1.1. We, at SWSD Ltd. (“we, “us”, “our”, “S-PAY”, “SWSD ” or “Company”) are committed to keeping your information safe and secure.
1.2. SWSD Ltd. is a company incorporated in the United Kingdom at 21 Chase Side Avenue, Enfield, Middlesex, EN2 6JN, England.
1.3. Through our website (https://ico.s-pay.me) (“Website”) offering our related products and services such as participating in the sale by the Company of digital tokens (the “SPC Tokens”), you are subject to:
1.3.1. the Terms and Conditions during the Public Sale phase of the SPC Token
1.3.2 the possibility that through accessing documents contained on the Website or communicating electronically with us (collectively the “Services”), that we may collect, process or be provided with your personal data.
1.4. By visiting or continuing to use our Website you are accepting and consenting to the practices described in this policy.
1.6 This document does not constitute legal advice and should not be relied upon by any person. It is designed for general information purposes only. Visitors to our Website should consult their own counsel.
2. INFORMATION WE COLLECT
2.1. In operating our Website and providing our Services we may collect and process the following data about you:
2.1.1. details of your visits to our Website and the resources that you access, including but not limited to, traffic data, location data, web logs and other communication data.
2.1.2. information that you provide by filling in forms on our Website, such as when you register to access, apply to or receive our Services which includes (but is not limited to) your name, email, phone number, residential address, place of birth, date of birth, gender, official identification number, nationality, country of residence and source of wealth.
2.1.3. information provided to us when you communicate with us for any reason.
2.1.4. details contained in any request for support or assistance from us including resolving disputes or troubleshooting problems.
2.2. We endeavor only to capture information that is necessary to provide our Services to you in compliance with our legal and regulatory obligations.
3. LEGAL BASIS FOR COLLECTION
3.1. S-PAY may collect and process your information because:
3.1.1. we have a contract with you;
3.1.2. you have given us permission to do so;
3.1.3. you have applied for a Service from us; or
3.1.4. to comply with the law
4. USE OF YOUR INFORMATION
4.1. The information that we collect and store relating to you is primarily used to enable us to provide our Services to you. In addition, we may use the information for the following purposes:
4.1.1. to provide you with information requested from us, relating to our Services and to provide information on other Services which may be of interest to you, where you have consented to receive such information;
4.1.2. to improve our Website and our Services;
4.1.3. to verify your status and confirm any information you have provided to us;
4.1.4. to distribute SPT Tokens to you;
4.1.5. to verify compliance with the terms and conditions in relation to the use of our Services;
4.1.6. to compare the personal data provided with third party databases to verify its accuracy and confirm your identity to comply with relevant regulations that apply to our Company;
4.1.7. to meet our regulatory, legal and compliance obligations in meeting our obligations to you; or
4.1.8. to notify you about any changes to our Website or improvements and changes to our Services.
4.2. We will only contact you when you have provided consent and only by those means you have provided consent for.
5. DISCLOSURE OF YOUR PERSONAL DATA
5.1. We may disclose your personal data:
5.1.1. to a third party, if we are under a duty to disclose or share your personal data with them in order to comply with any legal obligation, or in order to enforce or apply our terms and conditions and other agreements, or to protect the rights, property, reputation, security and safety of our Website, applicants for SPC Tokens or others including exchanging information with or providing information to third parties; or
5.1.2. to any law enforcement or revenue authorities (when requested by them to do so) but only to the extent necessary to adequately deal with the requests made.
5.2. We may retain the services of a third party for the purposes of obtaining or engaging their external expertise. In such circumstances we may permit access to certain aspects of any applicant’s personal information or your information, but only once they have agreed to treat such personal information with the strictest levels of security and confidentiality.
6. ACCESS TO AND AMENDING YOUR PERSONAL DATA
6.1. At any time, you can make a written request to us to have access to all the personal information that we hold about you.
6.2. You may inform us of any changes in your personal information or data in accordance with our obligations to you by accessing our Website and communicating with us directly. It is your responsibility to contact us when information that you have provided to us is out of date or requires amendment.
6.3. We will confirm with you any amendments, updates or deletions of our personal data that you make in your request.
7.1. On occasion we may gather information about your computer or the personal device that you access the Website with to facilitate usage of our Services and to provide statistical information regarding the use of our Website.
7.2. Such information will not contain personally identifiable data and will solely be used by us for statistical purposes about our visitors and their use of our Website.
7.3. We may gather information about your general internet use by using a cookie file. These cookies are downloaded to your computer or personal device automatically and stored on the hard drive of your computer or personal device. It contains information that assists us in improving our Website and the Services we provide to you.
8. STORING YOUR PERSONAL DATA
8.1. Data that is provided to us is stored on secured servers managed, controlled or exclusively accessed by us. Details relating to any transactions entered on our Website will be encrypted to ensure its safety.
8.2. We may store and process your information using cloud services in various jurisdictions. The information we collect from you may also be transferred to or stored in jurisdictions outside of your country of residence. The laws and regulations processing such information in these locations may differ than in your country. It may also be processed by a party operating outside of your country including a third-party service provider or business partner. By submitting your information, you agree to this transfer, storing or processing of personal data. We will take all steps reasonably necessary to ensure that your information is treated securely and in accordance with this policy.
8.3. The transmission of information via the internet is not completely secure and therefore we cannot guarantee the security of data sent to us electronically and transmission of such data is entirely at your risk.
8.4. Where we have given you a password (or where you have chosen a password) to access certain parts of our Website or usage of our Services, you are responsible for keeping this password confidential.
8.5. We take all appropriate security measures in line with market driven best practice to protect your personal information.
9. RETENTION OF INFORMATION
9.1. S-PAY will not retain your personal information for longer than it is required.
9.2. We will keep your personal information:
9.2.1. for as long as required by law;
9.2.2. until we no longer have a valid reason for retaining it; or
9.2.3. until you request us to stop using it.
9.3. We may keep enough personal information from you to ensure that we comply with your requests not to use your personal information or comply with your right to erasure. For example, we must keep your request to be erased even if it includes your personal data until you are no longer our customer.
10. YOUR RIGHTS
10.1. Below are the rights that you may have under law, and what S-PAY does to protect those rights:
|Legal right||What S-PAY does to protect your rights|
|The right to be informed||S-PAY is publishing this Privacy Notice to keep you informed as to what we do with your personal information. We strive to be transparent about how we use your data.In addition, if there is a data breach that includes your personal information that results in a risk for your rights and freedoms as an individual we will notify you within 72 hours of first becoming aware of the breach.|
|The Right to Access||You have the right to access your information. Please contact us at [email protected] if you wish to access the personal information S-PAY holds about you.|
|The right to rectification||If the information S-PAY holds about you is inaccurate or not complete, you have the right to ask us to rectify it. If that data has been passed to a third party with your consent or for legal reasons, then we must also ask them to rectify the data. Please contact us you need us to rectify your information: [email protected]|
|The right to erasure||This is commonly known as ‘the right to be forgotten’. If you want S-PAY to erase all your personal data and we do not have a legal reason to continue to process and hold it, please contact us: [email protected]|
|The right to restrict processing||You have the right to ask S-PAY to restrict how we process your data. This means we are permitted to store the data but not further process it. We keep just enough data to make sure we respect your request in the future. If you want us to restrict processing of your data, please contact us: [email protected]|
|The right to data portability||S-PAY must allow you to obtain and reuse your personal data for your own purposes across services in a safe and secure way without this effecting the usability of your data. Please contact us if you want information how to port your data elsewhere: [email protected]. This right only applies to personal data that you have provided to us where we have determined the purposes and means of processing your personal data. The data must be held by us by consent or for the performance of a contract.|
|The right to object||You have the right to object to S-PAY processing your data even if it is based on our legitimate interests, the exercise of official authority, direct marketing (including data aggregation), and processing for the purpose of statistics. If you wish to object, please contact us: [email protected]|
|The right to withdraw consent||If you have given us your consent to process your data but change your mind later, you have the right to withdraw your consent at any time, and S-PAY must stop processing your data. If you want to withdraw your consent, please contact us: [email protected]|
|The right to complain to a Supervisory Authority||You have the right to complain to the Information Commissioner’s Office if you feel that S-PAY has not responded to your requests to solve a problem. You can find their contact details here: https://ico.org.uk/concerns/|
11. THIRD PARTY LINKS
11.1. You may find links to third party websites on our Website. These websites may have their own privacy policies which you should review.
11.2. We do not accept any responsibility or liability for their policies as we do not have control over them.
12. COMMUNICATIONS WITH US