Privacy

Last Updated: October 24, 2019

SWFI may collect, use and disclose personal data about users of its Sites so that it can carry out any obligations owed to users and for other related purposes, including monitoring and analysis of its business, crime prevention, legal and regulatory compliance, the marketing by SWFI of other services and transfer of any of SWFI’s applicable rights or obligations. SWFI will not disclose any personal data it collects about users to third parties except: (i) to the extent that it is required to do so by any applicable law or regulation; (ii) where there is a duty to the public to disclose; (iii) where SWFI’s interests require disclosure; or (iv) at a user’s request or with a user’s consent. SWFI may disclose personal data about users to those who provide services to SWFI or act as SWFI’s agents, to any person to whom SWFI transfers or proposes to transfer any of its applicable rights or obligations and to licensed credit reference agencies or other organizations that help SWFI and others make credit decisions and reduce the incidence of fraud or in the course of carrying out identity, fraud prevention or credit control checks. SWFI may also transfer information collected and held about users to any country, including countries outside the European Economic Area which may not have data protection laws, for any of the purposes described in this clause. Users may have a right of access to some or all of the personal data SWFI collects and holds about them, or to have inaccurate information corrected, under applicable data protection laws. If a user wishes to exercise such rights he should contact SWFI in writing.

Information Security
The security of your information is important to us. SWFI has implemented safeguards to protect the information we collect. However, no website or Internet transmission is completely secure. We urge you to take steps to keep your personal information safe, such as choosing a strong password and keeping it private, as well as logging out of your user account, and closing your web browser when finished using the SWFI Platform on a shared or unsecured device.

Children’s Privacy
SWFI does not knowingly collect or solicit personal information from anyone under the age of 13 (or under the age of 14 for anyone living in Spain or South Korea) or knowingly allow such persons to register. If we become aware that we have collected personal information from a child under the relevant age without parental consent, we take steps to delete that information.

Information Security and Cookies
Specifically, the information we collect automatically may include information like your IP address, device type, unique device identification numbers, browser-type, broad geographic location (e.g. country or city-level location), “click stream” data and other technical information. We also collect information about how your device has interacted with our websites and products, including the pages and products accessed and links clicked. Collecting this information enables us to better understand the visitors who come to our website and the users of our products and services, where they come from, and what content on our website and products and services is of interest to them.

We use this information: for our analytics purposes; to improve the quality and relevance to users, of our websites and products and services; to develop and update our websites and products and services; for customer services purposes, for instance, reviewing our customers’ training needs in respect of the use of our products; to satisfy SWFI’s customers’ requests regarding the use of our products and services by the individual users licensed by their corporate account (please note that such information in many instances and jurisdictions will be offered to clients in an aggregated form); note that customers may be required by law to request such information from SWFI; to send you tailored information on our products and services that we believe may be of interest or value to you and also marketing and promotional e-mails with your consent if and when required by applicable law; on rare occasions to identify unauthorized use or unauthorized distribution of our products and services related or unrelated to a security issue; where relevant, to review and / or update our pricing model agreed with our corporate customers; and for billing purposes, so that we or others (such as content providers) are able to bill for the services provided. Some of this information may be collected using cookies and similar tracking technology. Cookies are small data files that are placed on your computer or mobile device when you visit a website. Cookies are widely used by website owners in order to make their websites work, or to work more efficiently, as well as to provide reporting information.

You have the right to decide whether to accept or reject cookies. You can set or amend your web browser controls to accept or refuse cookies. If you choose to reject cookies, you may still use our website though your access to some functionality and areas of our website may be restricted. To learn how to manage your cookies, please follow the instructions from your specific browser.