Privacy Policy

Swivel Secure Privacy Policy
Swivel Secure Limited a private limited company registered in England and Wales, whose registered address is Equinox 1, Audby Lane, Wetherby, LS22 7RD (registered company number 04068905). (“Swivel,” “We” or “Us”), is committed to respecting the privacy rights of visitors to the Swivel web site at www.swivelsecure.com and our associated customer support portal at supportdesk.swivelsecure.com (the “Site”). While visiting the Site, We may ask you (“You” or “Your”) to provide information that personally identifies you (“Personal Information”) for purposes of interacting with the Site.

We will take measures to ensure that the Personal Information You submit to Us remains private and is used only for the purposes as set out in this Privacy Policy. To further the protection of Your Personal Information, We have adopted a set of guidelines (outlined below) to describe the Personal Information we collect about You, why We collect it, how We use it and when We share it with third parties.

This Privacy Policy has been developed with the recognition that Internet technologies are rapidly evolving. Accordingly, this Privacy Policy is subject to change without prior notice. Any such changes will be posted on this page. Please see the Effective Date stated at the conclusion of this Privacy Policy.

What kind of information do We collect from You?

Contact Us

We only collect Personal Information that You submit to Us via our “contact us” section. The data collected via our form will be Your name, company name, email address, phone number and country. We may also collect your IP address, as set out below.

Demo Registration

Where You wish to set up a demo, We may collect the Personal Information including Your first name, last name, email address, mobile number and company name. These details will be stored for 14 days both locally on Our web server and on our cloud demo server instance to allow the demo to work. After 14 days details stored locally on the web server and on the cloud demo server will be deleted.

How do We use Your Personal Information?

We may use Your Personal Information for the following purposes:

Our legal basis for processing Your Personal Information

In order to process and use Your Personal Information, we rely on one of more of the following legal bases:

Processing is necessary for the performance of the services We provide to You; or
Processing is necessary for the purposes of a legitimate business interest pursued by Us; or
You have given explicit consent to the processing of Your Personal Information for a specified business purpose, such as marketing

When might We disclose Your Personal Information?

Except to the extent required by any applicable law or governmental or judicial body, We will not disclose Your Personal Information to any third party other than to (i) a regulator; (ii) to Our sales partners Swivel Secure Europe and Swivel Secure Inc. for the purposes of providing You with services and support; and (iii) third party suppliers, resellers and distributors to enable Us to provide services to You.

We do not provide specific Personal Information to unaffiliated third parties without Your consent. However, We may share aggregate, non-personally identifiable information with our business partners and other affiliated third parties (i.e., the number of users who have visited the Site on a specific day, etc.). Swivel may match aggregated user information with third party data. Also, We may disclose aggregated user statistics in order to describe our services to potential advertisers, partners and other third parties, and for other lawful purposes.

It should be noted, however, that this Privacy Policy only addresses the use and dissemination of information that We collect from You. To the extent that You disclose any information to other parties, through other web sites on the Internet linked to the Site, different policies may apply. Since Swivel Secure does not control the privacy policies of third parties, You are subject to the privacy customs and policies, if any, of that third party, and Swivel Secure shall not be responsible for the use or dissemination of Your Personal information by that third party.

Therefore, We encourage You to ask questions before You disclose Your Personal Information to others.

Transferring Your Personal Information outside of the EEA

To deliver services to You, it is sometimes necessary for Us to share your Personal Information outside the European Economic Area (EEA), for example with Our resellers located outside of the EEA. These transfers are subject to special rules under European and UK data protection law. These non-EEA countries do not have the same data protection laws as the United Kingdom and EEA. If you would like further information regarding the mechanisms We use to comply with data protection law, please contact Us.

Storage and Transfer of Your Personal Information

Your Personal Information is stored in either Microsoft Offce 365, our CRM (SalesForce) and Our support software program (Team Support). Access to these systems is limited to registered technology, which must be registered with our Mobile Device Management system. This allows Us to remotely block or wipe the device where your Personal Information is stored should it be lost or stolen.
We also hold physical records containing Personal Information, which are protected by being stored in locked cabinets and by access being limited to authorised personnel only. We also operate a clear desk policy to assist in protecting Personal Information. We will only hold Your Personal Information for the duration that is necessary to carry out the data processing purposes set out above, or where we are required to store it for longer under applicable laws.

Your Rights

Subject to certain limitations, You have the right to:

Access Personal Information held about You free of charge;
Restrict Our processing of Your Personal Information if:
- You contest the accuracy of the Personal Information held by Us (for a period enabling Us to verify the accuracy of the information);
- Our processing activities are unlawful;
- or Your Personal Information is no longer necessary for the purposes for which it was collected by Us;
Ask Us to erase Your Personal Information if:
- We are processing Your Personal Information on the basis of Your consent and You withdraw Your consent to Our processing of Your Personal Information;
- Your Personal Information has been processed unlawfully by Us;
- Your Personal Information is no longer necessary for the purposes for which it was collected by Us;
Ask Us (and third parties to whom We transfer Your Personal Information) to rectify Your Personal Information if it becomes inaccurate;
Challenge processing which has been justified on the basis of legitimate interests or in the public interest;
be notified of a personal data breach which is likely to result in high risk to Your rights and freedoms;
in limited circumstances, to receive or ask for Your Personal Information to be transferred to a third party in a structured, commonly used and machine readable format;
request a copy of an agreement under which Personal Information is transferred outside of the EEA; and
prevent processing that is likely to cause damage or distress to You or anyone else.

You can exercise these rights at any time by contacting Us at: dataprivacy@swivelsecure.com

If You believe Our processing of Your Personal Information does not comply with data protection law, You can make a complaint to the Information Commissioner’s Office using the following details:

Information Commissioner’s Office
Wycliffe House
Water Lane
Wilmslow
Cheshire
SK9 5AF

Telephone: 0303 123 1113

Cookies

Our Site uses cookies to distinguish You from other users of our Site. By continuing to use our Site, you are agreeing to Our use of cookies. A cookie is a text file made up of numbers and letters, that a web site can send to Your browser, which may then be stored on Your computer’s hard drive. The Site can only access the information from a cookie sent by the Site. We cannot access other cookies sent by other web sites or the information contained therein. Additionally, We are not provided Your email address or any other information about You through the use of a cookie. The only way We would be provided with such information is if You specifically submit that information to Us.

Why does the Site use cookies?

Swivel uses cookies to track usage of the Site and further customise Your experience when You are visiting the Site. By tracking usage, We can best determine what features of the Site best serve You. No Personal Information is tracked.

Cookie	Name	Purpose
_hjIncludedInSample	_hjIncludedInSample	This session cookie is set to let Hotjar know whether that visitor is included in the sample which is used to generate funnels. When someone visits swivelsecure.com, we collect details of visitor behaviour patterns. We do this to find out things such as the number of visitors to the various parts of the site. We collect this information in a way which does not personally identify anyone. Kept for 365 days. Dos not contain any PII.
Google Analytics	_gat	Used by Google Analytics to throttle the number requests being sent. Kept for 1 minute. Dos not contain any PII.
Google Analytics	_gid	Used by google analytics to distinguish users. Dos not contain any PII just a randomly generated ID. Kept for 24 hours.
Google Analytics	_ga	Used by google analytics to distinguish users. Dos not contain any PII just a randomly generated ID. Kept for 2 years.

May I decline to accept a cookie?

You may decline to accept cookies sent by the Site by selecting an option on Your browser to reject cookies. Other sites linked to the
Site may also send cookies; however We do not control such activities. If You decline a cookie, You may not be viewing the Site in a
way in which it was designed to optimally be presented.

What benefits do I receive from cookies?

Overall, the use of cookies helps to give You a customised experience at the Site. Through the use of cookies, We will know what’s working and what’s not. That information is then used to keep our Site fresh and relevant to You. Cookies also allow the personalisation of any online services We may provide to You.

Google Analytics

Swivel uses Google Analytics to analyse the activity of users on its website via anonymised data. Any personally identifiable information such as a user’s IP address is automatically anonymised. Details that are tracked are:

The total time a user spends on your site;
The time a user spends on each page and in what order those pages were visited;
What internal links were clicked (based on the URL of the next pageview);
The geographic location of the user;
What browser and operating systems are being used;
Screen size and whether Flash or Java is installed; and
The referring site

IP Addresses

An IP address is a number automatically assigned to Your computer whenever You access the Internet. All computer identification on the Internet is conducted with IP addresses, which allow computers and servers to recognize and communicate with each other. Swivel does log IP addresses, or the location of Your computer on the Internet, for systems administration and troubleshooting purposes.
However, We do not use IP address logs to track Your session or Your behaviour on the Site.

Effective Date and Changes

This Privacy Policy is effective as of May 25, 2018. Swivel reserves the right to modify the terms of this policy at any time and in our sole
discretion, by posting a change notice to this page. Your continued use of the Site following our posting of a change notice will constitute binding acceptance of those changes.