Privacy Notice

(updated 24rd May 2018)

At SwayD Europe we are committed to protecting your privacy & security. Please read our privacy notice carefully so that you are aware of the steps we take to look after any personal information you share with us. This notice also lists the information we collect from you and explains how we use it now or may use it in the future. You will also find information about your privacy rights and how the law protects you.

Applicable Data Protection Law

This privacy notice has been written in accordance with the General Data Protection Regulation (GDPR). If you are subject to more stringent data protection legislation please refrain from using this website or any of our other services.

Security

We endeavour to take all reasonable steps to protect your personal data, but cannot guarantee the security of any data you disclose online. You accept the inherent security implications of sending information over the internet and will not hold us responsible for any breach of security unless we have been negligent.

Changes to This Notice

We may occasionally make changes to this privacy notice. If we decide to change our privacy notice, we will post those changes on this page. We therefore recommend you re-visit this page periodically to check for changes.

How and Why We Collect and Store Your Data

Who We Are

Any personal information provided to or gathered by our website is controlled by SwayD Europe. Please use the details listed below to contact us about any of the topics set out in this privacy notice.

SwayD Europe
85 Vauxhall St
Norwich
Norfolk
NR2 2SD

Telephone: 0208 099 2112
Email: [email protected]

We aim to process information about you fairly and in a transparent manner. If you are unsure how we are handling information about you or you think we could improve our privacy information, please let us know.

Legal Basis for Processing Your Data

Data Protection law states that we are allowed to use personal information only if we have a proper reason to do so. The law says we may collect your data if we have a business or commercial reason of our own to use your information.

On that basis, we will collect personal data from you in the pursuit of our legitimate interests as a commercial organisation including the marketing and promotion of our brand, products, and services and on the basis of your consent.

What Information We Collect and How We Use It

When you use our website and/or register with us we may process your personal information for the following purposes:

1. The monitoring of customer traffic patterns and website usage to help us to develop the design and layout of the website

2. Notifying you of news and information which we think may be of interest to you including by email or SMS; only where you have granted us permission to do so

3. Offering, administering and providing products and services

4. Providing you with a more personalised user experience when using our application, website or any other services we might provide to you by analysing, segmenting and profiling our database and allowing us to target you with information we think you might be most interested in including products and services, only where you have granted us permission to do so

5. Sending you surveys for quality management purposes

6. We will use some of the data that we obtain about you to automatically build a profile of you to help us to understand our customers and prospects. This information may be used to determine which communications messages you receive and their frequency.

Where We Collect Personal Data From

We may collect personal information about you (or your business) when you browse our website, sign up to receive our newsletter, when you contact us via our online contact form, or via live chat. We may also collect personal data from you provided to us when you contact us by the phone numbers or email addresses provided on this site.

What We Do With the Information That We Collect

We will never use your information in a way incompatible with this privacy notice and we will not put any information about you on general release nor will we sell such information.

How Long We Keep Your Personal Information

We collect personal information for specific purposes and on specific legal bases and endeavour to collect only the personal information required for those purposes. We will keep your data on average for 10 years or until you ask us to delete it.

Once this purpose has been fulfilled and the personal information is no longer required, we will anonymise your data by removing any identifiable information or erasing it.

Third-Party Service Providers Processing Your Personal Information

SwayD Europe uses several third-party service providers for activities including data hosting, storage and processing.

The third-party service providers that will process your personal data will likely include the following:

• Hetzner Online GMBH (for data hosting and processing)
• Cloudflare Inc (for site performance and caching)
• Google LLC (for website analytics)

Your Rights and Control

Your Consent

By using our website, you consent to the use of any information provided by you, collected from you, or derived based on collected personal information by SwayD Europe for the purposes described in this privacy notice. You have a right to withdraw your consent at any time for any of the processing activities that are based on your consent.

How to Withdraw Your Consent

You can withdraw your consent at any time. Please contact us at [email protected] you wish to do so.
This will only affect the way we use information when our reason for doing so is that we have your consent. See the section ‘your rights’ about more generally restricting use of your information.

How to Complain

You have a right to lodge a complaint about any aspect of how we are handling your data with the UK data protection commissioner who can be contacted here: https://ico.org.uk/concerns/

How to Get a Copy of Your Personal Information

You have the right to request at reasonable intervals access to the personal information we have collected about you. Please refer any access request [email protected] When requesting access to your personal data provide as much detail as possible about what personal data you would like access to and include in the subject line that it regards an access request.

You can also request a copy of all the personal information we hold about you by writing to us at [email protected]

Your Rights

You can object to us keeping or using your personal information. This is known as the ‘right to object’. You can also ask us to delete, remove, or stop using your personal information if there is no need for us to keep it. This is known as the ‘right to erasure’ or the ‘right to be forgotten’.

If you so choose you may request us to rectify, erase or block the processing of your personal data if that personal data is no longer accurate, up-to-date or when the further processing of that personal date would be in violation of applicable data protection legislation.

You have a right to information about how we are processing information about you and we have an obligation to processes only a minimum of data for specific, explicit and legitimate purposes in a fair, lawful and transparent manner. This privacy notice fulfils our obligations to provide you with information but you should contact us directly if you have any questions or concerns.

If you want to object to how we use your data, or ask us to delete it, please contact us at [email protected]

Letting Us Know if Your Personal Information is Incorrect

You have the right to question any information we have about you that you think is incorrect. We’ll take reasonable steps to check this for you and correct it.

If you want to do this, please contact us at [email protected]

Terms & Conditions of Use

This website is owned and operated for and on behalf of SwayD Europe (“we”, “us”, “our”).

We reserve the right to change the terms, conditions and notices under which our services are offered. The user is responsible for regularly reviewing these terms and conditions and for additional terms posted on this website (i.e. we will not notify you of any change but we will post any changes on the website).

1. You may not copy, modify, transmit, display, distribute, perform, reproduce, licence, publish, create derivative works from, transfer, or sell any information software, or sell products and/or services obtained from this website.

2. You will not use the website/services for any purpose that is in contravention of any applicable local, national and international law or regulation or for any purpose that is prohibited by these terms and conditions.

3. You may not use the website in any manner which could damage, disable or impair the service provided on the website or interfere with any other parties use and/or enjoyment of those sites/services.

4. The services of the website are provided on as “as is” or “as available” basis. SwayD Europe makes no representations or warranties of any kind whether express on implied as to the operations of its website, the information, content, materials, or products included or offered for sale on the website. We disclaim all warranties, express or implied, including but not limited to implied warranties of merchantable quality and fitness for a particular purpose. You hereby agree that we shall not be liable for any loss, interruption of business, or any indirect, special, incidental, punitive or consequential damages of any kind (including loss of profits) regardless of the form of action, whether in contract, tort or otherwise. No oral advice or written information given by SwayD Europe, its affiliates, its agents, directors, employees or agents, or the like, shall create a warranty, nor will the user rely on any such information or advice. SwayD Europe in particular makes no warranty that:

(a) the website will meet your requirements;
(b) the website will be available on an uninterrupted, timely, secure or error free basis;
(c) the results that may be obtained from the use of the website or any services offered through the website will be accurate or reliable; or
(d) the quality of any products, services, information or the material purchased or obtained by you through the website will meet your expectations.

5. By uploading, e-mailing, posting, publishing or otherwise transmitting any content to SwayD Europe, you automatically grant (or warrant that the owner of such rights is expressly granting) SwayD Europe a perpetual, royalty free, irrevocable, non-exclusive right and licence to use, reproduce, modify, adapt, publish, transmit and distribute such content on in any form, medium, or technology now known or later developed. In addition you warrant that all so called moral rights in such content have been waived.

6. Any content, materials, information or software downloaded or otherwise obtained through the use of the website, is done at your own discretion and risk. SwayD Europe shall have no responsibility for any damage to your computer system or for any loss of data that results from the download of any content, materials, information or software or any consequential, incidental or indirect loss arising out of any damage to your computer system or loss of data.

7. You may not access, download, use or export the website, or the content, software, products or services provided on the website in violation of UK/Irish law or regulations or in violation of any other applicable laws or regulations relating to the export of and import of products. You may download, view, copy and print a document from photographs, videos or other graphics incorporated in these documents from this website subject to the following:

(a) the documents may be used solely for personal, informational, non-commercial purposes;
(b) the documents may not be altered or modified in any way. Except where your use constitutes “fair use” under copyright law you may not otherwise use, download, upload, copy, print, display, perform, reproduce, publish, licence, post, transmit or distribute any information from this website in whole or in part without the express authorisation of SwayD Europe.

8. All competitions or games of chance operated by SwayD Europe on this website are subject to the competition rules as may be posted on the website from time to time. You hereby acknowledge the application of these rules to the operation of competitions and acknowledge that you will adhere to the said rules.

9. The website provides links to other websites and access to content, products and services from third parties, including users, advertisers, affiliates and sponsors of the website. You agree that SwayD Europe is not responsible for the availability of, or content provided on, such third party websites. You should refer to the policies posted by other websites regarding privacy and other topics before you use them. You acknowledge and agree that SwayD Europe is not responsible for third party content accessible to the website, including opinions, advice, statements and advertisements and understand that you bear all risks associated with the risk of such content. If you choose to purchase any products or services from a third party, your relationship is directly with the third party. You agree that SwayD Europe is not responsible for:

(a) the quality of third party products and services; and/or
(b) fulfilling any of the terms of the agreement with the seller, including delivery of products or services and warranty obligations related to the purchased products or services. You acknowledge that SwayD Europe is not responsible for any loss or damage of any sort that you may incur from dealing with any third party.

10. All contents of the SwayD Europe website are copyright of Geoffrey Pan.

11. These terms and conditions shall be governed by and construed in accordance with the laws of the UK and the parties hereby submit to the non-exclusive jurisdiction of the UK courts to settle any disputes in connection with or arising out of the use of this site or its affiliate sites.

12. If any of the provisions of these terms and conditions is found by a court or other competent authority to be void or unenforceable, such provision shall be deemed to be deleted from the terms and conditions and the remaining provisions of the terms and conditions shall continue in full force and effect.

Cookies

EU Cookie Directive

From 26 may 2011 a new European Union directive requires us to gain the consent of our users to download cookies on to their machines. There are various methods we could use to gain users consent. For example, we could use pop-ups; prompting users to tick a box to confirm they give permission for us to download cookies on their machine.

Alternatively, we could use an online form that all users must complete before using the website.
We consider both of these solutions as obtrusive. We want our users find information and services quickly.

Therefore, we have taken the decision to promote how we use cookies on our website instead. This will enable users to make an informed decision whether they want to disable this feature.
There are links on our terms and conditions and disclaimer pages which are in the footer of every web page pointing to this information.

What is a Cookie?

Information may be sent to your computer in the form of an internet “cookie” to allow our servers to monitor your requirements. The cookie is stored on your computer. Our server may request that your computer return a cookie to it.

These return cookies do not contain any information supplied by you or any personally identifiable information about you.

Such measures are necessary to allow SwayD Europe to measure the usability of the systems, which will help to continually improve user experience of our websites. Your browser software should however enable you to block cookies if you wish to. For more information about cookies, please visit http://www.allaboutcookies.org/.

Strictly Necessary Cookies

These cookies are essential in order to enable you to move around the website and use its features, such as accessing secure areas of the website.

Performance Cookies

These cookies collect information about how visitors use a website, for instance which pages visitors go to most often, and if they get error messages from web pages. These cookies don’t collect information that identifies a visitor. All information these cookies collect is aggregated and therefore anonymous. It is only used to improve how a website works.

Functionality Cookies

These cookies allow the website to remember choices you make (such as your user name, language or the region you are in) and provide enhanced, more personal features. For instance, a website may be able to provide you with local weather reports or traffic news by storing in a cookie the region in which you are currently located.

These cookies can also be used to remember changes you have made to text size, fonts and other parts of web pages that you can customise. They may also be used to provide services you have asked for such as watching a video or commenting on a blog. The information these cookies collect may be anonymised and they cannot track your browsing activity on other websites.

Targeting or Advertising Cookies

These cookies are used to deliver adverts more relevant to you and your interests they are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They are usually placed by advertising networks with the website operator’s permission. They remember that you have visited a website and this information is shared with other organisations such as advertisers. Quite often targeting or advertising cookies will be linked to site functionality provided by the other organisation.

Google Analytics

SwayD Europe uses google analytics, a web analytics service provided by google. Google analytics collects first party cookies, which are text files placed on your computer to collect standard internet log information and visitor behaviour. This information is sent to google and is used to evaluate how our website is being used. This enables SwayD Europe to compile statistical reports. A full list of cookies used by google analytics and explanations on how these work are available on the google code website.

SwayD Europe does not collect (nor allow any third party to collect) personally identifiable information of visitors to our site. We will not associate any data gathered with any personally identifying information. We will not link or seek to link an ip address with the identity of a computer user. In short, google analytics doesn’t identify who you are, but it does track your movements on our websites.

How to Disable Cookies

You can stop cookies being downloaded on to your computer by selecting the appropriate settings on your browser. However please note that if you do this you may not be able to use the full functionality of this website.

There is more information about cookies, including how to delete them on the website aboutcookies.org. You may also opt out of being tracked by google analytics.

Consent

By using our website you consent to collection and use of any information you provide to us by SwayD Europe for the purposes described above. If we amend our privacy notice, any changes will be published on this web site.

We use cookies on our website and provide information to enable users to make an informed decision whether they want to disable this feature. There are links on our terms and conditions and disclaimer pages that are in the footer of every web page pointing to this information

We Use The Following Types of Cookie to Operate Our Website:

• cookies necessary for the optimal functionality of our website;
• analytical cookies to monitor the use and performance of our website; and
• third party cookies that are used for advertising and social media widgets.