SwiftNine EU Privacy Policy

Effective Date: 1 Jan 2025
Last Updated: 12 Aug 2025

I. Purpose

This European Union Privacy Policy (“Policy”) explains how SwiftNine (“we,” “our,” or “us”) handles and protects personal data belonging to individuals located in the European Economic Area (“EEA”) when you visit our website, interact with us, or use our services.Our aim is to ensure that all personal data is managed lawfully, securely, and transparently in compliance with applicable EU data protection laws, including the General Data Protection Regulation (“GDPR”).

II. Scope

This Policy applies to all SwiftNine entities and employees who process personal data from the EEA in any form—electronic, paper, or otherwise.

For the purposes of this Policy:

• Controller means the entity that determines how and why personal data is processed.
• Processing refers to any action performed on personal data, whether automated or not.
• ‍Data Subject means the identified or identifiable person to whom the personal data relates.
• ‍Sensitive Data refers to special categories of personal data as defined under the GDPR.
• Supplier refers to any third party providing goods or services to SwiftNine.

III. Compliance Commitment

SwiftNine is committed to meeting the requirements of the GDPR and other relevant EU legislation. We ensure that all processing of personal data is conducted in a lawful, fair, and transparent manner.

IV. Principles of Data Processing

When handling personal data, SwiftNine follows these principles:

• Lawfulness, Fairness & Transparency – We process personal data in a legal and open manner.
• Purpose Limitation – We collect personal data only for specific, clearly defined purposes.
• Data Minimization – We collect only the information we genuinely need.
• Accuracy – We keep personal data accurate and up to date.
• Storage Limitation – We retain personal data only for as long as it is needed.
• Integrity & Confidentiality – We protect personal data against loss, misuse, unauthorized access, or disclosure.
• Accountability – We maintain detailed records of our data processing activities and can demonstrate compliance when required.

V. Categories of Personal Data

Depending on your interactions with us, we may collect:

• Contact details (name, email address, phone number)
• Business information (company name, position, work address)
• Technical data (IP address, device type, browser type, operating system)
• Usage data (pages visited, time spent on site, interaction logs)

We do not intentionally collect sensitive personal data unless explicitly required and with your consent.

VI. Sources of Personal Data

We collect personal data from:

• Information you provide directly (e.g., when submitting forms, creating accounts, or contacting us)
• Your use of our website and online services (via cookies and analytics tools)
• Publicly available sources (e.g., professional directories, company websites)
• Trusted third-party partners who confirm that they have obtained your data lawfully

VII. Purpose of Processing

We process personal data to:

• Deliver and manage our services and business operations
• Communicate with you regarding inquiries, support requests, or updates
• Send you relevant marketing content (with your consent)
• Improve our website, services, and customer experience
• Meet legal or regulatory obligations

We do not sell or rent your personal data to third parties.

VIII. Data Security Measures

SwiftNine applies strong technical and organizational safeguards to protect personal data, including:

• Access controls and authentication
• Encryption of sensitive data in transit and at rest
• Regular security assessments and audits
• Employee training on data protection best practices

IX. Your Rights Under GDPR

If you are located in the EEA, you have the right to:

• Access your personal data
• Request corrections to inaccurate information
• Request deletion of your data (subject to legal retention requirements)
• Restrict or object to certain processing activities
• Receive your data in a portable format
• Withdraw consent at any time (where processing is based on consent)

You can exercise these rights by contacting us at privacy@swiftnine.com.

X. Data Transfers Outside the EEA

When transferring personal data outside the EEA, we implement appropriate safeguards such as:

• Standard contractual clauses approved by the European Commission
• Data transfer agreements with our suppliers and partners
• Compliance with applicable data protection laws in the receiving country

XI. Automated Decision-Making

SwiftNine does not engage in automated decision-making processes that produce legal or similarly significant effects on individuals.

XII. Contact Information

For questions, concerns, or to exercise your rights, please contact:

SwiftNine Limited
Email: office@swiftnine.com
Website: www.swiftnine.com