Effective Date: April 19, 2023


This Privacy Shield Policy (“Policy”) describes how Agero, Inc.’s subsidiary, SwoopMe, Inc. and its affiliates in the United States (“U.S.”) (“Swoop”, “we” or “us”) collect, use, and disclose certain personal information that we receive in the U.S. from the European Economic Area (“EEA”), Switzerland, and the United Kingdom (“U.K.”). This Policy applies to the U.S. affiliated entity SwoopMe, Inc. and supplements our Website Privacy Policy located at www.agero.com/privacy-cookies-policy. Unless specifically defined in this Policy, the terms in this Policy have the same meaning as the Website Privacy Policy.

Swoop complies with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union to the United States. Swoop has certified to the U.S. Department of Commerce that it adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/. For purposes of enforcing compliance with the Privacy Shield, Swoop is subject to the investigatory and enforcement authority of the U.S. Federal Trade Commission.

Questions or Complaints
In compliance with the Privacy Shield Principles, Swoop and its affiliates in the United States commit to resolve complaints about our collection or use of your personal information. Individuals in the European Union or Switzerland with inquiries or complaints regarding our Privacy Shield Policy should first contact Swoop at:

Postal Address:
Attn: Legal/Consumer Privacy Inquiries Mailbox
PO Box 9105
Medford, MA 02155

Email: consumerprivacyinquiries@agero.com

We will investigate and attempt to resolve any complaints or disputes regarding the use or disclosure of your personal information within 45 days of receiving your complaint. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider, (free of charge) at: https://feedback-form.truste.com/watchdog/request.

Swoop has further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning human resources data transferred from the EU in the context of the employment relationship. If you have an unresolved privacy or data use concern that we have not addressed satisfactorily, please contact our U.S.-based third party dispute resolution provider (free of charge) at: https://feedback-form.truste.com/watchdog/request. Under certain circumstances, we may remain liable for the acts of our third-party agents or service providers who perform services on our behalf for their handling of Personal Data that we transfer to them.

Binding Arbitration
You may have the option to select binding arbitration for the resolution of your complaint under certain circumstances, provided you have taken the following steps: (1) raised your compliant directly with Swoop and provided us the opportunity to resolve the issue; (2) made use of the independent dispute resolution mechanism identified above; and (3) raised the issue through the relevant data protection authority and allowed the US Department of Commerce an opportunity to resolve the complaint at no cost to you. For more information on binding arbitration, see US Department of Commerce's Privacy Shield Framework: Annex I (Binding Arbitration).

Changes to Our Privacy Shield Policy
Swoop reserves the right to amend this policy at our discretion and at any time. When we make changes to this policy, we will post the updated notice on the website and update the notice’s effective date. Your continued use of our Services following the posting of changes constitutes your acceptance of such changes.

SwoopMe, Inc. is a subsidiary of Agero, Inc.
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