If you want to use certain features of the Website, you will have to create an account (“Account”) using your email address. You may also receive an invitation to proceed with the registration via the email used to register an account.
It is important that you provide us with accurate, complete and up-to-date information for your Account and you agree to update such information to keep it accurate, complete and up-to-date. If you don’t, we might have to suspend or terminate your Account. You agree that you won’t disclose your Account password to anyone, and you’ll notify us immediately of any unauthorised use of your Account. You’re responsible for all activities that occur under your Account, whether or not you know about them.
We collect personal information from you such as email address, phone number, or mailing address when you request information about our Services, register for our newsletter, or otherwise communicate with us.
We may contact you to participate in surveys. If you decide to participate, you may be asked to provide certain information which may include personal information.
We may offer interactive features such as forums, blogs, chat and messaging services, and social media pages. We and others who use our Services may collect the information you submit or make available through these interactive features. Any content you provide on the public sections of these features will be considered “public” and is not subject to the privacy protections referenced herein. By using these interactive features, you assume the risk that the personal information provided by you may be viewed and used by third parties for their own purposes.
If you call or otherwise interact with Trust Swiftly’s customer service and support, we may collect the information you provide to our representatives. In addition, we may record telephone calls between you and our representatives for training and quality assurance purposes.
We collect personal information when you voluntarily submit information to us. This can include information you provide to us when you register for a Customer account, fill in a form, respond to surveys, sign up for our mailing list, or otherwise communicate with us or provide information to Trust Swiftly.
If you choose not to provide personal information, we will not be able to provide you the Service or respond to or fulfil your other requests.
The below sets out the categories of personal information we collect about you and how we use that information also it lists the legal basis which we rely on to process the personal information.
Contact information and basic personal details. Such as your name, phone number, physical address, email address.
We use this information to operate, maintain and provide to you the features and functionality of the Service.
The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the ToS Agreement between Customer and Trust Swiftly).
We use this information to communicate directly with you to respond to your queries (for example, support requests) and to send Service-related emails (for example, account verification, change or updates to features of the Service, or technical and security notices).
This processing is necessary for our legitimate interests, namely, administering the Service and communicating with you in connection with the Service.
We use this information to send you news, alerts and marketing communications in accordance with your preferences.
We will only process your personal information in this way to the extent you have given us consent to do so.
Payment and transaction information. Payment information, such as the credit or debit card details; transaction information such as the Service purchased, date and time of the transaction.
We use this information to facilitate transactions. Note we use a third party payment provider that collects your credit or debit card details on our behalf; we do not store that information.
The processing is necessary for the performance of a contract and to take steps prior to entering into a contract (namely the ToS Agreement between Customer and Trust Swiftly).
Correspondence and comments. When you contact us directly, e.g. by email, phone, mail, when you respond to customer surveys or when you interact with customer service, we will record your comments and opinions.
To address your questions, issues and concerns and to resolve your customer service issues.
This processing is necessary for our legitimate interests, namely, administering the Service and communicating with you in connection with the Service.
All personal information set out above.
We will use all the personal information we collect to operate, maintain and provide to you the features and functionality of the Service, to monitor and improve the Service and business and to help us develop new products and services.
The processing is necessary for our legitimate interests, namely to administer and improve the Service and our business.
Information you submit and that we receive from third parties
We collect personal information from you when you submit information to the Service when it is deployed on a Customer site or when a Customer provides a direct link to the Service. The information we collect could include your name, date of birth, phone number, email address, photo of your driver license, street address, and other identification documents or indicators. We use this information to operate, maintain and provide the features and functionality of the Service, including to verify your identity on our Customer sites. You authorize your wireless carrier to use or disclose information about your account and your wireless device, if available, to Trust Swiftly or its service provider for the duration of your business relationship, solely to help them identify you or your wireless device and to prevent fraud.
We may also ask you to provide one or more photos of yourself at the request of our Customer. Trust Swiftly uses facial recognition technology for verification and fraud detection purposes. Face geometry data will be used to match the photo on your identity document with the photo(s) taken of yourself. This face geometry data will be destroyed when the information is no longer needed for verification and fraud detection purposes, or within 3 years of your last interaction with our Customer, whichever comes first.
We may receive information about you from third parties, including from our Customers when they provide us with information about you. We may also collect information about you that is publicly available on behalf of our Customers.
Please note that the Customer (on whose site the Service is deployed or that has provided you with a direct link to the Service) is the controller of this personal information.
Information we collect automatically
We also collect information automatically about the way in which you use the Service deployed on the Customer site (“Service Usage Data”). We are the controller of the Service Usage Data. The below sets out the Service Usage Data, how we use it and the corresponding information:
Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and other such information.
We use this information to monitor and improve the Service, and for other internal purposes.
The processing is necessary for our legitimate interests, namely to improve our Service generally, to monitor and resolve issues and for other internal purposes.
Information about the way you access and use the Service, for example, for example, what options you choose, the number of attempts you make, how much time it takes you, and other actions you take while using the Service.
We use this information to monitor and improve the Service, and for other internal purposes.
The processing is necessary for our legitimate interests, namely to improve our Service generally, to monitor and resolve issues and for other internal purposes.
Information about your location, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address.
We use this information to present the Service to you on your device and to enhance and personalize your experience on the Service.
The processing is necessary for our legitimate interests, namely to tailor the Service to you.
We use this information to monitor and improve the Service, and for other internal purposes.
The processing is necessary for our legitimate interests, namely to improve our Service generally, to monitor and resolve issues and for other internal purposes.
We automatically collect information about how you use and browse our Site and the device you use to access the Site. We typically collect this information through a variety of cookies and similar technologies, including web beacons, embedded scripts, location-identifying technologies, and file information. Please refer to section 3 below for more information on cookies and other tracking technologies that we use.
The below sets out the categories of personal information we collect about you automatically and how we use that information. It also lists the legal basis which we rely on to process the personal information.
Information about your device and its software, such as your IP address, browser type, Internet service provider, device type/model/manufacturer, operating system, date and time stamp, and other such information.
We use this information to present the Site to you on your device and to enhance and personalize your experience on the Site.
The processing is necessary for our legitimate interests, namely to tailor the Site to you.
We use this information to monitor and improve the Site, and for other internal purposes
The processing is necessary for our legitimate interests, namely to improve our Site generally, to monitor and resolve issues and for other internal purposes.
Information about the way you access and use our Site, for example, the site from which you came and the site to which you are going when you leave our Site, the pages you visit, the links you click, whether you open emails or click the links contained in emails, whether you access the Site from multiple devices, and other actions you take on the Site.
We use this information to present the Site to you on your device and to enhance and personalize your experience on the Site.
The processing is necessary for our legitimate interests, namely to tailor the Site to you.
We use this information to monitor and improve the Site, and for other internal purposes
The processing is necessary for our legitimate interests, namely to improve our Site generally, to monitor and resolve issues and for other internal purposes.
Information about your location, including GPS coordinates (e.g., latitude and/or longitude) or similar information regarding the location of your mobile device, or we may be able to approximate or infer a device’s location by analyzing other information, like an IP address.
We use this information to present the Site to you on your device and to enhance and personalize your experience on the Site.
The processing is necessary for our legitimate interests, namely to tailor the Site to you.
We use this information to monitor and improve the Site, and for other internal purposes
The processing is necessary for our legitimate interests, namely to improve our Site generally, to monitor and resolve issues and for other internal purposes.
Automatic Data Collection. We may collect certain information automatically when you use the Website. This information may include your registration date, Internet protocol (IP) address, user settings, MAC address, cookie identifiers, mobile carrier, details about your browser, operating system or device, location information (including inferred location based off of your IP address), Internet service provider, pages that you visit before, during and after using the Services, information about the links you click, information about how you interact with the Website, including the frequency and duration of your activities, and other information about how you use the Website. Information we collect may be associated with accounts and other devices.
Cookies, Pixel Tags/Web Beacons, and Analytics Information. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies (“Technologies”) to automatically collect information through the Services. Technologies are essentially small data files placed on your device that allow us and our partners to record certain pieces of information whenever you visit or interact with our Website.
Cookies. Cookies are small text files placed in device browsers to store their preferences. Most browsers allow you to block and delete cookies. However, if you do that, the Website may not work properly.
Pixel Tags/Web Beacons. A pixel tag (also known as a web beacon) is a piece of code embedded in the Website which collects information about engagement. The use of a pixel tag allows us to record, for example, that a user has visited a particular web page or clicked on a particular advertisement. We may also include web beacons in e-mails to understand whether messages have been opened, acted on, or forwarded.
Analytics. We may use Google Analytics and other service providers to collect and process analytics information on our Website.
For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the website by going to http://tools.google.com/dlpage/gaoptout.
How We Use Automatic Collection Technologies. We, as well as third parties that provide content, advertising, or other functionality on the Services, may use cookies, pixel tags, local storage, and other technologies to automatically collect information through the Services. Our uses of these Technologies fall into the following general categories:
The online advertising industry also provides websites from which you may opt out of receiving targeted ads from data partners and other advertising partners that participate in self-regulatory programs. You can access these websites and learn more about targeted advertising and consumer choice at www.networkadvertising.org/managing/opt_out.asp, http://www.youronlinechoices.eu/, https://youradchoices.ca/choices/, and www.aboutads.info/choices/ . Please note you must separately opt out in each browser and on each device.
Personal Information Use. Trust Swiftly shall use your personal information for a variety of business purposes, including:
To Provide Services or Information Requested, such as:
Administrative Purposes, such as:
Marketing Our Products and Services. We may use personal information to tailor and provide you with content and advertisements. We may provide you with these materials as permitted by applicable law. Some of the ways we market to you include email campaigns, custom audiences advertising, and “interest-based” or “personalised advertising” including cross-device tracking.
If you have any questions about our marketing practices or if you would like to opt out of the use of your personal information for marketing purposes, you may contact us at any time by emailing [email protected]
Consent. We may use personal information for other purposes that are clearly disclosed to you at the time you provide personal information or with your consent.
De-identified and Aggregated Information Use. We may use personal information and other data about you to create de-identified and/or aggregated information, such as de-identified demographic information, de-identified location information, information about the device from which you access our Services, or other analyses we create. De-identified and/or aggregated information is not personal information, and we may use and disclose such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes.
Trust Swiftly does not share, sell, rent or loan Personal Information with independent third parties. Nevertheless, we may access, preserve, and disclose any information we store in association with you to external parties if we, in good faith, believe doing so is required or appropriate to: (i) comply with law enforcement or national security requests and legal process, such as a court order or subpoena; (ii) protect your, our, or others’ rights, property, or safety; (iii) enforce our policies or contracts; (iv) collect amounts owed to us; or (v) assist with an investigation or prosecution of suspected or actual illegal activity.Under such circumstances where the law, a court order or other legal process prohibits notice prior to disclosure, none shall be provided.
We may share your personal information with the following categories of third parties:
Other Organisations at your Instruction. You may instruct Trust Swiftly to share your personal information, including your biometric data, with third parties for their own, independent purposes. Once you share your personal information with these parties, it will be subject to the privacy policy and practices of the receiving party. These third parties are not controlled by Trust Swiftly. We encourage our users to read the privacy policies of each third party with which they interact. We are not responsible for the privacy and security practices of such third parties. Disclosing your information to these third parties is at your own risk.
Service Providers. Trust Swiftly employs third party service providers. Where Personal Information is shared with a service provider each third party is required under contract with Trust Swiftly to secure all Personal Information with access permissions provided to only those employees who need it to complete a task on our behalf. The categories of service providers to whom we entrust personal information include service providers for: (i) the provision of information, products, and other services you have requested; (ii) marketing and advertising; (iii) payment and transaction processing; (iv) customer service activities; and (v) the provision of IT and related services.
Disclosure in the Event of Merger, Sale, or Other Asset Transfer. If we are involved in a merger, acquisition, financing due diligence, reorganisation, bankruptcy, receivership, purchase or sale of assets, or transition of service to another provider, then your information may be sold or transferred as part of such a transaction, as permitted by law and/or contract.
All information processed by us may be transferred, processed, and stored anywhere in the world, including but not limited to the United States or other countries, which may have data protection laws that are different from the laws where you live. We endeavour to safeguard your information consistent with the requirements of applicable laws. Further details can be provided upon request.
General. You may have the right to opt out of certain uses of your personal information.
Email Communications. If you receive an unwanted email from us, you can use the unsubscribe link found at the bottom of the email to opt out of receiving future emails. Note that you will continue to receive transaction-related emails regarding products or Services you have requested. We may also send you certain non-promotional communications regarding us and our Services, and you will not be able to opt out of those communications (e.g., communications regarding updates to our Terms of Service or this Privacy Notice).
Mobile Devices. We may send you push notifications through our mobile application. You may at any time opt-out from receiving these types of communications by changing the settings on your mobile device. With your consent, we may also collect precise location information if you use our mobile applications. You may opt-out of this collection by changing the settings on your mobile device.
For purposes of the California Consumer Privacy Act, we do not “sell” your personal information.
In accordance with applicable law, you may have the right to: (i) request confirmation of whether we are processing your personal information; (ii) obtain access to or a copy of your personal information; (iii) receive an electronic copy of personal information that you have provided to us, or ask us to send that information to another company (the “right of data portability”); (iv) object to our processing of your personal information (v) restrict our uses of your personal information; (vi) seek correction or amendment of inaccurate, untrue, incomplete, or improperly processed personal information; (vii) withdraw your consent; and (viii) request erasure of personal information held about you by us, subject to certain exceptions prescribed by law. If you would like to exercise any of these rights, please contact us as set forth below.
We will process such requests in accordance with applicable laws. To protect your privacy, we will take steps to verify your identity before fulfilling your request.
If you are a California resident, you have the right not to receive discriminatory treatment by Trust Swiftly for the exercise of your rights conferred by the California Consumer Privacy Act.
We store the personal information we receive as described in this Privacy Notice for as long as necessary to fulfil the purpose(s) for which it was collected, resolve disputes, establish legal defences, conduct audits, pursue legitimate business purposes, enforce our agreements, and comply with applicable laws. We will delete your data within three years of your last interaction with the Website.
We take steps to ensure that your information is treated securely and in accordance with this Privacy Notice. Unfortunately, no system is 100% secure, and we cannot ensure or warrant the security of any information you provide to us. To the fullest extent permitted by applicable laws, we do not accept liability for unauthorised disclosure.
By using the Website, you agree that we may communicate with you electronically regarding security, privacy, and administrative issues relating to your use of the Website. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services, by mail or by sending an email to you.
The Services are not directed to children under 13 (or other age as required by local law), and we do not knowingly collect personal information from children. If you learn that your child has provided us with personal information without your consent, you may contact us as set forth below. If we learn that we have collected any personal information in violation of applicable law, we will promptly take steps to delete such information and terminate the child’s account.
If you are located in the European Economic Area or the United Kingdom, you have the right to lodge a complaint with a supervisory authority in your jurisdiction if you believe our processing of your personal information violates applicable law. This Privacy Policy is governed by the applicable laws in the United States.
We may revise this Privacy Notice from time to time in our sole discretion. If there are any material changes to this Privacy Notice, we will notify you as required by applicable law. You understand and agree that you will be deemed to have accepted the updated Privacy Notice if you continue to use the Services after the new Privacy Notice takes effect.
General questions about our privacy practices, or this Privacy Notice: [email protected]