Who are we?
We are SwiftComply TopCo Limited. We own and operate www.swiftcomply.com and any related domains or sub-domains (the Website) and we are committed to protecting and respecting your privacy.

We are a limited company registered in Ireland under company number 582983 and have our registered office at 30/31 Francis Street, The Liberties, Dublin 8, D08 YHW1, Ireland. Our main trading address is at 30/31 Francis Street, The Liberties, Dublin 8, D08 YHW1, Ireland and our VAT number is 3419869MH.

For the purposes of the Data Protection Act 1988 and as amended by the Data Protection Act (Amended) 2003 (together the Act), the data controller is SwiftComply TopCo Limited.

What’s the point of this policy?
This policy tells you how we deal with any data we collect from you, that you provide to us or that we receive from third parties. Please read it carefully to understand our views and practices regarding your data and how we will treat it.

By visiting the Website, you are accepting and consenting to the practices described in this policy.

Might this policy change?
It may well do and any changes we make will be posted on this page. Please check back frequently to see any updates or changes to this policy as we will assume that you agree to them if you use the Website after the date shown at the end of this policy.

What data do we collect?
We collect and store the information which you give us via forms on the Website (including when you register to use the Website) – such as your name, business address, business email address, business phone number, financial and credit card information and so on – or when communicating with us by email or in some other way.

We may collect and store certain information automatically when you visit the Website. Examples include the internet protocol (IP) address used to connect your computer or device to the internet, connection information such as browser type and version, your operating system and platform, a unique reference number linked to the data you enter on our system, login details, the full URL clickstream to, through and from the Website (including date and time), cookie number and your activity on our Website, including the pages you visited, the searches you made and, if relevant, the services you purchased. We may receive information about you if you use any of the other websites we operate or the other services we provide from time to time.

We may also receive information about you from third parties if you use any websites or social media platforms operated by third parties (for example, Facebook, Twitter or LinkedIn) and, if such functionality is available, you have chosen to link your profile on the Website with your profile on those other websites or social media platforms.

We also work closely with third parties (including, for example, business partners, sub-contractors in technical, payment and delivery services, advertising networks, analytics providers, search information providers, credit reference agencies) and may receive information about you from them.

If you are using the Website as one of our registered service providers (a Service Provider), we will collect and store the information you supply to us during the application process and thereafter. We may also collect supplemental information about you from third parties. For example, we reserve the right to carry out credit checks.

What about cookies?
We use cookies to distinguish you from other users of the Website. This helps us to provide you with a good experience when you browse the Website and also allows us to improve the Website.  A cookie is a small file of letters and numbers that we store on your browser or the hard drive of your computer or device (if you agree). You can block cookies by activating the setting on your browser that allows you to refuse the setting of all or some cookies. However, the Website’s functionality will be limited if you do not accept cookies.

Cookies are widely used to make websites work, or work more efficiently, as well as to provide information to the Website owner or others. ‘Session cookies’ are temporary cookies that remain in the cookie file of your browser only until you leave the Website. They allow websites to link your actions during a browser session. ‘Persistent cookies’ stay in the cookie file of your browser for longer (though how long will depend on the lifetime of the specific cookie). For further information on cookies, including how to use your browser to block them, visit: www.allaboutcookies.org.

We use the following cookies on the Website for the following purposes:
• Session cookies: We use session cookies to enable the Website to keep track of your movement from page to page and to store your selections so that you do not get asked repeatedly for the same information. These cookies allow you to proceed through many pages of the Website quickly and easily without having to authenticate or reprocess each new area you visit.
• Log-in cookies: We use persistent cookies (up to 14 days) to remember you so as to simplify the log-in process if you return to the Website.
• Google analytics cookies: Google sets persistent cookies (up to two years) to recognize and count the number of Website visitors, as well as providing other information about each visit to the Website such as duration, route through the Website and what Websites the visitor came from. This information helps us to improve the way the Website works, for example by making sure users find what they need easily. These cookies are provided by Google. Google requires us to tell you the following: “This website uses Google Analytics, a web analytics service provided by Google, Inc. (“Google”).  Google Analytics uses “cookies”, which are text files placed on your computer, to help the website analyze how users use the Website. The information generated by the cookie about your use of the website (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the website, compiling reports on website activity for website operators and providing other services relating to website activity and internet usage.  Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google’s behalf. Google will not associate your IP address with any other data held by Google.  You may refuse the use of cookies by selecting the appropriate settings on your browser. However please note that if you do this you may not be able to use the full functionality of this website.  By using this website, you consent to the processing of data about you by Google in the manner and for the purposes set out above.” Click here for more information about Google Analytics cookies. Click here to opt out of Google Analytics.

By continuing to use the Website, you are agreeing to the use of cookies on the Website as outlined above. However, please note that we have no control over the cookies used by third parties.

How do we use the information we hold about you?
We will use the information you give us:
• to carry out our obligations arising from any contracts entered into between you and us and to provide you with the information, products and/or services that you request from us;
• to provide you with information about us (including other products and services we offer) and to send you newsletters;
• to notify you about changes to our service;
• to help us communicate with you effectively should you try to contact us via the Website, including verification of any claims you may make; and
• to ensure that content from the Website is presented in the most effective manner for you and for your computer or device.

We may use your data to send you emails (or other communications) with details of our or third party products or services which may be of interest to you, including information about special offers or promotions. If you would prefer not to receive any such emails or other communications, please tell us by emailing us at hello@swiftcomply.com.

We will use any information collected about you automatically when you visit the Website:
• to administer the Website and for internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes;
• to improve the Website and to ensure that content is presented in the most effective manner for you and for your computer or device;
• to allow you to participate in any interactive features of our service, when you choose to do so;
• as part of our efforts to keep the Website safe and secure; and
• to make suggestions and recommendations to you and other users of the Website about products or services that may interest you or them.

We may combine information we receive from other sources with information you give to us and information we collect about you. We may use this information and the combined information for the purposes set out above (depending on the types of information we receive).

We retain data from closed accounts in order to comply with legal obligations, enforce our terms and conditions, prevent fraud, collect any fees owed, resolve disputes, troubleshoot problems, assist with any investigations and take other actions as permitted by law.

How do we protect data?
Security is a high priority. We take appropriate precautions to protect data from loss, misuse, unauthorised access or disclosure, alteration or destruction using the same safeguards as we use for our own proprietary information. All information you provide to us is stored on our secure servers and any payment transactions will be encrypted using SSL technology. Where we have given you (or where you have chosen) a password which enables you to access certain parts of the Website, you are responsible for keeping this password confidential. We ask you not to share a password with anyone.

Unfortunately, email and other electronic communications are not secure if they have not been encrypted and your communications may pass through servers in a number of different countries before they reach us. Although we will do our best to protect your data (and will use strict procedures and security features to try to prevent unauthorised access once we have received it), we cannot guarantee the security of your data transmitted to the Website and any transmission is at your own risk. We also cannot accept responsibility for any unauthorised access to, or loss of, data that results from a cause beyond our control, nor can we be held responsible for the actions or omissions of other users or third parties who may misuse your data which they collect from the Website.

To whom do we disclose your information?
We may share your information with any member of our group (which means our subsidiaries, our ultimate holding company and its subsidiaries from time to time, in each case as defined in section 7 of the Companies Act 2014).

Payment details, including credit card numbers, are supplied direct to Stripe. We do not receive such information. However, to ensure your details are not being used without consent, your data may be supplied to relevant third parties, including credit reference and fraud prevention agencies, who may keep a record of that information.

We may share your information with selected third parties, including:
• business partners, suppliers and sub-contractors for the performance of any contract we enter into with them or you;
• analytics and search engine providers that assist us in the improvement and optimization of the Website; and
• e-commerce platform providers, webWebsite hosts and businesses which assist us in undertaking communications or monitoring the Website.

Very important: If, as a user of the Website, you have booked a Service Provider to provide services to you, we will provide your contact details to the relevant Service Provider in order to enable them to attend at service visits and to contact you if necessary (for example, if the Service Provider is delayed).

Very important: If you post a review/rating/comment on the Website, your username will be shown

• if we have reason to believe that you have breached our terms and conditions, that such steps are necessary to protect us or others or that a criminal act has been committed;
• if we are required to do so by law or appropriate authority; or
• in the case of an actual or proposed (including negotiations for a) sale or merger or business combination involving all or the relevant part of our business

Except as otherwise specifically included in this policy, this document addresses only the use and disclosure of information that you give to us, that we collect from you or that we receive from third parties. If you disclose your information to third parties, whether they are other users of the Website or other websites (including websites which link to or from the Website), different rules and/or policies may apply to their use or disclosure of your information and we do not accept any responsibility or liability for these rules and/or policies. Please therefore check them before submitting any data.

Where do we store your data?
The data that we collect from you may be transferred to, and stored at, a destination outside the European Economic Area (EEA). It may also be processed by staff operating outside the EEA who work for us or for one of our suppliers. Such staff may be engaged in, among other things, the processing of your payment details and the provision of support services. By submitting your business data, you agree to this transfer, storing or processing. We will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this privacy policy and we will of course comply with the applicable laws relating to the transfer of data outside the EEA.

Can you ask us not to process your data for marketing purposes?
You have the right to ask us not to process your data for marketing purposes. We will usually inform you (before collecting your data) if we intend to use your data for such purposes or if we intend to disclose your information to any third party for such purposes. You can exercise your right to prevent such processing at any time by contacting us at hello@swiftcomply.com

How can you access your data?
The Act gives you the right to access your data held by us. Your right of access can be exercised in accordance with the Act. We may charge an administration fee of €10 to meet our costs in providing you with details of the information we hold about you.

For information about your rights under Irish data protection laws, see the website of the Data Protection Commissioner.

Contact
If you have any questions or feedback about this policy, please contact us by writing to us at 30/31 Francis Street, The Liberties, Dublin 8 or by emailing us at hello@swiftcomply.com.

Last updated: 30th August 2017

Acceptable use policy
This acceptable use policy sets out the terms between you and us under which you may access our our Website. This acceptable use policy applies to all users of, and visitors to, our Website (whether as guests or registered users).

Your use of our Website means that you accept, and agree to abide by, all the policies in this acceptable use policy, which supplement our terms and conditions.
www.swiftcomply.com is a website operated by SwiftComply TopCo Limited. We are a limited company registered in Ireland under company number 582983 and have our registered office at 30/31 Francis Street, The Liberties, Dublin 8, D08 YHW1, Ireland. Our main trading address is at 31 Francis Street, Dublin 8, D08 YHW1, Ireland and our VAT number is 3419869MH.
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Prohibited uses
You may use our Website only for lawful purposes. You may not use our Website:
• In any way that breaches any applicable local, national or international law or regulation.
• In any way that is unlawful or fraudulent, or has any unlawful or fraudulent purpose or effect.
• To send, knowingly receive, upload, download, use or re-use any material which does not comply with our content standards (see below).
• To transmit, or procure the sending of, any unsolicited or unauthorised advertising or promotional material or any other form of similar solicitation (spam).
• To knowingly transmit any data, send or upload any material that contains viruses, Trojan horses, worms, time-bombs, keystroke loggers, spyware, adware or any other harmful programs or similar computer code designed to adversely affect the operation of any computer software or hardware.

You also agree:
• Not to reproduce, duplicate, copy or re-sell any part of our Website in contravention of the provisions of our terms and conditions
• Not to access without authority, penetrate, interfere with, damage or disrupt (or attempt to do any of the same): (i) the accounts of other members; (ii) any part of our Website or its security measures; (iii) any equipment or network on which our Website is stored; (iv) any software used in the provision of our Website; or (v) any equipment, network or software owned or used by any third party.

Interactive services
We may from time to time provide interactive services on our Website, including, without limitation, chat rooms, bulletin boards, messaging services and feedback forms.

Where we do provide any interactive service, we will provide clear information to you about the kind of service offered, if it is moderated and what form of moderation is used (including whether it is human or technical).

We will do our best to assess any possible risks for users from third parties when they use any interactive service provided on our Website, and we will decide in each case whether it is appropriate to use moderation of the relevant service (including what kind of moderation to use) in light of those risks. However, we are under no obligation to oversee, monitor or moderate any interactive service we provide on our Website, and we expressly exclude our liability for any loss or damage arising from the use of any interactive service by a user in contravention of our content standards, whether the service is moderated or not.

Where we do moderate an interactive service, we will normally provide you with a means of contacting the moderator, should a concern or difficulty arise.

Content standards
These content standards apply to any and all material which you contribute to our Website, and to any interactive services associated with it.

You must comply with the spirit of the following standards, as well as the letter. The standards apply to each part of any contribution as well as to its whole.

Contributions must:
• Be accurate (where they state facts).
• Be genuinely held (where they state opinions).
• Comply with applicable law in the UK and in any country from which they are posted.

Contributions must not:
• Contain any material which is defamatory or inaccurate of any person.
• Contain any material which is obscene, offensive, hateful or inflammatory.
• Promote indecent or sexually explicit material.
• Promote violence.
• Promote discrimination based on race, sex, religion, nationality, disability, sexual orientation or age.
• Infringe or violate any copyright, database right or trade mark of any other person.
• Be likely to deceive any person.
• Be made in breach of any legal duty owed to a third party, such as a contractual duty or a duty of confidence.
• Promote any illegal activity.
• Be threatening, abuse or invade another’s privacy or cause annoyance, inconvenience or needless anxiety.
• Be likely to harass, upset, embarrass, alarm or annoy any other person.
• Be used to impersonate any person, or to misrepresent your identity or affiliation with any person.
• Give the impression that they emanate from us, if this is not the case.
• Advocate, promote, assist or enable any illegal or unlawful activities (including, without limitation, copyright infringement or computer misuse) or intend to defraud, swindle or deceive other users of our Website.
• Relate to commercial activities (including, without limitation, sales, competitions and advertising, links to other webWebsites or premium rate telephone numbers).
• Disseminate or otherwise disclose another person’s personal information without his or her prior permission, or collect or solicit another person’s personal information for commercial or unlawful purposes.

Suspension and termination
A registered user may at any time, and without the need to provide any reason, request the closure of his/her account by emailing us at hello@swiftcomply.io.

We will determine, in our discretion, whether there has been a breach of this acceptable use policy through your use of our Website. When a breach of this policy has occurred, we may take such action as we deem appropriate.

Failure to comply with this acceptable use policy constitutes a material breach of the terms and conditions upon which you are permitted to use our Website and may result in our taking all or any of the following actions:
• Immediate, temporary or permanent withdrawal of your right to use our Website.
• Immediate, temporary or permanent removal of any content uploaded, posted, submitted or displayed by you on or to our Website.
• Issue of a warning to you.
• Legal proceedings against you for reimbursement of all costs on an indemnity basis (including, but not limited to, reasonable administrative and legal costs) resulting from the breach.
• Further legal action against you.
• Disclosure of such information to law enforcement authorities as we feel is reasonably necessary.
We exclude liability for actions taken in response to breaches of this acceptable use policy. The responses described in this policy are not limited, and we may take any other action we reasonably deem appropriate.

Changes to this acceptable use policy
We may revise this acceptable use policy at any time by amending this page. You are expected to check this page from time to time to take notice of any changes we make, as they are legally binding on you. Some of the provisions contained in this acceptable use policy may also be superseded by provisions or notices published elsewhere on our Website.