requests. Our use of information other than for the purpose of completing a requested transaction or service is on an opt-in basis. This means that you will not receive communications from us regarding, for example, specials, new products or new services, unless you have given us affirmative permission to receive such communications.

Authorized service providers. We may share your personal information with our authorized service providers that perform certain services on our behalf. These services may include providing customer service, performing business analysis and supporting our website functionality or other services that are necessary to operate the site. We do not disclose any personal information to authorized service providers from Student Account holders beyond what is necessary to operate the site. We may share personal information from Teacher Account holders on an opt-in basis to authorized service providers to support contests, sweepstakes, surveys and other features offered through our website now or in the future.

Business partners. We do not disclose any personal information from student account holders with our business partners. We may share personal information from teacher account holders with the businesses with which we partner to offer certain products, services, and promotions. When you elect to engage in a particular offer or program from a third party (for example, through any link that may appear on our website), you authorize us to provide your email address and other information to that third party.

Other situations.

-In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

- When we believe disclosure is appropriate in connection with efforts to investigate, prevent, report or take other action regarding illegal activity, suspected fraud or other wrongdoing; to protect and defend the rights, property or safety of our company, our users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Legal Terms or other agreements or policies.

- In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Information Collected from Residents of the European Union. Swivl's services are hosted and operated entirely within the United States of America, and any information you submit to us is presumed to be hosted on servers located within the USA. By submitting information to us you consent to this transfer of your personal information to the United States. Please note that United States laws may vary from your national laws, and may not offer the same privacy protections as your national laws.

Swivl adheres to the U.S. – EU Safe Harbor Agreement and the U.S. – Switzerland Safe Harbor Agreement concerning the transfer of personal data to the United States of America. We follow the Safe Harbor Principles published by the U.S. Dept. of Commerce with respect to all such data. If there is any conflict between this Privacy Policy and the Safe Harbor Principles, the Safe Harbor Principles shall govern. Information about the Safe Harbor certification program may be reviewed at the U.S. Dept. of Commerce Safeharbor website, and more information about the Safe Harbor Principles may also be found by visiting the U.S. Dept. of Commerce.
Swivl shall refer unresolved privacy complaints received under the Safe Harbor Agreement to the independent dispute resolution program BBB EU Safe Harbor Program as administered by the Council of Better Business Bureaus. If your complaint is not resolved to your satisfaction through our internal dispute resolution efforts, then please visit consult with the BBB EU Safe Harbor program for more information or to file a complaint.

Our Commitment To Children’s Privacy. The Children’s Online Privacy Protection Act (COPPA) was created to protect children under the age of thirteen from unsuspecting practices related to collecting, using, or disclosing any information about them. Children under the age of thirteen must receive consent by an educator or educational institution to use Swivl Recap™ and the educator or educational institution assumes responsibility for obtaining the appropriate parental consent. Swivl does not knowingly accept, collect, maintain or use any information from any child under the age of thirteen without the appropriate consent. If a child whom Swivl knows or suspects to be under the age of thirteen sends personal information to us online without appropriate consent, we will only use that information to respond directly to that child, notify the parents, or seek parental or other appropriate consent. Parents can at any time request deletion of data or of the entire account.

Security. We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration, or destruction. We will use our reasonable efforts to limit access to your personal information to our authorized personnel and third party vendors, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.

General. The Swivl Recap™ Services may include a communications service, such as the ability to forward text and videos to others. If you use the Swivl Recap™ Services to post information about yourself or others, or communicate with others; share content (e.g. pictures, videos, audio files, etc.); and post comments of content, such postings are governed by our Legal Terms. Whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. Once you have posted information, you may not be able to edit or delete such information.

In addition, the Swivl Recap™ Services and information stored on Student Accounts on the Swivl Recap™ Services are not private or confidential between the associated Teacher Account, and Student Account Users should have no expectation of privacy in any part of them. Although each Student Account user has an individual password or class pin to access the Swivl Recap™ Services, the Swivl Recap™ Services and all account information created through or hosted on the Swivl Recap™ Services belongs to the Teacher Account holder and/or Swivl, and all parts of the Swivl Services are accessible by the Teacher Account holder and Swivl management and other personnel as described below in the section on Swivl Policies. The Teacher Account Holder has the right to monitor the Swivl Recap™ Services and their associated Student Account usage at their discretion.

Retention of Educational Records. Users are responsible for determining the duration necessary to retain content for educational purposes. When the educational purpose is complete, it is recommended that users delete the content. Note that content deleted by the user is retained for 30 days for recovery purposes due to accidental deletion (per user request) and then removed permanently from the Swivl Cloud storage servers. In addition, if a users account is inactive for more than a calendar year, content will be automatically deleted using the same procedure. This insures that data is not retained any longer than is required for educational purposes.

Public Video Access. The public cannot see or access the information you post through Swivl Recap™ Services unless you deliberately share public links via email or social media. You are responsible for the content of anything you share, in accordance with our Legal Terms.

Swivl Policies Regarding Access to Information Posted by Swivl Recap™ Services Users. In general, Swivl employees are prohibited from viewing the content of files you store in your account other than for the purposes of providing the Swivl Recap™ Services. Employees may access file metadata (e.g., file names and locations) when they have a legitimate reason, like providing technical support. Like most online services, we have a small number of employees who must be able to access user data for the reasons stated elsewhere in this Privacy Policy (e.g., when legally required to do so). A very select number of employees (senior engineering leadership) have the ability to access video data for the purposes of monitoring that policies are adhered to, when legally required or requested by a user for technical support.

California Privacy Rights. California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an e-mail to or write to us at Privacy, Swivl, 1450 El Camino Real, Menlo Park, CA 94025.

Contact Us

If you have any questions, please send an e-mail to