Last updated: August 2023
You are not legally required to provide us with any Personal Data (as defined in Section 1), and may do so (or avoid doing so) at your own free will.
If you do not wish to provide us with such Personal Data, or to have it processed by us or any of our Service Providers (as defined in Section 5), please simply do not enter our Sites or use our Service. You may also choose not to provide us with “optional” Personal Data, but please keep in mind that without it we may not be able to provide you with the full range of our services or with the best user experience when using our Service.
1.1 We collect various types of personal data regarding our Users as well as data regarding Visitors to our Sites. Such data is typically collected and generated through your interaction with us or our Service, through automatic means, or directly from you, from other Users, from our customers, or from other third parties (including Service Providers, as defined in Section 5).
1.2 Specifically, we collect the following categories of data (which, to the extent it relates to an identified or identifiable individual, is deemed as “Personal Data“):
1.2.1 User Data received from you: When you contact us or sign up to the Service and create your individual profile (“User Profile”), you may provide us with Personal Data. This includes your name, workplace, contact details (such as e-mail, phone and address), account login details (e-mail address and passwords which are automatically hashed), as well as any other data you choose to provide when you use our Service, contact us, or interact with others via our Service. If you choose to sign up or login using your Google or Microsoft account, we will receive these and other details you might have listed there. Once you are logged in to our Service, you (or your organisation’s Admin) may also submit various additional details (collectively, “User Data”).
1.2.2 Data automatically collected or generated: When you visit, interact with, or use our Service, we may collect, record or generate certain technical data about you. We do so either independently or with the help of third party Service Providers, including through the use of “cookies” and other tracking technologies (as detailed in Section 6 below). Such data consists of connectivity, technical and aggregated usage data, such as IP addresses and general locations, device and application data (like type, operating system, mobile device id, browser version, locale and language settings used), date and time stamps of usage, the cookies and pixels installed or utilised on such device and the recorded activity (sessions, clicks and other interactions) of Visitors and Users in connection with our Service. In addition, phone calls (e.g. with our customer success or product consultants) may be automatically recorded, tracked and analysed, for purposes including analytics, service-, operations-, and business quality control and improvements, and record-keeping purposes.
1.2.3 User Data received from our customers and Users: Our customers and Users may provide us with the contact details of their employees, team members and colleagues, in order for us to contact, invite or subscribe them as Users to our Service. Such data typically includes these individuals’ names and work e-mails.
1.2.4 Data received from other third parties: We may receive Personal Data concerning you from other sources. For example, if you participate in an event, webinar or promotion that we sponsor or participate in, we may receive your Personal Data from its organisers. We may also receive your contact and professional details (e.g., your name, company, position, contact details and professional experience, preferences and interests) from our business partners or Service providers, and through the use of tools and channels commonly used for connecting between companies and individuals in order to explore potential business and employment opportunities, such as LinkedIn and other data sources.
1.2.5 Data concerning service integrations: If, when using the Service, you or your Admin choose to integrate your organisation’s Service account with a third-party service (and such service is supported by our Service as detailed in our Site), we will connect and integrate that third-party service to ours. The third-party provider of this integration may receive certain relevant data about or from your organisation’s account (including User Data), or share certain relevant data from your account on their service with our Service, depending on the nature and purpose of such integration. Note that we do not receive or store your passwords for any of these third-party services (but we instead usually store a secure token or sometimes require your API key in order to integrate with them). If you do not wish your data to be shared with such third-party service(s), please contact your Admin.
1.2.6 Data obtained through Analytics Tools: We use analytics tools (e.g. Google Analytics) to collect data about the use of our Sites and Service. Analytics tools collect data such as how often Users and Visitors visit or use the Sites or Service, which pages they visit and when, and which website, ad or e-mail message brought them there.
2.1 We use Personal Data as necessary for the performance of our Service; to comply with our legal and contractual obligations; and to support our legitimate interests in maintaining and improving our Service, e.g. in understanding how our Service are used and how our campaigns are performing, and gaining insights which help us dedicate our resources and efforts more efficiently; in marketing, advertising and selling our Service to you and others; providing customer service and technical support; and protecting and securing our Users, customers, Visitors, ourselves and our Service.
2.2 Specifically, we use Personal Data for the following purposes:
2.2.1 To facilitate, operate, and provide our Service;
2.2.2 To authenticate the identity of our Users, and to allow them access to our Service;
2.2.3 To provide our Visitors, Users and customers with assistance and support;
2.2.4 To gain a better understanding on how Visitors and Users evaluate, use and interact with our Service, and how we could improve their and others’ user experience, and continue improving our products, offerings and the overall performance of our Service;
2.2.5 To facilitate and optimise our marketing campaigns, ad management and sales operations, and to manage and deliver advertisements for our products and services more effectively, including on other websites and applications. Such activities allow us to highlight the benefits of using our Service, and thereby to increase your engagement and overall satisfaction with our Service. This includes contextual, behavioural and interests-based advertising based on the Visitor’s or User’s activity, preferences or other data available to us or to our business partners;
2.2.6 To contact our Visitors, Users and customers (whether existing or prospective) with general or personalised service-related messages, as well as promotional messages that may be of specific interest to them (as further described in Section 6 below);
2.2.7 To facilitate, sponsor and offer certain events, contests and promotions;
2.2.8 To publish your feedback, user story and submissions in our public forums and blogs;
2.2.9 To support and enhance our data security measures, including for the purposes of preventing and mitigating the risks of fraud, error or any illegal or prohibited activity;
2.2.10 To create aggregated statistical data, inferred non-personal data or anonymised or pseudonymised data (rendered non-personal), which we or our business partners may use to provide and improve our respective services, or for any other purpose; and
2.2.11 To comply with applicable laws and regulations.
2.4 We do not sell your personal information.
3.1 Your Personal Data is maintained, processed and stored by us and our authorised Service Providers in the UK. We may also retain your Personal Data in other locations as reasonably necessary for the proper performance and delivery of our Service, or as may be required by law.
3.2 Swallow is headquartered in the United Kingdom, a jurisdiction which is considered by the European Commission to be offering an adequate level of protection for the Personal Data of EU Member State residents.
4.1 We will retain your Personal Data for as long as it is reasonably necessary in order to maintain and expand our relationship and provide you with our Service and offerings; in order to comply with our legal and contractual obligations; or to protect ourselves from any potential disputes (i.e. as required by laws applicable to log-keeping, records and bookkeeping, and in order to have proof and evidence concerning our relationship, should any legal issues arise following your discontinuance of use), all in accordance with our data retention policy.
4.2 Please note that except as required by applicable law or our specific agreements with you, we will not be obligated to retain your Personal Data for any particular period, and we are free to securely delete, anonymise or restrict access to it for any reason and at any time, with or without notice to you.
5.1 Legal compliance
5.1.1 In exceptional circumstances, we may disclose or allow government and law enforcement officials access to your Personal Data, in response to a subpoena, search warrant or court order (or similar requirement), or in compliance with applicable laws and regulations.
5.1.2 Such disclosure or access may occur if we believe in good faith that: (a) we are legally compelled to do so; (b) disclosure is appropriate in connection with efforts to investigate, prevent, or take action regarding actual or suspected illegal activity, fraud, or other wrongdoing; or (c) such disclosure is required to protect the security or integrity of our products and services.
5.2 Service providers
5.2.1 We may engage selected third-party companies and individuals to perform services complementary to our own. Such service providers include hosting and server co-location services, communications and content delivery networks (CDNs), data and cyber security services, billing and payment processing services, fraud detection and prevention services, web analytics, e-mail distribution, marketing and monitoring services, session or activity recording services, remote access services, data optimisation and enrichment services, social and advertising networks, content providers, e-mail, voicemails, support and customer relation management systems, and our legal, compliance and financial advisors (collectively, “Service Providers“).
5.2.2 These Service Providers may have access to your Personal Data, depending on each of their specific roles and purposes in facilitating and enhancing our Service, and may only use it for such limited purposes as determined in our agreements with them.
5.2.3 Our Service Providers shall be deemed as ‘data processor’ in circumstances where Swallow assumes the role of ‘data controller’; and where Swallow acts as the ‘data processor’ for our customer, the Service Provider shall be deemed our ‘sub-processor’ (as further explained in Section 10).
5.3 Sharing personal data with our customers and their users
5.3.1 We may share your Personal Data with the customer owning the account to which you are subscribed as a User (including data and communications concerning your User Profile). In such cases, sharing such data means that the account’s Admin(s) may access it on behalf of the customer, and will be able to monitor, process and analyse your Personal Data.
5.3.2 Your public User Profile will also be made available to other Users on the same account.
5.4 Sharing your feedback or recommendations
5.4.1 If you submit a public review or feedback, note that we may (at our discretion) store and present your review to other users of our Sites and Service (including other customers). If you wish to remove your public review, please contact us at email@example.com.
5.4.2 If you choose to send others an e-mail or message inviting them to use the Service, we will use the contact information you provide us to automatically send such invitation e-mail or message on your behalf. Your name and e-mail address may be included in the invitation e-mail or message.
5.5 Protecting rights and safety
5.5.1 We may share your Personal Data with others if we believe in good faith that this will help protect the rights, property or personal safety of Swallow, any of our Users or customers, or any members of the general public.
5.6 Swallow subsidiaries and affiliated companies
5.6.2 If we believe that such change in control might materially affect your Personal Data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Service.
5.6.3 For the avoidance of doubt, Swallow may share your Personal Data in additional manners, pursuant to your explicit approval, or if we are legally obligated to do so, or if we have successfully rendered such data non-personal and anonymous. We may transfer, share or otherwise use non-personal data at our sole discretion and without the need for further approval.
6.1 Our Sites and Service (including some of our Service Providers) utilise “cookies”, anonymous identifiers, pixels, container tags and other technologies in order for us to provide our Service and ensure that it performs properly, to analyse our performance and marketing activities, and to personalise your experience.
7.1 Service communications
7.1.1 We may contact you with important information regarding our Service. For example, we may send you notifications (through any of the means available to us) of changes or updates to our Service, billing issues, service changes, log-in attempts or password reset notices, etc.
7.2.2 Our customers, and other Users on the same account, may also send you notifications, messages and other updates regarding their or your use of the Service.
7.2.3 You can control your communications and notifications settings from your User Profile settings. However, please note that you will not be able to opt-out of receiving certain service communications which are integral to your use (like password resets or billing notices).
7.2 Promotional communications
7.2.1 We may also notify you about new features, additional offerings, events and special opportunities or any other information we think our Users will find valuable. We may provide such notices through any of the contact means available to us (e.g. phone, mobile or e-mail), through the Service, or through our marketing campaigns on any other sites or platforms.
7.2.2 If you do not wish to receive such promotional communications, you may notify Swallow at any time by sending an e-mail to firstname.lastname@example.org, changing your communications preferences in your User Profile settings, or by following the “unsubscribe”, “stop”, “opt-out” or “change e-mail preferences” instructions contained in the promotional communications you receive.
8.1 In order to protect your Personal Data held with us, we are using industry-standard physical, procedural and technical security measures, including encryption as appropriate.
8.2 Please be aware that regardless of any security measures used, we cannot and do not guarantee the absolute protection and security of any Personal Data stored with us or with any third parties as described in Section 5 above.
9.1 If you wish to exercise your rights under any applicable law, including the EU General Data Protection Regulation (GDPR) such as the right to request access to, and rectification or erasure of your Personal Data held with Swallow, or to restrict or object to such Personal Data’s processing, or to port such Personal Data, or the right to equal services and prices (each to the extent available to you under the laws which apply to you) – please contact us by e-mail at email@example.com.
9.2 Please note that once you contact us by e-mail, we may instruct you on how to fulfil your request independently through your User Profile settings; or may require additional information and documents, including certain Personal Data, in order to authenticate and validate your identity and to process your request. Such additional data will be then retained by us for legal purposes (e.g. as proof of the identity of the person submitting the request), in accordance with Section 4 above.
9.3 If you would like to make any requests or queries regarding Personal Data we process on your organisation’s (our customer’s) behalf, please contact your organisation’s Admin directly (as your organisation is the ‘data controller’ of such data – as further explained in Section 10).
10.1 Certain data protection laws and regulations, such as the GDPR, typically distinguish between two main roles for parties processing Personal Data: the ‘data controller’, who determines the purposes and means of processing; and the ‘data processor’, who processes the data on behalf of the ‘data controller’. Below we explain how these roles apply to our Service, to the extent that such laws and regulations apply.
10.3 If any of our Users upload or submit to the Service Personal Data which relates to other individuals, such data will only be processed by Swallow on behalf of our customer, which is the owner of the respective account, along with all other User Data processed on such customer’s behalf.
10.4 In such instances, our customer shall be deemed the ‘data controller’ of such data, and Swallow will process such data on the customer’s behalf, as its ‘data processor’, in accordance with its reasonable instructions, subject to our Terms, any Data Processing Agreement with such customer (to the extent applicable) and other commercial agreements. Swallow’s Service Providers shall act as designated ‘sub-processors’ in these instances. Swallow’s customer will be responsible for meeting any legal requirements applicable to ‘data controllers’ (such as establishing a legal basis for processing and responding to Data Subject Rights requests concerning the data they control).
10.5 If you would like to make any requests or queries regarding personal data we process as a ‘data processor’ on our Customer’s behalf, including accessing, correcting or deleting your data, please contact your Admin directly.
11.3 Children under the age of 16: We do not knowingly collect Personal Data from children and do not wish to do so. If we learn that a person under the age of 16 is using the Service, we will attempt to prohibit and block such use and will make our best efforts to promptly delete any Personal Data stored with us with regard to such child. If you believe that we might have any such data, please contact us by e-mail at firstname.lastname@example.org.
11.3 Representatives: Swallow has designated representatives for data protection matters (Callum Rimmer). Inquiries regarding our EU & UK privacy practices may be sent by e-mail to email@example.com or via mail as follows:
Llow Group Ltd
Arquen House, 4-6 Spicer Street
St Albans AL3 4PQ