Privacy Policy – Archived

June 2023

Introduction

We ask that you read this Privacy Policy carefully as it contains important information on who we are, how and why we collect, store, use and share personal information, your rights in relation to your personal information and on how to contact us and supervisory authorities if you have a complaint.

​We are CovertSwarm Limited, a company registered in England & Wales under company number 12564314 with our registered office at International House, 36-38 Cornhill, London EC3V 3NG, United Kingdom

​We collect, use and are responsible for certain personal information about you. When we do so we are regulated under the General Data Protection Regulation which applies across the European Union and the United Kingdom and we are responsible as “controller” of that personal information for the purposes of those laws.

​This Privacy Policy relates to your use of our website and our services. By using our website, you indicate your agreement to this Privacy Policy. If you register for our services, we will ask you to accept this Privacy Policy.

This Privacy Policy does not cover any third-party websites which you may access from our website or by using our services. Such third-party websites will be governed by their own separate privacy policies.

Our collection and use of your personal information

We collect personal information about you when you access our website, contact us, send us feedback, purchase services from us or complete client surveys. We collect this personal information from you either directly, such as when you contact us or purchase services, or indirectly, such as your browsing activity while on our website (see “Cookies” below).

The personal information we collect about you may include:

  • your name, business address and contact details including telephone number, job title and email address

  • details of any feedback you give us by phone, email, post, submission of a form from our website or via social media

  • information about the services we provide to you

  • technical data including Internet Protocol (IP) address details including your public browser type and version.

We use this personal information for various reasons including:

  • confirm acceptance of your registration and create and manage your account with us

  • verify your identity

  • communicate with you to provide our services

  • notify you of any changes to our services that may affect you

  • improve our services

  • for marketing purposes

Our legal basis for processing your personal information

When we use your personal information, we are required to have a legal basis for doing so. There are various legal bases on which we may rely, depending on what personal information we process and why.

The legal bases we may rely on include:

  • consent: where you have given us clear consent for us to process your personal information for a specific purpose.

  • contract: where our use of your personal information is necessary for a contract we have with you, or because you have asked us to take specific steps before entering into a contract.

  • legal obligation: where our use of your personal information is necessary for us to comply with the law (not including contractual obligations).

  • legitimate interests: where our use of your personal information is necessary for our legitimate interests or the legitimate interests of a third party (unless there is a good reason to protect your personal information which overrides our legitimate interests).

Who we share your personal information with

We routinely share your personal information with partner companies who we use to provide some of our services. We do not allow these companies to use your personal information for any purposes beyond providing our services to you. This data sharing enables us to provide the services to you.

We will also share personal information with:

  • law enforcement or other authorities if required by applicable law.

  • third parties if there is a change in the ownership of CovertSwarm or any of our assets.

  • FreshSales and Google for marketing and business development purposes.

We will not share your personal information with any other third party.
Some of these third party recipients may be based outside the United Kingdom and European Economic Area. Please see below for how we safeguard your personal information when a transfer occurs.

Transfer of your information out of the UK and EEA

We may transfer your personal information to the following which are located outside the United Kingdom (UK) and European Economic Area (EEA) as follows:

  • to the USA for marketing purposes.

Such countries do not have the same data protection laws as the UK and EEA. While the European Commission has not given a formal decision that the USA provides an adequate level of data protection similar to those which apply in the UK and EEA, the EU-US Privacy Shield Framework allows for the transfer of personal information to a third party who is acting as a service provider, agent or data processor if we take certain steps to ensure privacy and security protections. We take reasonable steps to require the third party recipient to protect your personal information in accordance with the EU- US Privacy Shield Framework.​

If you would like further information, please contact us (see ‘How to contact us’ below). We will not otherwise transfer your personal data outside of the UK or to any organisation (or subordinate bodies) governed by public international law or which is set up under any agreement between two or more countries.

Marketing

We would like to send you information about our services and special offers, which may be of interest to you. Where we have your consent or it is in our legitimate interests to do so, we may do this by post, email, telephone, text message (SMS) or automated call.

​We will only ask whether you would like us to send you marketing messages when you tick the relevant box when submitting requests for assistance or information on any of the public web forms presented upon the www.CovertSwarm.com website.

If you have previously agreed to being contacted in this way, you can unsubscribe at any time by:

  • contacting us

  • using the ‘unsubscribe’ link in emails

It may take up to 10 business days for this to take place. For more information on your rights in relation to marketing, see ‘Your rights’ below.

Cookies

A cookie is a small text file which is placed onto your device (e.g. computer, smartphone or other electronic device) when you use our website. Once you agree, the file is added and the cookie helps analyse web traffic or lets you know when you visit a particular site. Cookies allow web applications to respond to you as an individual. The web application can tailor its operations to your needs, likes and dislikes by gathering and remembering information about your preferences.

​We use traffic log cookies to identify which pages are being used. This helps us analyse data about web page traffic and improve our website in order to tailor it to client needs. We only use this information for statistical analysis purposes and then the data is removed from the system.

Overall, cookies help us provide you with a better website, by enabling us to monitor which pages you find useful and which you do not. A cookie in no way gives us access to your device or any information about you, other than the data you choose to share with us.

You can choose to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. This may prevent you from taking full advantage of the website.

We also collect information from visitors to our website and registered clients to help us improve our website and services. This information tells us, for instance, how many visitors there were to our website, when they visited, for how long and which areas of our website they went to. This information helps us to assess which parts of our website are popular or need improving. We may share this data in an aggregated form with our partners but only in ways that do not identify any living individuals.

Your rights

Under the General Data Protection Regulation, you have several important rights. In summary, those include rights to:

  • fair processing of information and transparency over how we use your use personal information

  • access to your personal information and to certain other supplementary information that this Privacy Policy is already designed to address

  • require us to correct any mistakes in your information which we hold

  • require the erasure of personal information concerning you in certain situations

  • receive the personal information concerning you which you have provided to us, in a structured, commonly used and machine-readable format and have the right to transmit those data to a third party in certain situations

  • object at any time to processing of personal information concerning you for direct marketing

  • object to decisions being taken by automated means which produce legal effects concerning you or similarly significantly affect you

  • object in certain other situations to our continued processing of your personal information

  • otherwise restrict our processing of your personal information in certain circumstances

For further information on each of those rights, including the circumstances in which they apply, see the Guidance from the UK Information Commissioner’s Office (ICO) on individuals’ rights under the General Data Protection Regulation.

If you would like to exercise any of those rights, please:

  • email, call or write to us

  • let us have enough information to identify you

  • let us have proof of your identity and address (a copy of your driving licence or passport and a recent utility or credit card bill), and

  • let us know the information to which your request relates

Keeping your personal information secure

​We have appropriate security measures in place to prevent personal information from being accidentally lost or used or accessed in an unauthorised way. We limit access to your personal information to those who have a genuine business need to know it. Those processing your information will do so only in an authorised manner and are subject to a duty of confidentiality.

​We also have procedures in place to deal with any suspected data security breach. We will notify you and any applicable regulator of a suspected data security breach where we are legally required to do so.

How to complain

We hope that we can resolve any query or concern you raise about our use of your information. The General Data Protection Regulation also gives you the right to lodge a complaint with a supervisory authority, in particular in a European Economic Area state or in the United Kingdom if you work, normally live or if any alleged infringement of data protection laws occurred in the relevant state. The supervisory authority in the UK is the Information Commissioner who may be contacted at https://ico.org.uk/concerns/ or telephone: +44 (0) 303 123 1113.

​Changes to this privacy policy

This Privacy Policy was published in June 2023.

​We may change this Privacy Policy from time to time. Any changes will be posted on this page and, where appropriate, notified to you by email.

How to contact us

Please contact us if you have any questions about this Privacy Policy or the information we hold about you.

If you wish to contact us, please write to our Data Protection Manager at: Data Protection Manager, CovertSwarm, International House, 36-38 Cornhill, London EC3V 3NG, United Kingdom