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Legal Documents

Effective April 20, 2026
Terms of ServicePrivacy PolicyDisclaimer
Document 1 — Terms of Service

Terms of Service & User Agreement

Effective Date: April 20, 2026  |  Last Updated: April 20, 2026

Please read these Terms of Service (“Terms,” “Agreement”) carefully before using the Swivel platform (“Service,” “Platform”) operated by 1001578463 Ontario Inc., a corporation incorporated under the laws of Ontario, Canada, carrying on business as Swivel (“Company,” “we,” “us,” “our”). By creating an account, accessing, or using our Service, you (“User,” “you,” “your”) agree to be bound by these Terms. If you do not agree with any part of these Terms, you may not use the Service.

1. Description of Service

Swivel is a software platform that assists healthcare practices in generating appeal letters for denied insurance claims. The Service uses automated intelligence and natural language processing to analyze denial information provided by the User and produce draft appeal correspondence.

IMPORTANT: Swivel is a drafting assistance tool. It is NOT a legal service, medical coding consultancy, or claims adjudication service. The Service does not guarantee any specific outcome, including but not limited to the overturn or reversal of any denied claim.

2. No Guarantee of Outcomes

2.1 THE SERVICE PROVIDES NO WARRANTY, GUARANTEE, OR ASSURANCE THAT ANY APPEAL LETTER GENERATED THROUGH THE PLATFORM WILL RESULT IN A SUCCESSFUL APPEAL, CLAIM REVERSAL, PAYMENT, OR ANY PARTICULAR OUTCOME FROM ANY INSURANCE PAYER, GOVERNMENT PROGRAM, OR THIRD-PARTY ENTITY.

2.2 Appeal outcomes depend on numerous factors outside of our control, including but not limited to: the specific payer's policies and procedures, the clinical documentation provided, the medical necessity of the services rendered, applicable federal and state regulations, the accuracy of coding and billing information, and the individual payer representative reviewing the appeal.

2.3 Any statistics, estimates, projections, or potential recovery amounts presented on our website, marketing materials, or within the Service are for illustrative purposes only and do not constitute a guarantee of similar results for any individual User.

3. User Responsibilities — Verification and Accuracy

3.1 You are solely responsible for reviewing, verifying, and approving the accuracy and completeness of every appeal letter generated by the Service before submitting it to any payer, government entity, or third party.

3.2 You acknowledge and agree that:

  1. All appeal letters produced by the Service are drafts that require your professional review before use;
  2. You must verify that all patient information, provider information, CPT/HCPCS codes, ICD-10 codes, dates of service, claim numbers, payer identifiers, and all other factual content is accurate and complete;
  3. You must verify that all clinical reasoning, medical necessity arguments, and regulatory citations contained in the letter are appropriate and accurate for the specific claim;
  4. You must ensure that the appeal letter complies with all applicable federal and state laws, payer-specific submission requirements, and filing deadlines;
  5. You assume full responsibility for any appeal letter you submit, regardless of whether it was generated in whole or in part by the Service;
  6. The submission of inaccurate, misleading, or fraudulent appeal correspondence may violate federal and state laws, including but not limited to the False Claims Act (31 U.S.C. § 3729 et seq.), and you bear sole responsibility for ensuring compliance.
Plain language: Swivel writes a strong first draft for you. But you must read every letter, check every fact, and make sure it is correct before you send it anywhere. If you send a letter without reviewing it and something is wrong, that is your responsibility — not ours.

4. Intelligence Layer & Content Updates

4.1 The Service utilizes automated intelligence systems, including machine learning models, clinical databases, payer policy databases, and regulatory reference materials (collectively, the “Intelligence Layer”) to generate appeal letters.

4.2 We regularly update the Intelligence Layer to improve accuracy and reflect changes in payer policies, clinical guidelines, and regulatory requirements. However, we do not warrant that the Intelligence Layer is current, complete, or error-free at any given time.

4.3 You acknowledge that payer policies, medical coding guidelines, and regulatory requirements change frequently; there may be a delay between when a change occurs and when the Intelligence Layer is updated; and it is your responsibility to ensure that all content in any appeal letter is current, accurate, and appropriate for the specific claim and payer at the time of submission.

5. Disclaimer of Warranties

5.1 THE SERVICE IS PROVIDED ON AN “AS IS” AND “AS AVAILABLE” BASIS WITHOUT WARRANTIES OF ANY KIND, WHETHER EXPRESS, IMPLIED, STATUTORY, OR OTHERWISE. WE SPECIFICALLY DISCLAIM ALL IMPLIED WARRANTIES OF MERCHANTABILITY, FITNESS FOR A PARTICULAR PURPOSE, AND NON-INFRINGEMENT.

6. Limitation of Liability

6.1 TO THE MAXIMUM EXTENT PERMITTED BY APPLICABLE LAW, IN NO EVENT SHALL SWIVEL, ITS OFFICERS, DIRECTORS, EMPLOYEES, AGENTS, OR AFFILIATES BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, INCLUDING BUT NOT LIMITED TO LOSS OF REVENUE, LOSS OF PROFITS, LOSS OF DATA, OR LOSS OF BUSINESS OPPORTUNITY.

6.2 IN NO EVENT SHALL OUR TOTAL AGGREGATE LIABILITY TO YOU EXCEED THE TOTAL AMOUNT OF FEES PAID BY YOU TO SWIVEL DURING THE SIX (6) MONTHS IMMEDIATELY PRECEDING THE EVENT GIVING RISE TO THE CLAIM.

7. Indemnification

You agree to indemnify, defend, and hold harmless Swivel, its officers, directors, employees, agents, and affiliates from and against any and all claims, damages, losses, liabilities, costs, and expenses (including reasonable legal fees) arising out of or relating to: (a) your use of the Service; (b) any appeal letter you submit that was generated in whole or in part by the Service; (c) your violation of these Terms; (d) your violation of any applicable law or regulation; or (e) your failure to verify the accuracy of content generated by the Service before submission.

8. Governing Law & Dispute Resolution

8.1 Governing Law. These Terms and any dispute arising out of or relating to them or the Service shall be governed by and construed in accordance with the laws of the Province of Ontario and the federal laws of Canada applicable therein, without regard to conflict of law principles.

8.2 Mandatory Mediation. Any dispute, claim, or controversy arising out of or relating to these Terms or the Service (“Dispute”) shall first be submitted to good-faith mediation before a neutral mediator agreed upon by both parties. The mediation shall take place in the Province of Ontario, Canada, or remotely by mutual agreement.

8.3 The costs of mediation shall be shared equally between the parties, unless the mediator determines otherwise. Each party shall bear its own legal fees and costs associated with the mediation.

8.4 No party may commence a legal proceeding relating to a Dispute unless and until the parties have participated in at least one mediation session and the mediator has declared an impasse, or thirty (30) calendar days have elapsed since the written request for mediation was delivered to the other party, whichever occurs first.

8.5 If mediation does not resolve the Dispute, either party may pursue resolution through binding arbitration administered by the ADR Institute of Canada (“ADRIC”) under its National Arbitration Rules, or through a court of competent jurisdiction in the Province of Ontario, Canada. The parties attorn to the exclusive jurisdiction of the courts of Ontario for any Dispute not resolved by arbitration.

8.6 CLASS ACTION WAIVER: You agree that any Dispute resolution proceedings will be conducted only on an individual basis and not in a class, consolidated, or representative action.

9. Waiver of Guarantee

BY USING THE SERVICE, YOU EXPRESSLY ACKNOWLEDGE THAT Swivel does not guarantee any specific outcome; you will not rely solely on the Service for any critical decision; you have been advised to independently verify all content generated by the Service; and you waive any claim against Swivel arising from your failure to review and verify appeal letters before submission.

10. Account Terms

You must provide accurate, current, and complete information when creating an account. You are responsible for maintaining the confidentiality of your account credentials and for all activities that occur under your account. You must be at least 18 years of age and have the legal authority to enter into this Agreement.

11. Payment & Cancellation

Subscription fees are billed in advance on a monthly basis and automatically renew unless cancelled before the renewal date. You may cancel at any time; cancellation takes effect at the end of the current billing period. No refunds will be issued for partial billing periods. We reserve the right to modify pricing with thirty (30) days' advance written notice.

12. Intellectual Property

The Service, including its design, code, algorithms, and Intelligence Layer, is owned by Swivel and protected by applicable intellectual property laws. Appeal letters generated through the Service may be used by you for their intended purpose. You may not resell, redistribute, or commercially exploit the Service or its output.

13. Data Privacy & Security

Our collection, use, and protection of your data is governed by our Privacy Policy, incorporated into these Terms by reference. You represent and warrant that you have obtained all necessary consents to share patient or claim data with the Service, and that your use complies with all applicable privacy laws, including HIPAA where applicable.

14. Modifications to Terms

We may modify these Terms at any time by posting the revised Terms on our website. Continued use of the Service after the effective date of any modification constitutes your acceptance of the modified Terms.

15. Severability

If any provision of these Terms is held to be invalid or unenforceable, the remaining provisions shall continue in full force and effect.

16. Entire Agreement

These Terms, together with our Privacy Policy, constitute the entire agreement between you and Swivel regarding the Service.

17. Contact Information

If you have questions about these Terms, please contact us at:
Company: 1001578463 Ontario Inc. (operating as Swivel)
Email: legal@swivelit.app
Website: swivelit.app

BY CLICKING “I HAVE READ AND AGREE TO THE TERMS OF SERVICE,” YOU ACKNOWLEDGE THAT YOU HAVE READ, UNDERSTOOD, AND AGREE TO BE BOUND BY THESE TERMS.

Document 2 — Privacy Policy

Privacy Policy

Effective Date: April 20, 2026  |  Last Updated: April 20, 2026

This Privacy Policy describes how 1001578463 Ontario Inc., a corporation incorporated under the laws of Ontario, Canada, carrying on business as Swivel (“Company,” “we,” “us,” “our”) collects, uses, discloses, and protects your information when you use our platform and services (the “Service”).

1. Information We Collect

Account Information: When you create an account, we collect your name, email address, practice name, and billing information.

Claim Data: When you use the Service, you may provide claim information including denial details, CPT/HCPCS codes, ICD-10 codes, payer information, and related clinical documentation. We process this data solely to generate appeal letters on your behalf.

Usage Data: We automatically collect information about how you interact with the Service, including pages visited, features used, timestamps, and device/browser information.

2. How We Use Your Information

We use your information to: provide and maintain the Service; generate appeal letters based on your inputs; improve and optimize the Service; process payments; communicate with you about your account; comply with legal obligations; and protect our rights and the rights of our users.

3. Data Sharing

We do not sell your personal information. We may share your information with: service providers who assist in operating the Service (payment processors, hosting providers); as required by law, regulation, or legal process; to protect the rights, property, or safety of Swivel, our users, or the public; or in connection with a merger, acquisition, or sale of assets.

4. Data Security

We implement industry-standard security measures to protect your data, including encryption in transit and at rest. However, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.

5. HIPAA Compliance

If you are a covered entity or business associate under HIPAA and provide protected health information (PHI) through the Service, please contact us to execute a Business Associate Agreement (BAA) prior to submitting PHI.

6. Data Retention

We retain your account data for as long as your account is active. Claim data and generated appeal letters are retained for the duration of your subscription plus twelve (12) months, after which they are securely deleted. You may request deletion of your data at any time by contacting us.

7. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, or delete your personal information; opt out of certain data processing activities; request a copy of your data in a portable format; and withdraw consent where processing is based on consent.

8. Cookies & Tracking

We use cookies and similar technologies to maintain your session, remember your preferences, and analyze usage. You may control cookies through your browser settings.

9. Children's Privacy

The Service is not intended for use by individuals under the age of 18. We do not knowingly collect personal information from children.

10. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by posting the revised policy on our website and updating the “Last Updated” date.

11. Contact

For questions or concerns about this Privacy Policy:
Company: 1001578463 Ontario Inc. (operating as Swivel)
Email: privacy@swivelit.app
Website: swivelit.app

Document 3 — Disclaimer

Disclaimer

Effective Date: April 20, 2026

General Disclaimer

The information and services provided on swivelit.app and through the Swivel platform are for informational and drafting assistance purposes only. Nothing on this website or within the Service constitutes legal advice, medical advice, medical coding advice, or professional consulting of any kind.

No Guarantee of Results

Swivel does not guarantee that the use of our Service will result in the successful overturn of any denied claim. Potential earnings recovery figures displayed on our website are estimates based on industry averages and are provided for illustrative purposes only. Actual results will vary.

Not a Substitute for Professional Judgment

The Service is designed to assist qualified healthcare billing and administrative professionals. It is not a substitute for the professional judgment of physicians, certified coders, compliance officers, or attorneys. Users should independently verify all output from the Service.

Limitation of Liability

Under no circumstances shall Swivel be liable for any direct, indirect, incidental, special, or consequential damages arising from the use of our website or Service. Use of this website and Service is at your own risk.

Accuracy of Information

While we strive to provide accurate and up-to-date information, we make no representations or warranties of any kind about the completeness, accuracy, reliability, or availability of the information contained on our website.

© 2026 1001578463 Ontario Inc. operating as Swivel. All rights reserved.