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Privacy Policy

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As of 22 September 2022

This privacy statement explains how your personal data is handled by Sword Group whilst you browse our websites and where you submit information through our website, and your options regarding the ways in which your data is to be used.

Processing of Your Personal Data

Generally, you can visit our website without providing any personal data about yourself. However, in order to access some parts of our websites and/or for you to request specific information or services, we may need to collect personal data from you which we will process for the purposes described hereunder.

As part of pre-contractual and/or contractual obligations, we may process your personal data for:

  • answering any requests, queries or inquires you may submit on our website; but also
  • enabling you log on certain restricted parts of our website;
  • managing your participation to online context

We may also use the personal data you share with us, for:

  • maintaining and improving the website as well as to ensuring its security;
  • conducting customer satisfaction surveys;
  • manage the forums to which you may take part;
  • recruitment purposes related when you submit a resume or a job application online; and
  • compiling aggregate statistics regarding the use of the website.

These purposes are justified by our legitimate interest to make sure that you enjoy the experience when visiting our website and interacting with us.

GDPR & Your Rights

The GDPR establishes a harmonised regulatory framework across Europe that is directly applicable in each of the 28 Member States. This common language on the protection of personal data also applies to organisations outside the European Union that use data about the activities of EU organisations and residents.

While the French Data Protection Act already recognised individuals’ rights (opposition to processing subject to a legitimate reason, right of access to data, right of rectification/deletion), seven rights (including two new ones) are now highlighted or reinforced by the RGPD / GDPR:

Transparency of information and communications

  • Right of access to the data of the data subject
  • Right of rectification
  • Right to be forgotten (new)
  • Right to restriction of processing
  • Right to data portability (new)
  • Right to object

In the same spirit, the RGPD / GDPR formalises a number of obligations for organisations:

  • Accountability principle: the organisation must be able to demonstrate its compliance.
  • Information principle: individuals must be informed of their rights and explicitly agree to the collection and processing of their personal data.
  • Lawfulness principle: personal data can only be collected and used for a given and legitimate purpose, corresponding to the tasks of the controller.
  • Principle of minimisation: companies may only retain data that is strictly necessary for the performance of their activities. It is complemented by the principle of limited retention: the duration of data retention is limited to the performance of the contract (or to the legal retention obligations).
  • Privacy by Design & Privacy by default: security and data governance must be taken into account upstream of product/service design. Furthermore, security is no longer optional, but activated by default: the user no longer has to tick a box to protect his data.

Appointment of a DPO (Data Protection Officer): if the organisation uses personal data on a large scale. This is also mandatory for the public sector.

Registration and completing forms

When you make a general enquiry or complete any forms, you may be asked to provide personal information such as your name, address, email address, and telephone number.

The information is primarily used for administration purposes so we can process your enquiry. We maintain strict security standards and procedures with a view to preventing unauthorised access to your data by anyone, including our employees.

Transferring/sharing your data

We will not disclose your personal information unless we need to do so to handle your query.

In some cases there may requirement us to transfer your data outside of your country, for example information may be passed to and used by other subsidiaries of Sword Group (some of which may be outside the EU). Should this be the case, we will ensure that compliant confidentiality and data processing agreements in line with applicable data protection legislation are in place.

Cookies

Cookies are pieces of information that a website transfers to your computer’s hard drive for records keeping purposes. Cookies are very common, being used to improve how a website works. Cookies contain information that can be used on particular sites and to tailor a visitor’s experience on the website or provide data that can be used for analysis by our web servers.

Most browsers are initially set to accept cookies. If you would prefer, you can set your browser to disable cookies or to inform you when they are set. However, you may not be able to take full advantage of our website if you disable them.

Our website may use cookies to monitor website usage. This is statistical information allows us to manage and develop our website(s), for example to improve usability, or measure the popularity of a given web page. The information gathered does not identify you personally. Cookies cannot read data off your hard disk or read cookie files created by other sites or damage your system.

Cookies and the law
Our approach, your choice.

European privacy laws came into force in 2012 which require websites to inform users when placing ‘cookies’ on visitors computers, mobiles or other devices.

The Information Commissioner’s Office (ICO) is the organisation in the UK responsible for regulating the law.

Sword Group is committed to providing our website visitors with a clear understanding of how and why we use cookies. In this document, Sword gives information on how we use cookies and the steps that you can take to disable cookies. If you have concerns regarding any aspect of the way in which we deploy cookies on this website, please contact us.

How we use cookies

Our website uses cookies for two purposes: to monitor website usage and to store individual preferences for the site.

How to disable cookies

Please note, turning cookies off at the browser level could disable cookies on ALL sites you visit, and therefore disable functionality on other sites that use cookies.

To find out how to disable cookies in Microsoft Internet Explorer, please click here
To find out how to disable cookies in Firefox, please click here
To find out how to disable cookies in Google Chrome, please click here
To find out how to disable cookies in Safari, please click here

Google AdWords re-marketing

Our website uses the Google AdWords re-marketing service to advertise on third-party websites to users who have previously visited our website. This could be an advertisement on the Google search results page of a site within the Google Display Network.

Please note that third-party vendors, including Google, use cookies to serve ads based on past visits to our website. Any data collected will be used in accordance to the Sword Group privacy policy and Google’s own policy.

You can set your preferences for how Google advertise to you using the Google Ad Preferences page, and you can also opt out of interest-based advertising entirely by cookie settings or permanently using a browser plugin.

Data for direct marketing

We will not immediately enter personal data you provide to us on our marketing database. Where it may be relevant to do so and we feel you are interesting in hearing more of our services you will be given an opportunity to opt-in to electronic marketing and select your own preferences. At each further point of marketing communication individuals are given the opportunity to opt-out of receiving direct marketing activity. Where individuals want to receive marketing communication, we may provide information on:

  • Services and products that may be of interest.
  • Changes and improvements to the website.

Should you decide to change your mind on receiving such communications, select the opt-out option in the marketing communication or contact our Data Protection Officer at the details below.

Amend/update information

If you believe that any information held by us about you is incorrect or incomplete you should write to the Data Protection Officer at the address given below. Any information which is found to be incorrect will be corrected as soon as possible. Should you wish to access the data we hold about you at any time, you are welcome to write to the Data Protection Officer and make your request for a copy of the data. Any such request will be processed in accordance with the relevant data protection and privacy legislation.

Retention of Data

We will retain the data you give us for differing periods of time dependent on the reason you have supplied it to us, whether there is a need to retain the data and in accordance with our data retention policies. Such time frames will be guided by industry best practice and other relevant legislation.

Category

Policy

Contacts wishing to be informed about Sword Group activity such as shareholder meetings, annual results etc.

Data held: Name, company, position, email address

  • Retain user-identifiable data for no longer than 5 years after the user last confirmed their consent
  • Contact user every 5 years to confirm they still wish their data to be processed

Cookies

  • As per each cookie within the cookie control notice accessible from the bottom of each page.

Contacts calling or emailing any given Sword Group subsidiary regarding its services

  • Retain user-identifiable data for no longer than 5 years after the user last confirmed their consent
  • Contact user every 5 years to confirm they still wish their data to be processed

Notification of changes to the Privacy Statement

We may change the content of service found on our site at any time without notice and consequently our privacy policy may change at any time in the future. Please ensure to familiarise yourself with it from time to time.

The Data Protection Officer:
privacy@sword-group.com