Privacy Policy

1.1 We operate a service which allows you to import, and validate your design using our website located at www.swtstay.com (the “Service”).

1.2 We appreciate your interest in our Service. Privacy protection is very important to us and we are committed to protecting you and respecting your privacy. This privacy policy sets out information about how we collect, store, process, transfer, share, and use data that identifies or is associated with you when providing our Service (hereinafter “personal information”).

1.3 The Service is operated by Swtstay (“Swtstay”, “we”, “our” or “us”) and we act as a data controller in relation to the personal information we hold about you. Our registered address is [Swtstay registered address].

2.1 We process two broad categories of personal information when you access the Service:

1. Your personal information as a customer (or potential customer) of the Service, or as a visitor to our website (hereinafter “Customer Data”); and
2. Your personal information that we received from a customer who signed you up as a tester/participant on the Service (hereinafter “Participant Data”).

2.2 For the purposes of data protection laws, we act as: (i) the controller of Customer Data, but as (ii) a processor of Participant Data (acting on behalf of the customer who provided your personal information to us in the first place). A controller decides why and how to process personal information. A processor processes personal information on behalf of a controller based on the controller’s instructions.

4.1 We use cookies and similar technologies to:

• Enhance your experience: Save your preferences and settings
• Analyze usage: Understand how you use our Service
• Marketing: Provide relevant content and advertisements.
• Security: Ensure the security and integrity of our Service.

You can manage your cookie preferences through your browser settings.

5.1 We may share any of your personal information with the following parties (to the limited extent required in accordance with the uses set out in Annexes 1 and 2):

• (a) Companies in the same group of companies as us: Our subsidiaries (i.e., any organisation we own or control) or our holding company or ultimate holding company (i.e., any organisation that owns or controls us) and any subsidiaries they own. These companies will only use your personal information in the same way as we can under this privacy policy.
• (b) Service providers and advisors: Third parties who provide a service to us. For example, we may use a service provider to fulfil our marketing functions, our IT support, or to otherwise support the provision of the Service. This includes Google Analytics, who we use to track and report on the traffic to our Service. Unless you are logged into our Service, this data is anonymized. If you are logged in, then we will be able to track your actions on our Service and associate this with your account.
• (c) Third-party social networks: Third-party social networks (such as Facebook and Twitter) may collect or receive information from our Service and from other apps and websites and use that information to provide measurement services and targeted adverts. This occurs regardless of whether or not you are logged into your account with the third party. If you do not wish for this type of data collection to occur, please visit your social network account settings and adjust your privacy settings.
• (d) Law enforcement, regulators and other parties for legal reasons: Third parties as required by law or subpoena or if we reasonably believe that such action is necessary to: (i) comply with the law and the reasonable requests of law enforcement; (ii) enforce our terms of use or to protect the security or integrity of our Service; and/or (iii) exercise or protect the rights, property, or personal safety of Swtstay, our customers, or others.
• (e) Acquiring companies: Third parties where necessary to facilitate our acquisition by a third party, such as in the event that we sell all or part of our business. In these circumstances, we will always inform you of the transfer and ensure that the acquiring company continues to process your personal information in accordance with this privacy policy.

You can manage your cookie preferences through your browser settings.

6.1 The personal information we collect may be transferred to and stored in countries outside of your jurisdiction. Some of these jurisdictions offer differing levels of protection in respect of personal information and may, in certain instances, be less protective than the jurisdiction you are typically resident in.

6.2 We ensure that the transfer of your personal information to other countries meets the requirements of applicable data protection laws. We may transfer your personal information to:

• (a) countries which have been found to provide adequate protection for personal information; or
• (b) to countries which do not provide adequate protection for personal information, but we will ensure the transfer is subject to adequate safeguards and data protection requirements.

7.1 In accordance with applicable privacy law, you have the following rights in respect of your personal information that we hold:

• (a) Right of access and portability: The right to obtain access to and to receive your personal information.
• (b) Right to rectification: The right to obtain rectification of your personal information without undue delay where that personal information is inaccurate or incomplete.
• (c) Right to erasure: The right to obtain the erasure of your personal information without undue delay where one of the grounds set out in the relevant legislation applies.
• (d) Right to restriction: The right to restrict the use of your personal information where one of the grounds set out in the relevant legislation applies.
• (e) Right to object: The right to object, on grounds relating to your particular situation, to the use of your personal information in certain circumstances, including where your personal information is used for direct marketing purposes.
• (f) Right to prevent automated decision-making: The right not to be subject to a decision based solely on automated processing, including profiling, which produces legal effects concerning you or similarly significantly affects you.

7.2 If you wish to exercise one of these rights, please contact us using the contact details at the end of this privacy policy. For more information on your rights under the relevant legislation, please contact your local data protection authority.

8.1 We retain your personal information for as long as is necessary to fulfil the purposes for which we collected it. Where there is no longer a legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

9.1 We implement appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, change or damage. All information you provide to us is stored on secure servers.

9.2 We also take measures to protect your personal information against unauthorized access, use and disclosure. For example, we limit access to your personal information to employees and contractors who need to access the information in order to perform their assigned job duties. In addition, all our employees and contractors are subject to confidentiality obligations.

10.1 Our Service is not directed to children under the age of 13. If we become aware that we have collected personal information from a child under 13, we will delete any such information without undue delay.

11.1 We may update this privacy policy from time to time. When we update this privacy policy, we will notify you by posting the revised policy on our Service. Where the changes are material, we will use reasonable endeavours to notify you – for example, by email or via a notice on our Service. We encourage you to review this privacy policy whenever you visit our Service to understand how your personal information is used.

12.1 If you have any questions or concerns about this privacy policy, please contact us using the following contact details:

1. Email: [email protected]