Effective date: 25-01-2023
Introduction
Hello and welcome to mysweetdate’s privacy policy (“Privacy Policy”).
We keep our Privacy Policy under regular review. Historic versions can be obtained by contacting us.
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your
personal data changes during your relationship with us, for example a new address or email address.
We offer our services in different countries. As a result, you understand and accept that the information in your
user
profile will be visible to members in all of these countries.
Currently we offer services in the United Kingdom. We will update our Privacy Policy should we
make any changes to the counties where we offer our services.
Our Website uses cookies. You have control over your cookie settings and can manage preferences via your browser.
Our cookies policy details the types of cookies we use and their purposes, ensuring transparency in our tracking
practices.
- 1. WHO WE ARE (paragraph 1)
- 2. TYPES OF PERSONAL DATA WE COLLECT ABOUT YOU (paragraph 2)
- 3. HOW IS YOUR PERSONAL DATA COLLECTED? (paragraph 3)
- 4. HOW WE USE YOUR PERSONAL DATA (paragraph 4)
- 5. INTERNATIONAL TRANSFERS (paragraph 5)
- 6. DATA SECURITY (paragraph 6)
- 7. DATA RETENTION (paragraph 7)
- 8. YOUR LEGAL RIGHTS (paragraph 8)
- 9. CONTACT DETAILS (paragraph 9)
- 10. COMPLAINTS (paragraph 10)
- 11. THIRD PARTY LINKS (paragraph 11)
1. Who we are and application of this Privacy Policy
Privacy policy
This Privacy Policy applies to this website or other services that we provide and gives you information about how
Swiftanon Limited collects and uses your personal data through your use of this website, including any data you may
provide when you register with us or purchase a product or service.
This website is not intended for children and we do not knowingly collect data relating to children.
Data Controller
Swiftanon Limited is the controller and responsible for your personal data (referred to as “Company”, "we", "us" or
"our" in this Privacy Policy).
If you have any questions about this Privacy Policy, including any requests to exercise your legal rights (paragraph
8),
please contact us using the information set out in the contact details section (paragraph 9).
2. The types of personal data we collect about you
Personal data means any information about an individual from which that person can be identified.
We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as
follows:
- Identity Data includes first name, last name, any previous names, username
or similar identifier, marital status, title,
date of birth, gender and photographs.
- Contact Data includes billing address, delivery address, email address and
telephone numbers.
- Financial Data includes bank account and payment card details.
- Transaction Data includes details about payments to and from you and other
details of products and services you have
purchased from us.
- Technical Data includes internet protocol (IP) address, your login data,
browser type and version, time zone setting and
location, browser plug-in types and versions, operating system and platform, device ID and other technology
on the
devices you use to access this website.
- Profile Data includes your username and password, purchases or orders made
by you, your interests, preferences, feedback
and survey responses.
- Marketing and Communications Data includes your preferences in receiving
marketing from us and our third parties and
your communication preferences.
We also collect, use and share aggregated data such as statistical or demographic data which is not personal data as
it
does not directly (or indirectly) reveal your identity. For example, we may aggregate individuals' Usage Data to
calculate the percentage of users accessing a specific website feature in order to analyse general trends in how
users
are interacting with our website to help improve the website and our service offering.
3. How is your personal data collected?
We use different methods to collect data from and about you including through:
-
Your interactions with us. You may give us your personal data by filling in online forms or by
corresponding with us by
post, phone, email or otherwise. This includes personal data you provide when you:
- apply for our products or services;
- create an account on our website;
- purchase, or subscribe to, our services;
- give us feedback or contact us.
- Automated technologies or interactions. As you interact with our website, we
will automatically collect Technical Data
about your equipment, browsing actions and patterns. We collect this personal data by using cookies and
other similar
technologies. We may also receive Technical Data about you if you visit other websites employing our
cookies. Please see
our cookie policy for further details.
4. How we use your personal data
Legal basis
We will use the information that we hold about you for a number of different reasons. The law requires us to have a
legal basis for collecting and using your personal data. We rely on one or more of the following legal bases:
- Performance of a contract with you: Where we need to perform the contract we
are about to enter into or have entered
into with you.
- Legitimate interests: We may use your personal data where it is necessary to
conduct our business and pursue our
legitimate interests, for example to prevent fraud and enable us to give you the best and most secure
customer
experience. We make sure we consider and balance any potential impact on you and your rights (both positive
and
negative) before we process your personal data for our legitimate interests. We do not use your personal
data for
activities where our interests are overridden by the impact on you (unless we have your consent or are
otherwise
required or permitted to by law).
- Legal obligation: We may use your personal data where it is necessary for
compliance with a legal obligation that we are
subject to. We will identify the relevant legal obligation when we rely on this legal basis.
- Consent: We rely on consent only where we have obtained your active
agreement to use your personal data for a specified
purpose, for example if you subscribe to an email newsletter. Where you provide your consent, you may
withdraw it at any
time.
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use the various categories of
your
personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate
interests
are where appropriate.
Purpose/Use |
Type of data |
Legal basis |
To enable you to use our services and register you as a new user/customer
|
(a) Identity
(b) Contact
|
Performance of a contract with you |
To process and deliver our services and your order including:
(a) Manage payments, fees and charges
(b) Collect and recover money owed to us
|
(a) Identity
(b) Contact
(c) Financial
(d) Transaction
(e) Marketing and Communications
|
(a) Performance of a contract with you
(b) Necessary for our legitimate interests (to recover debts due to us)
|
To manage our relationship with you which will include:
(a) Notifying you about changes to our terms and conditions or privacy policy
(b) Dealing with your requests, complaints and queries
(c) Identify you when you visit our website or communicate with us
(d) detecting and fighting fraud and other unauthorised activities
|
(a) Identity
(b) Contact
(c) Profile
(d) Marketing and Communications
(e) Financial Data
(f) Technical Data
(g) Transaction Data
|
(a) Performance of a contract with you
(b) Necessary to comply with a legal obligation
(c) Necessary for our legitimate interests (to keep our records updated and manage our relationship with
you and to help
prevent fraud
(d) Necessary to protect the vital interests of an individual or another person
|
To administer and protect our business and this website (including troubleshooting, data analysis,
testing, system
maintenance, support, reporting and hosting of data)
|
(a) Identity
(b) Contact
(c) Technical
(d) Profile
|
(a) Necessary for our legitimate interests (for running our business, provision of administration and IT
services,
network security, to help prevent fraud, and in the context of a business reorganisation or group
restructuring
exercise)
(b) Necessary to comply with a legal obligation
|
To maintain and enhance the safety, security, and stability of the business, the website and our
services by
identifying, addressing (and reporting where required) any technical or security problems or issues
(such as technical
bugs, false accounts, and detecting abuse, fraud, or illegal or unauthorised activity)
|
(a) Identity
(b) Contact
(c) Technical
(d) Transaction
(e) Profile
(f) Usage Data
|
(a) Necessary to comply with a legal obligation
(b) Necessary for our legitimate interests (for running our business, provision of administration and IT
services,
network security, to prevent fraud and in the context of a business reorganisation or group
restructuring exercise)
(c) Necessary to protect the vital interests of an individual or another person
|
To deliver relevant website content and online advertisements to you and measure or understand the
effectiveness of the
advertising we serve to you
|
(a) Identity
(b) Contact
(c) Profile
(d) Usage
(e) Marketing and Communications
(f) Technical
|
Necessary for our legitimate interests (to study how customers use our products/services, to develop
them, to grow our
business and to inform our marketing strategy)
|
To use data analytics to improve our website, products/services, customer relationships and experiences
and to measure
the effectiveness of our communications and marketing
|
(a) Technical
(b) Usage
|
Necessary for our legitimate interests (to define types of customers for our products and services, to
keep our website
updated and relevant, to develop our business and to inform our marketing strategy).
|
To send you relevant marketing communications and make personalised suggestions and recommendations to
you about goods
or services that may be of interest to you based on your Profile Data
|
(a) Identity
(b) Contact
(c) Technical
(d) Usage
(e) Profile
(f) Marketing and Communications
|
Necessary for our legitimate interests (to carry out direct marketing, develop our products/services and
grow our
business)
Consent, having obtained your prior consent to receiving direct marketing communications
|
To carry out market research through your voluntary participation in surveys
|
|
Necessary for our legitimate interests (to study how customers use our products/services and to help us
improve and
develop our products and services).
|
Direct marketing
You will receive marketing communications from us if you have requested information from us or purchased goods or
services from us and you have not opted out of receiving the marketing when you register with us on our website.
We may also analyse your Identity, Contact, Technical, Usage and Profile Data to form a view which products,
services
and offers may be of interest to you so that we can then send you relevant marketing communications.
Third-party marketing
We will get your express consent before we share your personal data with any third party for their own direct
marketing
purposes.
Opting out of marketing
You can ask to stop sending you marketing communications at any time by following the opt-out links within any
marketing
communication sent to you or by contacting us (see paragraph 10).
If you opt out of receiving marketing communications, you will still receive service-related communications that are
essential for administrative or customer service purposes.
5. International transfers
We share your personal data within Swiftanon Limited affiliate companies. This will involve transferring your data
outside the UK.
Whenever we transfer your personal data out of the UK to countries which have laws that do not provide the same
level of
data protection as the UK law, we always ensure that a similar degree of protection is afforded to it by ensuring
that
the appropriate safeguards are implemented. We use specific standard contractual terms approved for use in the UK
which
give the transferred personal data the same protection as it has in the UK. To obtain a copy of these contractual
safeguards, please contact us (see contact details in clause 9).
We may also transfer your personal data to service providers that carry out certain functions on our behalf. This
may
involve transferring personal data outside the UK to countries which have laws that do not provide the same level of
data protection as the UK law. Whenever we transfer your personal data out of the UK to service providers, we ensure
a
similar degree of protection is afforded to it by ensuring that the appropriate safeguards are in place. We may use
specific standard contractual terms approved for use in the UK which give the transferred personal data the same
protection as it has in the UK. To obtain a copy of these contractual safeguards, please contact us (see ‘Contact
details’ in paragraph 9).
6. Data security
We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used
or
accessed in an unauthorised way, altered or disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need to know. They will only process your
personal data on our instructions and they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and will notify you and any
applicable
regulator of a breach where we are legally required to do so.
7. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it
for,
including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may
retain
your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect
of
litigation in respect to our relationship with you.
To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of
the
personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes
for
which we process your personal data and whether we can achieve those purposes through other means, and the
applicable
legal, regulatory, tax, accounting or other requirements.
By law we have to keep basic information about our customers (including Contact, Identity, Financial and Transaction
Data) for six years after they cease being customers.
In some circumstances you can ask us to delete your data: (see paragraph 8) below for further information.
In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for
research or statistical purposes, in which case we may use this information indefinitely without further notice to
you.
8. Your legal rights
You have a number of rights under data protection laws in relation to your personal data.
You have the right to:
- Request access to your personal data (commonly known as a "subject access
request"). This enables you to receive a copy
of the personal data we hold about you and to check that we are lawfully processing it.
- Request correction of the personal data that we hold about you. This enables you to
have any incomplete or inaccurate
data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to
us.
- Request erasure of your personal data in certain circumstances. This enables you to
ask us to delete or remove personal
data where there is no good reason for us continuing to process it. You also have the right to ask us to
delete or
remove your personal data where you have successfully exercised your right to object to processing (see
below), where we
may have processed your information unlawfully or where we are required to erase your personal data to
comply with local
law. Note, however, that we may not always be able to comply with your request of erasure for specific legal
reasons
which will be notified to you, if applicable, at the time of your request.
- Object to processing of your personal data where we are relying on a legitimate
interest (or those of a third party) as
the legal basis for that particular use of your data (including carrying out profiling based on our
legitimate
interests). In some cases, we may demonstrate that we have compelling legitimate grounds to process your
information
which override your right to object.
- You also have the absolute right to object any time to the processing of your
personal data for direct marketing
purposes (see ‘OPTING OUT OF MARKETING’ in paragraph 4 for details of how to object to receiving direct
marketing
communications).
- Request the transfer of your personal data to you or to a third party. We will
provide to you, or a third party you have
chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right
only applies to
automated information which you initially provided consent for us to use or where we used the information to
perform a
contract with you.
- Withdraw consent at any time where we are relying on consent to process your
personal data (see the table in section 4
for details of when we rely on your consent as the legal basis for using your data). However, this will not
affect the
lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we
may not be
able to provide certain products or services to you. We will advise you if this is the case at the time you
withdraw
your consent.
-
Request restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your
personal data in one of the following scenarios:
- If you want us to establish the data's accuracy;
- Where our use of the data is unlawful but you do not want us to erase it;
- Where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal
claims; or
- You have objected to our use of your data but we need to verify whether we
have overriding legitimate grounds to use it.
If you wish to exercise any of the rights set out above, please contact us (see ‘Contact details’ in paragraph 9).
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we
may
charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could
refuse to
comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity and ensure your right to
access
your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal
data is
not disclosed to any person who has no right to receive it. We may also contact you to ask you for further
information
in relation to your request to speed up our response.
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if
your
request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you
updated.
9. Contact details
If you have any questions about this Privacy Policy or about the use of your personal data or you want to exercise
your
privacy rights, please contact us in the following ways:
- Email address: [email protected]
- Postal address: Swiftanon Limited, 3 Caledon Court, County Dublin, Dublin, D03
H308.
- Telephone number: +44 11 8230 3904 / +353 1 592 4146
10. Complaints
You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK regulator
for
data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before
you
approach the ICO so please contact us in the first instance.
11. Third-party links
This website may include links to third-party websites, plug-ins and applications. Clicking on those links or
enabling
those connections may allow third parties to collect or share data about you. We do not control these third-party
websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read
the
privacy policy of every website you visit.