Welcome to the SWAN website. This policy explains how we handle and use your personal information and your rights in relation to that information. Under data protection law, Swan Community is the controller of that information.
Swan Community (we, our or us) are committed to protecting and respecting your privacy.
This policy describes the way we handle and use the personal information that we obtain from all the different interactions you may have with us as a business, including when you visit our social media pages or website currently located at swan.community (Site) or when you contact us or take part in any of our competitions or promotions.
Swan Community is the controller in relation to the processing activities described below. This means that Swan Community decides why and how your personal information is processed. Please see the section at the end of this policy for our contact and legal information.
This policy was last updated on the date that appears at the top of this page.
2. Personal information we collect about you
We receive personal information about you that you give to us, that we collect from your visits to our Site and social media pages and that we obtain from other sources. We only collect personal information which we need and that is relevant for the purposes for which we intend to use it.
Personal information that you give to us
We collect the following information if you choose to give it to us when you visit our Site or social media pages or when exercising your legal rights:
your name, title and contact details (email address, telephone number, postal address, social media handle);
your job title and the name of the organisation for whom you work;
your communication preferences in relation to webinars;
any information you include in correspondence you send to us or in forms you submit to us when using our Site or social media pages; and
your identification information when exercising the rights that you have in relation to our processing of your personal information (see further Your rights in relation to your personal information).
Information that we collect about you
When you visit our Site we automatically collect:
- the internet protocol (IP) address of your device and details regarding the type of device and browser software you use to access the Site.
When you visit our social media pages we collect:
the information you post on those pages;
information regarding your interactions with the content we post; and
statistical information regarding all our followers’ activities (but from which we cannot identify you as we only have access to this information in aggregated form).
3. Use of your personal information
We use your personal information for a variety of reasons. We rely on different legal grounds to process your personal information, depending on the purposes of our use and the risks to your privacy.
We use your personal information in the following ways:
Where necessary to comply with our LEGAL OBLIGATIONS
We will use your personal information to comply with our legal obligations:
to keep a record relating the exercise of any of your rights relating to our processing of your personal information; and
to handle and resolve any complaints we receive relating to the services we provide.
Where necessary for us to pursue a LEGITIMATE INTEREST
We may use and process your personal information where it is necessary for us to pursue our legitimate interests as a business for the following purposes:
Processing necessary for us to promote our organisation and network and measure the reach and effectiveness of our campaigns
for analysis and insight conducted to inform our strategies, and to enhance and your visitor experience;
to send webinar alerts to you by email if you have asked us to send these to you.
Processing necessary for us to support our visitors with their enquiries
to respond to correspondence you send to us and fulfil the requests you make to us.
Processing necessary for us to operate the administrative and technical aspects of our business efficiently and effectively
to administer our Site and our social media pages and for internal operations, including troubleshooting, testing, statistical purposes;
for the prevention of fraud and other criminal activities;
to verify the accuracy of data that we hold about you and create a better understanding of you as an account holder or visitor;
for network and information security in order for us to take steps to protect your information against loss or damage, theft or unauthorised access;
to comply with a request from you in connection with the exercise of your request);
for the purposes of corporate restructure or reorganisation or sale of our business or assets;
for efficiency, accuracy or other improvements of our databases and systems, for example, by combining systems or consolidating records we hold about you;
to enforce or protect our contractual or other legal rights or to bring or defend legal proceedings;
to inform you of updates to our terms and conditions and policies; and
for other general administration including managing your queries, complaints, or claims, and to send service messages to you.
4. Disclosure of your personal information by us
We only disclose your personal information outside our business in limited circumstances. If we do, we will put in place a contract that requires recipients to protect your personal information, unless we are legally required to share that information. Any contractors or recipients that work for us will be obliged to follow our instructions. We do not sell your personal information to third parties.
We may disclose your information to our third party service providers, agents and subcontractors (Suppliers) for the purposes of providing services to us or directly to you on our behalf, including the operation and maintenance of our Site and social media pages. Our Suppliers can be categorised as follows:
|Recipient / relationship to us||Industry sector and sub-sector|
|Advertising, PR, digital and creative agencies||Media (Advertising & PR)|
|Cloud software system providers, including database, email and document management providers||IT (Cloud Services)|
|Facilities and technology service providers including scanning and data destruction providers||IT (Data Management)|
|Social media platforms||Media (Social Media)|
|Legal, security and other professional advisers and consultants||Professional Services (Legal & Accounting)|
|Website and App developers||IT (Software Development)|
|Website hosting services providers||IT (Hosting)|
When we use Suppliers, we only disclose to them any personal information that is necessary for them to provide their services and only where we have a contract in place that requires them to keep your information safe and secure.
We may disclose the personal information to other third parties as follows:
social media platforms with whom we work (see further Our use of social media);
any third party who is restructuring, selling or acquiring some or all of our business or assets or otherwise in the event of a merger, re-organisation or similar event; and
if we are under a duty to disclose or share your information in order to comply with any legal or regulatory obligation or request, including by the police, courts, tribunals or regulators.
5. Our use of social media
We use social media platforms in a variety of different ways, including by publishing pages through which you can interact, running competitions or advertising to you using information you have provide those platforms or which has been provided by us or collected from this Site. Our legal relationship with each platform will vary with the particular way we are using that platform.
We process your personal information using social media platforms in a variety of ways, as follows:
Pages. We use your personal information when you post content or otherwise interact with us on our official pages on Facebook, LinkedIn and other social media platforms. We also use the Page Insights service for Facebook and LinkedIn to view statistical information and reports regarding your interactions with the pages we administer on those platforms and their content. Where those interactions are recorded and form part of the information we access through the Page Insights services, we and the relevant platform are joint controllers of the processing necessary to provide that service to us.
Our relationship with Facebook and LinkedIn. As we are joint controllers with these platforms for certain processing, we and each platform have:
entered into agreements in which we have agreed each of our data protection responsibilities for the processing of your personal information described above;
agreed that we are responsible for providing to you the information in this privacy statement about our relationship with each platform; and
agreed that each platform is responsible for responding to you when you exercise your rights under data protection law in relation to that platform’s processing of your personal information as a joint controller.
Further information. The Facebook company that is a joint controller of your personal information is Facebook Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. The LinkedIn company that is a joint controller of your personal information is LinkedIn Ireland Unlimited Company, Wilton Place, Dublin 2, Ireland. For further information regarding these platforms and their use of your personal information, please see:
Facebook’s Controller Addendum for Page Insights and Controller Addendum for Business Tools and LinkedIn’s Page Insights Joint Controller Addendum which include information regarding how our and those platforms’ responsibilities to you are allocated as controllers of your personal information;
LinkedIn’s help pages regarding its Page Insights.
6. Transfers of your personal information outside of Europe
Except in a limited number of cases, we do not transfer your personal information outside of Europe. Where we do, we take measures to protect your personal information.
Some of the information you provide to us may be transferred to countries outside the UK and European Economic Area (EEA). These countries may not have similar data protection laws to the UK and EEA. Countries outside these locations to which we transfer your personal information are listed in the table under Disclosure of your personal information by us.
Where we transfer your information outside of the UK and EEA in this way, we take steps to ensure that appropriate security measures are taken with the aim of ensuring that your privacy rights continue to be protected in the ways required by data protection law as outlined in this policy. These steps include imposing contractual obligations on the recipient of your personal information. Please contact us using the details at the end of this policy for more information about the protections that we put in place and to obtain a copy or access to the relevant documents.
If you use our services whilst you are outside the UK and EEA, your information may be transferred outside the UK and EEA in order to provide you with those services.
7. Security and links to other websites
We take the security of your personal information seriously and use a variety of measures based on good industry practice to keep it secure. Nonetheless, transmissions over the internet and to our Site may not be completely secure, so please exercise caution. When accessing links to other websites, their privacy policies, not ours, will apply to your personal information.
We employ security measures to protect the personal information you provide to us, to prevent access by unauthorised persons and unlawful processing, accidental loss, destruction and damage. When we have provided (or you have chosen) a password allowing you access to certain parts of the Site, you are responsible for safeguarding it and keeping it confidential and you promise not to allow it to be used by third parties. Unfortunately, the transmission of information via the internet is not completely secure. Although we will do everything possible to protect your personal information, we cannot guarantee the security of any personal information during its transmission to us online. You accept the inherent security implications of using the internet and will not hold us responsible for any breach of security unless we are at fault.
In addition, if you linked to our Site from a third party website, we cannot be responsible for the privacy policies and practices of the owners and operators of that third party website and recommend that you check the policy of that third party website.
8. The periods for which we retain your personal information
We will not hold your personal information in an identifiable format for any longer than is necessary for the purposes for which we collected it. For certain purposes we retain your personal information for a very short period (e.g. your IP address) whilst for others we retain it for a longer period once it is no longer required for business reasons so that we can deal with any legal proceedings that could arise.
We retain your personal information for the following periods:
|Type of personal information||When do we receive your personal information?||How long do we keep your personal information after we receive it?|
|Details regarding when you have subscribed to receive webinar alerts||When you complete the relevant form||2 years from the date you complete the form.|
|Social media handles||When you follow our social media account or page||Until you stop following our social media account or page.|
|Information included in any correspondence between us||When we receive the correspondence||1 year, but up to 10 years to bring, establish or defend legal claims.|
|Your identification information in relation to the processing of your personal information||When we receive a submitted loyalty application or voucher redemption from you||3 years|
|IP addresses and type of device||When you use any of our websites or apps||1 month from the date of collection.|
The only exceptions to the periods mentioned above are where:
you exercise your right to have the information erased (where it applies) and we do not need to hold it in connection with any of the reasons permitted or required under the law (see further Your rights in relation to your personal information);
you exercise your right to require us to retain your personal information for a period longer than our stated retention period (see further Your rights in relation to your personal information);
we bring or defend a legal claim or other proceedings during the period we retain your personal information, in which case we will retain your personal information until those proceedings have concluded and no further appeals are possible;
in limited cases, existing or future law or a court or regulator requires us to keep your personal information for a longer or shorter period.
9. Your rights in relation to your personal information
You have a number of rights in relation to your personal information under data protection law. In relation to certain rights, we may ask you for information to verify your identity and, where applicable, to help us to search for your personal information. Except in rare cases, we will respond to you within 1 month after we have received this information or, where no such information is required, after we have received full details of your request.
You have the following rights, some of which may only apply in certain circumstances:
to be informed about the processing of your personal information (this is what this statement sets out to do);
to have your personal information corrected if it is inaccurate and to have incomplete personal information completed;
to object to processing of your personal information;
to withdraw your consent to processing your personal information;
to restrict processing of your personal information;
to have your personal information erased;
to request access to your personal information and information about how we process it;
to electronically move, copy or transfer your personal information in a standard, machine-readable form; and
rights relating to automated decision making, including profiling.
To find out more about each of your rights, please click the ✓ icon next to each right above. To exercise these rights, please contact us using the details at the end of this policy.
You have the right to lodge a complaint with the UK data protection regulator. The contact details for the Information Commissioner’s Office (ICO), the data protection regulator in the UK, are available on the ICO website, where your personal information has or is being used in a way that you believe does not comply with data, however, we encourage you to contact us before making any complaint and we will seek to resolve any issues or concerns you may have.
Please check this page regularly for changes to this policy. We will email you with changes if we hold a valid email address for you.
We may review this policy from time to time and any changes will be notified to you by posting an updated version on our Site and/or by contacting you by email. Any changes will take effect 7 days after we post the modified terms on our Site or after the date we notify you by email. We recommend you regularly check this page for changes and review this policy each time you visit our Site.
11. Contact and legal information
You can contact us with your queries in relation to this policy or for any other reason by post, email or by phone.
To contact us in relation to this policy, including to exercise any of your rights in relation to your personal information, please contact our General Manager by post at c/o 51Degrees.mobi Ltd, 9 Greyfriars Road, Reading, Berkshire, RG1 1NU, ENGLAND or by email at contact at swan.community.
For anything else, including general enquiries, please contact us by post c/o 51Degrees.mobi Ltd, 9 Greyfriars Road, Reading, Berkshire, RG1 1NU, ENGLAND, or by email at contact at swan.community.
Swan Community’s company registration number is not yet available and registered office address is to be confimed.