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Disclosure Facts Privacy Policy

Last Updated: September 7, 2026

At Disclosure Facts, we're building the payment method for regulated endorsements, and trust is what makes the transaction work. We know that earning your trust starts with respecting your privacy. The information you share with us powers your account, your transactions, and the records that document them. That's why we're committed to handling your Personal Information thoughtfully and transparently.

This Disclosure Facts Privacy Policy ("Privacy Policy") describes how Swaypay It, Inc. ("Disclosure Facts," "we," "our," or "us") collects, uses, discloses, and protects your Personal Information, and the rights you may have regarding it.

Key Takeaways

Here's the short version:

  • We collect Personal Information to operate accounts and transactions, verify identity and credentials, process and authorize payments, prevent fraud, comply with law, improve Disclosure Facts, and communicate with you.
  • We may collect information directly from you, automatically through your use of the Services, and from trusted third parties such as verification providers, payment providers, and other parties involved in a transaction.
  • We may disclose information to service providers, transaction participants, regulators, and others as required or permitted by law. Certain transaction information is public by design, and we may create and use aggregated and de-identified information that does not identify you.
  • We retain information as long as necessary to provide our Services and meet legal, regulatory, security, and recordkeeping obligations. Certain Transaction Records are retained permanently.
  • We use security safeguards designed to protect your information, though no system can be guaranteed completely secure.
  • Depending on where you live, you may have rights to access, correct, delete, restrict, or otherwise control certain uses of your Personal Information, subject to applicable exceptions.

For full details, continue reading below.

1. Scope

This Privacy Policy applies to Disclosure Facts' websites, applications, products, services, and related tools (collectively, the "Services"), as well as when you otherwise communicate or interact with Disclosure Facts, including through email, customer support, social media, or other business communications.

"Personal Information" in this Privacy Policy means information that relates to an identified or identifiable individual or household, or that is linked or reasonably linkable to them. Personal Information does not include:

  • Publicly available information, as defined by applicable law; or
  • De-identified or aggregated information that cannot reasonably identify you.

2. Personal Information We Collect

We collect the following types of Personal Information through our Services, including when you provide it to us, when you create an account or communicate with us; automatically through our Services, including from cookies and other tracking technologies; and from our service providers, verification providers, or third parties, depending on how you interact with us:

  • Identifiers, including first and last name, account name, IP address, unique personal identifier, online identifier, email address, or other similar identifiers.
  • Identity and business verification information, including government-issued identification, business registration or incorporation documents, tax identification, beneficial ownership information, authorized signatory details, and the results of verification checks performed by us or by third-party verification providers or Payment Providers.
  • Professional credential information, including professional license number and status, issuing authority and jurisdiction, board certification, registration with applicable regulatory authorities, education and training, and the results of exclusion, sanctions, and restricted-party screening.
  • Commercial Information, including records of products or services purchased, consuming histories, or tendencies.
  • Internet or other electronic network activity information, including browsing history, search history, and information regarding your interaction with our Services and advertisements.
  • Employment Information, including role, compensation, and related data.
  • Geolocation data, including location data inferred from your device IP address.
  • Inferences used to create a profile reflecting your preferences, characteristics, and behavior.
  • Transaction Information, including information associated with regulated endorsement transactions; standardized Transaction Conditions and their status; Attestations submitted in response to those conditions; identity, credential, and eligibility information and verification results; approvals; payment-related records; electronic acceptances and signatures; the identity of the Account, User, and Organization associated with an action; timestamps; Broker participation and any recorded delegation of authority; the applicable Terms version, Transaction Condition set version, schema version, Transaction-specific terms, and other version identifiers that make up the governing version of a Transaction; amendments and acceptance of amendments; disclosures generated from Transaction information, including UCDs; Public Transaction Records; regulatory and reporting classifications, fields, materials, and supporting information used to generate Open Payments Reporting Data Packets or OPDP Submission Packets; generated packet versions, exports, transmission instructions, and transmission-status records where applicable; and other supporting Transaction artifacts.

Information you provide

Account setup. When you create an account, we may collect your name, email address, display photo (optional), organization or brand information, and settings relevant to your role, such as Advertiser, Endorser, Broker, or other Transaction Participant.

Verification information. To open or participate in transactions, you may be asked to provide information and documents so that we can verify your identity, your organization, your authority to act for that organization, and, where applicable, your professional credentials. This may include government-issued identification, business registration documents, ownership and signatory details, and professional license or certification details.

Transaction information. When you participate in a regulated endorsement Transaction, you may provide information necessary to open, administer, and complete the Transaction, clear applicable standardized Transaction Conditions, generate disclosures, authorize payment, and generate the Transaction Record. We also record electronic actions taken within the Transaction, including acceptances, approvals, Attestations, amendments, payment authorizations, the identity and Organization associated with the action, and the applicable version information.

Broker information. For purposes of this Privacy Policy, a "Broker" is a third-party intermediary participating in a Transaction, such as an advertising agency, talent manager, marketing agency, public relations firm, creator-management company, or other service provider. Where a Broker participates, we may collect the Broker's identity, Organization, role in the Transaction, relationship to the Advertiser or Endorser, any scope of authority represented or expressly delegated through the Services, and the actions the Broker takes. Use of the term Broker is functional within the Services and does not itself indicate that the person or entity is licensed as a broker under any regulated-profession law.

Regulatory and reporting information. If you use features that generate regulatory or reporting materials, you may provide or confirm information needed for those outputs. For an Open Payments Reporting Data Packet, this may include recipient and participant identifiers, payment information, product information, payment classifications, intermediary information, and other reporting fields. For an OPDP Submission Packet, this may include promotional materials, product and sponsor information, labeling or reference materials, approval and version information, publication or dissemination information, and other submission-related data or artifacts. We may also record the generation, version, export, transmission instruction, or transmission status of a packet where the applicable feature is used.

Profile information. If you complete a Disclosure Facts Profile, you may provide company or endorser details, links to posts, role or compensation selections, and other disclosures.

Communications. If you contact us, we may collect your name, email, and the content of your message.

Information collected automatically

Device and log data. IP address, browser type and version, device identifiers, operating system, pages viewed, time and date stamps, and referring URLs.

Usage data. Interactions with the Services, including transaction activity, label creation, toggles selected, profile edits, link clicks, and other interactions with transaction records or artifacts.

Location data. Approximate location, such as location inferred from your IP address or device settings, to improve service functionality and display regionally relevant content. You can disable location sharing in your device or browser settings.

Information from third parties

If you connect a third-party service, or if a third-party service is used in connection with a transaction, we may receive information consistent with your settings on that service and as necessary to provide the Services.

Verification providers and primary sources. We may receive verification results from identity verification providers, from a credentials verification organization ("CVO"), and from primary sources such as state licensing boards, certifying bodies, regulatory registries, and exclusion or sanctions list administrators. These results describe the status of an identity or credential as of the date the verification was performed.

Payment providers. Transaction payments may be processed by Stripe or another third-party payment provider. Payment Providers may collect payment account information directly from you, and we may receive payment-related information they make available to us, such as account or customer identifiers, transaction amounts, payment status, timestamps, and processor references, as necessary to operate and record the transaction. Payment Providers also conduct their own identity and business verification and may share the outcome of that verification with us.

3. How We Process Personal Information

We may use your Personal Information for the following purposes, depending on how you interact with us and in what capacity:

  • Provide and operate the Services, including enabling regulated endorsement transactions; applying and clearing standardized Transaction Conditions; recording Attestations, electronic acceptances, approvals, signatures, and amendments; recording Broker participation and any delegation of authority reflected through the Services; recording the Terms version, Transaction Condition set version, schema version, Transaction-specific terms, and other version identifiers applicable to a Transaction; generating public-facing disclosures and Public Transaction Records from applicable Transaction information; authorizing payment; generating and maintaining the fuller underlying Transaction Packets; generating Universal Clickable Disclosures ("UCDs"); hosting Disclosure Facts Profiles ("DFPs"); maintaining Disclosure Integrity Protocol ("DIP") records; and generating regulatory and reporting outputs from Transaction information, including Open Payments Reporting Data Packets and OPDP Submission Packets where those features are enabled.
  • Verify identity, organizations, authority, and credentials, including confirming who you are, confirming that the organization you represent exists and that you are authorized to act for it, verifying professional licenses and certifications against the primary source or an approved equivalent, screening against exclusion, sanctions, and restricted-party lists, and recording the result, source, method, and date of each verification in the Transaction Packet.
  • Operate the Services, including providing access to the Services, assessing their performance, maintaining or enhancing their quality, monitoring and addressing security concerns, identifying visitors to our Site and Services, and ensuring the effective operation of the Services.
  • Improve, personalize, and secure the Services, including by evaluating how the Services perform, analyzing trends and usage, tracking and responding to issues, and developing new Services.
  • Create statistical and de-identified data, including by aggregating information about transactions across the Services to produce benchmarks, indices, research, standards, and risk and underwriting data products, and to make such aggregated and de-identified data available to third parties. This data does not identify you, and we do not attempt to re-identify it. See Section 7.
  • Communicate with you, including by sending service updates, account notices, marketing and promotional materials, and obtaining feedback.
  • Carry out legal and compliance activities, including enforcing our Terms of Use, complying with legal or regulatory obligations, identifying or managing legal actions related to our or others' rights or property, supporting actual or threatened claims, defenses, or declarations in a case or before any jurisdictional or administrative authority or arbitration or mediation panel, and exercising, establishing, or defending our legal rights.
  • Maintain the security of our Services, including protecting the Services from cyber risks, authenticating users, preventing and investigating illegal or malicious activities, and generally safeguarding our Services.
  • Corporate restructuring, including evaluating or executing a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, as part of regular business operations or pursuant to a bankruptcy, liquidation, or similar proceeding.

4. Disclosure of Personal Information

We may disclose your Personal Information to the following parties:

  • Affiliates, payment processors, service providers, and other vendors who help us operate, maintain, and improve the Services;
  • Identity verification providers, credentials verification organizations, and Payment Providers, for the purpose of verifying individuals, organizations, authority to act, and professional credentials;
  • Advertisers, Endorsers, Brokers, and other Transaction Participants as necessary to facilitate a Transaction and generate, maintain, or provide access to the applicable Transaction Packet;
  • Applicable reporting entities, sponsors, CMS, FDA, or other governmental or regulatory systems where an Organization responsible for a report or submission directs or authorizes us to generate, export, make available, or transmit an Open Payments Reporting Data Packet, OPDP Submission Packet, or related Transaction information through a feature supported by the Services;
  • Members of the public and users of Third-Party Websites, with respect to information included in a Public Transaction Record, UCD, public DFP, or other information intentionally made public through the Services;
  • Insurers, reinsurers, insurance brokers, and underwriters, with respect to nonpublic identifiable Transaction information, where you have separately and specifically authorized us to provide your information for the purpose of obtaining, maintaining, or making a claim under a policy, or where you have directed us to provide it to your own insurer or insurance broker;
  • Legal, regulatory, or governmental authorities if required by law or to protect our rights;
  • Business partners or acquirers in the event of a merger, acquisition, or sale of assets; and
  • Recipients of aggregated and de-identified data, including insurers, reinsurers, insurance brokers, rating organizations, data exchanges, researchers, and other third parties, as described in Section 7. Aggregated and de-identified data does not identify you.

5. Transaction Records, Public Records, Profiles, and Disclosures

When you participate in a regulated endorsement Transaction, Disclosure Facts generates and maintains records of the information, Attestations, verifications, approvals, and other events associated with that Transaction.

Public Transaction Records and disclosures

Certain information generated or recorded through a Transaction is intended to be public. Disclosure Facts may create a Public Transaction Record containing a standardized subset of Transaction information for transparency, disclosure, and reporting purposes.

Where the applicable Transaction Conditions require material-connection Attestations or other disclosure information, Disclosure Facts may use those Attestations and Transaction information to generate a Universal Clickable Disclosure ("UCD"). The UCD is a standardized public-facing output of the applicable recorded Transaction information and may travel with, link from, or otherwise provide information concerning the associated endorsement.

A Public Transaction Record may include, as applicable, the UCD, material-connection information, identities or roles of Transaction Participants (including a Broker where applicable), relevant verification status, Transaction dates or identifiers, and other information designated by the Services for public disclosure.

Information contained in a Public Transaction Record, public DFP, UCD, or other public-facing feature may be visible to anyone and may be indexed, copied, archived, republished, or otherwise retained by search engines, social-media platforms, archives, or other third parties. We cannot control how third parties use or retain information after it has been made public.

Nonpublic Transaction Packets

Disclosure Facts also maintains a fuller Transaction Packet underlying each Transaction. Depending on the Transaction, the Transaction Packet may include Transaction Conditions and their status, Attestations, credential and eligibility information, verification results, approvals, payment-related records, DIP entries, timestamps, supporting artifacts, the identity of the Account, User, and Organization associated with recorded actions, Broker participation and any recorded delegation of authority, electronic acceptances and signatures, the applicable Terms version, Transaction Condition set version, schema version, Transaction-specific terms and other version identifiers, amendments and acceptance of amendments, regulatory and reporting fields or materials, generated Open Payments Reporting Data Packets or OPDP Submission Packets and their versions, export or transmission records where applicable, and the information from which public-facing disclosures were generated.

The fuller Transaction Packet is not made publicly accessible merely because a Public Transaction Record or UCD exists. We disclose nonpublic information from a Transaction Packet only as described in this Privacy Policy, including to Transaction Participants and service providers as necessary to provide the Services; to regulators, courts, or other authorities where required by law or legal process; or to other third parties where you have provided the authorization required for that disclosure.

Verification information

Where we verify an identity or credential, the Transaction Packet records what was verified, the source relied upon, the method used, the date performed, and the verifying provider. It records the result of the verification, not necessarily the underlying documents you submitted to obtain it.

Electronic transaction, authority, and version records

When the Services present an action for electronic acceptance, approval, confirmation, signature, Attestation, amendment, or payment authorization, we may record the Account and User taking the action, the Organization on whose behalf the User represented that they were acting, the action taken, the Transaction to which it relates, the date and time, and the applicable transaction version information. Where an Advertiser or Endorser expressly delegates a permitted action to a Broker through the Services, we may record the scope of that delegation, the parties involved, the time it was made, and the action later taken under it. We retain these records as part of the Transaction Packet so the Packet can show not only what was submitted, but who acted, for whom, under which version of the Transaction, and when.

Regulatory and reporting packets

Where enabled, Disclosure Facts may use information in a Transaction Packet, together with classifications, selections, promotional materials, or other information supplied or confirmed by Transaction Participants, to generate structured regulatory and reporting outputs. These may include an Open Payments Reporting Data Packet for use in connection with a reporting entity's CMS Open Payments workflow and an OPDP Submission Packet for use in connection with a prescription-drug sponsor's FDA promotional-material submission workflow.

These packets may contain Personal Information and nonpublic Transaction Records. They are not public merely because they are generated. We may provide them to the applicable Transaction Participants or Organizations and, where a supported transmission feature is used, may make them available to or transmit them to CMS, FDA, or another governmental or regulatory system at the direction or authorization of the Organization responsible for the applicable report or submission. We may record packet generation, versioning, export, transmission instructions, and transmission status as part of the Transaction Packet. Once information is disclosed or transmitted outside Disclosure Facts, the recipient's own laws, systems, retention requirements, and privacy practices may apply.

Other public content

When you choose to share other content, such as pictures, videos, product reviews, profile information, or social-media content, that information may also become public according to your choices and settings. Public Transaction Records are different: specified information included in those records is public by design as part of the Transaction.

Any content you share publicly may be republished or archived by search engines or other third parties, and we cannot control this. We also may revise, delete, or combine User Content that is not a Transaction Record as permitted by our Terms of Use. This does not apply to Transaction Records, which are governed by the permanence and correction rules described below.

Please note that if you mention Disclosure Facts, tag us, or comment about or in response to us in your post on social media, we may be allowed to use your post, including by publishing it on our social media, websites, and apps. You should review the terms, policies, and settings of your social media accounts to learn more about their data practices and adjust your settings accordingly.

6. Data Retention

We retain different categories of information for different periods.

Transaction records are permanent

From the time a regulated endorsement Transaction is opened, the Services may create Transaction Records. Any Transaction Record actually created through the Services — including Attestations, Transaction Conditions and their status, verification results, approvals, payment-related records, DIP entries, electronic acceptances and signatures, authority or delegation records, applicable version identifiers, amendments, timestamps, regulatory or reporting fields and materials, generated regulatory or reporting packets that form part of the Transaction Packet, related export or transmission records, and supporting artifacts — is retained indefinitely whether the Transaction is completed, suspended, canceled, or otherwise not completed. These records are not subject to a retention period after which they are discarded, and we do not delete them at the request of a Transaction Participant.

We retain these records permanently because the record is a core purpose of the Transaction. A regulated endorsement Transaction is opened through the Services so that events occurring through the Transaction can be recorded contemporaneously as they happen, including where the Transaction ultimately does not complete. A record that could later be deleted on request by a party to it would not serve that purpose — not for the other parties to the Transaction, and not for anyone later relying on the record.

Recorded entries cannot be edited or removed. Where a party believes an entry is inaccurate or incomplete, that party may submit a correction, which is recorded as a new, separately timestamped entry referencing the original. The original entry remains.

If a Transaction is not completed, its Transaction Packet or partial record may reflect that status and the events that occurred before the Transaction stopped. An incomplete Transaction is not represented as a completed one.

We will delete or redact information within a Transaction Record only where we are required to do so by applicable law or valid legal process. Where that occurs, we record within the affected Transaction Packet that a deletion or redaction was made, the date, and the stated basis for it.

Public visibility and retention are separate. Information designated as part of a Public Transaction Record is public by design. Other information, including certain DFP fields, may have configurable visibility. Changing a configurable display setting does not alter, delete, or rewrite the underlying Transaction Record.

Account closure does not delete Transaction Records. Closing your account, or having your account suspended or terminated, does not delete any Transaction Record created before that point and does not entitle you to have one deleted.

Verification documents are not permanent

Documents you submit so that we can verify you — such as copies of government-issued identification, business registration or incorporation documents, and license or certification documents — are treated differently from Transaction Records. We retain these documents only for as long as reasonably necessary to complete and substantiate the verification and to meet applicable legal and recordkeeping requirements, and then delete them.

The result of the verification is permanent. The document that produced it is not. In other words, the Transaction Packet may show that a professional license was verified as active with the issuing board on a stated date by a named provider; it does not necessarily retain a copy of the identification you submitted along the way.

Other Personal Information

Personal Information that does not form part of a Transaction Record — for example, account settings, marketing preferences, support correspondence, and website analytics — is retained only as long as necessary to provide the Services, fulfill the purposes described in this Privacy Policy, and meet legal or regulatory requirements. Retention periods vary by the type of data and applicable obligations.

Aggregated and de-identified data

Aggregated and de-identified data is retained indefinitely and is not associated with you.

7. Aggregate and De-Identified Data

We create statistical, aggregated, and de-identified data from transactions conducted through the Services ("Aggregate Data"). Aggregate Data may describe the volume, frequency, composition, timing, condition sets, verification outcomes, completion rates, and outcomes of transactions across the Services. It does not identify, and is not reasonably capable of being used to identify, you, any Transaction Participant, or any specific Transaction.

We may use, license, publish, and commercialize Aggregate Data for any lawful purpose, including to develop benchmarks, indices, standards, and research, and to develop and provide risk and underwriting data products to insurers, reinsurers, insurance brokers, rating organizations, and other third parties.

Our commitments regarding Aggregate Data. We take reasonable measures to ensure Aggregate Data cannot be associated with any individual or Transaction Participant. We publicly commit to maintain and use Aggregate Data only in de-identified form, and not to attempt to re-identify it. We contractually require recipients of Aggregate Data to make the same commitments, and we do not permit recipients to attempt re-identification.

Your nonpublic identifiable information is treated differently. Except for information contained in a Public Transaction Record or otherwise intentionally made public through the Services, we do not provide Transaction Packets or other nonpublic Transaction Records in identified or identifiable form to any insurer, reinsurer, insurance broker, underwriter, rating organization, or data exchange except where: (a) you have given us separate, specific, affirmative authorization to do so, which you may withdraw at any time on a going-forward basis; (b) you have directed us to provide it to your own insurer or insurance broker, on your behalf; or (c) we are required to by law or legal process. Accepting the Terms is not authorization under (a). We will ask you separately, and you can decline without losing access to the Services.

Information about people who are not Transaction Participants. Transaction Records concern the parties to a Transaction and the obligations between them. They do not include Personal Information about consumers, purchasers, or audience members who are not parties to the Transaction, and Aggregate Data is not derived from any such information.

Notice of changes. We will provide notice, consistent with applicable law, before materially expanding the categories of recipients to whom we make Aggregate Data available.

8. Security

We use reasonable technical and organizational measures to protect your information. Because Transaction Records are permanent and cannot be recreated, these measures include access controls, tamper-evidence measures, and backup and recovery procedures designed to preserve their integrity, availability, and durability. Verification documents are subject to additional access restrictions and are deleted on the schedule described in Section 6. However, no transmission or storage system is fully secure, and we cannot guarantee absolute security.

9. Interactive Features and Integrations

We may engage vendors to provide certain interactive features on the Services. Your use of these interactive features is voluntary, and we may retain the information that you submit through the features.

For example, we may offer an interactive chat feature on our Services to answer questions and for other customer service purposes. When you participate in the interactive chat, either with a virtual or live agent, the contents of the chat may be captured and kept as a transcript. By using these features, you understand that our vendors may process the information obtained through the feature to provide the service on our behalf.

We may offer additional third-party integrations on the Site. If you choose to connect a third-party account to our system, you should refer to that party's privacy policy for information on how your Personal Information is collected, used, and protected.

10. Links to Other Websites

Our Services may contain links to, or features provided by, third parties, including the practices described in Section 9 above.

Our inclusion of these third-party links does not constitute our endorsement of these third parties or their services. These websites are not operated or controlled by us, and we are not responsible for their content, privacy practices, or security measures.

We encourage you to review the privacy policies of any third-party websites you visit to understand how they collect, use, and share your information.

11. International Users

Our Services are operated in the United States. If you are accessing them from outside the United States, your information may be transferred, stored, and processed in the United States or other jurisdictions, which may not have equivalent data protection laws.

12. Your Rights and Choices

All users, regardless of jurisdiction, may opt out of marketing emails by clicking "unsubscribe" or adjusting your account settings. You may also update certain Personal Information in your account settings.

California Shine the Light

We do not share Personal Information with third parties for those third parties' own direct marketing purposes. Californians may request information about our compliance with this law by emailing us at support@disclosurefacts.com, including "California Shine the Light" in the subject line.

State Privacy Rights

Depending on your jurisdiction, you may be able to submit certain requests related to your Personal Information. To exercise any of the rights listed below, please email us at support@disclosurefacts.com with "Privacy Request" in the subject line.

Please note that we may need to authenticate your identity before your request can be processed. To authenticate, you may be required to provide us with additional pieces of Personal Information to match against our records, or to log into your account.

Residents of covered jurisdictions may have the following privacy rights:

  • Right to access your Personal Information;
  • Right to confirm that we are processing your Personal Information;
  • Right to correct any inaccuracies in the Personal Information we may retain about you. For information forming part of a Transaction Record, a correction is recorded as a new, separately timestamped entry that references the original; the original entry is not overwritten or removed;
  • Right to delete your Personal Information, subject to certain exceptions described below; and
  • Right to appeal any request that we have previously denied that you believe was denied in error.

Sensitive Personal Information

Some of the information we collect for verification, such as government-issued identification numbers, may be treated as sensitive Personal Information under applicable state privacy laws. We collect and use this information only to verify identity, organizations, authority to act, and professional credentials, to prevent fraud, and to meet legal and recordkeeping obligations. We do not use or disclose it to infer characteristics about you, and we do not use it for advertising. Where applicable law provides a right to limit the use of sensitive Personal Information, our use is already limited to those permitted purposes.

Transaction Records and the Right to Delete

Applicable privacy laws may permit us to decline a deletion request where retaining the information is necessary to complete the transaction for which it was collected, to comply with a legal obligation, or for internal uses reasonably aligned with the context in which you provided it. To the extent an applicable exception permits retention of a Transaction Record, we will decline a request to delete that record.

A regulated endorsement Transaction is opened through the Services in order to create a durable record of the events that occur through that Transaction, including what the parties represented, approved, accepted, delegated, or amended and when. The record is not a byproduct we happen to keep — it is a core reason the Transaction is structured this way. Other parties to the Transaction, and third parties who may later rely on the record, may have an interest in it that does not end when one party would prefer it deleted.

This does not affect your other rights. You may still request access to your Transaction Records, request confirmation that we are processing your information, and submit a correction, which will be recorded as a new entry alongside the original. You may also delete, or request deletion of, Personal Information that does not form part of a Transaction Record, and verification documents are deleted on the schedule described in Section 6 whether or not you ask.

If you are considering opening or participating in a Transaction on the Services and do not want the Transaction Records created through that Transaction to be permanent, do not enter the Transaction. We would rather tell you that clearly in advance than have it come as a surprise afterward.

Sale and Sharing of Personal Information

We do not sell your Personal Information, and we do not share it for cross-context behavioral advertising, as those terms are defined under applicable state privacy laws.

We do create and license aggregated and de-identified data, as described in Section 7. Aggregated and de-identified data is not Personal Information under applicable state privacy laws, and licensing it is not a sale or sharing of your Personal Information.

We do not license nonpublic identifiable Transaction Records to insurers, insurance brokers, data exchanges, or other third parties without the authorization described above. Information contained in a Public Transaction Record is public information made available through the Services for the purposes described in this Privacy Policy; its public availability does not authorize disclosure of the fuller nonpublic Transaction Packet.

If this changes, we will update this Privacy Policy and provide the notice and opt-out mechanism required by applicable law before doing so.

Targeted Advertising

We do not engage in targeted advertising, so we do not offer this right.

Automated Decisionmaking and Profiling

We do not use automated decisionmaking, automated processing, or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you, and we do not use it in any manner that would trigger a right to opt out of such activities. Verification results are returned by primary sources and verification providers and are recorded as received; we do not generate automated scores or ratings about you. Aggregate Data is de-identified and is not used to make decisions about you.

Non-Discrimination

If you choose to exercise your privacy rights, we will not subject you to any discriminatory treatment.

Recordkeeping of Privacy Requests

Please be aware that when you submit a privacy rights request, we will retain the Personal Information provided with your request for recordkeeping purposes.

13. Children's Privacy

The Services are not directed to children under 13 (or the age of majority in your jurisdiction). We do not knowingly collect Personal Information from children. If we learn that we have, we will delete it as required by applicable law.

14. Changes to this Policy

We may update this Privacy Policy from time to time. The "Last Updated" date at the top reflects the most recent version. If required by applicable law, we will provide additional notice if changes are material, such as via email or in-app notification.

15. Contact Us

Questions, concerns, or requests regarding this Privacy Policy? Contact us at:

Swaypay It, Inc.
169 Madison Ave STE 52046
New York, NY 10016
support@disclosurefacts.com

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