Privacy Policy Overview


Effective from September 4, 2018.

The Terms, Intercut Rules and Privacy Policy collectively make up the End User License Agreement (EULA or  “Agreement”) that governs a user’s access to and use of Intercut’s services. For EU users, it also incorporates the Data Processing Addendum (DPA).

This policy (collectively, the “Privacy Policy”) tells you how Swivl (“Swivl”, “we” or “us”) uses personal information collected through the Intercut Services that you access on this site or the Intercut app (collectively the “site” or “website”).

Intercut is a service intended for users both outside of and within educational settings with policies aimed to protect children. It is intended for use with children above and below the age of sixteen with appropriate consent, and to protect Student records. It is compatible for use in schools subject to FERPA, and complies with COPPA and GDPR requirements. Swivl is also a Privacy Pledge Signatory and works to safeguard Student privacy regarding the collection, maintenance, and use of Student personal information.

This policy is separate and unique to our company website or any other Swivl service that may be linked to it. The main purpose of is marketing and is not intended for use or by users in educational settings. The privacy practices set forth in this Privacy Policy are for this web site only. If you link to other web sites, please review the privacy policies posted at those sites.

Please read this Privacy Policy before using the site or submitting any personal information. When you sign up to start using the site, you are accepting the practices described in this Privacy Policy. We may revise and update this Privacy Policy from time to time. We will provide notice and require opt-in consent for any material changes to this policy before using.

Privacy Policy


Use of Cookies/Do Not Track.

Intercut Services uses cookies to store visitors’ preferences and to record session information, for purposes of managing and improving the services. We do not link the information we store in cookies to any personal information you submit while on our site. You may be able to configure your browser to accept or reject all or some cookies, or notify you when a cookie is set, so check the “Help” menu of your browser to learn how to change your cookie preferences. We do not respond to “do-not-track” signals or other mechanisms that allow users to signal their preferences on the collection of their personal information over time and across third-party web sites or online services.

To opt-out of our use of cookies, you can instruct your browser, by changing its options, to stop accepting cookies or to prompt you before accepting a cookie from websites you visit. If you do not accept cookies, however, you may not be able to use all aspects of our Services.

How we Collect, Use and Disclose Non- Personal Information.

For each visitor to our websites, we collect non-personally-identifiable information including IP address, profile information, aggregate user data, preferences, technical session information, browser type (“non-personal information”). If you arrived at our website via a link from another webpage, we also may receive aggregate or otherwise anonymous statistical information about your visit to our site. We also use information collected from cookies and other anonymous identifiers to improve your user experience and the quality of our services. If you give us personal information, we may remove the identifiers and aggregate it, in which case it also becomes non-personal information. We will not use non-personal information for any reason other than the purpose for which it was collected or authorized for use. We may use or share aggregate non-personal information for any reason.

What Personal Information We Collect.

We collect personal information (“personal information”), like names, email addresses, comments, images and videos of your likeness etc., only when voluntarily submitted by you or your authorized users. This information may be provided in the form of videos, comments, photos or forms that contain personal information. We may offer some services on or in collaboration with other Internet web sites, or through third party applications such as gadgets or extensions. Personal information that you provide to those third-party sites may be sent to us so that we can deliver the requested service. We process such information under this Privacy Policy. Any information collected when you enable a third party application on our site is processed under our Privacy Policy. However the use of that information by the third party application provider to whom it is given is governed by their privacy policies.

We also may collect and store personal information about other people that you provide to us. If you use our website to send others information that may interest them or messages through our system, we may store your personal information, and the personal information of each such recipient. Similarly, if you use our website to share and/or distribute content (including videos, comments or other submissions), and such content contains personal information about others, such information may be stored in order to allow for such uploading, sharing and/or distribution.

We also obtain other information, including personal information, from third parties and combine that with information we collect through our Intercut services. You can log in to our Services using your credentials through Google. Google will authenticate your identity and provide you the option to share certain personal information with us such as your name and email address to pre-populate our sign up form.

Our Services uses YouTube API Services, and data shared with us by users from a YouTube account is subject to YouTube’s Terms of Service ( and the Google Privacy Policy ( In the case that a YouTube account is linked to our Services, we store your Google User ID for authentication purposes, and an encrypted token for uploading the videos on YouTube. We do not store thumbnails of the videos and the videos themselves – you can watch the videos on the official YouTube website. You can revoke our access to your YouTube account at any time via the Google security settings page at Data provided by YouTube is not shared with any external parties.

How We Use and Disclose Personal Information

We only use or process personal information in a way that is compatible with and relevant for the purpose for which it was collected or authorized for use. We may use personal information we collect to provide the service or transaction you requested, and importantly, to maintain and improve the services we provide, including for example by providing you with a better user experience when accessing our services. We may use your personal information to respond to your requests. Our use of information other than for the purpose of completing a requested transaction or service is on an opt-in basis. This means that you will not receive communications from us regarding, for example, specials, new products or new services, unless you have given us affirmative permission to receive such communications.

How We Protect Children’s Privacy.

Children under the age of sixteen can use the Intercut services with consent from a parent. An educator can also provide consent and assume responsibility for obtaining the appropriate parental consent. Swivl does not knowingly accept, collect, maintain or use any information from any child under the age of sixteen without the appropriate consent. If a child whom Swivl knows or suspects to be under the age of sixteen sends personal information to us online without appropriate consent, we will only use that information to respond directly to that child, notify the parents, or seek parental or other appropriate consent. Parents can at any time request deletion of data or of the entire account.

Retention of Data and Authorized Data Processors

Users are responsible for determining the duration necessary to retain content for their purposes. When the purpose is complete, it is recommended that users delete the content. Note that content deleted by the user is retained for 30 days for recovery purposes due to accidental deletion (per user request) and then removed permanently from the Intercut storage servers. In addition, if a users account is inactive for more than a calendar year, content will be automatically deleted using the same procedure. This insures that data is not retained any longer than is required.

We may share your personal information with our authorized service providers (sub-processors) that perform certain services on our behalf. These services may include providing customer service, performing business analysis and supporting our website functionality or other services that are necessary to operate the site. We do not disclose any personal information to authorized service providers from Student Account holders beyond what is necessary to operate the site. See our List of Sub-processors.

We may share personal information of users above the age of sixteen on an opt-in basis to business partners to support contests, sweepstakes, surveys and other features offered through our website now or in the future.

How To Access and Control Your Information

You, and parents of users under the age of sixteen have the right to request a copy of your information, to object to our use of your information, to request the deletion of your information, or to request your information in a structured, electronic format. Below, we describe the tools and processes for making these requests. For all other requests, you may contact us as provided in the Contact Us section below to request assistance.

Your request and choices may be limited in certain cases: for example, if fulfilling your request would reveal information about another person, or if you ask to delete information which we are permitted by law or have compelling legitimate interests to keep. If you have unresolved concerns, you may have the right to complain to a data protection authority in the country where you live, where you work or where you feel your rights were infringed.

Our Services give you the ability to access and update certain information about you from within the Service. You can update your profile information within your profile settings and modify content that contains information about you using the editing tools associated with that content.

If you no longer wish to use our Services and you wish to delete your account, please contact Intercut Support as shown in the Contact Us section.

You may opt out of receiving promotional communications from us by using the unsubscribe link within each email, updating your email preferences within your Service account settings menu, or by contacting us as provided below to have your contact information removed from our promotional email list or registration database. Even after you opt out from receiving promotional messages from us, you will continue to receive transactional messages from us regarding our Services.

Other Situations That Require Sharing Data

-In response to a subpoena or similar investigative demand, a court order, or a request for cooperation from law enforcement or other government agency; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases, we may raise or waive any legal objection or right available to us, in our sole discretion.

– When we believe disclosure is appropriate in connection with efforts to investigate, prevent, report 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 users, our employees, or others; to comply with applicable law or cooperate with law enforcement; or to enforce our Legal Terms or other agreements or policies.

– In connection with a substantial corporate transaction, such as the sale of our business, a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

Information for Residents of the European Union.

Intercut’s services are hosted and operated entirely within the United States of America, and any information you submit to us is presumed to be hosted on servers located within the USA. By submitting information to us you consent to this transfer of your personal information to the United States. Governed by the following Data Processing Addendum (DPA).

How we Approach Security

We have implemented generally accepted standards of technology and operational security in order to protect personal information from loss, misuse, alteration, or destruction. We will use our reasonable efforts to limit access to your personal information to our authorized personnel and approved processors, and these employees and vendors are required to treat this information as confidential. Despite these precautions, we cannot guarantee that unauthorized persons will not obtain access to your personal information.

Sharing & Social Media Guidelines

Other users of the service can see or access the information you post through Intercut when shared using “Public” (not provided to users under 16). When shared using “Private” (weblink, Discussions, etc), they can only be viewed as defined by the sharing tool and cannot be seen by general service users. You can deliberately share public links via email or social media for all content. You are responsible for the content of anything you share, in accordance with our Legal Terms.

The Intercut Services includes the ability to forward text. audio and videos to others. If you use the Intercut™ Services to post information about yourself or others, or communicate with others; share content (e.g. pictures, videos, audio files, etc.); and post comments of content, such postings are governed by our Legal Terms. Whenever you voluntarily disclose personal information on publicly-viewable web pages, that information will be publicly available and can be collected and used by others. For example, if you post your email address, you may receive unsolicited messages. We cannot control who reads your posting or what other users may do with the information you voluntarily post, so we encourage you to exercise discretion and caution with respect to your personal information. Once you have posted information, you may not be able to edit or delete such information.

The Intercut Services uses social sharing buttons, which help share web content directly to the social media platform in question. Users are advised before using such social sharing buttons that they do so at their own discretion and note that the social media platform may track and save your request to share a web page respectively through your social media platform account. Your use of these platforms is governed by their respective privacy policies and terms.

Internal Policies for Managing Your Data.

In general, Swivl employees are prohibited from viewing the content of files you store in your account other than for the purposes of providing the Intercut Services. Employees may access file metadata (e.g., file names and locations) when they have a legitimate reason, like providing technical support. Like most online services, we have a small number of employees who must be able to access user data for the reasons stated elsewhere in this Privacy Policy (e.g., when legally required to do so). A very select number of employees (senior engineering leadership) have the ability to access user data for the purposes of monitoring that policies are adhered to, when legally required or requested by a user for technical support.

California Privacy Rights.

California Civil Code Section § 1798.83 permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, send an email to

Contact Us

If you have any questions, please contact us at:

Swivl, Inc.
1450 El Camino Real, Menlo Park, CA 94025

For European privacy related inquiries, contact us at: