Swarm Group - Privacy Policy

SWARM LIMITED

PRIVACY POLICY

Last Updated: May 2020

1. INTRODUCTION AND GENERAL TERMS

This privacy policy (“Policy”) sets out how we collect and use personal data where we are the data controller or where we refer to the applicability of this Policy. “Personal data” means information relating to you or another identifiable individual. We use Personal data that you provide to us, or that we may collect, through our website https://swarm.group/ (the “Website”). The Website is owned and operated by Swarm Limited, a company registered in England and Wales under company number [06857206] and with our registered office at Swarm Limited, 34 Linkfield Street, Redhill, Surrey, RH1 6BW (“Swarm Limited”, “we”, “us” or “our”).

If you have any questions or comments about this Policy please contact us on https://swarm.group/.

We are committed to protecting and respecting your privacy. This Policy explains what Personal data we collect and how that information will be processed. Where we decide the purpose or means for which Personal data you supply through these online services is processed, we are the “data controller.” We will comply with all applicable data protection laws, including the General Data Protection Regulation 2016/679.

This Policy explains the following:

What Personal data we may collect
How we will use Personal data we collect
Whether we will disclose Personal data details to anyone else
Your choices and rights regarding the Personal data you have provided to us.

The Website may contain hyperlinks to websites owned and operated by third parties. They will govern the use of Personal data you submit or which is collected by cookies whilst visiting these websites. We do not accept any responsibility or liability for the privacy practices of such third party websites and your use of them is at your own risk.

2. INFORMATION WE MAY COLLECT

We collect and process the following information which may include Personal data.

Submitted Information

You may give us information about you if you voluntarily supply it through the Website. For example, when you communicate with us via the contact page on the Website.

This can include:

your name;
your email address;
your telephone number; and
your postal address.

Your Browsing Activities

In relation to your activity on our website, we may collect information relating to the web address that you arrive from or click through to, pages viewed, page response times, download errors, the length of time you spend on certain pages, page interaction information such as scrolling, clicks, and methods used to browse away from our Website.

How you use our Website (“Analytics”)

We may collect technical information about your computer and/or device that may identify you, including your IP or MAC address, operating system, browser type, time-zone and browser plug-in details through third party analytics providers. These third party analytics providers may collect analytics on our behalf and in accordance with our instructions, and their applicable privacy notice.

Information about you collected from Third Parties

We may collect information about you from third party service providers (like social media companies, marketing partners or public databases) to use along with the information that we collect from you.

Other companies may set their own cookies or similar technologies when you visit the Website. This includes third parties that we have engaged to provide services on our behalf (like website analytics), as well as third parties that deliver content (like videos from Vimeo).

3. WHY WE COLLECT INFORMATION ABOUT YOU

We will only use your Personal data when the law allows us to. Most commonly, we will use your Personal data in the following circumstances:

Where we need to perform the contract we are about to enter into or have entered into with you.
Where we need to develop and manage our services and marketing.
Where we may contact you to inform you of services or to conduct market research when we have your consent or it is otherwise allowed.
Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
Where we need to comply with a legal obligation.

To provide the Website and to understand how our Website is used

We will use information about you for providing the website and delivering our services to you. We process information to understand how visitors use our Website. This processing is necessary for us to pursue our legitimate interest of (i) ensuring that our Website functions properly so that you and other users have the best experience when using it, and (ii) improving the quality of our Website and providing a better experience to our users.

Marketing

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising.

We will use data analytics to improve our website, products/services, marketing, customer relationships and experiences. This is necessary for our legitimate interests (to define types of customers for our products and services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy).

4. DATA SHARING

We will share your information with third parties only in the ways that are described in this Policy. If you would like to find out more about how the third parties listed in this Policy use your information, this should be set out in their respective privacy policies.

Personnel, Suppliers or Subcontractors: We keep your information confidential, but may disclose it to our personnel, suppliers or subcontractors or anyone we transfer or delegate our rights and obligations to, as allowed under the terms and conditions of any contract you have with us, insofar as it is reasonably necessary for the purposes set out in this Policy. However, this is on the basis that they do not make independent use of the information, and have agreed to safeguard this information.

Required by law: In addition, we may disclose your information to the extent that we are required to do so by law (which may include to government bodies and law enforcement agencies); in connection with any legal proceedings or prospective legal proceedings; and in order to establish, exercise or defend our legal rights (including providing information to others for the purposes of fraud prevention).

Merger or acquisition: If we are involved in a merger, acquisition, or sale of all or a portion of its assets, you will be notified via email and/or a prominent notice on our website of any change in ownership or uses of this information, as well as any choices you may have regarding this information.

Enforcement: We may also disclose your Personal data to third parties in order to enforce or apply the terms of agreements, to investigate potential breaches, or to protect our rights, property or safety or those of our customers or others.

5. YOUR RIGHTS IN RELATION TO PERSONAL DATA WHICH WE PROCESS RELATING TO YOU

You have the right to access, modify, rectify and delete any data that concerns you over the way we process Personal data relating to you. We aim to comply without undue delay, and within one month at the latest.

To make a request, please let us know via the contact email: info@swarm.group

If you do provide us with Personal data we generally retain it for as long as you are our client, or as is otherwise necessary for us to provide the Website to you, or as otherwise described in this Policy. We will only retain your Personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your Personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for Personal data, we consider the amount, nature and sensitivity of the Personal data, the potential risk of harm from unauthorised use or disclosure of your Personal data, the purposes for which we process your Personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

You have the rights to:

Request access to your Personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the Personal data we hold about you and to check that we are lawfully processing it.

Request correction of the Personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

Request erasure of your Personal data. This enables you to ask us to delete or remove Personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your Personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Object to processing of your Personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your Personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

Request restriction of processing of your Personal data. This enables you to ask us to suspend the processing of your Personal data in the following scenarios:

If you want us to establish the data's accuracy.
Where our use of the data is unlawful but you do not want us to erase it.
Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

Request the transfer of your Personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

Withdraw consent at any time where we are relying on consent to process your Personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

6. CHILDREN

You should be at least 13 to use our Website. We do not use the Website to knowingly solicit data from or market to children under the age of 13. If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us via the contact details detailed at the top of this Policy. We will delete such information from our files within a reasonable time.

7. SECURITY

We will take reasonable and appropriate physical, technical and organisational precautions and measures to protect your Personal data from unauthorised access, use or disclosure. For example, we use computer systems with antivirus software, two factor authentication and use technologies like encryption and hashing to protect some of the Personal data we collect. In addition, we limit access to store and/or access your Personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your Personal data on our instructions and they are subject to a duty of confidentiality.

Please be aware that, although we endeavour to provide reasonable security for information we process and maintain, no security system can prevent all potential security breaches. By choosing to share Personal data with us you agree and accept that you do so at your own risk.

8. INTERNATIONAL DATA TRANSFERS

Where we transfer your data outside of the EEA, we have agreements in place with those parties which include standard data protection clauses adopted by a data protection regulator and approved by the European Commission to ensure that appropriate safeguards are in place to protect your personal data. If you would like to find out more about these safeguards, please let us know by writing to us through the Support Services.

9. COOKIES

A cookie is a text file placed onto your device when you access the Website. We use cookies and other online tracking devices such as web beacons, and flash object storage to deliver, improve and monitor the Website, including in the following ways:

Authentication	We use cookies to identify you when you visit our Website and as you navigate our Website.
Preferences	To remember information about you such as your preferred language and configuration.
Analytics	To help us understand how you use the Website, and how often, so we can improve it to deliver a better experience for our users.
Cookies used by our service providers	Our service providers use cookies and those cookies may be stored on your computer when you visit our Website.

The information we obtain from our use of cookies will not usually contain your Personal data. Although we may obtain information about your device such as your IP address, your browser and/or other internet log information, this will not usually identify you personally.

Please note that if you choose to disable cookies, or similar technologies, on your device you may be unable to make full use of the Website.

10. CHANGES

We may make changes to this Policy from time to time, and such changes will be posted on this page. You should check this page from time to time to ensure that you are aware of any changes. Where appropriate we may notify you of any changes by email.