Swate Inc. (“Company”, “we”, “our” or “us”) is committed to protecting your personal information about an identifiable individual and respecting your privacy (as defined by applicable privacy, personal information or data protection laws).
If this Policy changes in the future, we will post an updated version on our website at https://www.swate.today (the “Website”). We recommend that you check this Website periodically in order to review our current Policy. You can tell if this Policy has changed by checking the effective date that appears at the bottom of this Policy. Depending on the circumstances, we may also decide to send you a notice in other ways at our discretion, such as via email or other contact information you have provided that the Policy was changed. If you continue to use our Products after the Policy changed or notice of the change has been given, you will be deemed to have accepted such changes.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.
4 Contact Information
If you have any questions or concerns regarding our policy or practices, please contact us.
- Full name of legal entity: Swate Inc
- Name or title of data privacy manager: Jamie Lee
- Email address: email@example.com
5 Third Party Links
Our Sites may, from time to time, contain links to and from the websites of our partner networks, advertisers and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies and that we do not accept any responsibility or liability for these policies or for any personal data that may be collected through these websites or services, such as Contact and Location Data. Please check these policies before you submit any personal data to these websites or use these services.
6 Collection of Data
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Identity Data.
- Contact Data.
- Financial Data.
- Transaction Data.
- Device Data.
- Content Data.
- Profile Data.
- Usage Data.
- Marketing and Communications Data.
- Location Data.
We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.
We will collect and process the following data about you:
We may collect, use, store and transfer different kinds of personal data about you as follows:
- Information you give us. This is information (including Identity, Contact, Financial, and Marketing and Communications Data) you consent to giving us about you by filling in forms on the App Site and the Services Sites (together Our Sites), or by corresponding with us (for example, by email or chat). It includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our Services, search for an App or Service, make an in-App purchase, share data via an App’s social media functions, enter a competition, promotion or survey, or other activities ordinarily and reasonably carried out on an app like Swate and when you report a problem with an App, our Services, or any of Our Sites. If you contact us, we will keep a record of that correspondence.
- Information we receive from other sources including third parties and publicly available sources. We will receive personal data about you from various third parties and public sources as set out below:
Device Data from the following parties:
- analytics providers such as Google;
- advertising networks; and
- search information providers.
- Contact, Financial and Transaction Data from providers of technical, payment and delivery services;
- Identity and Contact Data from data brokers or aggregators;
- Identity and Contact Data from publicly available sources; and
- Unique application numbers. When you want to install or uninstall a Service containing a unique application number or when such a Service searches for automatic updates, that number and information about your installation, for example, the type of operating system, may be sent to us.
8 Usage of Data
We will only use your personal data when the law allows us to do so. Most commonly we will use your personal data in the following circumstances:
- Where you have consented before the processing.
- Where we need to perform a contract we are about to enter or have entered with you.
- 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 or regulatory obligation.
We will only send you direct marketing communications by email or text if we have your consent. You have the right to withdraw that consent at any time by contacting us.
|Purpose/activity||Type of data||Lawful basis for processing|
|To install the App and register you as a new App user||Identity, Contact, Financial, Device||Your consent|
|To process in-App purchases and deliver Services including managing payments and collecting money owed to us||Identity, Contact, Financial, Transaction, Device, Marketing and Communications, Location||Your consent, Performance of a contract with you, Necessary for our legitimate interests (to recover debts due to us)|
|To manage our relationship with you including notifying you of changes to the App or any Services||Identity, Contact, Financial, Profile, Marketing and Communications||Your consent, Performance of a contract with you Necessary for our legitimate interests (to keep records updated and to analyse how customers use our products/ Services), Necessary to comply with legal obligations (to inform you of any changes to our terms and conditions)|
|To enable you to participate in a prize draw, competition or complete a survey||Identity, Contact, Device, Profile, Marketing and Communications||Your consent, Performance of a contract with you, Necessary for our legitimate interests (to analyse how customers use our products/Services and to develop them and grow our business)|
|To administer and protect our business and this App including troubleshooting, data analysis and system testing||Identity Contact Device||Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security)|
|To deliver content and advertisements to you
To make recommendations to you about goods or services which may interest you
To measure and analyse the effectiveness of the advertising we serve you
To monitor trends so we can improve the App
|Identity, Contact, Device, Content, Profile, Usage, Marketing and Communications, Location, Consent||Necessary for our legitimate interests (to develop our products/Services and grow our business)|
9 Disclosures of Personal Data
When you consent to providing us with your personal data, we will also ask you for your consent to share your personal data with the third parties set out below for the purposes set out in the table Purposes for which we will use your personal data:
- Internal Third Parties as set out in the Glossary.
- External Third Parties as set out in the Glossary.
10 Data Security
All information you provide to us is stored on Google Cloud servers. Any payment transactions carried out by us or our chosen third-party provider of payment processing services will be encrypted using Secured Sockets Layer technology OR similar encryption technology. Where we have given you (or where you have chosen) a password that enables you to access certain parts of Our Sites, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Once we have received your information, we will use strict procedures and security features to do our due diligence in preventing your personal data from being accidentally lost, used or accessed in an unauthorised way.
We may collect and store personal data on your Device using application data caches and browser web storage (including HTML5) OR similar technology.
Certain Services include social networking, chat room or forum features. Ensure when using these features that you do not submit any personal data that you do not want to be seen, collected or used by other users.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.
11 Data Retention
In some circumstances you can ask us to delete your data (see your legal rights below for further information).
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you. In the event that you do not use the App for a period of one year then we will treat the account as expired and your personal data may be deleted.
12 Your Legal Rights
Under certain circumstances you have the following rights under data protection laws in relation to your personal data. Please contact us for more about these rights:
- Request access to your personal data.
- Request correction of your personal data.
- Request erasure of your personal data.
- Object to processing of your personal data.
- Request restriction of processing your personal data.
- Request transfer or your personal data.
- Right to withdraw consent.
“Lawful basis consent” means processing your personal data where you have signified your agreement by a statement or clear opt-in to processing for a specific purpose. Consent will only be valid if it is a freely given, specific, informed and unambiguous indication of what you want. You can withdraw your consent at any time by contacting us.
“Legitimate Interest” means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.
“Performance of Contract” means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.
“Comply with a legal obligation” means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
14 Third Parties
INTERNAL THIRD PARTIES:
Other companies in the Swate group of companies.
EXTERNAL THIRD PARTIES:
Service providers acting as processors who provide IT and system administration services.
Professional advisers acting as processors or joint controllers including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.
HM Revenue and Customs, regulators and other authorities acting as processors or joint controllers who require reporting of processing activities in certain circumstances.
Market research companies, price comparison sites.
15 Your Legal Rights
You have the right 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; or
- 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.
16 Description of Categories of Personal Data
- Identity Data: first name, last name, maiden name, username or similar identifier, marital status, title, date of birth, gender.
- Contact Data: billing address, delivery address, email address and telephone numbers.
- Financial Data: bank account and payment card details.
- Transaction Data: includes details about payments to and from you and details of in-App purchases.
- Device Data: includes the type of mobile device you use, a unique device identifier (for example, your Device’s IMEI number, the MAC address of the Device’s wireless network interface, or the mobile phone number used by the Device), mobile network information, your mobile operating system, the type of mobile browser you use, time zone setting.
- Content Data: includes information stored on your Device, including friends’ lists, login information, photos, videos or other digital content, check-ins.
- Profile Data: includes your username and password, in-App purchase history, your interests, preferences, feedback and survey responses.
- Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise and the resources that you access.
- Marketing and Communications Data: includes your preferences in receiving marketing from us and our third parties and your communication preferences.
- Location Data: includes your current location disclosed by GPS technology OR similar technology.
Effective Date: June 1, 2020