Privacy

My Swft Ltd Privacy & Cookies Policy

 

1. Introduction

At My Swft we like to keep things private and we never compromise when it comes to your privacy. We will always be clear about why we need the details we ask for, and ensure that your personal information is kept as secure as possible.

This Website provides a wide range of information to our visitors. Like many websites, we also collect information from our visitors, including personally identifiable information (including full name, e-mail address, phone number) and non-personally identifiable information (e.g. aggregate statistics about what parts of our Website are most popular). This Privacy Policy is designed to tell you about our information collection practices at this site – that is, the ways we collect information; what kinds of information we collect; why we collect information; how we use information we collect; with whom we share information we collect; how you can access, amend, and delete information we collect from you; and what kinds of security we use to protect information you provide.

Before using this Website, and particularly before submitting personally identifiable information via this Website, you should read this entire policy. Use of this Website constitutes your agreement to the terms of this policy. If the terms and conditions of the policy are not acceptable to you, do not submit any personally identifiable information via this site.

This privacy policy applies between you, the User of this Website and My Swft Ltd, the owner and provider of this Website. It applies to our use of any and all Data collected by us or provided by you in relation to your use of the Website. Please read this Privacy Policy carefully.

 

2. Definitions and interpretations

2.1: In this Privacy Policy, the following definitions are used:

Data: Collectively all information that you submit to My Swft Ltd via the Website, WhatsApp, Facebook, Facebook Messenger or via any other channel. This definition incorporates, where applicable, the definitions provided in the EU General Data Protection Regulation (GDPR).

My Swft Ltd, we or us: My Swft Ltd, a company registered in England and Wales under company number 10719004, whose registered office address is at Kemp House, 160 City Road, London, EC1V 2NX

User or you: any third party that accesses the Website and is not either (i) employed by My Swft Ltd and acting in the course of their employment or (ii) engaged as a consultant or otherwise providing services to My Swft Ltd and accessing the Website in connection with the provision of such services

Website: the website that you are currently using, www.myswft.com, and any sub-domains of this site unless expressly excluded by their own terms and conditions

2.2: In this Privacy Policy, unless the context requires a different interpretation:

  1. the singular includes the plural and vice versa;
  2. references to sub-clauses, clauses, schedules or appendices are to sub-clauses, clauses, schedules or appendices of this privacy policy;
  3. a reference to a person includes firms, companies, government entities, trusts and partnerships;
  4. “including” is understood to mean “including without limitation”
  5. reference to any statutory provision includes any modification or amendment of it
  6. the headings and subheadings do not form part of this privacy policy

 

3. Scope of this Privacy & Cookies Policy

This Privacy Policy applies only to the actions of My Swft Ltd and Users with respect to this Website. It does not extend to any websites that can be accessed from this Website including, but not limited to, any links we may provide to social media websites. We therefore encourage you to read the privacy policy of each website that you visit. We provide these references and links for your convenience; they should not be construed as an endorsement of such sites, their content, or their information practices. You are solely responsible for any interactions you may have with such web sites.

 

4. Your rights:
 
Right to be informed: This encompasses the obligation for us to be transparent in how we collect and use your personal data
 
Right of access: You have the right to access your personal data and supplementary information
 
Right to rectification: If the information we hold on you is inaccurate or incomplete, you can request we correct this
 
Right to erasure: You can request we delete or remove personal data where there is no compelling reason us to continue processing
 
Right to restrict processing: You have the right to request we cease processing your data, if: 
  • You consider it inaccurate or incomplete
  • Where you object to processing and we are considering whether we still have a legitimate interest to process it
  • Where we don’t need the data for the original reason we collected it, but may need it to support a legal claim 
Right to data portability: Where you have consented to our processing your data, or where the processing is necessary for us to deliver a contract, you can request a copy of that data be provided to a third party in electronic form
 
Right to object: You have the right to object to our processing under certain circumstances. For example, you can object to: 
  • direct marketing (including profiling); and 
  • processing for purposes of scientific/historical research and statistics 
Rights relating to automated decision making including profiling: Where we apply automated decision making, we must:
  • give you information about the processing
  • introduce simple ways for you to request human intervention or challenge a decision
  • carry out regular checks to make sure that our systems are working as intended 
Information related to automated decision making is contained later in this notice
 

5. Data collected

5.1 Active information collection:

This Website collects information from its visitors in two ways: actively and passively. Active information collection refers to instances in which we gather information from you when you fill it in and send it to us, such as by completing a registration form, signing up for an electronic newsletter, or sending us a message via an e-mail reply mechanism provided by this site. Active information collection can include both personally identifiable information (e.g. your full name or information that is unique to you) and non-personally identifiable information (e.g. if we were to ask for your first name and a list of the top three things you like about our site). Passive information collection refers to instances in which we collect information from you that you have not actively provided (please see the next section of this policy for a summary of our passive information collection practices).

(a) Registration Information:

If you are interested in receiving electronic updates, alerts, and other information from us regarding this Website and our products and services, you must provide us with an e-mail address. In completing your registration, we may also ask for optional information, such as how you found us, to help us better serve you in the future.

(b) Feedback Information:

We welcome your comments and feedback regarding this Website and our products, services and programs. This Website provides an e-mail address that permits you to send us your own e-mail address, comments, and any other information you choose to include. E-mail is not secure. As a result, you should carefully consider what information you wish to send to us via e-mail.

5.2 Passive information collection:

We may use third party software to passively collect information while you are visiting www.myswft.com (that is, you do not actively provide this information). These technologies allow us to collect certain kinds of non-personally identifiable information, including your internet domain name, the type of web browser you use, the operating system you use, the date and time of your visit to the Website, the specific pages you visit, and the address of the web site you visited prior to entering www.myswft.com. We do not link this passively collected non-personally identifiable information with personally identifiable information you have actively provided elsewhere on this site. This data is used only to help us improve our customers’ experience on our website and we reserve the right to share with third parties, including our business partners and advertisers, the anonymous aggregated information that we have passively collected via this site.

Below we have summarized the primary means of passive information collection on our Website.

(a) Cookies:

This site uses cookies, which are small text files that store non-personally identifiable information about you, either temporarily in connection with your Internet Protocol (IP) address (known as a temporary or session cookie, and deleted once you close your browser window) or more permanently on the hard drive of your computer (known as a permanent or persistent cookie). This Website uses session cookies so that you do not have to fill in the same information from page-to-page within www.myswft.com. If you elect not to receive cookies, you may be able to view some, but not all, of the content on this Website.

(b) Internet Protocol (IP) Addresses:

This site uses Internet protocol (IP) addresses. IP addresses are unique identifiers automatically assigned to each computer when logging onto the Internet. IP addresses allow us to collect much of the same information we collect through cookies, including browser type, what pages you visit, and how long you stay on the site. In general, IP addresses allow us to identify problems with our servers, prepare aggregate demographic information and other information regarding this use of this site, and improve the functions of this site.

5.3 This site is not intended for use by children:

This site is not directed to, and does not seek to collect personally identifiable information from, children under the age of 13. Nevertheless, if we are informed that we have collected information from someone in this age category, we will take reasonable steps to delete that information.

 

6. What do we do with your information & transfer of data:

For the purposes of EU General Data Protection Regulation (GDPR), My Swft Ltd is the “data controller”

The personally identifiable information we collect from you will only be used and disclosed in accordance with this Privacy Policy or as specifically disclosed to you at the time you provide the information. We will not sell, lease, transfer, share, or otherwise permit access to your personally identifiable information with any third parties other than as described in this Privacy Policy. We reserve the right to sell, lease, transfer, or otherwise share without restriction aggregated, de-identified, and other non-personally identifiable information regarding website usage, sales, traffic patterns, demographics, and other statistics about our site or those from whom we collect information via www.myswft.com.

We reserve the right to use or disclose personal information provided via this site as necessary to respond to your requests and our contractual obligations to you, to comply with applicable laws, regulations, legal processes, and law enforcement inquiries, as required by litigation, to take precautions against liability, and protect the security and integrity of the Website and the safety of its users.  Your data will only be transferred overseas when it is necessary for us to fulfil our obligation to you, for example, to an overseas hotel that you are staying at or to an overseas activity provider, which you are using. Moreover, we will only send the data that is required for that third party to fulfill its obligation to you. 

We may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of the Website. The providers of such services may have access to certain personal Data provided by Users of this Website. Any Data used by such parties is used only to the extent required by them to perform the services that we request. Any use for other purposes is strictly prohibited.

Booking Enquiries:

When a user makes a booking enquiry, we collect personal information so we may contact them with a quotation. All enquiries are allocated to staff members internally in the company and your details are only used by members of staff that need to deal with the enquiry.

Hotel, Flight and Holiday Package Bookings:

When a customer books a hotel, flight or holiday package, personal information is used to process and manage all elements of the booking. Your personal information may be passed to third party suppliers of the booking components, some of which may be located outside of the UK.

Email Newsletters:

If you choose to subscribe to our email newsletter, your personal information is used to send targeted emails featuring relevant travel products and special offers. These details are not used for any other purpose and will not be shared with any third parties. You may unsubscribe from our newsletter at any point by following the relevant instructions on any of our emails.

Prize Draws:

If you enter a prize draw on our Website or a social media site, your personal information will be used to contact you if you win a prize. If you choose to subscribe to our email newsletter when you enter any prize draw, you will also receive regular emails featuring relevant travel products and special offers.

Online Surveys:

If you complete a survey on our Website, we will collect personal information and details of your user preferences and behaviour when shopping for travel products. All information will only be used for statistical purposes and your individual personal information will not be accessible in any survey results.

Job Applications:

Any personal information sent in response to a job application will only be used for recruitment purposes. We may contact you by telephone or email about any job application you make.

Retargeting:

When browsing our website, we collect information regarding which pages you have visited so that we can target you with adverts at a later time. This is done through a Google Display Network Remarketing campaign and means that third party vendors, including Google may show My Swft adverts across the internet. This can be opted out of at any time through your Google Ads settings.

Analytics:

We also collect demographic data from visitors to our website to help with our understanding of website users and customers. We also use this demographic information for internal reporting.

Cookies:

A cookie is a piece of text based information that a website transfers to your computer’s hard drive. When using selected services on our Website, we will use cookies to help recognise you and the bookings that you have made. If your browser is set to reject the use of cookies, you will be unable to use selected online services on our Website. In this situation, please contact our Customer Services department who will be able to access this booking information either by phone on +44(0) 2039 000 223 or by e-mail at hello@myswft.com.

Please find below a summary of the specific active information we collect, why we collect it and how we use this to deliver services to you: 

Name:
  • This is required for us to fulfill our contractual obligations to you as a customer
  • This is collected via our website and chat channels (WhatsApp and Facebook Messenger) and stored in our CRM system and our email marketing platform where relevant
Email address:
  • Customer correspondence and service emails relating to important information about your booking. Direct marketing where the customer has opted-in to receiving such communication 
  • This is collected via our website and chat channels (WhatsApp and Facebook Messenger) and stored in our CRM system and our email marketing platform where relevant. For the purpose of marketing related emails, your data will be processed in order to provide you with the most relevant and personalised information
Phone number:
  • Customer correspondence, including WhatsApp messages
  • This is collected via our website and chat channels (WhatsApp and Facebook Messenger) and stored in our CRM system. If you choose to communicate with us via WhatsApp, you have shown legitimate interest under the terms of GDPR
Facebook profile:
  • Customer correspondence and service messages via Facebook Messenger
  • If you choose to communicate with us via Facebook Messenger, you have shown legitimate interest under the terms of GDPR and your profile will be stored in our messenger account
Address:
  • This is required for payment processing and is kept to make future payments easier for you as a customer
  • This is collected via our website and is stored in our CRM system
Date of birth:
  • This is only requested when it is a booking requirement for one element of your holiday
  • This is collected via our website and chat channels (WhatsApp and Facebook Messenger) and may be stored in our CRM system
Passport information:
  • This is only requested when we are booking flights for you, the customer
  • This is collected via a form on our website or via chat channels (WhatsApp and Facebook Messenger)
Payment information:
  • This is collected to process payments
  • This is collected via our secure website but is automatically passed on to our third-party authorised payment processor, Worldpay Group Plc. We cannot see or access your payment information
 
7. Retention of data:
 
We retains information for seven (7) years from our point of last contact. We hold this information to support our legal and regulatory requirements. If you object to this retention, please contact us – details are provided in the ‘Contact’ section and there is more on opting-out and information access below. 
 

8. Opting out:

We do not seek to collect personally identifiable information from you that you do not want collected. To that end, we indicate at all active information collection points whether requested information is required or optional. We also attempt to tell you at the point of collection and in this Privacy Policy what the consequences will be (e.g. inability to access important functions of the Website, less tailoring of information to match your interests, etc.) if you do not provide the required or optional information. When you submit personally identifiable information via this Website, whether such information is required or optional, you consent to its disclosure and use in accordance with this Privacy Policy. If you ever decide that you do not wish to receive information from us regarding our products and services, you may opt out of receiving this information by contacting us by e-mail at hello@myswft.com (please write “unsubscribe” in the subject line), by post at My Swft, Kemp House, 160 City Road, London, EC1V 2NX, or by clicking on the clearly marked ‘unsubscribe’ button at the bottom of any My Swft email newsletter, or by typing “unsubscribe” in response to a Facebook Messenger broadcast message.

 

9. Information access:

We take reasonable steps to ensure that personally identifiable information that you send us via this Website is accurate, current, and complete. To that end, we provide you with reasonable access to your personal information to correct errors or delete the information you have provided. If you wish to correct or delete your personally identifiable information, please contact us by e-mail at hello@myswft.com or by post at My Swft, Kemp House, 160 City Road, London, EC1V 2NX.

To respond to your request or inquiry, we may require follow-up or contact information to allow us to verify that you are the person authorized to view the information you are requesting. We may, at our discretion, refuse to allow you access to certain information if, in our view, to provide such access would jeopardize another person’s privacy; would violate any applicable federal, state, or foreign law, regulation, or directive; or would unreasonably burden this Website.

 

10. Data security:

All personal Data is stored securely in accordance with the principles of the EU General Data Protection Regulation (GDPR).

Although we take reasonable steps to protect the personally identifiable information that you provide via this Website, no system is 100% secure or error-free. Therefore, we do not, and cannot, guarantee the security or accuracy of the information we gather. Under GDPR, if a data breach is identified, it is mandatory that we notify the Information Commisioners Office (ICO) and the customer, where relevant.  

One way we protect your personally identifiable information is through usernames and passwords. This safety measure is only effective if you protect the secrecy of both your username and password. If you ever suspect your username or password may have been compromised or subject to unauthorized use, contact us immediately at by phone on +44(0) 2039 000 223 or by e-mail at hello@myswft.com

For your peace of mind, our site is protected by Thawte and all card payments are encrypted using the internationally accepted security system, SSL. We do not store any card details and all payments are processed by Worldpay Group plc.
 

11. Changes of business ownership and control:

My Swft Ltd may, from time to time, expand or reduce our business and this may involve the sale and/or the transfer of control of all or part of My Swft Ltd. Data provided by Users will, where it is relevant to any part of our business so transferred, be transferred along with that part and the new owner or newly controlling party will, under the terms of this Privacy Policy, be permitted to use the Data for the purposes for which it was originally supplied to us. We may also disclose Data to a prospective purchaser of our business or any part of it.

 

12. Contact details:
 
We recognise that you may have questions on how we process and/or store your data, or may want to change either the data we hold on you or how we communicate with you in the future. 
If you have given consent for processing, you are free to withdraw that consent. To let us know this is the case please email hello@myswft.com or see section 8 ‘Opting-out’ above. 
 
If you have any questions in respect of this policy, or would like to exercise your rights as a data subject (for example, to correct data or to exercise your right to access): 
  • My Swft Ltd, as data controller, can be contacted as follows: hello@myswft.com or 02039 000 223
  • Our Data Protection officer is Tom Pain, and he can be contacted as follows hello@myswft.com
  • If you are unhappy that we have responded to your query adequately, of if you have a further complaint, The Information Commissioner’s Office can be contacted on 0303 123 1113 or by live chat here: https://ico.org.uk/global/contact-us/
 

13. Changes to this policy:

We reserve the right to change this Privacy Policy at any time and in our sole discretion. If we do change the Privacy Policy, the new Privacy Policy will be posted here, along with its revision date so that you are always aware of what information we collect, how we use it, and under what circumstances we disclose it.

 

This policy was last revised on the 14th May 2018

 

 

ACCEPT COOKIESTo give you the best possible experience, this site uses cookies. Using this site means you agree to our use of cookies. We have published a cookies policy, which you should read to find out more about the cookies we use. View cookies policy.