Privacy Policy

Effective Date: September 27, 2022


Swirlds Labs Inc. (“Swirlds Labs,” “we,” “our,” or “us”) is committed to protecting your privacy.  This Privacy Policy (“Privacy Policy”) describes how Swirlds Labs collects and treats your personal information.  By accessing or using our websites, including,, and other sites where the Privacy Policy is located or linked (the “Site(s)”), you signify that you agree to our collection, storage, use and disclosure of your personal information as described in this Privacy Policy and our Terms of Use.


We may collect information from you and about you. Here are some examples of the information we may collect:

  • Contact Information. For example, we may collect your name, mailing address, telephone number and email address. We may also collect your mobile phone number.
  • Information You Submit. We may collect information when you send us a message through the “Contact Us” page or similar features on our Site(s).
  • Device Information. For example, we may collect the type of device you use to access our Site(s). We may also collect your device identifier, IP address or mobile operating system.
  • Commercial Information. We may collect personal information that could identify you and relates to the services in which you are interested or have considered. We may also collect personal information about your consuming history or tendencies.
  • Account Information. Certain portions of the Site(s) may allow you to create a user account. In connection with that account, we may collect your username and password.
  • Other Information. If you use our Site(s), we may collect information about the browser you are using. We might look at what site you came from, or what site you visit when you leave us.


We collect your information in different ways. Below are some examples of how we may collect your information.

  • Directly From You. For example, when you register for an account or submit an inquiry to us.
  • Passively. For example, when you visit and navigate our Site(s) on any device. We may also collect information about users over time and across different websites and devices when you use the Site(s).
  • From Third Parties. We may receive information about you from other sources. For example, this may include receiving information from our business partners, including analytics vendors.
  • By Combining Information. For example, we may combine information that we collect offline with information we collect through our Site(s). We may also combine information we collect about you from the different devices you use to access our Site(s).


Examples of how we may use your information include:

  • To Run and Improve Our Site(s), Services, and Business. We may use your information to make our Site(s) and business better. We may also use your information to provide you with information about our business.
  • To Customize the content you see when you use the Site(s).
  • To Respond to Your Requests or Questions. This may include responding to your feedback.
  • To Communicate With You. We may communicate with you about your account or our relationship. We may also contact you about this Privacy Policy or our Site(s) terms and conditions.
  • For Marketing Purposes. We may provide you with information about our company and our business initiatives. For more information about your choices related to these communications, see the Choices section below.
  • For Security Purposes. This could include protecting our company and consumers who use our products and services. It may also include protecting our Site(s) or the services that we offer.
  • As Otherwise Permitted By Law or As We May Notify You.
  • As Requested or Directed By You.


We may share your information in the following ways:

  • Internally. We may share your information with our parent, subsidiary, and affiliate entities.
  • With Our Service Providers. We may share your information with third parties who perform services on our behalf. For example, this may include companies that send emails on our behalf or help us run our Site(s) or services.
  • With Our Business Partners. For example, we may also share personal information with social media sites, advertisers, media buying agencies, advertising networks and advertising service providers for the purposes described in this Privacy Policy. We may also share personal information with companies that help us learn more about our customers.
  • With Any Successors to All or Part of Our Business. For example, if we merge with, are acquired by, or sell part of our business to another entity. This may include an asset sale, corporate reorganization or other change of control.
  • To Comply With the Law or To Protect Ourselves. For example, this could include responding to subpoenas, court orders, legal process, law enforcement requests, legal claims or government inquiries, and to protect and defend our rights, safety, and security.  We might share information when we are investigating a potential fraud.
  • For Other Reasons We May Describe to You.
  • As Requested or Directed By You.


The Site(s) where this Privacy Policy is located are meant for adults. We do not knowingly collect personally identifiable data from persons under the age of 13, and strive to comply with the provisions of COPPA (The Children’s Online Privacy Protection Act). If you are a parent or legal guardian and think your child under 13 has provided us with information, please contact us at [email protected]. You can also write to us at the address listed at the end of this Privacy Policy. Please mark your inquiries “COPPA Information Request.” Parents, you can learn more about how to protect children’s privacy on-line here.


You have certain choices about how we use your information. Certain choices you make are browser and device specific.

Marketing Communications:

You can opt out of receiving our marketing communications. Note that you will still receive transactional messages from us, including information about your account and responses to your inquiries.

Cookies & Other Tracking Technologies:

  • Cookies: You can adjust your browser to control cookies to require your affirmative acceptance for new cookies, automatically reject cookies and/or delete or disable existing cookies. How you do so depends on the type of cookie and the browser that you are using. For more information on how to control browser cookies, click here. If information about your browser is not available through this page, please search your browser for instructions about how to opt-out of cookie collection.
  • Flash Cookies: You may need to take an additional action to manage flash cookies, which you can learn more about here. Why? Because flash cookies cannot be controlled through your browser settings.
  • Google Analytics: We may use Google Analytics on our Site(s) to help us understand how you use our Site(s) and services. You can learn about how to opt-out of Google Analytics here.
  • Facebook: We may use Facebook cookies to target ads to you. You can learn about how to opt-out of receiving targeted advertisements from Facebook here.
  • Email Tools: You can also change your email settings to block the automatic download of images in email messages, as such images may contain technologies that help us understand how you interact with the message.
  • Note that deleting or blocking cookies may impact your experience on our Site(s), as some features may not be available. Certain options you select are browser and device specific.

Our Do Not Track Policy:

  • Some browsers have “do not track” features that allow you to tell a website not to track you. These features are not all uniform. We do not currently respond to those signals.  If you block cookies, certain features on our Site(s) may not work.  If you block or reject cookies, not all of the tracking described here will stop.
  • Options you select are browser and device specific.


There are potentially serious security issues with any computer connected to the Internet without the appropriate protection. By using the Site(s), you acknowledge and knowingly accept the potentially serious risks of accessing the Internet over an unsecured network.

We do not promise that your use of our Site(s) will be completely safe. We encourage you to use caution when using the Internet. We use commercially reasonable means to safeguard personal information under our control.  A username and a password may be needed to access certain areas of our Site(s). It is your responsibility to protect your username and password.


We operate our Site(s) and engage service providers in various jurisdictions. Information we maintain and/or collect through our Site(s) may be stored in or outside of the United States. If you live outside of the United States, you understand and agree that we may transfer your personal information to the United States or to another country or jurisdiction that does not have the same data protection laws as your jurisdiction.  We will take steps to ensure that your personal data are treated securely and in accordance with this Privacy Policy.  For individuals based in the EU, we store personal data for as long as necessary to fulfill the purposes for which we collect the data (see “How We Use Your Information”) and in accordance with our legal obligations and legitimate business interest, except if otherwise required by law.


The California Consumer Privacy Act or “CCPA” (Cal. Civ. Code § 1798.100 et seq) requires specific disclosures and provides certain rights for California residents with respect to their personal information. If you are a California resident, this section applies to you.

We explain the categories of information that we collect and the sources of that information in the section above entitled “Types of Information We Collect” and “How We Collect Your Information.”  We explain how we use your personal information in the section above entitled “How We Use Your Information” and we explain when we may share your information in the section entitled “How We Share Your Information.”

We do not sell your personal information.

Subject to certain limits, you have the right to request information about how we collect, use and disclose your personal information, the right to request deletion of your personal information, and the right not to be discriminated against for exercising your privacy rights.  We explain the controls you have to manage your personal information in the section above entitled “Choices Regarding Your Information.”  In addition, you may make requests related to your rights under the CCPA by contacting us as set out in the “How to Contact Us” section below.  We will verify your request by asking you to provide information related to your recent interactions with us.  We will not discriminate against you for exercising any of your rights under the CCPA.


If you are located in the European Economic Area (“EEA”), the United Kingdom (“UK”), or Switzerland, the law provides you certain rights and protections with respect to the processing of your personal data, and this section applies to you.

You have a right to know the legal basis on which we collect, use and process your personal data.  When we collect, use or process your personal data, we rely on the following legal bases: (a) to perform any contractual relationship we have with you; (b) where it is necessary for compliance with our legal obligations (such as to record your permissions or consents and track who has opted out of communications); (c) where we have legitimate interests in processing your personal information to operate our business or protect our interests and/or the interests of our affiliated entities, such as to communicate with you to respond to your requests and inquiries, to conduct data analysis, to improve our product and service offerings, to personalize your visit to the Site(s), for fraud prevention and detection, and to comply with applicable laws, regulations or codes of practice; and (d) when we have your consent to do so, provide that where consent is the legal basis for our processing your personal information, you have the right to withdraw your consent at any time.

Subject to certain limits, you have the following rights with respect to your personal information: (i) the right to obtain access to the personal information that we have about you; (ii) the right have your personal information corrected if it is inaccurate or incomplete, (iii) the right to have your personal information deleted in certain circumstances, such as where the personal information is no longer necessary in relation to the purposes for which it was collected or processed, (iv) the right to object to, or request that we restrict, processing of your personal information under certain circumstances, such as if you are contesting the accuracy of the data for a period enabling us to verify its accuracy; and (v) the right to move, copy or transfer your personal data from one organization to another (I.e., the right of portability).

Please note that if you withdraw your consent for us to process your personal information, or you remove or request erasure of your personal information from the Site(s), this may affect your ability to access or use the Site(s) or the quality of your experience.

If you would like to exercise any of your rights with respect to your personal information, please contact us as set out in the “How To Contact Us” section below.

If you have questions or concerns that we are not able to resolve about how we handle your personal information, you also have the right to lodge a complaint to your local data protection authority.  Further information about how to contact your local data protection authority is available at the following links:  (EEA), (UK), (Switzerland).


Our Site(s) may contain links to other third-party sites that available over the Internet and are not governed by this Privacy Policy. If you click on a link to a third-party site, you are leaving our Site(s) and will be taken to a site we do not control.  We are not responsible for the content or privacy practices used by third-party sites. We suggest that you read the privacy policies of those sites carefully. If you access third-party services through the Site(s) to login to the Site(s) or to share information about your experience on the Site(s) with others, these third-party services may be able to collect information about you, including information about your activity on the Site(s), and they may notify your connections on the third-party services about your use of the Site(s), in accordance with their own privacy policies.


If you have any questions, comments or concerns with respect to our privacy practices or this Privacy Policy, or wish to update your information, please contact us at [email protected] Re: Swirlds Labs Privacy Policy.


You acknowledge and agree that this Privacy Policy may be revised from time to time in our sole discretion, with any such modifications effective when the revised Privacy Policy is posted here as of the Effective Date. It is your responsibility to review this Privacy Policy frequently and remain informed about any changes to it, so we encourage you to visit this page often. Your continued use of the Site(s) indicates consent to be bound by the revised Privacy Policy.