Welcome to our privacy policy.

Swycha respects your privacy and is committed to protecting your personal data. This privacy policy will inform you as to how Swycha looks after your personal data when you purchase goods through our website or otherwise engage with us. 

  1. Introduction and how to contact Swycha

This privacy policy is intended to give you information on how Swycha collects and processes your personal data when you engage with us, including any data you may provide when: using this website, purchasing goods from us, providing us with feedback or taking part in a survey or competition we are hosting.

This website is not intended for use by anyone below 18 years of age, and we do not knowingly collect data relating to minors.

It is important that you read this privacy policy together with our Terms and Conditions or any other policies we may provide on specific occasions when we are collecting or processing personal data about you, so that you are fully aware of how and why we are using your data. This privacy policy supplements other notices and policies and is not intended to override them.

Swycha Ltd is a company registered in Jersey under company number 133782 and is the controller and is responsible for your personal data (collectively referred to as "Swycha”, "we", "us" or "our" in this privacy policy).

We have appointed a Data Privacy Manager 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, please contact the Data Privacy Manager using the details set out below:

Email address: hello@swycha.com

Postal address: Beauprt House, L’Avenue De La Commune, St Peter, Jersey, JE3 7BY, United Kingdom

Telephone number: +44 (0)1534 520250

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

We keep our privacy policy under regular review. This version was last updated on 14th May 2021. We will notify you of any changes to our privacy policy by email or by notification on this website. We will do our best to provide you with reasonable notice of any changes. It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data need updating during your relationship with us.

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave our website, we encourage you to read the privacy policy of every website you visit.

  1. The types of data we collect about you

Personal data, or personal information, 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 as follows:

  • Identity Data includes first name, last name, title, date of birth and gender.
  • Contact Data includes billing address, collection/delivery address, email address and telephone numbers.
  • Financial Data includes bank account and detail of your payment method (such as payment card details).
  • Transaction Data includes details about payments to and from you and details of the products you purchase.
  • Technical Data includes internet protocol (IP) address, your login data, browser type and version, time zone setting and location, browser plug-in types and versions, operating system and platform, and other technology on the devices you use to access this website.
  • Profile Data includes your username and password, information you provide when you create an account with us, your interests, preferences, feedback and survey responses.
  • Usage Data includes information about how you use our website and services.
  • Marketing and Communications Data includes your preferences in receiving marketing from us and our third parties and your communication preferences.

We may also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. 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. For example, we may aggregate your Usage Data to calculate the percentage of users accessing a specific website feature. 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 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.

Where we need to collect personal data by law, or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with a product you have ordered). In this case, we may have to cancel any orders you have placed with us, we will always let you know if this is the case at the time.

  1. How we collect your personal data

We use different methods to collect data from and about you such as:

  • Direct interactions. You may give us your Identity, Contact and Financial Data by corresponding with us through our website, phone and email or otherwise. This includes personal data you provide when you:
  • create an account on our website;
  • make a purchase on our website;
  • request marketing to be sent to you;
  • enter a competition, promotion or survey; or
  • give us feedback or otherwise contact us.
  • Automated technologies or interactions. As you interact with our website, we will automatically collect Technical Data about your equipment, browsing actions and patterns. We may collect this personal data by using cookies, server logs and other similar technologies. Please see our cookie policy for further details.
  1. How we use your personal data

We will only use your personal data when the law allows us. Most commonly, we will use your personal data in the following circumstances:

  • Where we need to perform the contract we are about to enter into or have entered into with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
  • Where we need to comply with a legal obligation.

Generally, we do not rely on consent as a legal basis for processing your personal data although we will get your consent before sending third party direct marketing communications to you via email or text message. You have the right to withdraw consent to marketing at any time by contacting us.

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.

Purpose/Activity

Type of data

Lawful basis for processing including basis of legitimate interest

To register you as a new customer

(a) Identity

(b) Contact

(a) Performance of a contract with you

To process and deliver your order including:

(a) Manage payments, fees and charges

(b) Collect and recover money owed to us

 

(a) Identity

(b) Contact

(c) Financial

(d) Transaction

(e) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary for our legitimate interests (to recover debts due to us)

 

To manage our relationship with you which will include:

(a) Notifying you about changes to our terms or privacy policy

(b) Asking you to leave a review, provide feedback or complete a survey

(c) When you partake in a prize draw or competition

(a) Identity

(b) Contact

(c) Profile

(d) Marketing and Communications

(a) Performance of a contract with you

(b) Necessary to comply with a legal obligation

(c) Necessary for our legitimate interests (to keep our records updated and to study how customers use our website, to inform our marketing strategy and provide incentives to encourage engagement with our business)

To administer and protect our business and this website (including troubleshooting, data analysis, testing, system maintenance, support, reporting and hosting of data)

(a) Identity

(b) Contact

(c) Technical

(a) Necessary for our legitimate interests (for running our business, provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganisation or group restructuring exercise)

(b) Necessary to comply with a legal obligation

To deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you

(a) Identity

(b) Contact

(c) Profile

(d) Usage

(e) Marketing and Communications

(f) Technical

Necessary for our legitimate interests (to study how customers use our services, to develop them, to grow our business and to inform our marketing strategy)

To use data analytics to improve our website, services, marketing, customer relationships and experiences

(a) Technical

(b) Usage

Necessary for our legitimate interests (to define types of customers for our services, to keep our website updated and relevant, to develop our business and to inform our marketing strategy)

To make suggestions and recommendations to you about services that may be of interest to you

(a) Identity

(b) Contact

(c) Technical

(d) Usage

(e) Profile

(f) Marketing and Communications

Necessary for our legitimate interests (to develop our services and grow our business)

We strive to provide you with choices regarding certain personal data uses, particularly around marketing and advertising. We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you.

You will receive marketing communications from us if you have requested information from us or placed and order with us and you have not opted out of receiving that marketing. We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by following the opt-out linkson any marketing message sent to you or by contacting us at any time. Where you opt-out of receiving these marketing messages, this will not apply to personal data provided to us as a result of service use and experience or for other transactions.

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 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.

  1. When we disclose your data

We may share your personal data with the parties set out below:

  • Internal third parties such as other companies in the Swycha group based in Jersey who may undertake leadership reporting;
  • Payment services provider who act as a processor by providing us with payment gateway and processing services;
  • I-fulfilment, The Runway, Christchurch, BH23 4FL, United Kingdom, who act as a processor by providing us with logistics and delivery services so we can process and delivery your order;
  • Professional advisers including lawyers, bankers, auditors and insurers who may provide consultancy, banking, legal, insurance and accounting services;
  • HM Revenue & Customs, regulators and other authorities who require reporting of activities in certain circumstances;
  • Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this privacy policy; or
  • To law enforcement or other authorities in relation to any investigations or the prevention of crime.

We require all third parties to respect the security of your personal data and to treat it in accordance with the law. We do not allow our third-party service providers to use your personal data for their own purposes and only permit them to process your personal data for specified purposes and in accordance with our instructions (unless otherwise permitted by law).

  1. Cookies

You can set your browser to refuse all or some browser cookies, or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of this website may become inaccessible or not function properly. For more information about the cookies we use, please see our cookie policy.

  1. International transfers

As we are a Jersey based entity when you provide us with your personal data this will involve transferring your data outside the UK. Jersey has an adequacy decision from the European Commission which means that Jersey is recognised as having laws that provide individuals with adequate protection when processing their personal data.

Whenever we transfer your personal data out of the UK, we ensure a similar degree of protection is afforded to it by ensuring at least one of the following safeguards is:

  • We will only transfer your personal data to countries that have been deemed to provide an adequate level of protection for personal data; or
  • Where we use certain service providers, we may use specific contracts approved for use which give personal data the same protection it has in the UK. 
  1. How we secure your data

We have put in place appropriate security measures to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Although we have put these measures in place, the security of the internet is not guaranteed, therefore any information provided by you through our website is at risk of interception beyond our control.

We limit access to your personal data to those employees, agents, contractors and other third parties who have a business need to know. They will only process your personal data on our instruction and they are subject to a duty of confidentiality.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

  1. How long we keep your data for

We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

  1. Your legal rights

Under certain circumstances, you have rights under data protection laws in relation to your personal data, such as:

  • To access to your personal data;
  • To request correction of your personal data;
  • To request erasure of your personal data;
  • To object to processing of your personal data;
  • To request restriction of processing your personal data;
  • To request transfer of your personal data; and
  • To withdraw consent to your personal data being processed.

More information about your legal rights can be found on the Information Commissioner’s website. If you wish to exercise any of the rights set out above, please contact us.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

Klarna

In order to be able to offer you Klarna’s payment options, we will pass to Klarna certain aspects of your personal information, such as contact and order details, in order for Klarna to assess whether you qualify for their payment options and to tailor the payment options for you.

General information on Klarna you can find here. Your personal data is handled in accordance with applicable data protection law and in accordance with the information in Klarna’s privacy policy.


Klarna Bank AB (publ) (“Klarna”) uses cookies to recognize the user’s device for the purpose of providing personalized advertising of Klarna products the next time the user will browse a merchant website offering Klarna products, and for analytics purposes.


Persistent marketing and analytics cookies
These cookies contain a unique user ID which will enable Klarna to recognize the user’s device the next time that user returns to a merchant using Klarna’s services. These are persistent cookies, stored on the device for a period of up to 540 days as of the last interaction with Klarna, or until they are deleted and allow Klarna (i) to show personalized marketing of Klarna products, including credit promotions to the user, and (ii) to perform analytics of the user behaviour.


By connecting the unique user ID stored in the cookie on the device to the information Klarna has about the user, Klarna will be able to recognize the user of that device. The information Klarna collects through the cookies is not shared with any third party.


The user’s consent and revocation of consent
Setting cookies for marketing purposes is subject to the user’s consent, which will have to be obtained before the cookies are set on the user’s device. In addition, the web browser or device often allows the user to change the settings for the use of cookies. More information on how to adjust the settings can be found in the browser of device reference information, and on aboutcookies.org.


About Klarna
Klarna Bank AB (publ) is subject to Swedish Data Protection legislation, and is the data controller for the purpose of processing the personal data as described above. Klarna has a data protection officer and a team consisting of personal data experts.

Klarna also has a customer service team handling questions relating to personal data. You are welcome to contact Klarna at dataskydd@klarna.se.

Please visit www.klarna.com for more information about Klarna, and how Klarna processes personal data.