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PRIVACY POLICY

Last updated April 7, 2020


Snooozy, Inc. ("ExciteM") understands that privacy is important.

This Privacy Policy applies to any and all of the services offered by ExciteM on the web site www.swift.excitem.com (the “Site”) owned, controlled, operated or produced by Snooozy. Throughout this Policy, "ExciteM" and "We" refers to Snooozy, Inc. "You" or "Users" refers to You, the Site’s users meaning everyone who uses the Site and its related services (the “Service”).

By using the Site, You expressly consent to the information handling practices described in this Privacy Policy. This Privacy Policy is incorporated into and is subject to the Site’s Terms of Service.

This privacy policy applies to all information collected through our website, and/or any related services, sales, marketing or events (we refer to them collectively in this privacy policy as the "Services"). Your use of the Site and any personal information you provide through the Site are subject at all times to this Privacy Policy and to the Site’s Terms of Service.

We may make changes to this Privacy Policy from time to time, which we will include on this page. It is your responsibility to review this Privacy Policy frequently and remain posted about any changes to it, so we encourage you to visit this page often. This generally describes how ExciteM handles personal data, including personal information collected through the Site. This Privacy Policy also describes any other privacy practices specific to the Service.

1. When Does ExciteM collect Personal Data?

When Users register on the Site: If you want to become a User of the Service, You will have to register and open your personal ExciteM account. At the time of such registration, ExciteM will ask you to provide ExciteM with a certain amount of personal information. ExciteM may also ask you to provide ExciteM with additional demographic information (e.g. time zones and business names) in order to supplement information already associated with your ExciteM account. Submission of such personal information is voluntary, but without it you may not be able to (i) register on the Site and/or open your ExciteM account, and/or (ii) use any features of the Service which require such personal information.

When Users submit a phone list to ExciteM: When Users submit phone lists to ExciteM, ExciteM stores such phone numbers and, if provided to us, names and demographic information of third parties who will be participating in the Survey or any of ExciteM’s services. We regard and treat such Participant information as confidential.

When Participants answer an ExciteM survey: If a User has included, as part of a survey or a general phone campaign, questions regarding any Participant’s personal information, ExciteM may collect that information from any such Participant on a User's behalf. A Participant's submission of personal information in response to a ExciteM question is voluntary, and Participants may decline to answer a ExciteM survey at any time. However, by providing their personal information, Participants consent to providing their personal information to ExciteM for the purpose of delivering the Service to Users.

2. What Can The Personal Information We Collect Include?

Publicly Available Personal Information: We collect first name, maiden name (if applicable), last name, and nickname (if applicable); demographic information (time zone, business name etc.); email addresses; business email; IP address, geolocation, social media; and other similar data.

Personal Information Provided by You: We collect data collected from surveys; purchase history; passwords; financial information (credit card number, purchase history, invoices); and other similar data.

Payment Data: We collect data necessary to process your payment if you make purchases, such as your payment instrument number (such as a credit card number), and the security code associated with your payment instrument. All payment data is stored by the third party payment processor.

Social Media Login Data: We may provide you with the option to register using social media account details, like your Facebook, Google or other social media account.

All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.

3. On which Grounds does ExciteM use personal data?

To provide and enhance the Service: We may use personal information and survey data in-house in order to provide and enhance the Service, to improve the Users’ interface.

To check compliance: ExciteM may inspect User account information and survey responses, which may contain the personal information of Users, Participants and third parties, in order to (i) ensure compliance by any User with the Site’s Terms of Service, (ii) to identify, contact or take action against a User whom we reasonably believe is in breach or has been in breach of the Site’s Terms of Service, or (iii) to identify a User whom we reasonably believe has caused or is causing an injury or a damage to or an infringement upon the rights or property of ExciteM, another User, or a third party.

4. To which extent and to whom does ExciteM disclose your personal data?

ExciteM uses personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:



ExciteM safeguards and treats as confidential all survey data and individually identifiable information relating to Users and Participants, as well as information relating to the contents or results of any particular survey or phone campaign.

No electronic data is 100% secure and protected, nor are Internet transmissions 100% secure and protected. Thus, ExciteM cannot guarantee that survey data, which may or may not include individually identifiable information, can never be accessed or retrieved by individuals who are not authorized by ExciteM to do so.

ExciteM may disclose aggregate information about Users, Participants and surveys. In such cases, ExciteM does not release any information that would specifically identify a Participant or his or her survey answers, or a User.

For example:

ExciteM may disclose information about the size of the average phone list for a 5-question survey, but ExciteM would not disclose the actual phone numbers dialed, the contents of the survey, or the results of the survey; or

ExciteM may disclose the total number of calls that have been made while using the Service during the previous week, but ExciteM would under no circumstances disclose the actual phone numbers dialed.

5. Will your information be shared with anyone?

When you create an account with ExciteM you give your consent that we may process or share data based on the following legal basis:


More specifically, we may need to process your data or share your personal information in the following situations:

6. How Do We Handle Your Social Logins?

If you choose to register or log in to our services using a Facebook or Google account, we may have access to certain information about you.

Our Services offer you the ability to register and login using your third party social media account details (like your Facebook or Google logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile Information we receive may vary depending on the social media provider concerned, but will often include your name, e-mail address, friends list, profile picture, as well as other information you choose to make public.

We will use the information we receive only for the purposes that are described in this privacy policy or that are otherwise made clear to you on the Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third party social media provider. We recommend that you review their privacy policy to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

7. Participants’ choice to respond to surveys:

Responding to any ExciteM survey is purely voluntary.

8. How Long Do We Keep Your Information?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy policy unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy policy, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this policy will require us to keep your personal information for longer than 1 year past the start of the idle period of the user's account.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

If you claim your personal information to be deleted and your account with our Services to be cancelled, we will cancel your account and information associated with it to exercise your right “to be forgotten”.

9. What Are Your Privacy Rights?

In some regions, such as the European Economic Area, you have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

In some regions (like the European Economic Area), you have certain rights under applicable data protection laws. These may include the right (i) to request access and obtain a copy of your personal information, (ii) to request rectification or erasure; (iii) to restrict the processing of your personal information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information. To make such a request, please use the contact details provided below. We will consider and act upon any request in accordance with applicable data protection laws.
If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal.

If you are resident in the European Economic Area and you believe we are unlawfully processing your personal information, you also have the right to complain to your local data protection supervisory authority. You can find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.

10. Account Information

If you would at any time like to review or change the information in your account or terminate your account, you can:

Upon your request to terminate your account, we will deactivate or delete your account and information from our active databases. However, some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms of Use and/or comply with legal requirements.

11. Opting out of email marketing

You can unsubscribe from our marketing email list at any time by clicking on the unsubscribe link in the emails that we send or by contacting ExciteM via its Help Center by email at swift@excitem.co or by logging into your account and accessing the account settings. You will then be removed from the marketing email list – however, we will still need to send you service-related emails that are necessary for the administration and use of your account. To otherwise opt-out, you may:


12. Information From Minors Regulation

Our website and services are not directed to children. Access to and use of ExciteM is only for those over the age of 13 (or 16 in the European Union). If you are younger than that, you may not register for or use ExciteM. Everyone who registers as a user or provides their personal information represents that they are 13 years of age or older (and 16 years or older in the European Union).

13. Cookies

Cookies (i) are small text files stored by your browser in your computer when you visit the Site, and (ii) often includes an anonymous unique identifier. Indeed, Cookies allow ExciteM to identify Users and avoid repetitive requests for the same information/data. Most browsers will accept cookies until you change your browser settings in order to refuse such cookies. This Privacy Policy applies to the use of cookies by ExciteM but does not apply to the use of cookies by any other third party.

14. Data Breach

A privacy breach occurs when there is unauthorized access to or collection, use, disclosure or disposal of personal information. You will be notified about data breaches when ExciteM believes you are likely to be at risk or serious harm. For example, a data breach may be likely to result in serious financial harm or harm to your mental or physical well-being. In the event that ExciteM becomes aware of a security breach which has resulted or may result in unauthorized access, use or disclosure of personal information ExciteM will promptly investigate the matter and notify the applicable Supervisory Authority not later than 72 hours after having become aware of it, unless the personal data breach is unlikely to result in a risk to the rights and freedoms of natural persons.

15. California Residents Privacy Rights

California Civil Code Section 1798.83 permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any) we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to us using the contact information provided below.

If you are under 18 years of age, reside in California, and have a registered account with the Services, you have the right to request removal of unwanted data that you publicly post on the Services. To request removal of such data, please contact us using the contact information provided below, and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the Services, but please be aware that the data may not be completely or comprehensively removed from our systems.

16. Contacting ExciteM

If you have questions or comments about this policy, you may contact our Data Protection Officer (DPO), Hussain Sheikh, by email at swift@excitem.co.

If you believe that ExciteM has not adhered to this Privacy Policy, please contact us by email at swift@excitem.co. We will use commercially reasonable efforts to remedy the problem.