My Swft Privacy Policy

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.

 

Our Apps (the My Swft mobile phone application available on Apple App Store and Google Play Store) and Website (www.myswft.com) provide a wide range of information to our visitors. Like many apps and websites, we also collect information from our visitors, including personally identifiable information (including full name, email address, phone number) and non-personally identifiable information (e.g. aggregate statistics about what parts of our Apps and Website are the most popular). This Privacy Policy is designed to tell you about our information collection practices at – 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 our Apps or Website, and particularly before submitting personally identifiable information via our Apps or Website, you should read this entire policy. Use of our Apps or 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 either our Apps or our Website.

 

This privacy policy applies between you, the User of our Apps or Website and My Swft Ltd, the owner and provider of the Apps and the 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 iOS Application, Android Application, 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

 

Apps: our iOS and Android mobile phone applications named My Swft, whether downloaded from Apple App Store or Google Play Store

 

Website: 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 Policy:

 

This Privacy Policy applies only to the actions of My Swft Ltd and Users with respect to our Apps and Website. It does not extend to any applications or websites that can be accessed from our Apps or Website including, but not limited to, any links we may provide to social media websites or other travel booking sites. 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 websites.

 

 

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:

1. You consider it inaccurate or incomplete

2. Where you object to processing and we are considering whether we still have a legitimate interest to process it

3. 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:

1. direct marketing (including profiling); and

2. 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:

1. give you information about the processing

2. introduce simple ways for you to request human intervention or challenge a decision

3. 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:


When you use our Apps or Website, you send pieces of data to My Swft; this can be a name, an email address, information relating to your holiday, or the holiday that you are planning. Other data is generated implicitly by your use of our Apps or Website, e.g. log data. We use this information for internal analytical purposes to improve our products for you. Furthermore we employ other companies to perform tasks on our behalf and may need to share this information with them to provide services to you.

 

5.1 Active information collection

 

Our Apps and Website collect information from 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 email 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 our Apps, Website, our products or services, you must provide us with an email address or mobile phone number if you have agreed to WhatsApp notifications. 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.

 

If you want to create a user-account either on our Apps or Website, it will be protected by passwords. You should choose a secure password and ensure its confidentiality to prevent unauthorized access to your account.

 

Social Login


My Swft employs third party tools to provide you with the convenience you are used to from elsewhere on the internet to sign in to our Apps and Website with one click (so called “social login”). Some of these tools can track your actions when you interact with them. At My Swft you can sign in with Google, Facebook or your email and password. Please refer to the terms of the respective providers for further guidance:

 

Google https://policies.google.com/privacy

Facebook https://www.facebook.com/policy

 

(b) Feedback Information

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

 

My Swft also uses Feefo for collection of feedback information. Any information you submit to Feefo will be submitted on the Feefo website and will be subject to their terms: https://www.feefo.com/business/gb_en/privacy-policy

 

5.2 Passive information collection

 

We may use third party software to passively collect information while you are visiting our Apps or Website (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 device and operating system you use, the date and time of your visit to our Apps or Website, the specific pages you visit, and the address of the web site you visited prior to entering our Apps or Website. 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 Apps and Website and we reserve the right to share the anonymous aggregated information that we have passively collected via this our Apps and Website with third parties, including our business partners and advertisers,

My Swft uses Google Analytics, Google Firebase Analytics (for iOS and Android applications), and Hotjar to compile usage statistics. These services are provided by Google, Inc. and Hotjar Limited, respectively. Their terms can be found here http://www.google.com/privacy, https://firebase.google.com/terms/analytics, and https://www.hotjar.com/legal/policies/privacy.

My Swft also uses Dashbot to compile anonymised usage and behavioural statistics on conversations held in WhatsApp and Messenger. This service is provided by Dashbot Inc. Their term can be found here: https://www.dashbot.io/legal/privacy/

 

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

 

(a) Cookies

Our Website 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). Our 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 our 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 Our Apps and Website are not intended for use by children

 

Our Apps and Website are not directed to, and do 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 we do with your information & transfer of data:

 

For the purposes of the 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 usage of our Apps, Website usage, sales, traffic patterns, demographics, and other statistics about our users or those from whom we collect information via our Apps or Website.

 

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. We are entitled to transfer your Personal Data overseas, including to third party companies (designated service providers) insofar as this is expedient for the Data Processing described in this Privacy Policy. The recipients will be obliged to protect Your Data to the same extent as ourselves.
 

We may, from time to time, employ the services of other parties for dealing with certain processes necessary for the operation of our Apps and Website. The providers of such services may have access to certain personal Data provided by Users of our Apps or 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.


Communication between you and My Swft

If you send My Swft a message via any channel, including WhatsApp, Facebook Messenger and email, this message can be stored to process it, to compile statistical information, to improve our services and support, or to get in touch with you.

 

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 Apps or 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 Apps or 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 Apps and Website to help with our understanding of App and 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.

Payment information

My Swft uses a third-party authorised payment processor, Worldpay Group Plc, to process payments. Your payment information is collected via our secure Website but is automatically passed on to Worldpay Group Plc for processing. You can find their terms here: https://www.worldpay.com/uk/worldpay-privacy-notice. We do not store any debit card or credit card information.

 

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

 

Information we collect

Why we collect this

How we process this

Name

This is required for us to fulfill our contractual obligations to you as a customer

This is collected via our Apps, Website and chat channels (WhatsApp and Facebook Messenger) and stored in our CRM system, our email marketing platform where relevant, and our App database

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

For email & password login credentials for our Apps and Website

This is collected via our Apps, Website and chat channels (WhatsApp and Facebook Messenger) and stored in our CRM system, our email marketing platform where relevant, and our App database

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 conversational messages and WhatsApp notifications from our Apps

This is collected via our Apps, website and chat channels (WhatsApp and Facebook Messenger) and stored in our CRM system and our App databases. 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

It is also collected when you input your passport information as outlined below

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 requested when we are booking flights for you, the customer.

It is also requested on our Apps when the group leader requests such details from the group members

For flight bookings, this is collected via a form on our website or via chat channels (WhatsApp and Facebook Messenger)

It is also requested on our App and stored in our App database

Dietary requirements and allergies

This is requested when we are booking catered accommodation for you, the customer.

It is also requested on our Apps when the group leader requests such details from the group members

For catered accommodation bookings, this is collected via a form on our website or via chat channels (WhatsApp and Facebook Messenger)

It is also requested on our App and stored in our App database

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

Current location

This is requested in Messenger to make recommendations that are local to you

This is collected via the share your location function or via text input in Messenger and is stored as either latitude and longitude or as the location name on our Google Cloud Platform servers.


 

7. Data specific to the My Swft Apps


Trip access code

To access a trip on our Apps, you use the unique link which My Swft provides and which contains a random access code. This link is an important element to prevent unauthorized access to a trip. You should send this link only to authorized people, i.e., the people you wish to participate in your trip.

 

Inviting from one of our Apps

As an option, you can contact and invite people to participate in a trip from our Apps. In this case, My Swft needs to know the email addresses of the people to be contacted. You can enter these email addresses in the corresponding form. My Swft stores these email addresses in your trip for your convenience so that you can see who has been invited. You can have My Swft delete all stored email addresses along with other data at any time. Please see section 11 in this Privacy Policy
 

Like all other personal information, My Swft will not share participants’ email addresses with third parties without consent and we will not send any email communication to participants’ email addresses without lawful grounds to do so.

 

Contacts integration

Alternatively, you can use your existing Google, Android phone, or iPhone phone contacts to gain access to the email addresses of the people to be contacted. In this case, you authorize My Swft to access your Google contacts, iPhone phone contacts or Android phone contacts. Your Google contacts will still be stored at Google. Please note also: The process of accessing your Google contacts is set up (thanks to OAuth) to make sure that My Swft at no time has access to your Google password.


 

8. Location of your data

 

All data collected and processed on our Website is stored on servers hosted by Rackspace Hosting group within the EU. You can find their terms here: https://www.rackspace.com/information/legal/privacystatement

All data collected and processed on our Apps is stored on servers hosted by DigitalOcean, LLC within the EU. You can find their terms here: https://www.digitalocean.com/legal/privacy-policy/


If you have requested location aware recommendations in Messenger, your Facebook profile information and location information are stored in Google Firestore via Google Cloud Platform within the EU. You can find their terms here: https://cloud.google.com/security/gdpr/
 

 

9.   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.
 

Inactive accounts

My Swft reserves the right to delete user-accounts and associated personal data and trip data, including trips planned on our Apps, if they remain inactive (i.e. not accessed) for 1 year or longer.


 

10.   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 Apps or 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 email at hello@myswft.com (please write “unsubscribe” in the subject line), by post at My Swft, Kemp House, 160 City Road, London, EC1V 2NX, by clicking on the clearly marked ‘unsubscribe’ button at the bottom of any My Swft email newsletter, by typing “unsubscribe” in response to a Facebook Messenger broadcast message, or by typing “stop” in response to a WhatsApp broadcast message.

 

 

11.   Information access:

 

We take reasonable steps to ensure that personally identifiable information that you send us via our Apps, Website and communication channels such as WhatsApp, Facebook Messenger and email 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 enclosing appropriate proof of your identity.

 

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 reserve the right to exchange correspondence with you in this regard. 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 My Swft Ltd.

 

Please note that we may be required to retain your Personal Data in part even after a request for blocking or cancellation under the terms of our statutory or contractual retention requirements (such as for accounting purposes) and in such an eventuality will only block your Personal Data insofar as necessary for this purpose. In addition, the cancellation of your Personal Data may have the effect that you are no longer able to acquire or use the services registered by you. Under certain circumstances, you have the right to require us to provide you or a third party specified by you with your personal data in a commonly used format.

 

 

12.   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 Website 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.

 

 

13.   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.

 

 

14.   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):

1. My Swft Ltd, as data controller, can be contacted as follows: hello@myswft.com or 02039 000 223

2. Our Data Protection officer is Tom Pain, and he can be contacted as follows hello@myswft.com

3. 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/

 

 

15.   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 24th May 2019

 

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