SmartSwipe Privacy Policy

[Last Modified: April 27, 2025]

1. Introduction

This privacy policy (“Privacy Policy”) governs the data collection practices Big Star Labs LP (“Company”, “us”, “we” and “our”) uses when you use our SmartSwipe mobile application (“App”) or visit our website at: https://crxmouse.com/. The Website, App and any services provided therein shall be referred to collectively in this Privacy Policy as the “Services”. This Privacy Policy is provided to make important and transparent disclosures on how or why we collect and use or share our users’ information. Our users’ privacy is important to us. We encourage you to read this Privacy Policy carefully prior to using any of our Services and use it to make informed decisions. For the purposes of this Privacy Policy and user of one of the App may also be referred to as a “User.”

PLEASE MAKE SURE TO READ AND UNDERSTAND THIS PRIVACY POLICY BEFORE USING ANY OF THE SERVICES. 

If permitted under applicable law, this Privacy Policy is an integrated part of the Company’s Terms and Conditions (“Terms”). Your use of our Services constitutes your acknowledgement of this Privacy Policy. The definitions herein shall have the same meaning as defined in the Terms. If you object to this Privacy Policy, please do not access or use the App.

This Privacy Policy applies to all of our users globally. Please review Section 15 for more information about your California privacy rights and the categories of Personal Information we collect, if you are a resident of California. For other residents of other U.S. states please read Section 16 to learn more about the privacy rights you may have if you are a resident of certain other U.S. states (e.g., Colorado, Connecticut, Virginia, Utah, Montana, Oregon, and Texas).

2. Who are we? 

Big Star Labs LP is a Delaware limited partnership and is the Controller (as defined under the General Data Protection Regulations (“GDPR”) and UK privacy law or any equivalent privacy law) of any Personal Information (as such term is defined below) that we may process from our users. Please contact us at: dpo@crxmouse.com if you have any inquiries regarding this privacy policy or our privacy practices. 

3. How do we Collect your Personal Information?

4. What Information Do We Collect?

The information we collect in connection with your use of our Services are either Personal Information or Non-Personal Information as we explain further below. Non-Personal Information is mainly non-identifiable information, which may be made available or gathered via your use of our Services (“Non-Personal Information”). In other words, we are not aware of, and cannot determine the identity of the user from which the Non-Personal Information is collected. 

We may also collect individually identifiable information, namely information that identifies an individual or may with reasonable effort be used to identify an individual (“Personal Information”) when you install, download, visit or use our Services. The term Personal Information will include the definitions for Personal Information and Personal Data as such terms are defined under applicable privacy laws. Personal Information will only be processed if we have a legal basis for us to do so for example: (i) in the event it was voluntarily provided by you if and when you contact us, to communicate with you and provide you with the support you have requested; and (ii) with respect to online identifiers, to provide and improve our Services and features, as further detailed below. In addition, some of the Personal Information that we collect, as further explained below, may be considered “Special Categories of Personal Data” as defined under the GDPR or “Personal Sensitive Data” under the CCPA (collectively, “Sensitive Information”). Please read the Visited Webpages and Usage Data section to further understand why this may be the case.   

For clarification, we adhere to the data minimization principal, and thus, we have implemented applicable measures to make an effort, where possible to de-identify or pseudonymize the data sets processed while you use our Services, as further explained below. We will treat any Non-Personal Information that is somehow connected with Personal Information as Personal Information as long as such information continues to be connected. It is also important for us to note, that you are not under any obligation to provide us with any Personal Information and you can decide what, if any, Personal Information to provide us with.

Please see below the types of information we process:  

(I) Information Processed from visitors to our Website (including our Users): 

(II) Information Processed from Users:  

5. How is your Information Used?

6. Lawful Basis for Data Processing

In addition, subject to applicable laws, with regards to our use of cookies, we will request your consent prior to enabling the collection of your Personal Information by cookies, and where permissible, we will process the data collected based on our legitimate interest. We may share some of the information above if we are required to do so by law and we may share the information with our affiliates for them to compile and disclose analytics and market intelligence data derived from the information we collect about you and other users through the Services. We make an effort to remove or filter out identifiers from the data that we process from you; however, we cannot guarantee that all Personal Information is removed at all times. Generally, the data that our affiliates disclose to their customers is aggregated and converted into metrics that do not identify you. In certain very limited cases, our affiliates may disclose your Personal Information to their customers so they can then conduct their own analysis on consumer behaviors; however, our affiliates will contractually prohibit their customers from using this information to send you targeted advertising or from sharing or disclosing this information with other third parties.

You are always able to opt out of the data collection, including in relation to our use of cookies and our direct marketing activities, as explained herein. 

7. How is the Data Shared?

We will not share any Personal Information collected from you with third parties, other than in the following limited circumstances: (i) to comply with our obligations under applicable laws; (ii) in the event necessary to detect and resolve security issues; (iii) in the event of a corporate transaction (e.g. sale of a substantial part of our business, merger, consolidation or asset sale); or (iv) with our service providers (operating under our instructions), who may need to access the information in connection with their services on our behalf, for the purpose of enabling and improving the App and features (including our third-party payment processors and service providers who manage our direct marketing for us). These service providers may include our affiliated companies (including as explained in Section 5 (Lawful Basis for Data Processing)) above, and other third party providers such as Google Analytics (as detailed under the cookies section below). 

8. Cookies and Third-Party Tools

When you use our Services, we may use cookies which are small text files found in a browser directory, assigned by a website. It is a standard practice to use cookies, and they are used for different purposes including allowing you to navigate among pages efficiently, facilitating automatic activation of some features, remembering your preferences, and making the interaction between you and various services such as ours easier and faster. In addition, cookies are used to help customize your user experience. More information about cookies can be found at www.allaboutcookies.org.

Our Website includes the following third-party cookies:

Google Analytics: these cookies are used for analytics purposes and to collect information about how users use our website, in order to improve it, as well assess performance of the content therein. These cookies enable us, for example, to assess the number of users who have viewed a certain webpage as well as their country of origin. 

For more information, please review Google’s privacy policy available HERE, as well as Google Analytics opt out available HERE. For additional information regarding our use of Google products, click HERE.

Youtube: this cookie is an analytical, measurement and performance cookie and is used to collect information about how users use our website, in order to improve it, as well as assess the performance of the content therein. Please see the relevant privacy policy here.

Facebook: this cookie this cookie is an analytical, measurement and performance cookie and is used to collect information about how users use our website, in order to improve it, as well as assess the performance of the content therein. Please see the relevant privacy policy here.

Cookies Opt-Out:   

You may disable cookies via your device or browser settings. Please review the following links in order to learn more about how you can disable cookies with respect to your particular browser: Google Chrome ; FireFox ; Internet Explorer ; Safari ; Edge ; Opera 

9. Data Retention 

Please note that, unless you instruct us otherwise, we retain the information we collect solely for as long as needed to provide the Services and to comply with our legal obligations, resolve disputes and enforce our agreements (including our Terms), all subject to our reasonable discretion. 

10. User Rights

You may opt out of the collection of your Personal Information by visiting the Privacy Center in the app and disabling “Smart Suggestions”.

After you opt out, we will no longer automatically collect and share your information as described in this Privacy Policy. Note that once you opt out, part of the services provided by the App will no longer be available. 

Some Users may have certain rights under applicable law (for example if you are a resident of the EU or UK), and subject to applicable exceptions, you may have the following rights: 

  1. Right to be Informed; Right to Know: This means you would have the right to understand and confirm what Personal Information we collect about you and how we use or share this data. 
  2. Right to Access: This means you would have the right to access and obtain a copy of the Personal Information that we hold about you. 
  3. Right to Correction: This means that you would have the right to ask that we correct Personal Information of yours that is inaccurate, depending on the nature of the processing. 
  4. Right to be Forgotten; Right to Deletion: Under certain situations, you may have the right to request that we delete your Personal Date. 
  5. Right to Restriction: Under certain circumstances, you may have the right to ask us to restrict our processing of your Personal Information. 
  6. Right to Port your Personal Information: This means you can ask us to provide you with your Personal Information in a machine readable, commonly used and structured format (of our choosing) and be able to transmit the Personal Information to a third party (another Controller). 
  7. Right to Object to Processing Based on Legitimate Interest: This means you can object to the processing of your Personal Information based on our legitimate interests however, if you choose to exercise your right we will be able to demonstrate that we have a compelling legitimate interest which overrides your rights and freedoms. 
  8. Right to Withdraw Consent: This means you can choose to opt-out of the processing of your Personal Information that we obtained your consent to process in the first place as we explained above how to do so. Your withdrawal of your consent will not affect the processing of your Personal Information that was done prior to your request to withdraw your consent.
  9. Right to Information Regarding Data Transfers: This means you may have the right to get a copy or reference to the safeguards we use to transfer your Personal Information. 

In order to assert any of these rights, please contact our Data Protection Officer at: dpo@crxmouse.com. Note that we may request proof of identity, and we reserve the right to charge a fee, where allowed by law, such as in circumstances where your request is excessive.

In addition, you may have the right to lodge a complaint with a supervisory authority, subject to applicable law (as is the case in the European Union and the UK).

If you are a resident of a U.S. state, please see the relevant U.S. privacy law section below for your state to learn more about your rights under such laws. 

11. How do we safeguard your information?

We use security methods and encryptions when handling processing data (i.e., handle the user data securely, including transmitting it via modern cryptography), and we have implemented technical, physical and administrative security measures to protect your information, among others, the filtering and hashing methods we are using, in order to secure your Personal Data. We use AWS data servers to store the data we collect. For information regarding the data security measures offered by AWS, please see: https://aws.amazon.com/security/.  

Please note, we cannot guarantee that your information is 100% secure when it is transmitted over the internet and therefore, we recommend that you take appropriate steps to protect your information. 

If in the event you feel that your privacy was not dealt with in an appropriate manner or in breach of this Privacy Policy, please contact our DPO at dpo@crxmouse.com. Additionally, please contact our DPO if you are made aware of a third party’s attempt to access your Personal Information and is unauthorized to do. If we are required to do so under applicable law, we will make a reasonable effot to notfiy you and any relevant authorities (if required to do so under applicable law) if we become aware of a security breach of your Personal Information. 

12. Data Transfer

Transfers of your Personal Information will be made in accordance with applicable data protection laws. We will take the steps necessary to ensure that international transfers of Personal Information meet all requirements under applicable data protection laws. When Personal Information collected within the European Economic Area (“EEA“) or the UK is transferred outside the EEA or the UK (for example to AWS servers located in the US or among our affiliates), we will take the steps necessary to ensure that the transfer of such data provides sufficient safeguards, including, pursuant to standard contractual clauses approved by the relevant data protection authorities. You may exercise your rights, where applicable, to receive information on such transfer mechanism and contact our DPO at: dpo@crxmouse.com. 

13. Minors

Children under 16 (or a younger age as applicable in the jurisdiction where you reside) are prohibited from using the App. In the event that we become aware that a user under the age of 16 has shared any information, we will discard such information. If you have any reason to believe that a child under the age of 16 has shared any information with us, please contact our Data Protection Officer at: dpo@crxmouse.com. If you are under 18, please be sure to read this policy with your parents or legal guardians and ask questions about things you do not understand.

14. Amendments

This Privacy Policy may be updated from time-to-time. The effectiveness of such updates will be reflected in the  “Last modified” heading above. We recommend that you check back from time-to-time for any updated to this Privacy Policy. We will notify you of any material changes if we are required to do so under applicable law.

15. Privacy Information for California Residents

California Consumer Privacy Act

This section applies only to California residents. It explains what types of Personal Information we collect, where we collect it from, the purposes for which we use it, and how and for what purposes we may share it. “Personal Information” as used in this section has the meaning ascribed to it under the California Consumer Privacy Act (“CCPA“) which is any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular California resident or household. This section of the Privacy Policy does not apply to publicly available information or Personal Information that is otherwise exempt under the CCPA.

If you are not able to access this Privacy Policy due to a disability or any physical or mental impairment, the Company will, upon request, provide the information in an alternative format for you. 

Categories of Personal Information Collected and Disclosed:

Categories of Personal Information Collected and DisclosedCategories of Third-Parties Disclosed to for a Business or Commericial Purpose
Identifiers: Includes direct identifiers, such as name, alias, account number or unique personal identifier; email address, phone number, and other contact information; IP address and other online identifiers.AffiliatesAdvisors and AgentsSecurity and fraud prevention providersRegulators, government entities and law enforcementOthers as required by law
Internet or Other Electronic Network Activity Information. Includes but is not limited to, browsing history, clickstream data, search history, and information regarding interactions with our website and services, advertisements, including other usage data related to your use of any of our services or other similar online services.Affiliates and their Business CustomersAdvisors and AgentsSecurity and fraud prevention providersRegulators, government entities and law enforcementOthers as required by law
Profiles and Inferences. Such as inferences drawn from any of the information described in this section about a consumer including inferences reflecting the consumer’s preferences, characteristics, behaviors, attitudes, abilities, and aptitudes.Affiliates and their Business CustomersRegulators, government entities and law enforcementOthers as required by law
Sensitive Personal Information. In some circumstances, since we generally collect information on all the URLs visited these may include URLs or visits to sensitive websites. Such sensitive websites may relate to religious or philosophical beliefs, consumer health related data, and information concerning a consumer’s sex life or sexual orientation.Affiliates and their Business Customers

Sources of Personal Information:

We may collect your Personal Information as follows: 

Purposes of Collection, Use, and Disclosure: As we described above in Sections 4, 5 and 7, we may process, collect, use and share the abovementioned Personal Information for the following business or commercial purposes or if you agree for us to do so: 

Sales and Sharing of Personal Information:

The CCPA defines “sale” as disclosing or making available Personal Information to a third-party in exchange for monetary or other valuable consideration, and “sharing” includes disclosing or making available Personal Information to a third-party for purposes of cross-context behavioral advertising. We may “sell” or “share” the following categories of Personal Information: Identifiers, commercial information, internet and electronic network activity information, profiles and inferences, and sensitive personal information, as described above. We may “sell” or “share” these categories to our affiliates who in turn may “sell” or “share” this information with their business customers so that they can better understand consumer behavior and analyze and improve their marketing and advertising campaigns. 

We do not sell or share personal information about individuals who we know are less than 16 years old.

Data Retention:

We retain the Personal Information we collect in accordance with what we disclosed to you at the time of its collection or as reasonably necessary for the purposes described. We take into account whether we are subject to any legal obligations  when deciding how long to keep your Personal Information or whether we have taken any legal positions that would require its retention. We may also de-identify your information by removing identifying details instead of deleting your Personal Information. We agree not to re-identify deidentified data except as permitted by applicable law, when we have committed to using the data in its de-identified form.

Your CCPA Rights: 

Subject to certain conditions and exceptions, California residents have the following rights with respect to their Personal Information under the CCPA:

Exercising of Privacy Rights by California Residents

If you are a California resident and would like to exercise your rights under the CCPA and/or as described in this Privacy Policy or access this Privacy Policy in an alternative format, or if you have other questions or comments about your rights or our privacy practices, please contact us at dpo@crxmouse.com or at support@crxmouse.com. In any such communication, please include sufficient details so that we can properly respond. You may contact us directly, or you can exercise the option to designate an authorized agent to do so. Your authorized agents should be given written authorization to exercise your rights on your behalf. In the event the Company receives a communication from an agent, we will request a copy of such authorization and may request other information from such agent, which may include your and/or your agent’s Personal Information, as necessary to verify his or her identity, in the interest of protecting your privacy rights. If we are unable to verify the agent’s identity or confirm that he or she is acting on your behalf, we may refuse the request. The Company aims to respond to all requests that have been verified within the period of time set forth under applicable law, and specifically under the CCPA, within 45 days, but in certain cases up to 90 days may be necessary. If we are unable to respond within the applicable period of time, we will update you regarding the status of the request and the basis for any extension.

Right to Opt-Out of Sales and Sharing. To exercise your right to opt-out of the “sale” or “sharing” of your Personal Information, you may do so by clicking the “Do Not Sell or Share My Personal Information” link on the footer of our website and by submitting a request to opt-out of the selling or sharing of your Personal Information via our Do not Sell or Share My Personal Information form. You can also email us directly at: dpo@crxmouse.com  to submit an opt-out request. We will fulfill your opt out request based upon the Personal Information in our records that is linked or reasonably linkable to the information provided in your request.

“Shine the Light” Law

Under California’s “Shine the Light” law, if you are a California resident and have an established business relationship with the Company, you have the right to request information regarding the disclosure of certain types of Personal Information to third parties for direct marketing purposes during the immediately preceding calendar year. Such requests may be made no more than once per calendar year. If you wish to make such a request, please contact us at dpo@crxmouse.com.

16. Additional Privacy Information for Other U.S. States

Residents of certain U.S. states, including Colorado, Connecticut, Virginia, Utah, Montana, Oregon, and Texas, may have additional rights under applicable privacy laws and be entitled to additional disclosures. 

Sale of Personal Data: We may sell the following categories of Personal Information or Personal Data: Identifiers, commercial information, internet and electronic network activity information, profiles and inferences, and “sensitive data,” as that term is defined under applicable U.S. privacy laws. We sell such categories of Personal Data to our affiliates who then may sell it to their business customers so that they may conduct their own analysis on consumer behaviors and analyze and improve their marketing and advertising campaigns.

Consumer Rights:

Residents of certain U.S. states, including Colorado, Connecticut, Virginia, Washington, Nevada, Montana, Oregon, Texas and Utah, may have additional rights under applicable privacy laws, subject to certain limitations, which may include:

You may submit a request by emailing us as dpo@crxmouse.com. When you submit a request, we will take steps to verify your identity and your request by matching the information provided by you with the information we have on record. In some cases, we may request additional information in order to verify your identity or process your request. We may deny your request if we are unable to verify your and, we will explain the basis for such  denial and how you would be able to, where applicable, fix any deficiencies in your request.

To opt out of our “sales”, you can email us at dpo@crxmouse.com or submit a request to opt out of the selling of your Personal Information via our Do not Sell or Share My Personal Information form. 


If you are an authorized agent you can submit a request on behalf of another individual by contacting us at dpo@crxmouse.com; you will need to provide proof of your authorization and we may also require that the relevant consumer directly verify your identity and your authority. 

17. How to contact us?

If you have any questions about this Privacy Policy, please contact us at: dpo@crxmouse.com or  support@crxmouse.com.