Privacy Policy

Last Revised: November 1, 2014

The following privacy policy (“Privacy Policy”) outlines the information Swillio, Inc., (“Swill,” “we” or “us”) may collect and how we may use that information to better serve visitors and users while using our website, (the “Website”) and our mobile application “Swill” (the “App”).


If you have questions about this Privacy Policy, please contact us at [email protected].

Age Restrictions

The Service is not intended for use by anyone under the age of 21. Persons under 21 are not allowed to register with or use the Service. We do not knowingly collect personal information from or about anyone under the age of 21. If we discover that we have collected personal information from a person under 21, we will delete that information immediately. Please refer to our End User License Agreement and Terms of Service (License) for additional information about age verification and eligibility.

Information We Collect

Registration Information

Upon registration with the Service, a user profile is developed to further customize the user’s experience. We collect and store in log files the information you actively enter onto our online forms, such as:

  • Email
  • Password
  • Name
  • Date of Birth
  • Delivery Phone Number
  • Billing Phone Number
  • Delivery Address and Zip Code
  • Billing Address and Zip Code
  • Sex
  • Alcohol Preferences

Device Type

When you register or use the App, we also collect device type within the App and store this information in log files. We use this information to provide you with the most up to date application and features, or to advertise or promote products and services to you that are applicable to your device type, as described in this Privacy Policy.

Tracking Information

In addition, tracking information is collected and stored in log files as you navigate through the Website or use the Service, including, but not limited to purchase history, delivery location history, and click tracking.

Geolocation Data

If you use the Services through your mobile device, we will collect your geo-location information so that we can determine to which retailer we should send your order for fulfillment. We will not share this information with third parties and will only use this information for the sole purpose of fulfilling your order. You may at any time no longer allow the App to use your location by turning this off at the device level.

Job Applications

If you wish to apply for a job on our Website we will collect personal information such as your name, email address, phone number and additional information such as your resume. We use the information collected within this area of the Website to determine your qualifications for the position in which you have applied and to contact you to set up an interview.

Invitations to Swill

If you choose to invite an individual to use the Services, you will need to provide his/her name and email address. Swill stores this information to track the results of the invitation referrals.


To help us serve your needs better, we use “cookies” to store and sometimes track user information. A cookie is a small amount of data that is sent to your browser from a web server and stored on your computer’s hard drive. A website can use cookies to recognize repeat users or track web usage behavior. Cookies take up minimal room on your computer and cannot damage your computer’s files. Cookies work by assigning a number to the user that has no meaning outside of the assigning website. Users of the Website should be aware that non-personal information and data may be automatically collected by virtue of the standard operation of Swill’s computer servers or through the use of cookies. If you do not want information to be collected through the use of cookies, your browser allows you to deny or accept the use of cookies. There may, however, be some features of the Service which require the use of cookies in order to customize the delivery of information to you.

Users should be aware that Swill cannot control the use of cookies (or the resulting information) by third-parties. The use of third party cookies is not covered by our Privacy Policy. We do not have access or control over these cookies.

How We Use Your Information

To Provide the Service

We use the information that we collect from you to provide you with the Service, support and enhance your use of the Service, to monitor which features of the Service are used most, to allow you to view your purchase history, to allow you to view any promotions we may currently be running, to allow you to rate purchases, and to determine which features we need to focus on improving. If you choose to provide us with personal information, you consent to the transfer and storage of that information on our servers.

If you download the App and the Service is not available in your geographic location, you will have the option to provide us with your email address and zip code so that we may notify you when the Service becomes available in your geographic location. If you choose to provide us with this information, we will use it solely for this notification purpose.

We also use usage patterns and geographic locations to determine to which retailer we should send a user’s order for fulfillment, and where we should offer or focus services, features and/or resources. We may also track your past purchases to provide you with a personalized profile of your shopping history. In addition, Swill may notify you about new services or special promotional programs, or send you offers or information.

We use the device information collected so that we are able to serve you the correct application version depending on your device type, and for troubleshooting.

We use Non-Personally Identifiable Information (as defined below) in the aggregate, so that we can improve the Website and for business and administrative purposes. Non-Personally Identifiable Information means information that may correspond to a particular person, account, or profile, but that is not sufficient to identify, contact, or locate the person to whom such information pertains. We may also use or share with third parties for any purpose aggregated data that does not contain personally identifiable information.

Diagnose Website Problems

Swill uses your Internet Protocol (IP) address to help diagnose problems with our computer server, and to administer the Website. Your IP address is used to gather broad demographic data. Your IP address contains no personal information about you.

Service-related Announcements

We will send you strictly service-related announcements on rare occasions when it is necessary to do so. For instance, if our service is temporarily suspended for maintenance, we might send you an email.

Generally, you may not opt-out of these communications, which are not promotional in nature. If you do not wish to receive them, you have the option to deactivate your account.

Customer Service

We will send you a welcoming email to the address you provide at registration to verify your username and password. We will also communicate with you in response to your inquiries, to provide the services you request, and to manage your account. We will communicate with you by email or telephone, in accordance with your wishes.

Identification of Age Restricted Accounts

If deliver fails because of an underage issue, we will flag and/or suspend the account in our system.

Targeted or Behavioral Advertising

Targeted advertising (also known as Behavioral Advertising) uses information collected on an individual’s web browsing behavior such as the pages they have visited, the searches they have made, the type of device they have used, or the orders they have placed. This information is then used to select which advertisement should be displayed to a particular individual via the Service. For example, if you have shown a preference for a type of beverage while using the Service, you may be served an advertisement via the Service relating to that type of beverage. We may share or sell aggregated demographic information about our user base, including information related to your use of the Service (e.g., how you interact with our App and website, our partners and advertisers), your device type, UUID, purchase history, delivery location history, and click tracking, with third party advertisers for the purpose of selecting an appropriate audience for their advertisements, but only after either removing from such information anything that personally identifies you or combining it with other information so that it no longer personally identifies you. This information does not identify individual users by name, email or other contact information. If you would like to opt out of targeted advertising that occurs when using the Services, please contact us at [email protected]. Please note that this will opt you out of targeted ads delivered via the Services. If you opt out, you will continue to receive online advertising via the Services; however, these ads may not be as relevant to you.

Our Disclosure of Your Information

We share collected information from or about you only as follows:

Aggregated Data

Swill may share or sell aggregated demographic or other information about our user base that includes Non-Personally Identifying Information and log data (including how users interact with our App and website), with third parties for industry analysis, demographic profiling and to deliver targeted advertising about other products and services. This information does not identify individual users by name, email or other contact information.

Third Party Service Providers

We use a third party hosting provider who hosts our support section of the Service. Information collected within this section of the Service is governed by this Privacy Policy. Our third party service provider does not have access to this information.

We may employ third party companies and individuals to facilitate our Service, to provide the Service on our behalf, provide customer support, perform Website-related services (e.g., without limitation, maintenance services, database management, web analytics and improvement of the Website’s features) or to assist us in analyzing how our Website and Service are used. These third parties have access to your personal information only to perform these tasks on our behalf.

Payment/Credit Card Transactions

All payments and credit card transactions are processed by secure third party payment processors, and not by Swill. We have no control over third party payment processors. Any information that you provide to a third party payment processor is governed by such payment processor’s separate privacy policy, instead of this Privacy Policy. Please consult the privacy policy of the applicable third party payment processor. Swill neither accepts nor processes any payments, and neither Swill nor any retailers that facilitate the Services ever see or receive your payment card information.

Law Enforcement

Swill cooperates with government and law enforcement officials and private parties to enforce and comply with the law. We will disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), to protect the property and rights of Swill or a third party, to protect the safety of the public or any person, or to prevent or stop activity we may consider to be, or to pose a risk of being, an illegal, unethical or legally actionable activity.

Acquisition of Swill

In the event that all or a substantial portion of the assets, business or stock of Swill are acquired by, merged with or transferred to another party, or in the event that Swill goes out of business or enters bankruptcy, your personal information would be one of the assets that is transferred to or acquired by the third party. You acknowledge that such transfers may occur, and that any acquirer of Swill or its assets may continue to use your personal information as set forth in this Privacy Policy. If any acquirer of Swill or its assets will use your personal information contrary to this Privacy Policy, you will receive prior notice.

Accessing And Updating Your Personal Information and Preferences

If your personal information changes, or if you no longer desire our Service, or if you wish to update your preferences to receive email or other communications from us, you may correct, delete inaccuracies, or amend your personal information and preferences by making the change on our user information page or by emailing us at [email protected]. We will respond to your access request within 30 days. Please note that your friends and contacts may still choose to send email invitations to you. Any user who receives an email invitation to join the Service may choose not to receive such invitations in the future by following the instructions in the email invitations and, in addition, if you are a user, you may also choose not to receive such invitations by changing your preferences as indicated above. We will take commercially reasonable steps to implement your opt-out requests promptly, but you may still receive communications from us for up to 30 days as we process your request.

Retention of Personal Information

Swill will retain your personal information for the period necessary to fulfill the purposes outlined in this Privacy Policy unless a longer retention period is required or permitted by law.


All information we collect is securely stored within our database, and we use standard, industry-wide, [Payment Card Industry compliant, commercially reasonable security practices such as 128-bit encryption, firewalls and SSL (Secure Socket Layers).] However, as effective as encryption technology is, no security system is impenetrable. We cannot guarantee the security of our database, nor can we guarantee that information you supply won’t be intercepted while being transmitted to us over the Internet, and any information you transmit to Swill you do at your own risk. We recommend that you use unique numbers, letters and special characters in your password and not disclose your password to anyone. If you do share your password or personal information with others, you are responsible for all actions taken in the name of your account. If your password has been compromised for any reason, you should immediately notify Swill and change your password.

Public Forums

Our Website may offer publicly accessible blogs or community forums. You should be aware that any information you provide in these areas may be read, collected, and used for any purpose by others who access them. We are not responsible for the personally identifiable or other information you choose to submit in these areas. To request removal of your personal information from our blogs or community forums, contact us at [email protected]. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.

Changes To The Privacy Policy

We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice on this Website and in the App prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

Contact Information


Swillio, Inc.
85 Broad Street 18th Floor
New York, NY 10004

Email: [email protected]