There are many different ways that you can use our services. When you share information with us, for example by creating a Swifin Account, we can make those services even better, help you get the best and make the most of our services. As you use our services, we want you to be clear on how we use information and the ways in which you can protect your privacy.
Your privacy matters to us, our group companies and joint venture partners, and so whether you are new to Swifin or a long-time user, please read the following carefully to understand our views and practices regarding your personal data and how we will treat it.
We ("we" “us” “our” “Sedel” and “Swifin”) are committed to protecting and respecting your privacy.
This policy (together with our Terms and Conditions and any other documents referred to on it) sets out the basis on which any personal data we collect from you, or that you provide to us, will be processed by us.
This policy also covers:
(a) the Swifin Mobile App (App) once you have downloaded a copy of the App onto your mobile phone or handheld device; and
(b) any of the services accessible through the App or the website (the “Services Site”).
By using our services, you are accepting and consenting to the practices described in this policy.
For the purpose of the Data Protection Act 1998 (the Act), the data controller is Sedel Capital LLP (Sedel).
- INFORMATION WE COLLECT FROM YOU
We collect and process the following data about you:
- Information that you give us.This is information about you that you give us by registering for a Swifin Account on the App Site and the Services Site (together “our site”) or by corresponding with us (for example by phone, e-mail, chat or otherwise). It includes information you provide when you search for a product, place an order on our site, make an in-APP purchase, participate in discussion boards or other social media functions on our site, enter a competition, promotion or survey, and when you report a problem with our App or our site. If you contact us, we will keep a record of that correspondence. The information you give us may include your name, address, e-mail address, phone number and method of payment.
- Information we collect about you and your device.Each time you visit our site or use the App we will automatically collect the following information:
- technical information, including the Internet protocol (IP) address used to connect your computer to the Internet, your login information, browser type and version and language, time zone setting, browser plug-in types and versions, operating system and platform, hardware model, operating system version, device event information, such as crashes, system activity, hardware settings, the date and time of your request and referral URL, and cookies that may uniquely identify your browser. 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, (Device Information);
- information about your visit, including the full Uniform Resource Locators (URL), clickstream to, through and from our site (including date and time), products you viewed or searched for' page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), methods used to browse away from the page, and any phone number used to call our customer service number. We may collect and store information (including personal information) locally on your device using mechanisms such as storing application data in browser cache.
- Location information. We may also use GPS technology or other technology to determine your current location. Some of our location-enabled services require your personal data for the feature to work. If you wish to use the particular feature, you will be asked to consent to your data being used for this purpose.
- 3. COOKIES AND ANNONYMOUS IDENTIFIERS
- HOW WE USE INFORMATION THAT WE COLLECT
We use information held about you in the following ways:
- Information you give to us. We will use this information:
- to carry out our obligations arising from contracts entered into between you and us and to provide you with the information, products and services that you request from us;
- to conduct customer due diligence checks in accordance with our obligations under the Money Laundering, Terrorist Financing and Transfer of Funds (Information on the Payer) Regulations 2017 which requires us to process personal data for the purposes of preventing money laundering and terrorist financing and any other applicable regulations. This is a condition for entering into a contract with you;
- to verify your identity and protect against fraud and financial crime;
- A key feature of our service is the ability for any member to make payments easily and cost effectively to any other member of the exchange. This means that every member of the exchange will be able to find other members for purposes of making payments after entering their Swifin ID, Swifin name, mobile number or QR code. You agree and acknowledge that this will not constitute a breach of your privacy as it forms an integral part of the services we provide to you.
- to inform you about our services, such as letting you know about improvements to our service or notify you about changes to our service;
- to provide you, or permit selected third parties to provide you, with information about goods or services we feel may interest you. If you are an existing customer, we will only contact you by electronic means (e-mail or SMS) with information about goods and services similar to those which were the subject of a previous sale or negotiations of a sale to you. If you are a new customer, and where we permit selected third parties to use your data, we (or they) will contact you by electronic means only if you have consented to this.
- to ensure that content from our site is presented in the most effective manner for you and for your computer;
- to provide, maintain, protect and improve our services and to offer you a tailored content;
- to keep a record if necessary of your communication to help resolve any issues that you might be facing; and
- to improve your user experience and the overall quality of our services using information collected from cookies and other technologies. For example, by saving your language preferences, you will be able to have our services appear in the language you prefer.
We process personal information on servers in many countries around the world. We may process your personal information on a server located outside the country where you live.
- Information we collect about you. We will use this information:
- to administer our site and the APP, and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
- to improve our site and the APP, and to ensure that content is presented in the most effective manner for you and for your computer;
- as part of our efforts to keep our site safe and secure;
- to measure or understand the effectiveness of advertising we serve to you and others, and to deliver relevant advertising to you;
- to make suggestions and recommendations to you and other users of our site about goods or services that may interest you or them;
- with domain administrators; and
- If your Swifin Account is managed for you by a third party (administrator), then the third party will have access to your account information (including your emails and other data) and may be able to:
- view statistics regarding your account, such as statistics regarding transactions;
- change your account password;
- suspend or terminate your account access;
- access or retain information stored as part of your account;
- receive your account information in order to satisfy applicable law; and
- restrict your ability to delete or edit information or privacy settings.
We do not store credit card details nor do we share customer details with third parties who are not members/partners of the transaction services exchange.
- DISCLOSURE OF YOUR INFORMATION
You agree that we have the right to share your personal information with:
- any member of our group, which means our subsidiaries, our parent company and its subsidiaries, or any ultimate holding company as defined in section 1159 and 1162 of the UK Companies Act 2006;
- selected third parties including:
- business partners, banking partners, joint venture companies, sub-contractors agents, for the performance of any contract we enter into with them;
- analytics and search engine providers that may assist us in the improvement and optimisation of our site and services;
- electronic-KYC (Know You Customer) providers for the purpose of conducting customer due diligence checks in accordance with our obligations under the UK fourth money laundering directive which requires us to process personal data for the purposes of preventing money laundering and terrorist financing; and
- third parties to verify your identity and protect against fraud.
We may also disclose your data to enforce applicable Terms and Conditions, including investigation of potential violations; detect, prevent or otherwise address fraud, security or technical issues; and protect against harm to the rights, property or safety of Swifin, our users or the public, as required or permitted by law.
We will disclose your personal information to third parties:
- In the event that we sell or buy any business or assets, in which case we will disclose your personal data to the prospective seller or buyer of such business or assets.
- If we or substantially all of our assets and our group of companies are acquired by a third party, in which case personal data held by it about our customers will be one of the transferred assets.
- TRANSPARENCY AND CHOICE
People have different privacy concerns. Our goal is to be clear about what information we collect, so that you can make meaningful choices about how it is used.
We provide you with the tools you may use to manage your privacy. You may also set your browser to block all cookies, including cookies associated with our services. However, it’s important to remember that many of our services may not function properly if your cookies are disabled.
The services provided are better if other members can find you easily, be able to see your profile and be able to communicate with you.
- ACCESSING AND UPDATING YOUR PERSONAL INFORMATION
Whenever you use our services, we aim to provide you with access to your personal information, which you can update as may be appropriate, and other supplementary information.
Where we can provide access to information, we will do so free of charge, except when a request is manifestly unfounded or excessive, particularly if it is repetitive then we may charge a reasonable fee which will be based on the administrative cost of providing the information.
We strive to give you ways to update information quickly or to delete it unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.
We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.
- INFORMATION THAT YOU SHARE
Many of our services let you share information with others. Remember that when you share information publicly, it may be indexable by search engines. Our services provide you with different options for sharing and removing your content.
- WHERE WE STORE YOUR PERSONAL DATA
All information you provide to us is stored on our secure servers. Any payment transactions will be encrypted. Where we have given you (or where you have chosen) a password which enables you to access certain parts of our site, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.
Unfortunately, the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted to our site; any transmission is at your own risk. Once we have received your information, we will use strict procedures and security features to try to prevent unauthorised access.
- INFORMATION SECURITY
We work hard to protect our users from unauthorised access to or unauthorised alteration, disclosure or destruction of information that we hold.