Mobile Pay Systems Limited (“We/Us/Our”) understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.swooperetail.com (“Our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with Our obligations and your rights under the law.
1. Definitions and Interpretation
In this Policy the following terms shall have the following meanings:
Account: means an account required to access and/or use certain areas and features of Our Site;
Cookie: means a small text file placed on your computer or device by Our Site when you visit certain parts of Our Site and/or when you use certain features of Our Site. Details of the Cookies used by Our Site are set out in Part 14, below; and
Cookie Law: means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003.
2. Information About Us
2.1 Our Site is owned and operated by Mobile Pay Systems Limited, a limited company registered in England and Wales under company number 09710950, whose registered address is 494 Midsummer Boulevard, Milton Keynes, MK9 2EA, United Kingdom.
2.2 Our VAT number is GB 242 488 105.
2.3 Our Data Protection Officer is Lee Nazari and can be contacted by email at firstname.lastname@example.org by telephone on 01212707500 or by post at 494 Midsummer Boulevard, Milton Keynes, MK9 2EA, United Kingdom.
3. What Does This Policy Cover?
4. What Is Personal Data?
Personal data is defined by the General Data Protection Regulation (EU Regulation 2016/679) (the “GDPR”) and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.
Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.
5. What Are My Rights?
Under the Data Protection Legislation, you have the following rights, which this Policy and Our use of Personal Data have been designed to uphold:
- b) The right to access the personal data We hold about you. Part 13 will tell you how to do this.
- c) The right to have your personal data rectified if any of your personal data held by Us is inaccurate or incomplete. Please contact Us using the details in Part 15 to find out more.
- d) The right to be forgotten, i.e. the right to ask Us to delete or otherwise dispose of any of your personal data that We hold. Please contact Us using the details in Part 15 to find out more.
- e) The right to restrict (i.e. prevent) the processing of your personal data.
- f) The right to object to Us using your personal data for a particular purpose or purposes.
- g) The right to withdraw consent. This means that, if We are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
- h) The right to data portability. This means that, if you have provided personal data to Us directly, We are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask Us for a copy of that personal data to re-use with another service or business in many cases.
- i) Rights relating to automated decision-making and profiling. We do not use your personal data in this way.
For more information about Our use of your personal data or exercising your rights as outlined above, please contact Us using the details provided in Part 15.
It is important that your personal data is kept accurate and up-to-date. If any of the personal data We hold about you changes, please keep Us informed as long as We have that data.
Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.
If you have any cause for complaint about Our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns Ourselves, however, so please contact Us first, using the details in Part 15.
6. What Data Do You Collect and How?
For sellers of goods via Our Site:
6.1 name of business;
6.2 address of business;
6.3 type of organization; e.g., limited company;
6.4 type of business;
6.5 name of contact person;
6.6 contact information such as email addresses and telephone numbers of businesses and contact persons;
6.7 financial information such as credit / debit card numbers;
6.8 IP address;
6.9 web browser type and version;
6.10 operating system;
For Users of Our Site / buyers of goods via Our Site:
6.12 delivery address;
6.13 contact information such as email addresses and telephone numbers;
6.14 financial information such as credit / debit card numbers;
6.15 IP address;
6.16 web browser type and version; and
6.17 operating system.
7. How Do You Use My Personal Data?
7.1 All personal data is processed and stored securely, for no longer than is necessary in light of the reason(s) for which it was first collected. We will comply with Our obligations and safeguard your rights under the GDPR at all times.
7.2 Our use of your Personal Data will always have a lawful basis, either because it is necessary for Our performance of a contract with you, because you have consented to Our use of your personal data (e.g. by subscribing to emails), or because it is in Our legitimate interests. Specifically, We may use your data for the following purposes:
7.2.1 Providing and managing your account;
7.2.2 Providing and managing your access to Our Site;
7.2.3 Personalising and tailoring your experience on Our Site;
7.2.4 Supplying Our products and services to you (please note that We require your Personal Data in order to enter into a contract with you);
7.2.5 Personalising and tailoring Our products and services for you;
7.2.6 Replying to emails from you;
7.2.7 Supplying you with emails that you have opted into. You may unsubscribe or opt-out at any time by pressing unsubscribe on any correspondent email, or emailing email@example.com and requesting it.
7.2.8 Market research;
7.2.9 Analysing your use of Our Site and gathering feedback to enable Us to continually improve Our Site and your user experience;
7.3 With your permission and/or where permitted by law, We may also use your data for marketing purposes which may include contacting you by email with information, news and offers on products and services. We will not, however, send you any unsolicited marketing or spam and will take all reasonable steps to ensure that We fully protect your rights and comply with Our obligations under the GDPR and the Privacy and Electronic Communications (EC Directive) Regulations 2003 and any regulation substituting the GDPR in the United Kingdom.
7.4 Third parties whose content appears on Our Site may use third party Cookies, as detailed below. Please note that We do not control the activities of such third parties, nor the data they collect and use and advise you to check the privacy policies of any such third parties.
7.5 You have the right to withdraw your consent to Us using your personal data at any time, and to request that We delete it.
8. How Long Will You Keep My Personal Data?
8.1 We do not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Data will therefore be retained for 24 months of your last activity.
8.2 You can delete you account at any time, which will delete your data from Our database.
9. How and Where Do You Store or Transfer My Personal Data?
9.1 We only keep your personal data for as long as We need to in order to use it as described above in section 7, and/or for as long as We have your permission to keep it.
9.2 Your data will only be stored within the European Economic Area (“the EEA”) or the United Kingdom (The EEA consists of all EU member states, plus Norway, Iceland, and Liechtenstein).
9.3 Data security is very important to Us, and to protect your data We have taken suitable measures to safeguard and secure data collected through Our Site.
10. Do You Share My Personal Data?
10.1 We may share your data with other companies in Our group for to supply better services attached to our core business. This includes Our holding company and its subsidiaries.
10.2 We may sometimes contract with third parties to supply products and services to you on Our behalf. These may include payment processing, delivery of goods, search engine facilities, advertising, and marketing. In some cases, the third parties may require access to some or all of your data. Where any of your data is required for such a purpose, We will take all reasonable steps to ensure that your data will be handled safely, securely, and in accordance with your rights, Our obligations, and the obligations of the third party under the law.
10.3 We may compile statistics about the use of Our Site including data on traffic, usage patterns, user numbers, sales, and other information. All such data will be anonymised and will not include any personally identifying data, or any anonymised data that can be combined with other data and used to identify you. We may from time to time share such data with third parties such as prospective investors, affiliates, partners, and advertisers. Data will only be shared and used within the bounds of the law.
10.4 Any third party data processors used by Us are located within the European Economic Area (“the EEA”).
10.5 In certain circumstances, We may be legally required to share certain data held by Us, which may include your personal data, for example, where We are involved in legal proceedings, where We are complying with legal requirements, a court order, or a governmental authority.
11. How Can I Control My Personal Data?
11.1 In addition to your rights under the Data Protection Legislation, set out in Part 5, when you submit personal data via Our Site, you may be given options to restrict Our use of your data. In particular, We aim to give you strong controls on Our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from Us which you may do by unsubscribing using the links provided in Our emails and at the point of providing your details and by managing your Account).
12. Can I Withhold Information?
12.1 You may access certain areas of Our Site without providing any data at all. However, to use all features and functions available on Our Site you may be required to submit or allow for the collection of certain data.
13. How Can I Access My Personal Data?
13.1 You have the right to ask for a copy of any of your personal data held by Us (where such data is held). Under the GDPR, no fee is payable and We will provide any and all information in response to your request free of charge. Please contact Us for more details at firstname.lastname@example.org or using the contact details below in section 15.
14.2 By using Our Site you may also receive certain third party Cookies on your computer or device. Third party Cookies are those placed by websites, services, and/or parties other than Us. Third party Cookies are used on Our Site for Advertising purposes. These Cookies are not integral to the functioning of Our Site and your use and experience of Our Site will not be impaired by refusing consent to them.
14.3 All Cookies used by and on Our Site are used in accordance with current Cookie Law.
14.4 Before Cookies are placed on your computer or device, you will be shown a popup or push notification requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling Us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of Our Site may not function fully or as intended.
14.5 Certain features of Our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below in section 11, but please be aware that Our Site may not work properly if you do so. We have taken great care to ensure that your privacy is not at risk by allowing them.
The following first-party Cookies may be placed on your computer or device:
|Name of Cookie||Purpose||Strictly Necessary|
|_cfduid||Used by the content network, Cloudflare, to identify trusted web traffic.||Yes|
|XSRF-TOKEN||Ensures visitor browsing-security by preventing cross-site request forgery.||Yes|
|Swoopos_session||Used by the Swoopos Retail back office for security purposes.||Yes|