PRIVACY NOTICE (February 2023)

This online Privacy Notice describes the ways in which we collect information from you when you use this Website and Mobile App, and what we may use it for. If you have any questions or need further information about our privacy practices, please contact us at dpo@Swiipr.com or Swiipr Technologies, registered address 167-169 Great Portland, Street, 5th Floor, London, W1W 5PF.

We are committed to protecting your personal information and your right to privacy at Swiipr (“Company”, “we”, “us”, “our”). When you visit our Website and Mobile App, www.swiipr.com (the “Website and Mobile App”), and more generally, use any of our services (the “Services”, included in the Website and Mobile App), we appreciate that you are trusting us with your personal information. In this privacy notice, we seek to explain to you in the clearest way possible what information we collect, how we use it and what rights you have in relation to it. We hope you take some time to read through it carefully, as it is important. If there are any terms in this privacy notice that you do not agree with, please email dpo@Swiipr.com.

This privacy notice applies to all information collected through our Services (which, as described above, includes the Website and Mobile App), as well as, any related services, sales, marketing or events.

1. WHAT INFORMATION DO WE COLLECT? –

We collect personal information that you provide to us.

We collect personal information that you voluntarily provide to us when you express an interest in obtaining information about us or our products and services, when you participate in activities on the Website and Mobile App or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Website and Mobile App you are on, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information Provided by You:

Full name

Email address

Message

All personal information that you provide to us must be true, complete, and accurate, and you must notify us of any changes to such personal information.

Our use of your Data

We will use your Data we collect only for the following purposes:

  1. To provide this Website and Mobile App to you.
  2. We will use User Data to provide and improve this Website and Mobile App to enable us to deal with any queries you have about this Website and Mobile App and to notify you of any changes to this Website and Mobile App.
  3. To include User Data in anonymous statistics.
  4. We may provide anonymous statistics about our users and related usage information to reputable third parties, but these statistics will not enable any third party to identify individuals or individual businesses.
  5. To provide you with information you have requested.
  6. We will use User Data to provide you with information and brochures you have requested through this Website and Mobile App.
  7. Marketing Activities. If you have already registered to receive marketing materials from us in paper and/or electronic form, we may use your data to send you marketing and other materials relating to Swiipr Technologies Ltd, its products and/or services. We may use the data provided by you to update records held by Swiipr Technologies Ltd.
  8. If you are not already registered to receive marketing information from us in paper and/or electronic form and wish to receive such information, please click on the contact us button. You may withdraw your consent to the receipt of marketing materials at any time and free of charge by sending an e-mail to us at dpo@swiipr.com
  9. If Swiipr Technologies Ltd ceases to trade, or becomes insolvent, enters into receivership or any similar or equivalent event occurs, those acting on behalf of Swiipr Technologies Ltd may sell the business or parts of it to a third party, in fulfilment of legal or business requirements. This may result in the transfer of your data to a third party through which the business or parts of it will be carried out.
  10. In circumstances where the business of Swiipr Technologies Ltd or parts of it are transferred to a third party as described above, we shall use reasonable endeavours to contact you in advance of us disclosing your data to that third party, but you acknowledge that this might not be technically or commercially feasible in all the circumstances.

Consent

By continuing to use this Website and Mobile App and by providing any personal data (including sensitive personal data) to us via this Website and Mobile App or e-mail addresses provided on this Website and Mobile App you are consenting to our use of your personal data as set out in this Privacy Notice. Please do not send us any personal data if you do not want that information to be used by us in this manner.

Transfer of User Data outside the User Jurisdiction

The Internet is a global environment. In order to provide this Website and Mobile App we may need to transfer User Data to locations outside the jurisdiction in which you are viewing this Website and Mobile App (the User Jurisdiction) and process User Data outside the User Jurisdiction. If the User Jurisdiction is within the UK and the European Economic Area (the EEA) you data is protected by the GDPR and UK Data protection regulations. Any data sent or uploaded by you may be accessible in jurisdictions outside the User Jurisdiction (including outside the EEA), the level of data protection offered in such jurisdictions may be less than that offered within the User Jurisdiction or (as the case may be) within the EEA.

Swiipr will take all appropriate steps to ensure your data has the same level of protection as within the GDPR/EU through enhanced security and standard contractual clauses if going to the USA.

User Data may be controlled and processed by any of Swiipr Technologies Ltd’s offices, some of which may be outside the EEA. The location of our offices may change from time to time and Swiipr Technologies Ltd may acquire offices in any number of countries or territories at any time, any one or more of which may act as controllers of and/or process User Data.

By continuing to use this Website and Mobile App and by providing any personal data (including sensitive personal data) to us via this Website and Mobile App or e-mail addresses provided on this Website and Mobile App, you are consenting to such transfers, provided that they are in accordance with the purposes set out above and elsewhere in the Legal Notices. Please do not send us any personal data if you do not consent to the transfer of this information to locations outside the User Jurisdiction (including, if applicable, outside the EEA).

Legal Requirements

While it is unlikely, we may be required to disclose your User Data by a court order or to comply with other legal or regulatory requirements. We will use reasonable endeavours to notify you before we do so, unless we are legally restricted from doing so.

We may process your data that we hold based on the following legal basis:

1) Consent: We may process your data if you have given us specific consent through a positive option to use your personal information for a specific purpose such as sending marketing material

2) Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests such as sending you information about similar products and services, we will use the three question test to validate this.
3) Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract
4) Legal Obligations: We may disclose your information where we are legally required to do so.

5) Vital Interests: We may disclose your information where we believe it is necessary.
More specifically, we may need to process your data or share your personal information in the following situations:
6) Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company

4. HOW LONG DO WE KEEP YOUR INFORMATION?

We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law. See table below.

Data Captured

Time retained before deletion

Reason

First name and surname – query

6 months

To respond to any queries which may come back

Message – Query

6 months

To respond to any queries which may come back

Email address – Query

6 months

To respond to any queries which may come back

First name and surname

6 years plus 1

HMRC require all financial records be kept for this long before destroying

Address

6 years plus 1

HMRC require all financial records be kept for this long before destroying

Telephone Number

6 years plus 1

HMRC require all financial records be kept for this long before destroying

Email address

6 years plus 1

HMRC require all financial records be kept for this long before destroying

Bank account details

6 years plus 1

HMRC require all financial records be kept for this long before destroying

Products/services bought

4 years

Keep a log of what products have been sold

5. HOW DO WE KEEP YOUR INFORMATION SAFE?

We aim to protect your personal information through a system of organisational and technical security measures.

We have implemented appropriate technical and organisational security measures designed to protect the security of any personal information we process. We password protect all personal data and use the latest firewalls to prevent unauthorised access. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Website and App is at your own risk.

6. WHAT ARE YOUR PRIVACY RIGHTS?

You have rights that allow you greater access to and control over your personal information. You may review, change, or terminate your account at any time.

You have certain rights under applicable GDPR and UK data protection laws. These will include:

A) Your right of access – You have the right to ask us for copies of your personal information. This right always applies. There are some exemptions, which means you may not always receive all the information we process.

B) Your right to rectification – You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete. This right always applies.

C) Your right to erasure – You have the right to ask us to erase your personal information in certain circumstances, Unless we are obliged by law to retain it e.g. HMRC.

D) Your right to restriction of processing – You have the right to ask us to restrict the processing of your information in certain circumstances, such as stopping any direct marketing.

E) Your right to object to processing – You have the right to object to processing if we are able to process your information because the process forms part of our public tasks, or is in our legitimate interests.

F) Your right to data portability – This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organisation to another, or give it to you. The right only applies if we are processing information based on your consent or under, or in talks about entering into a contract and the processing is automated.

To make such a request, please use these contact details dpo@swiipr.com. We will consider and act upon any request in accordance with applicable data protection laws. If we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. To request to review, update, or delete your personal information, we will respond to your request within 30 days.

If you would like further information about data protection you can visit the Information Commissioner’s Office (ICO) at ico.org.uk. The ICO is the UK’s independent authority set up to uphold information rights in the public interest and data privacy for individuals. We comply with all ICO regulatory and statutory requirements. You have the right to make a complaint to the ICO regarding the handling of your data.

Changes to the Policy This Privacy Notice and/or the other Legal Notices may be amended by us at any time. Please check this Website and Mobile App periodically for any changes.

Our Use of Cookies

A cookie is a tiny element of data that a Website and Mobile App can send to your computer’s browser so that this computer will be recognised by the site on your return. Cookies allow our web server to recognise your computer on connection to our Website and Mobile App, which in turn allows the server to make downloading of pages faster than on first viewing. In addition, cookies may also be used by us to establish statistics about the use of this Website and Mobile App by Internet users by gathering and analysing data such as: most visited pages, time spent by users on each page, site performance, etc. By collecting and using such data, we hope to improve the quality of the site.

The data collected by our servers and/or through cookies that may be placed on your computer will not be kept for longer than is necessary to fulfil the purposes mentioned above. In any event, such information may not be kept for longer than one year.

Navigation data about site viewers is automatically collected by our servers. If you do not wish to have this navigation data collected, we recommend that you do not use this Website and Mobile App.

You can also set your browser to block the recording of cookies on your hard drive to minimise the amount of data that may be collected about your navigating on this site. The browser on your computer can be set to notify you when a cookie is being recorded on your computer’s hard drive. Most browsers can also be set to keep cookies from being recorded on your computer. However, for optimal use of this Website and Mobile App, we recommend that you do not block the recording of cookies on your computer.

All Swiipr Technologies servers and computer systems are protected from outside intrusions. As a result, all data that may be collected about site viewers through the use of cookies will be protected from unauthorised access.

Cookies used on this site are only active for the duration of your visit. Cookies used on this site are not stored on your computer once you have closed your web browser. Information generated by the use of cookies may be compiled into an aggregate form so that no individual can be identified.

For more information about cookies, please see the Information Commissioner’s Website and Mobile App home page or the Interactive Advertising Bureau.

You may choose to not receive a cookie file by enabling your web browser to refuse cookies. The procedure for refusal of cookies may vary for different software products. Please check with your internet browser software help or your software supplier if you wish to refuse cookies.

Privacy of Electronic Communications

Although we welcome your queries, please note that any electronic communication through this Website and Mobile App between you and us (or any of our employees or agents) may not be secure. For this reason, please do not send us any email that contains confidential or sensitive information.