Privacy Policy


Revision Date: April 18, 2018

Thank you for shopping at Snappee™ by SwirlyCurly (“SwirlyCurly”). SwirlyCurly is committed to respecting the privacy rights and protecting the personal information of online visitors to our website,, including all of its subdomains and subparts (the “Site”). This Privacy Policy was developed to inform visitors to the Site about how we handle and use personal information. BY USING THE SITE, YOU AGREE TO THE COLLECTION, USE, AND DISCLOSURE OF INFORMATION IN ACCORDANCE WITH THIS PRIVACY POLICY.

If you have questions about this Privacy Policy, please contact us at


When you visit the Site you may provide us with two types of information: (1) personally identifiable information that you voluntarily disclose so that we may provide products or services to you, such as when you register for an account; and (2) website use information collected automatically as you browse the Site. By using the Site, or allowing someone to do so on your behalf, you are consenting to our collection, use, disclosure, transfer, storage, retention, and eventual destruction in accordance with this Privacy Policy of any personally identifiable information or other information received by us as a result of such use.


We may collect personally identifiable information about you, including, without limitation, your name, address, telephone number, e-mail address, and order details. If you choose to correspond with us through email or social media, we may retain the content of your messages, together with your email address and our responses.


Like many site operators, we also collect certain data that your browser sends to us from the computer, mobile device, and/or browser through which you access the Site (“Log Data”). This Log Data includes, without limitation, your device’s Internet Protocol (“IP”) address, browser type, browser version, statistics on your activities on the Site (such as the date and time of visits, the pages viewed, time spent at the Site), information about how you came to the Site, and data collected through cookies or other similar technologies discussed in more detail below in our Cookie Policy. In addition, we may use third-party services such as Google Analytics that collect, monitor, and analyze Log Data. Much of this Log Data is not personally identifiable information. However, when you submit personally identifiable information to us, we may associate this Log Data with your personally identifiable information. At such time, we will treat any such combined data as personally identifiable information until such time as it can no longer be associated with you or used to identify you.


Generally speaking, we use personally identifiable information for the purpose for which you provided it. If you order a product, we will use your name and contact information to fulfill your needs, including billing, and delivery. If you send us an email, we may use your email address and other information you submit to provide customer service to you. We may also use your personally identifiable information or Log Data to administer our internal business activities, such as to design and arrange the Site in the most user-friendly manner and to continually improve the Site to better meet the needs of our customers and prospective customers, to better understand visitors to the Site, to manage your account, and/or to provide customer service.



We will not sell your personally identifiable information to third parties, including third party advertisers. There are, however, certain circumstances in which we may disclose, transfer, or share your personally identifiable information with certain third parties without further notice to you, as set forth below.


As we develop our business, we might sell or buy businesses or assets. In the event of a corporate sale, merger, reorganization, dissolution, or similar event, personally identifiable information may be part of the transferred assets. You acknowledge and agree that any successor to or acquirer of SwirlyCurly (or its assets) will continue to have the right to use your personally identifiable information and other information in accordance with the terms of this Privacy Policy.


We, like many businesses, sometimes engage other companies to perform certain business-related functions. These companies may include marketing agencies, database service providers, backup and disaster recovery service providers, email service providers, payment processors, and others. When we engage another company to perform such functions, we may provide it with personally identifiable information, Log Data, or aggregate information about our customers, sales, website traffic patterns, and related website information, in connection with its performance of such functions. However, we do not collect or store credit card information or internet protocol addresses directly; rather, we employ a third-party payment processor and web platform provider who may collect, store, and use such information. We take measures to select service providers that are responsible and afford privacy protections to their customers, such as those that comply with the Payment Card Industry Data Security Standards. However, we cannot make any representations about the practices and policies of these third-party companies.


We work with third parties, including social media sites like Facebook, YouTube, and Instagram, and with application developers who specialize in social commerce so you can connect to SwirlyCurly through your social networks. All of these companies operate Third Party Sites, as defined below. We provide access to our Site by third parties and business partners so we can generate interest in our products among members of your social networks and to allow you to share your interests with friends in your network. If you use features made available on our Site by a third party social media site, your personally identifiable information may be collected or shared by us or by the third party. We consider information collected or shared through any such social media features as public information because the third party social media sites made it publicly available. If you do not want us to be able to access information about you from Third Party Sites, you must instruct the Third-Party Sites not to share the information with us. We do not control how these third parties use information collected from or about you, so be sure to review the privacy policies and privacy settings on your social media sites to make sure you understand the information they are sharing. If you do not want a Third-Party Site to share information about you, you must contact that site and determine whether it gives you the opportunity to opt out of sharing such information.

We use features on third party social media sites that allow you to express opinions about products, surveys, or your interests. Those Third-Party Sites may collect or register your views (including whether you liked or purchased a product) and make those views available to us and on public portions of the Third-Party Sites. You can avoid such collection and use of your personally identifiable information by declining to buy products through Third Party Sites or to express your views on Third Party Sites. Third Party Sites may also give you the option to limit such data collection and disclosure in the privacy settings on their sites. We reserve the right not to display your personally identifiable information or content on our social media accounts or Site even if you express an opinion about our products or services or consent to our use of such information or content. We reserve the right to remove personally identifiable or other information of any person for any reason. We may also remove from our social media accounts or Site, in our sole discretion, any product offering or any photo or product description.


We may disclose your personally identifiable information if required to do so by law (including, without limitation, responding to a subpoena or request from law enforcement, a court, or a government agency) or in the good faith belief that such action is necessary to: (a) comply with a legal obligation; (b) protect or defend our rights, interests, or property, or that of third parties; (c) prevent or investigate possible wrongdoing in connection with the Site; (d) act in urgent circumstances to protect the personal safety of users of the Site or the public; or (e) protect against legal liability.


You may choose to limit the personally identifiable information you submit by merely browsing the Site without providing your name or other information. If you do so, you may not be able to use certain functionality of the Site.


We are committed to the protection of your information. When you place an order through the Site, we encode your information using Secure Socket Layer (SSL) encryption technology. While we have employed security technologies and procedures to assist safeguarding your personal information, no system or network can be guaranteed to be 100% secure.


We may store personally identifiable information itself or such information may be stored by third parties to whom we have transferred it in accordance with this Privacy Policy. We take what we believe to be reasonable steps to protect the personally identifiably information collected via the Site from loss, misuse, unauthorized access, inadvertent disclosure, alteration, and destruction. However, no network, server, database, or Internet or e-mail transmission, is ever fully secure or error free. Therefore, you should take special care in deciding what information you send to us electronically. Please keep this in mind when disclosing any personally identifiable information.


If you have registered for an account on the Site, you may request access to or correction of all of your personally identifiable information that we collect online and maintain by contacting us at We will take reasonable steps to respond to requests relating to personally identifiable information within thirty (30) days, however, we may reject requests that we find to be unreasonable (i.e., require disproportionate efforts or material changes to our information systems), impractical, or abusive (i.e., repetitive requests, requests made in bad faith, requests that would compromise third party information).


We may retain your personally identifiable information as long as you continue to use the Site. You may close your account by contacting However, we may retain personally identifiable information for an additional period as is permitted or required under applicable laws. Even if we delete your personally identifiable information, it may persist on backup or archival media for an additional period of time.


We periodically review this Privacy Policy for compliance with legal requirements, and corporate policies and procedures governing the security, confidentiality, and quality of our information. The effective date of this version of the Privacy Policy can be seen on top of this page (under the main headline).


Please refer to our Cookie Policy below, which is hereby incorporated by reference into this Privacy Policy, for more information about our use of these technologies.



Our emails and/or the Site may contain links to other websites not operated or controlled by us (the “Third Party Sites”). This Privacy Policy applies only to the Site. The policies and procedures we describe here do not apply to the Third-Party Sites. The links from our emails and/or the Site do not imply that we endorse or have reviewed the Third-Party Sites. We are not responsible for the practices employed by the Third-Party Sites linked to or from our emails or the Site nor the information or content contained therein. We suggest contacting those sites directly for information on their privacy policies.


When you interact with the Site, we may also collect non-personally identifiable data. The limitations and requirements in this Privacy Policy on our collection, use, disclosure, transfer, and storage/retention of personally identifiable information do not apply to non-personally identifiable data. The non-personally identifiable data we collect include, without limitation, Log Data, domain names of your Internet Service Provider, your approximate geographic location, a record of your usage of the Site, the time of your usage and aggregated personally identifiable information, but only to the extent that the foregoing cannot be used to specifically identify you. However, if we combine non-personally identifiable data with personally identifiable information, we will treat the combined data as personally identifiable information.


In an ongoing effort to better understand and serve visitors of the Site and customers we may conduct research on your demographics, interests, and behavior based on personally identifiable information and other information that we have collected. This research may be compiled and analyzed on an aggregate basis and this aggregate information does not identify you personally and therefore is considered and treated as non-personally identifiable data under this Privacy Policy.


We do not knowingly or intentionally collect any personally identifiable information from children under the age of eighteen (18), and our emails and the Site are neither directed nor targeted to children less than eighteen (18) years of age. If you are under the age of eighteen (18), please do not submit any personally identifiable information through the Site. If you have reason to believe that a child under the age of eighteen (18) has provided personally identifiable information to us through the Site, please contact us at, and we will use reasonable efforts to delete such personally identifiable information from the Site and our files.


If you are visiting the Site from outside of North America, please be aware that you are sending information (including personally identifiable information) to North America where our servers are located. That information may then be transferred within North America or back out of North America depending on the type of information and how it is stored by us. We will hold and process your personally identifiable information in accordance with privacy laws in the United States and this Privacy Policy. Please note that privacy laws in the United States may not be the same as, and in some cases may be less protective than, the privacy laws in your country, and while in the United States personally identifiable information may be subject to lawful access requests by government agencies.


We reserve the right, in our sole discretion, to modify or supplement this policy at any time. If a change to the terms of this policy is made, we will post a notice on the Site’s homepage with a link to the new policy. Modifications will be effective thirty (30) days following the date of posting the new policy. Your continued use of the Site following the effectiveness of any modifications to this Privacy Policy constitutes acceptance by you of those modifications. If any modification to this Privacy Policy is not acceptable to you, you should cease accessing, browsing, and otherwise using the Site and contact us at


By using the Site, you agree to this Privacy Policy. If you do not so agree, please do not use the Site. If we change this Privacy Policy, your continued use of the Site following the posting of such changes will signify your acceptance of those changes. By providing personally identifiable information to us, you fully and unambiguously consent to the collection and processing of your information throughout the world.


This Cookie Policy sets forth our policy with respect to information, including information that may be associated with a specific person and could be used to identify that person (“personally identifiable information”), that is collected from visitors to the Site through cookies, web logs, and other similar technologies.


Please also refer to our Privacy Policy, into which this Cookie Policy is incorporated by reference, which sets forth our policy with respect to the collection, use, disclosure, transfer, and storage of information, including personally identifiable information that is collected from visitors to the Site. Nothing in this Cookie Policy shall be deemed to modify, waive, amend, or rescind any other term of the Privacy Policy.


By using the Site you are consenting to the use of the technologies described in this Cookie Policy to collect both personally identifiable information and non-personal data and to the storage of information on your device or web browser as described in this Cookie Policy.


A cookie is a piece of information that is placed on your web browser or hard drive when you access and/or use the Site. Cookies store text and can later be read back by the Site or third parties. We use cookies to recognize your browser and you as a unique visitor to the Site through an anonymous unique identifier. Cookies can remember what information you access on one webpage to simplify your subsequent interactions with the Site or to use the information to streamline your transactions on related webpages. This makes it easier for you to move from one webpage to another and to complete commercial transactions over the Internet. Cookies should make your online experience easier and more personalized.


Cookies may be session cookies (i.e., last only for one browser session) or persistent cookies (i.e., continue on your browser until they are affirmatively deleted). You can manage cookies through your web browser’s option settings and through those settings you may be able to: (a) receive notifications when you are receiving new cookies; (b) disable cookies; or (c) delete cookies. Please refer to your web browser’s help section for information on how to do this.


We may use pixel tags, cookies set by us, and cookies set by third party service providers at our direction with respect to each of the uses set forth below.


We use these technologies in a way that is essential for the operation of the Site or parts of it. For example, we may use cookies to determine where to route your traffic to effectively distribute the Site workload across numerous servers. Web server logs allow us to count how many people visit the Site and evaluate their capacity.


We use these technologies to monitor the Site and analyze how you use the Site. We may place cookies that allow us to measure the time of your requests to our servers and our responses, to test new features, to record statistics about usage, to track your activities on the Site, and to track the places from which you come to the Site. We may also use third party cookies to collect information about behavior on the Site for these Performance/Analytics purposes.


We use these technologies to allow us to provide certain functionality on the Site and to remember your preferences. For instance, cookies allow us to track your order history and returns and to auto-populate shipping and billing addresses. If you disable or delete cookies, you may not be able to use some functions of the Site.


We may use these technologies to deliver focused online banner advertisements to you both on and off the Site. By using these technologies, we hope to better tailor these advertisements to your interests. Sometimes this is called online behavioral, interest based, or retargeted advertising.