eSwapp

Company Number 11644477

24 Holborn Viaduct, London, EC1A 2BN, United Kingdom

1 March 2021

Privacy Policy

1. INTRODUCTION

1.1            Important information and who we are

Welcome to eSwapp’s Privacy and Data Protection Policy (“Privacy Policy”).

At eSwapp (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

      • Customers
      • Visitors to our website who sign up to use our product(s)
      • Anyone who uses our product(s).

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2           Who is Your Data Controller and Data Protection Officer

eSwapp is your Data Controller and responsible for your Personal Data.

We have appointed a data protection officer (“DPO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the DPO using the details set out below:

Full name: Ghazal Diani

Email address: info@eswapp.com

Postal address: 24 Holborn Viaduct, London, EC1A 2BN, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3           Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

      • Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
      • Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
      • Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
      • Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
      • Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
      • Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
      • Maintain a record of all categories of processing activities carried out on behalf of a Controller;
      • Cooperate, on request, with the supervisory authority in the performance of its tasks;
      • Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
      • Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
      • Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority; and
      • Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain their expert knowledge;

2. LEGAL BASIS FOR DATA COLLECTION

2.1           Types of Data / Privacy Policy Scope

Personal Data” means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

We may collect, use, store and transfer different kinds of Personal Data about you which we have grouped together below. Not all of the following types of data will necessarily be collected from you but this is the full scope of data that we collect and when we collect it from you:

      • Profile/Identity Data: This is data relating to your first name, last name, location (city and country) and your profile photo. It also includes any information you may provide in your profile.
      • Contact Data: This is data relating to your phone number, email addresses and any other contact details you may provide us with.
      • Technical Data: This is your IP address, browser type and version, time zone setting and location, operating system and platform, and other technology on the devices you use to engage with us.
      • Customer Support Data: This includes feedback and survey responses.
      • Usage Data: information about how you use our website, products and services.

We also collect, use and share Aggregated Data such as our data showing the number of employees from particular organisations that want to use our services. Aggregated Data could be derived from your Personal Data but is not considered Personal Data in law as this data will not directly or indirectly reveal your identity. However, if we combine or connect Aggregated Data with your Personal Data so that it can directly or indirectly identify you, we treat the combined data as Personal Data which will be used in accordance with this Privacy Policy.

We may also aggregate data to enable research or analysis so that we can better understand and serve you and others. For example, we may conduct research on your demographics and usage. Although this aggregated data may be based in part on Personal Data, it does not identify you personally. We may share this type of anonymous data with others, including service providers, our affiliates, agents and current and prospective business partners.

We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do we collect any information about criminal convictions and offences.

2.2           The Legal Basis for Collecting That Data

There are a number of justifiable reasons under the GDPR that allow collection and processing of Personal Data. The main avenues we rely on are:

      • Consent”: Certain situations allow us to collect your Personal Data, such as when you tick a box that confirms you are happy to receive email newsletters from us, or ‘opt in’ to a service.
      • Contractual Obligations”: We may require certain information from you in order to fulfil our contractual obligations and provide you with the promised service.
      • Legal Compliance”: We’re required by law to collect and process certain types of data, such as fraudulent activity or other illegal actions.
      • Legitimate Interest”: We might need to collect certain information from you to be able to meet our legitimate interests – this covers aspects that can be reasonably expected as part of running our business, that will not have a material impact on your rights, freedom or interests. Examples could be your address, so that we know where to deliver something to, or your name, so that we have a record of who to contact moving forwards.

3. HOW WE USE YOUR PERSONAL DATA

3.1           Our Uses

We will only use your Personal Data when the law allows us to. Set out below is a table containing the different types of Personal Data we collect and the lawful basis for processing that data. Please refer to section 2.2 for more information on the lawful basis listed in the table below.

Examples provided in the table below are indicative in nature and the purposes for which we use your data may be broader than described but we will never process your data without a legal basis for doing so and it is for a related purpose. For further inquiries please contact our Data Protection Officer.

Activity

Type of data

Legal Justification

Lawful basis for processing data

When you sign up to use one of our products.

Contact Data,

Marketing and Communications Data

Consent

We need to process this data so we can let you know when our product is ready for you to use.

When you create a profile on one of our platforms.

Profile/Identity Data,

Contact Data

Consent

We need to process this data so that we can match you with the most relevant user for you to exchange skills with.

When you use our Products to carry out skill sharing activities

Usage Data

Consent,
Legitimate Interest

We need to process this data so that we can deliver our Products, including personalising features and content (making them more relevant to you) and making suggestions for you (such as people you may be interested in sharing skills with or skills you may want to add to your repertoire) on and off our Products. To create personalised Products that are unique and relevant to you, we use your skills, skill aspirations and activities based on the data we collect and learn from you and others; how you use and interact with our Products; and the people, places, or things you’re connected to and interested in on and off our Products.

 

3.2           Marketing and Content Updates

You will receive marketing and new content communications from us unless you specifically request that you would not like to receive these communications. From time to time we may make suggestions and recommendations to you about products that may be of interest to you.

3.3           Change of Purpose

We will only use your Personal Data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact our Data Protection Officer.

If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

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