Sway Privacy Policy
Last updated: March 24, 2026
This Privacy Policy covers the practices of Manifest Global, Inc. dba Sway (hereinafter, “Sway” or “we” or “us”) concerning information that we handle in the context of offering or providing our services, including any such information we may collect from you or that you may provide when you visit our website sway.xyz, mobile app, or any of our other websites or services that link to this Privacy Policy (collectively, our “Services”).
This notice may change from time to time, so please check the notice periodically for updates.
This Privacy Policy contains the following sections:
Information We Collect
Use of Information
Disclosure of Information
Your Rights and Choices
Protection of Information
Retention of Information
Children’s Privacy
Third-Party Links
Updates and Changes to This Notice
Contact Information
Information We Collect
a. Information You Provide to Us
You may provide the following types of information to us:
Identifiers (such as name, username, physical address, email address, phone number, and other contact information);
Commercial information (such as information provided to us in your communications, transaction data, pledges, selected rewards, information about interactions with Sway, information about your interests and preferences, and information you provide in response to surveys or promotions offered by us);
Financial data (such as payment card data, which is processed by our payment processor);
Your aggregated device usage metrics, such as whether and for how long you used your device (in accordance with our integration of Apple’s Screen Time API);
Internet or other network or device activity (such as IP addresses, device identifiers, cookie data, device attributes, device usage information, browsing information, metadata, and other information);
Other information that identifies or can be reasonably associated with you, including information you voluntarily provide when you interact with us (such as contacting our customer service teams, the pledges you make on Sway and your total Sway points, which rewards you redeem, and information you provide to help us determine eligibility for a refund); and
Inferences drawn from any of the above.
b. Cookies and Other Information Collection Technology
Through our Services, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality, and other computer code.
This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), general location data (inferred from IP address), other device information, Internet connection information, as well as details about your interactions with the relevant website, email, or other online property (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use.
These technologies help us and our partners:
Provide you with content that we think will be of interest to you on our Services and across the Internet;
Store information about your preferences, allowing us to customize our Services according to your interests;
Perform analytics, estimate our audience size and usage patterns, and better understand the types of users interested in our products and services;
Diagnose and fix technology problems;
Plan for and enhance our business; and
Facilitate the other uses and disclosures described in this Privacy Policy and our cookie consent tools.
Please refer to the “Online Analytics and Advertising” section below for further information.
c. Information From Third Parties
We may also receive personal information from third parties, including our vendors and service providers, affiliates, and partners (such as our ad and analytics partners), as well as from publicly available sources (such as social media websites and apps). We may receive information about potential users and practitioners that may be interested in the Services from other users. If you submit someone else’s information to us, you represent that you are authorized to provide this information to us.
We may combine any information we collect about you from you or these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information in accordance with this Privacy Policy.
d. Online Analytics and Advertising
Online analytics
We may use third-party analytics services on our Services (e.g., Google Analytics). These service providers may set and access their own cookies, pixel tags, and similar technologies on our Services and on third-party services to collect information that can be used to track users over time and across services. These analytics services help us understand how users arrive at and use our Services.
If you do not want Google Analytics to collect and use information about your use of our websites, then you can install an opt-out in your web browser. You also may opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings.
Online advertising
We strive to provide you with relevant, value-added content in our online advertisements. We work with online analytics and advertising partners to: (1) better understand the use of our Services so that we can improve our Services; and (2) deliver Sway advertisements that are more tailored to you both on our Services and on third-party Services.
Our partners may also place cookies, pixel tags and similar technologies on many online services, including ours. They use these technologies to collect information about your activities on these services in order to deliver you more relevant advertising. For example, they may use the information they collect from their cookies on our Services to identify Sway products and services you might be interested in and to recognize your device so they can show you relevant Sway advertisements while you are using our Services and other services. Additionally, we sometimes provide basic information we collect (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies, mobile ad identifiers, and other proprietary IDs, in order to provide you with more relevant ads when you visit other online services.
If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.
Use of Information
We and our vendors and service providers use the information described above for the following purposes:
Administer your account, including to process your registration and verify your information;
Provide, manage, and improve our products and services;
Determine eligibility to use our Services, and to redeem rewards and refunds, in accordance with applicable law and our policies;
Conduct business operations in support of our services, such as auditing, security, fraud prevention, invoicing and accounting, sales and marketing, analytics, and research and development;
Send messages that are related to products and services we provide (e.g., welcome messages and confirmation notices, and the like), your activity on the Services, or updates and changes to the Services or services, consistent with any applicable communications options we offer;
Contact you regarding Sway and third-party products, services, surveys, promotions, special events, and other subjects that we think may be of interest to you, consistent with any applicable communications options we offer;
Send you other marketing and promotional communications, consistent with any applicable communications options we offer;
Customize content, preferences, and advertising on the services, across the Internet and elsewhere;
Create aggregated, de-identified, or anonymized information (in which case, we may use and disclose appropriately aggregated, de-identified, or anonymized information for any lawful purpose);
Comply with laws, regulations, and other legal process and procedures; and
Establish, exercise, or defend our legal rights.
Disclosure of Information
Sway discloses information as follows:
To Other Users: As part of displaying a leader board on our Services, we may disclose your username in the leader board, along with other metrics specific to your use of the Sway app (such as the amount of points you earned, duration of commitments, and cumulative money pledged and forfeited).
To Vendors and Service Providers: We may disclose all categories personal information we collect to companies that provide services to us or to you, such as providers of data storage, payment processing, marketing, web hosting, security, analytics, and fraud prevention. For example, we may engage a third party to host or operate any aspect of the Services and any other aspect of our businesses, including any mechanism through which we send or receive communications, such as our email systems and our Services.
To Advertising Partners: We may disclose information to companies that help us provide advertising (on our Services and across the Internet) that we believe will be more interesting to you.
To Affiliates: We may disclose personal information to other members of our corporate family, including current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Sway, for the purposes described in this Privacy Policy.
Corporate Transactions: We may disclose personal information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
To Business Partners: We may disclose information to business partners, such as organizations with whom Sway partners to hold events and promotions.
Legal: We may disclose information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.
Protection of Sway and Others: We may disclose information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property, or safety of our company, our employees, our customers, or others; and to enforce our contracts.
Your Consent: If you have consented to additional disclosure of certain personal information, we may also disclose that personal information consistent with your consent.
We may disclose appropriately aggregated, de-identified, or anonymized information in these or other circumstances.
Your Rights and Choices
Marketing Preferences. You can unsubscribe from marketing emails you receive from a brand by clicking the unsubscribe link in the email or contacting us at privacy@sway.xyz.
Choices Regarding Cookies and Other Similar Technologies. Most browsers accept cookies by default. You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
Your browser settings may also allow you to automatically transmit a "Do Not Track" signal to online services you visit. Because there is no industry consensus as to what website operators should do with regard to these signals, we do not take action with respect to "Do Not Track" signals or other mechanisms, except as otherwise provided herein. For more information on "Do Not Track," visit http://www.allaboutdnt.com.
Access, Correction, Deletion. You can change your profile information at any time by visiting your profile and updating your information. You may also request access to, or correction or deletion of, information that we maintain about you by contacting us at the email address below. We will consider all requests we receive and reply in accordance with any applicable laws. We reserve the right not to agree to any such request if we deem it burdensome or otherwise injurious or inappropriate, or if such data will interfere with our ability to meet our own legal obligations, except to the extent required by applicable law.
Shine the Light (California Residents Only). California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Services that are California residents to request, once a year, certain information regarding our disclosure of “personal information” to third parties for their “direct marketing purposes” (as both terms in quotes are defined in the Shine the Light law). However, a company is not required to provide this information where it adopts and discloses a policy of not disclosing “personal information” to third parties for their “direct marketing purposes:” (1) unless the resident first affirmatively agrees or (2) if the resident has exercised an option that prevents that information from being disclosed. We maintain such a policy. To opt out, please email us at privacy@sway.xyz.
Protection of Information
We use various physical, technical, and administrative safeguards to help protect the personal information submitted to us. Unfortunately, no technology is completely secure. The safety and security of your personal information also depend on you. For example, you should safeguard your login credentials and must not share such credentials with others.
Retention of Information
Sway will retain your personal information until after we determine it no longer is needed to fulfill the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described in this Privacy Policy, we make backups of certain data, which we may retain for longer than the original data.
Children’s Privacy
Our Services are not directed to children, and we do not knowingly collect personal information from children under 13. If we discover that we inadvertently have collected such information, we will comply with legal obligations to delete it.
Third-Party Links
Our sites may contain links to third-party sites. They handle personal information pursuant to their own practices or policies, not this Privacy Policy.
Updates and Changes to This Notice
Sway may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.
Contact Information
If you have privacy or data protection questions, concerns, or suggestions for any of the Sway entities, the best way to contact us is by email at privacy@sway.xyz.
Sway Privacy Policy
Last updated: March 24, 2026
This Privacy Policy covers the practices of Manifest Global, Inc. dba Sway (hereinafter, “Sway” or “we” or “us”) concerning information that we handle in the context of offering or providing our services, including any such information we may collect from you or that you may provide when you visit our website sway.xyz, mobile app, or any of our other websites or services that link to this Privacy Policy (collectively, our “Services”).
This notice may change from time to time, so please check the notice periodically for updates.
This Privacy Policy contains the following sections:
Information We Collect
Use of Information
Disclosure of Information
Your Rights and Choices
Protection of Information
Retention of Information
Children’s Privacy
Third-Party Links
Updates and Changes to This Notice
Contact Information
Information We Collect
a. Information You Provide to Us
You may provide the following types of information to us:
Identifiers (such as name, username, physical address, email address, phone number, and other contact information);
Commercial information (such as information provided to us in your communications, transaction data, pledges, selected rewards, information about interactions with Sway, information about your interests and preferences, and information you provide in response to surveys or promotions offered by us);
Financial data (such as payment card data, which is processed by our payment processor);
Your aggregated device usage metrics, such as whether and for how long you used your device (in accordance with our integration of Apple’s Screen Time API);
Internet or other network or device activity (such as IP addresses, device identifiers, cookie data, device attributes, device usage information, browsing information, metadata, and other information);
Other information that identifies or can be reasonably associated with you, including information you voluntarily provide when you interact with us (such as contacting our customer service teams, the pledges you make on Sway and your total Sway points, which rewards you redeem, and information you provide to help us determine eligibility for a refund); and
Inferences drawn from any of the above.
b. Cookies and Other Information Collection Technology
Through our Services, we and third parties may collect information from your computer or other device by automated means such as cookies, web beacons, local storage, JavaScript, mobile-device functionality, and other computer code.
This information may include unique browser identifiers, IP address, browser and operating system information, device identifiers (such as advertising identifiers), general location data (inferred from IP address), other device information, Internet connection information, as well as details about your interactions with the relevant website, email, or other online property (for example, the URL of the third-party website from which you came, the pages on our website that you visit, and the links you click on in a website). In some cases (such as cookies), the tools described here involve storing unique identifiers or other information on your device for later use.
These technologies help us and our partners:
Provide you with content that we think will be of interest to you on our Services and across the Internet;
Store information about your preferences, allowing us to customize our Services according to your interests;
Perform analytics, estimate our audience size and usage patterns, and better understand the types of users interested in our products and services;
Diagnose and fix technology problems;
Plan for and enhance our business; and
Facilitate the other uses and disclosures described in this Privacy Policy and our cookie consent tools.
Please refer to the “Online Analytics and Advertising” section below for further information.
c. Information From Third Parties
We may also receive personal information from third parties, including our vendors and service providers, affiliates, and partners (such as our ad and analytics partners), as well as from publicly available sources (such as social media websites and apps). We may receive information about potential users and practitioners that may be interested in the Services from other users. If you submit someone else’s information to us, you represent that you are authorized to provide this information to us.
We may combine any information we collect about you from you or these various sources. If a combination of information that we collect identifies you as an individual, we will treat the combined information in accordance with this Privacy Policy.
d. Online Analytics and Advertising
Online analytics
We may use third-party analytics services on our Services (e.g., Google Analytics). These service providers may set and access their own cookies, pixel tags, and similar technologies on our Services and on third-party services to collect information that can be used to track users over time and across services. These analytics services help us understand how users arrive at and use our Services.
If you do not want Google Analytics to collect and use information about your use of our websites, then you can install an opt-out in your web browser. You also may opt-out from Google Analytics for Display Advertising or the Google Display Network by using Google’s Ads Settings.
Online advertising
We strive to provide you with relevant, value-added content in our online advertisements. We work with online analytics and advertising partners to: (1) better understand the use of our Services so that we can improve our Services; and (2) deliver Sway advertisements that are more tailored to you both on our Services and on third-party Services.
Our partners may also place cookies, pixel tags and similar technologies on many online services, including ours. They use these technologies to collect information about your activities on these services in order to deliver you more relevant advertising. For example, they may use the information they collect from their cookies on our Services to identify Sway products and services you might be interested in and to recognize your device so they can show you relevant Sway advertisements while you are using our Services and other services. Additionally, we sometimes provide basic information we collect (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies, mobile ad identifiers, and other proprietary IDs, in order to provide you with more relevant ads when you visit other online services.
If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your devices to deliver tailored advertising, you may visit the Digital Advertising Alliance’s Consumer Opt-Out link to opt out of receiving tailored advertising from companies that participate in those programs.
Use of Information
We and our vendors and service providers use the information described above for the following purposes:
Administer your account, including to process your registration and verify your information;
Provide, manage, and improve our products and services;
Determine eligibility to use our Services, and to redeem rewards and refunds, in accordance with applicable law and our policies;
Conduct business operations in support of our services, such as auditing, security, fraud prevention, invoicing and accounting, sales and marketing, analytics, and research and development;
Send messages that are related to products and services we provide (e.g., welcome messages and confirmation notices, and the like), your activity on the Services, or updates and changes to the Services or services, consistent with any applicable communications options we offer;
Contact you regarding Sway and third-party products, services, surveys, promotions, special events, and other subjects that we think may be of interest to you, consistent with any applicable communications options we offer;
Send you other marketing and promotional communications, consistent with any applicable communications options we offer;
Customize content, preferences, and advertising on the services, across the Internet and elsewhere;
Create aggregated, de-identified, or anonymized information (in which case, we may use and disclose appropriately aggregated, de-identified, or anonymized information for any lawful purpose);
Comply with laws, regulations, and other legal process and procedures; and
Establish, exercise, or defend our legal rights.
Disclosure of Information
Sway discloses information as follows:
To Other Users: As part of displaying a leader board on our Services, we may disclose your username in the leader board, along with other metrics specific to your use of the Sway app (such as the amount of points you earned, duration of commitments, and cumulative money pledged and forfeited).
To Vendors and Service Providers: We may disclose all categories personal information we collect to companies that provide services to us or to you, such as providers of data storage, payment processing, marketing, web hosting, security, analytics, and fraud prevention. For example, we may engage a third party to host or operate any aspect of the Services and any other aspect of our businesses, including any mechanism through which we send or receive communications, such as our email systems and our Services.
To Advertising Partners: We may disclose information to companies that help us provide advertising (on our Services and across the Internet) that we believe will be more interesting to you.
To Affiliates: We may disclose personal information to other members of our corporate family, including current or future parents, subsidiaries, affiliates, and other companies under common control or ownership with Sway, for the purposes described in this Privacy Policy.
Corporate Transactions: We may disclose personal information as part of, or to take steps in anticipation of, a sale of all or a portion of our business, a divestiture, merger, consolidation, asset sale, bankruptcy, or other significant corporate event.
To Business Partners: We may disclose information to business partners, such as organizations with whom Sway partners to hold events and promotions.
Legal: We may disclose information when we believe disclosure is appropriate due to a subpoena or similar investigative demand, a court order, or other request from a law enforcement or government agency; or as otherwise required by law.
Protection of Sway and Others: We may disclose information when we believe disclosure is appropriate in connection with efforts to investigate, prevent, or take other action regarding illegal activity, suspected fraud, or other wrongdoing; to protect and defend the rights, property, or safety of our company, our employees, our customers, or others; and to enforce our contracts.
Your Consent: If you have consented to additional disclosure of certain personal information, we may also disclose that personal information consistent with your consent.
We may disclose appropriately aggregated, de-identified, or anonymized information in these or other circumstances.
Your Rights and Choices
Marketing Preferences. You can unsubscribe from marketing emails you receive from a brand by clicking the unsubscribe link in the email or contacting us at privacy@sway.xyz.
Choices Regarding Cookies and Other Similar Technologies. Most browsers accept cookies by default. You can change your settings to notify you when a cookie is being set or updated, or to block cookies altogether. Please consult the “Help” section of your browser for more information (e.g., Internet Explorer, Google Chrome, Mozilla Firefox, or Apple Safari). Please note that by blocking any or all cookies, you may not have access to certain features or offerings of the Services.
Your browser settings may also allow you to automatically transmit a "Do Not Track" signal to online services you visit. Because there is no industry consensus as to what website operators should do with regard to these signals, we do not take action with respect to "Do Not Track" signals or other mechanisms, except as otherwise provided herein. For more information on "Do Not Track," visit http://www.allaboutdnt.com.
Access, Correction, Deletion. You can change your profile information at any time by visiting your profile and updating your information. You may also request access to, or correction or deletion of, information that we maintain about you by contacting us at the email address below. We will consider all requests we receive and reply in accordance with any applicable laws. We reserve the right not to agree to any such request if we deem it burdensome or otherwise injurious or inappropriate, or if such data will interfere with our ability to meet our own legal obligations, except to the extent required by applicable law.
Shine the Light (California Residents Only). California's “Shine the Light” law (Civil Code Section § 1798.83) permits users of the Services that are California residents to request, once a year, certain information regarding our disclosure of “personal information” to third parties for their “direct marketing purposes” (as both terms in quotes are defined in the Shine the Light law). However, a company is not required to provide this information where it adopts and discloses a policy of not disclosing “personal information” to third parties for their “direct marketing purposes:” (1) unless the resident first affirmatively agrees or (2) if the resident has exercised an option that prevents that information from being disclosed. We maintain such a policy. To opt out, please email us at privacy@sway.xyz.
Protection of Information
We use various physical, technical, and administrative safeguards to help protect the personal information submitted to us. Unfortunately, no technology is completely secure. The safety and security of your personal information also depend on you. For example, you should safeguard your login credentials and must not share such credentials with others.
Retention of Information
Sway will retain your personal information until after we determine it no longer is needed to fulfill the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period of time. To provide security and business continuity for the activities described in this Privacy Policy, we make backups of certain data, which we may retain for longer than the original data.
Children’s Privacy
Our Services are not directed to children, and we do not knowingly collect personal information from children under 13. If we discover that we inadvertently have collected such information, we will comply with legal obligations to delete it.
Third-Party Links
Our sites may contain links to third-party sites. They handle personal information pursuant to their own practices or policies, not this Privacy Policy.
Updates and Changes to This Notice
Sway may update this Privacy Policy from time to time, such as to reflect changes in our practices or for legal reasons. We will post those changes here or on a similarly accessible page.
Contact Information
If you have privacy or data protection questions, concerns, or suggestions for any of the Sway entities, the best way to contact us is by email at privacy@sway.xyz.