Who We Are and What This Policy Covers
Information We Collect
We only collect information about you if we have a reason to do so — for example, to provide our Services, to communicate with you, or to make our Services better.
We collect information in three ways: if and when you provide information to us, automatically through operating our Services, and from outside sources. Here is a summary of the information that we collect.
Information You Provide to Us
It’s probably no surprise that we collect information that you provide to us. The amount and type of information depends on the context and how we use the information. Here are some examples:
Basic Account Information: We ask for basic information from you in order to set up your account. For example, we require individuals who sign up for an account with us to provide a username and email address — and that’s it. You may provide us with more information — such your name — but we don’t require that information to create an account.
Public Profile Information: If you have an account with us, we collect the information required to provide our services to you. However, we do not create a ‘Public Profile’ of you or your company, nor do we pass your details on to other companies as part of any advertising, marketing, or other similar scheme.
Transaction and Billing Information: If you buy something from us, you will provide additional personal and payment information that is required to process the transaction and your payment, such as your name, credit card information, and contact information.
Credentials: Depending on the Services you use, you may provide us with credentials for your account. These details are held in our secure information vaults and are never divulged to 3rd parties.
Communications with Us: You may also provide us information when you respond to surveys, participate in our competitions, or post a question or initiate a query or dispute.
Information We Collect Automatically
We also collect some information automatically.
How And Why We Use Information
Purposes for Using Information
We use information about you as mentioned above and for the purposes listed below:
To provide our Services — for example, to set up and maintain your account, process your orders, or charge you for any of our paid Services;
To further develop and improve our Services — for example by adding new features that we think our customers will appreciate or will help them to manage their purchases more efficiently;
To measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition — for example, we may analyse how many customers purchase a particular product after receiving a marketing message, or the features used by those who continue to use our Services after a certain length of time;
To monitor and prevent any problems with our Services, protect the security of our Services, detect and prevent fraudulent transactions and other illegal activities, fight spam, and protect the rights and property of Swish and others, which may result in us declining a transaction or the use of our Services;
To communicate with you, for example through an email, about offers and promotions offered by Swish that we think will be of interest to you, solicit your feedback, or keep you up to date on Swish and our products; and To personalize your experience using our Services, target our marketing messages to groups of our users, and serve relevant advertisements.
Legal Bases for Collecting and Using Information
Under European Union law, specifically the GDPR (General Data Protection Regulation), our use of your information is based on the grounds that:
(1) The use is necessary in order to fulfil our commitments to you under our Terms of Service or other agreements with you or is necessary to administer your account — for example, in order to provide access to your network or to a computer covered by a support agreement; or
(2) The use is necessary for compliance with a legal obligation; or
(3) The use is necessary in order to protect your vital interests or those of another person; or
(4) We have a legitimate interest in using your information — for example, to provide and update our Services, to improve our Services so that we can offer you an even better user experience, to safeguard our Services, to communicate with you, to measure, gauge, and improve the effectiveness of our advertising, and better understand user retention and attrition, to monitor and prevent any problems with our Services, and to personalize your experience; or
(5) You have given us your consent.
How We Share Information
We do not sell our customers’ personal information.
We share information about you in the limited circumstances spelled out below and with appropriate safeguards on your privacy:
Third Party Vendors: We may share information about you with third party vendors who need to know information about you in order to provide their services to us, or to provide their services to you or your site. This group includes vendors that help us provide our Services to you (such as payment providers that process your credit and debit card information, fraud prevention services that allow us to analyse fraudulent payment transactions, postal and email delivery services that help us stay in touch with you, customer chat and email support services that help us communicate with you), or those that assist us with our marketing efforts (e.g. by providing tools for identifying a specific marketing target group or improving our marketing campaigns). We require vendors to agree to privacy commitments in order to share information with them.
Legal Requests: We may disclose information about you in response to a subpoena, court order, or other governmental request.
To Protect Rights, Property, and Others: We may disclose information about you when we believe in good faith that disclosure is reasonably necessary to protect the property or rights of Swish, third parties, or the public at large. For example, if we have a good faith belief that there is an imminent danger of death or serious physical injury, we may disclose information related to the emergency without delay.
With Your Consent: We may share and disclose information with your consent or at your direction. For example, we may share your information with third parties only with your explicit authority to do so.
How Long We Keep Information
We generally discard information about you when we no longer need the information for the purposes for which we collect and use it — which are described in the section above on How and Why We Use Information — and we are not legally required to continue to keep it.
For example, we keep the server logs that record information about a technical problem that we are requested to manage on your behalf. We retain these logs for as long as is reasonable to enable us to provide you with the best possible service.
We work very hard to protect information about you against any unauthorized access, use, alteration, or destruction, and take reasonable measures to do so, such as monitoring our Services for potential vulnerabilities and attacks.
If you are located in a country other than the UK, including those that fall under the scope of the European General Data Protection Regulation, data protection laws give you rights with respect to your personal data, subject to any exemptions provided by the law, including the rights to:
Request access to your personal data.
Request correction or deletion of your personal data.
Object to our use and processing of your personal data.
Request that we limit our use and processing of your personal data; and
Request portability of your personal data.
You can choose to access, correct, or delete any of the personal data that we hold on your behalf.
EU individuals also have the right to make a complaint to a government supervisory authority.