1. INTRODUCTION
The following describes the Privacy Policy for SwiftERM (“We” or “SwiftERM”), which contains four separate sections as follows:
- This Introduction;
- SwiftERM Online Privacy Policy, which addresses the privacy practices applicable to usage of the SwiftERM websites;
- SwiftERM’s SaaS Privacy Policy, which addresses the privacy practices applicable to information processed by SwiftERM in its role as a ‘software as a service’ provider;
- A General Section, which applies to all of our privacy policies.
SwiftERM respects individual privacy. SwiftERM strives to collect and use personal information in a manner consistent with the laws of the countries in which it does business. If you have questions or concerns regarding this Policy, in the first instance please contact us via the contact page. If this does not resolve your complaint, you may prefer to call us, our number is +44 (0) 207 998 3901.
Legal Disclaimer
We may disclose Personal Information when required by law or regulation or in the good faith belief that such action is necessary in order to conform to the edicts of the law, comply with legal mandates, or to protect the rights, property, or personal safety of SwiftERM, its employees, users and the public.
2. SWIFTERM ONLINE PRIVACY POLICY
This Online Privacy Policy covers use of this website and our on-line customer site available only to clients of SwiftERM. All information you disclose to us on this website or on our on-line customer site is subject to our Online Privacy Policy.
With respect to data received through its websites, SwiftERM will, comply with the following:
We may use personal information we obtain relating to you, including but not limited to your name, mailing address, phone number and email address, for the purposes of contacting you, conducting internal business research, and carrying out other marketing activities. Never at any time do we assume or take proprietorial interest in our client’s data. While the algorithm runs analytics through your data, no employee of SwiftERM has physical access, to your data. It always belongs to our client, who may retrieve it at any time and terminate access via the control panel provided.
Registering On-line
In order to use SwiftERM personalisation SaaS you first need to complete the registration form and create a user name and password. During registration you are required to give contact information (such as name, phone number and email address). This information can be used to contact you about our services. Where credit card details are provided, these are processed by our nominated payment provider Stripe, and this data is never in our possession.
Marketing and other activities
When registering on the website, you may have the option of receiving different subscriptions. These options include promotional information, press releases and newsletters. From time to time we may send our visitors and/or clients emails with new site feature announcements, enhancements, maintenance information and general updates. We provide you the opportunity to ‘opt-out’ of having your personally identifiable information used for certain purposes, when we ask for this information. If you no longer wish to receive our newsletter and promotional communications, you may opt-out of receiving them on the link provided.
We communicate with users to provide requested services and in response to issues relating to your account via email or phone.
From time to time we collect and store information generated through use of our on-line services. We may use some of this information in the aggregate for marketing research, such as, for example, in compiling statistics on website visitors and in assessing clients’ business needs. If we decide to mention a particular client on the site, we will take reasonable steps to gain that client’s consent before posting. We may collect and store information provided directly or indirectly to us through participation in online contests and/or client satisfaction surveys and the like. We may create standard usage logs through our web server, such as IP address, browser type, and access times. We use our web server to recognise your domain name and track your use of the website. In accordance with GDPR compliance this website also required consent by users to the cookies used for such purposes. This data is always encrypted.
We may request certain information from you (such as your name, address, telephone number, email address or business requirements) to help us evaluate our site traffic and overall usage, improve our on-line services, and develop our websites and program. We may add information from third parties to this collected information, for instance to research prospective clients. From time to time we may purchase marketing data from third parties, to better target our advertising and to provide pertinent offers in which we think you would be interested. To enrich our profiles of individual customers, we may tie this information to the personally identifiable information they have provided to us. We may post customer testimonials on our web site which may contain personally identifiable information such as the customer’s name. Wherever possible we obtain the customer’s consent prior to posting the testimonial.
Links to Other Sites
This website contains links to other sites that are not owned or controlled by SwiftERM. Please be aware that we, SwiftERM, are not responsible for the privacy practices of such other sites. We encourage you to be aware when you leave our site and to read the privacy statements of each and every site that collects personally identifiable information. This Privacy Policy applies only to the information collected by our Web site.
Order Processing
If you purchase services from us, we request certain personally identifiable information from you on our order form. You must provide contact information (such as name, email, and address) and financial information (such as credit card number, expiration date). We use this information for billing purposes and to fill your orders. If we have trouble processing an order, we will use this information to contact you. This information is also used to send you updates on the product or service you purchased. SwiftERM uses third parties to process the credit card transactions, currently
Stripe. The billing information is not stored on SwiftERM’s servers.
Third Parties
We use third parties (i.e., emailing or direct mail services, marketing services, Web analytics) to assist with the marketing services on our site. When you register on the website or purchase services from us on-line, we will share your name and address as necessary for the third party to provide service. These third parties are not permitted to use such information for their own purposes. SwiftERM does not share, sell, trade, or rent your personal information to third parties for their promotional purposes.
Maintenance of Data and Passwords
For our web systems on which you have a user account, you have access to your information to update and maintain your profile. It is solely your responsibility to maintain the confidentiality of your password. If you believe your password has been compromised, please contact us immediately. If your personally identifiable information changes, or if you no longer desire to receive marketing materials, you may correct, update, delete or deactivate it by emailing info at SwiftERM.com . SwiftERM will respond to your request within 30 days of receiving the request. If your personally identifiable information changes, or if you no longer desire our service, you may update this information by making the change on your control panel or by contacting us. Your account is active for as long as needed to provide you services and comply with our legal obligations, resolve disputes, and enforce our agreements.
Security
We follow generally accepted industry standards to protect the personal information submitted to us, both during transmission and once we receive it. When you enter sensitive information (such as a credit card number) on our order forms, we encrypt the transmission of that information using secure socket layer technology (SSL). No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. Therefore, while we strive to use commercially acceptable means to protect your personal information, we cannot guarantee its absolute security. If you have any questions about security on our Web site, please contact us.
Cookies and Google Analytics
We use cookies on this site. A cookie is a small text file that is stored on a user’s computer for record-keeping purposes. We do not link the information we store in cookies to any personally identifiable information you submit while on our site. We use both session ID cookies and/or persistent cookies. We use session cookies to make it easier for you to download documents on the site. A session ID cookie expires when you close your browser. A persistent cookie remains on your hard drive for an extended period of time. You can remove persistent cookies by following directions provided in your Internet browser’s “help” file. Our web analytics product uses cookies to track page views and visitors on the site. This information is only used to analyse the traffic on our websites by SwiftERM. This information is not tied to personally identifiable information.
If you choose to do so, we set a persistent cookie to store your passwords, so you don’t have to enter it more than once. Persistent cookies also enable us to track and target the interests of our users to enhance the experience on our site. If you reject cookies, you may still use our site, but your ability to use some areas of our site will be limited. The SwiftERM websites use Google Analytics, a web analysis service of Google Inc. (“Google”) Google Analytics uses “cookies”, text files, which will be saved on your computer and which allow an analysis of your use of the website. The information provided by the cookie concerning your use of the website (including your IP-address) will be transferred to a Google server in the United States and saved there. Google will use this information to analyse your use of the website, to compile reports about the website activities for the website operator and to provide additional services concerning the website and internet utilisation. Google may transfer this information to third parties, if this is a legal requirement or if third parties are commissioned by Google to process the information. Google will in no event connect your IP-address with other Google data. You can prevent the installation of cookies with the relevant browser software setting; however, in this case you may not be able to use all the functions on this website to the full extent. Through use of the SwiftERM websites, you agree to the processing of your data by Google in the way described above and for the purpose stated above.
Changes to this Policy
We reserve the right to modify this Privacy Policy at any time, so please review it frequently. If we make material changes to this Policy, we will notify you here, by email, or by means of a notice on our home page so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we disclose it.
3. SwiftERM’S SOFTWARE AS A SERVICE (SaaS) PRIVACY POLICY
SwiftERM provides our customers with applications that facilitate many data related requirements. These applications are not a part of our corporate web site. SwiftERM serves as a Data Processor for the clients who use these applications. More specifically, SwiftERM does not own the information that is submitted to our applications. The information that is submitted to our applications will be subject to our clients’ privacy policies. The following information discloses how information is submitted via our applications and how we handle the information for our clients who are the owners of this data. SwiftERM is a leading end-to-end provider of software, proprietary content, services and process outsourcing that enable organisations to more effectively process data for consumer personalised emails. This SaaS Privacy Policy applies only to the transfer of personally identifiable information (“Personal Information”) received by SwiftERM in any format through its hosted software, whether supplied directly by SwiftERM customers or by employees or users of the hosted software anywhere in the world.
Notification of Changes/Choice
SwiftERM will maintain Personal Information in accordance with this SaaS Privacy Policy. If SwiftERM decides to change this Policy, SwiftERM will post the changes on this page so our customers and/or their employees, and users are aware of what Personal Information SwiftERM processes, how SwiftERM uses it, and under what circumstances, if any, SwiftERM discloses it. If at any point SwiftERM decides to retain or use Personal Information in a different manner, SwiftERM will notify its customers by way of email or by posting a notice on SwiftERM’s website for at least 30 days prior to the change in use. Customers, in turn, are responsible for their users and providing them a choice as to whether or not SwiftERM uses their Personal Information in this revised manner.
Onward Transfer
SwiftERM is a global corporation with operations in several countries. We have developed global data practices designed to assure Personal Information is appropriately protected. While our primary data-centre is in the UK, we may transfer Personal Information to SwiftERM offices outside of the UK and United States. In addition, we may employ other companies and individuals to perform functions on our behalf. If we disclose Personal Information to a third party or to SwiftERM employees outside of the UK or United States, we will ensure that such party has agreed to abide by the principles of this policy, or can otherwise assure adequate protection of such Personal Information.
Data Integrity
SwiftERM will use Personal Information only in ways compatible with the purpose for which it was collected or authorised by our customers.
Security
SwiftERM is committed to ensuring the security of the Personal Information that it processes. To prevent unauthorised access or disclosure, maintain data accuracy, and ensure the appropriate use of Personal Information, SwiftERM has adopted appropriate physical, electronic, and managerial procedures to safeguard and secure the Personal Information we process. SwiftERM strives to protect the privacy of the Personal Information it processes, and inadvertent disclosure is unlikely. In the event of such an inadvertent disclosure, SwiftERM will take all commercially reasonable steps to limit and remedy the disclosure. However, SwiftERM cannot guarantee that unauthorised third parties will never be able to defeat those procedures or use Personal Information for improper purposes.
Access/Correction
In most cases, when SwiftERM collects Personal Information, it does so on behalf of another company (as an agent or data processor). To request access to, correction, amendment or deletion of this Personal Information, a user should contact the company to which the data was provided.
Oversight/Enforcement
SwiftERM is available to any of its customers, business partners, or others who may have questions concerning this Policy or data security practices. SwiftERM has agreed to cooperate with Data Protection Authorities. Any questions, comments or complaints about the data practices (including, without limitation, compliance with data privacy principles of notice, choice, onward transfer, access, security, data integrity, or enforcement) of a hosted software customer for which SwiftERM processes data should be addressed to that client company.
4. GENERAL COOKIES AND LINKS TO OTHER SITES
We may use cookies to enhance a user’s experience while using our hosted software. Cookies are a small piece of data stored locally by your browser that saves information and helps identify you to web sites upon subsequent visits. Cookies are uniquely assigned to a computer, and can only be read by a Web server in the domain that issued the cookie. Cookies generally assist users by performing certain functions such as saving passwords and personal preferences regarding the sites. You may have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline all cookies if you prefer. Alternatively, you may be able to modify your browser setting to notify you each time a cookie is tendered and permit you to accept or decline cookies on an individual basis. If you choose to decline cookies, however, that may hinder performance and negatively impact the use of the hosted software.
Our hosted software may contain links to other sites. Please be aware that we are not responsible for the privacy practices or content of such other sites.
We recommend all our clients to adopt a policy of offering a box on the checkout page of their site, necessitating it be explicitly ticked by consumer wishing to make a purchase from your site, (unable to do so without such agreement) and in so doing must Agree to the Terms and Conditions”. These in turn should allow provision for the site owner to have permission to both store and use this data, disclosure of this policy and the consumer’s protection provided and legal rights and recourse, which is a GDPR requirement.
Children’s Privacy
SwiftERM is committed to protecting the privacy needs of children and we encourage parents and guardians to take an active role in their children’s online activities and interests. SwiftERM does not knowingly collect information from children under the age of 13 and SwiftERM does not target its website or its products to children under the age of 13.
Last updated on: 1st February 2022
