Privacy Policy

Updated: May 2024

 

This Privacy Notice describes the information Swann Communications Ltd and its subsidiaries (including, but not limited to Swann Communications U.S.A. Inc., Swann Communications Pty Ltd, Swann Communications (Europe) Limited) (“Swann Communications”, “we”, “our”, or “us”) collects, how we use and retain this information, with whom we share it, and the choices you have in connection with these activities. This Privacy Notice applies to the Swann Communications’ websites (swann.com domains) (collectively, the “Website”), cloud services, device software, and mobile applications (“Mobile Apps”), owned and controlled by Swann Communications (collectively, our “Services”).In certain jurisdictions, Swann Communications may adopt a separate privacy policy to reflect the requirements of applicable local laws.

 

1. OUR ROLE IN DATA PROCESSING 

For residents of the European Union (“EU”) and United Kingdom (“UK”), the entity responsible for the collection and use (processing) of your personal data is Swann Communications (Europe) Limited (a subsidiary of Swann Communications Ltd), incorporated and registered in England and Wales under company number 06659777, whose registered office address is at First Floor, 2 Canon Harnett Court, Wolverton Mill, Milton Keynes, MK12 5NF. Under the UK General Data Protection Regulation and/or EU General Data Protection Regulation (collectively, “EU data protection law”), Swann Communications is a controller in relation to its processing of personal data through the Services. As used in this Privacy Notice, the term “personal information” includes the term “personal data” as defined under other countries data protection and privacy laws.

 

2. PERSONAL INFORMATION WE COLLECT, HOW WE USE IT, HOW LONG WE KEEP IT, AND HOW WE SHARE IT 

When you interact with our Services, we collect your personal information. Personal information is information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household. Except as otherwise indicated, the personal information we collect is such that we need to carry out the requested action. If you do not provide us with your personal information, we would not be able to do so. We use the following criteria to determine whether it remains reasonably necessary to retain your personal information for one or more disclosed operational purpose, or a service provider or contractor’s operational purpose(s): (i) whether there is a retention period required by statute or regulations; (ii) the existence of actual or threatened litigation for which we are required to preserve the information; (iii) the statutes of limitations for potential legal claims; and (iv) generally accepted best practices in our industry, including related to safety and security of our properties and assets. When we determine that it is no longer reasonably necessary to retain your personal information for one or more disclosed operational purposes based on the above criteria, we will delete your personal information. Below are the circumstances under which we collect, share, and retain your personal information.

 

A. When you engage with our Mobile Apps 

We will collect your personal information when you: 

• Register for the Mobile Apps. When you use the Mobile Apps, we will collect your registration information, which includes your personal identifiers (name, email address, country) and device information (product code, product name, registration date, number of devices, any subscription details). In addition, if you are a professional monitoring subscriber we will collect additional identifiers (telephone number, home address), and identifiers of your emergency contacts (name, email address, telephone number) to send emergency services if required. We will use this information to register your account and connect you with your security devices, and the services, such as professional monitoring, you have agreed for Swann to provide. We will retain this information for as long as necessary for the business purpose or to fulfill our legal obligations, unless you request to delete it, in which case we will only retain the information we have a legal obligation to retain. With your consent, we will use your email address to provide marketing emails regarding Swann Communications products and services. We will share your identifiers (name email address, country) with our email marketing provider to send you the marketing emails. You can unsubscribe at any time by clicking on the “unsubscribe” link in each email. Please note that we will continue to send you notifications necessary to the Services, or requested products or services, including periodic e-mails informing you of technical service issues related to a product or service you requested. Our communications contain tracking technologies to analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. For US residents, when you opt-in to our marketing communications, you are opting into the use of these technologies. You can avoid downloading the tracker by rejecting the download of images in the email. You can revoke your consent at any time with effect moving forward by emailing us at [email protected]. To the extent EU data protection law applies, the legal basis for this processing is your consent.
• Log In to the Mobile Apps. When you log in to the Mobile Apps, we will collect your personal identifiers (email and password). To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you.
• Automatic Data Collection.In addition to the personal information identified above, when you use the Mobile Apps, we and our third-party provider collects your internet and other electronic network activity (including IP Address) via SDKs to make the Mobile Apps work as you expect it to and to provide enhanced functionality as described below. Some of the SDKs we use will store and retrieve information on your device, like a cookie or other similar tracker would.
  • Essential SDKs: We use essential SDKs which are necessary for the Mobile Apps to function. If you do not provide this information, we would not be able to provide the Mobile Apps. To the extent EU data protection law applies, the legal basis for this our legitimate interest in providing well-functioning Mobile Apps.
  • Performance SDKs: When you use the Mobile Apps, we automatically collect, through our third party SDK provider, your internet and other electronic network activity (including IP Address) regarding your device and use of the Mobile Apps. Swann Communications uses the information to test the performance of and improve the Mobile Apps for all users. This information is shared with our third party SDK provider on an aggregated and anonymized basis.To the extent EU data protection law applies, the legal basis for this is your consent. 

• The normal use of Swann’s Mobile Apps requires that they communicate and share data with other security devices of your choosing. However, the sharing of data is only for the Mobile Apps to understand the current state of those devices and no user information or any other identifying data is transmitted or stored.
• Swann Communications directors and personnel do not and cannot access any personal information or video and electronic surveillance data, except for very limited circumstances (e.g., compliance with applicable law, incidental access for support and maintenance). 

 

B. When you interact with our Website, we collect your personal information when you: 

• Create an online account. When you create an online account, we will collect your personal identifiers (name, email address, mailing address, and telephone number). We will use this information to set up your account, and to provide you services you have opted to receive, such as professional monitoring. With your consent, we will also use your email address to provide marketing emails regarding Swann Communications products and services. We will share your identifiers (name, email address, mailing address and telephone number) with our email marketing provider to send you the marketing emails. You can unsubscribe at any time by clicking on the “unsubscribe” link in each email. Please note that we will continue to send you notifications necessary to the Services, or requested products or services, including periodic e-mails informing you of technical service issues related to a product or service you requested. Our communications contain tracking technologies to analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. For US residents, when you opt-in to our marketing communications, you are opting into the use of these technologies. You can avoid downloading the tracker by rejecting the download of images in the email. You can revoke your consent at any time with effect moving forward by emailing us at [email protected]. To the extent EU data protection law applies, the legal basis for this processing is your consent.
• Log In to your account. When you log in to your account through the Website, we will collect from you your identifiers (email address and password). We will use this information to authenticate you to your account. To the extent EU data protection law applies, the legal basis for processing this information is to perform a contract with you.
• Complete surveys or provide online feedback or product reviews. When you complete a survey or provide feedback or product reviews, we will collect your identifiers (name, username), and any other information you provide in the survey, feedback, or product review. We will use it to process the results of the survey, review your feedback and contact you to provide any further assistance, and publish the product review (with your permission under our Terms of Service). To the extent EU data protection law applies, the legal basis for processing this information is to perform a contract with you.
• When you submit an enquiry using the Website. When you submit an enquiry, we will collect your identifiers (name, email address, telephone number, company name, country of location) and anything else you include in your enquiry. We will use this information to process your enquiry, and correspond with you to provide further customer support. To the extent EU data protection law applies, the legal basis for processing this information is to perform a contract with you.
• Subscribe to our Mailing List.When you subscribe to our mailing list, we collect your personal identifiers (name, email address, mailing address, telephone number) and your notification preferences. We use this personal information to fulfill your request to receive Swann Communications alerts and other communications. With your consent, we will share your identifiers (name, telephone number, email address, country) with our SMS and email marketing providers to send you the SMS and email marketing messages. To the extent EU data protection law applies, the legal basis for processing this information is consent. You can unsubscribe at any time by clicking on the “unsubscribe” link in each email or sending “STOP” to any SMS message. Please note that we will continue to send you email notifications necessary to the Services or requested products or services, including periodic e-mails informing you of technical service issues related to a product or service you requested. Our communications contain tracking technologies, to analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. For US residents, when you opt-in to our marketing communications, you are opting into the use of these technologies. You can avoid downloading the tracker by rejecting the download of images in the email. You can revoke your consent at any time with effect moving forward by emailing us at [email protected]. To the extent EU data protection law applies, the legal basis for this is your consent.
• Use the Swann Assistant. When you use the live chat functionality of the website, we will collect your identifiers (name) and any other information you provide in your communication through the live chat functionality. We use this information to provide efficient customer service to you. We share this information with our third-party live chat provider in order facilitate the communication and efficient customer service experience. To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you. If you do not provide the information requested, we will not be able to provide the customer service you request.
• Automatic Data Collection. In addition to the personal information you provide directly to us, we use essential, functional, analytics, and advertising cookies to collect your internet or other electronic network activity information (device, usage, location information (determined through your IP address), such as your browsing history, configuration, unique online identifiers, and interactions with our ads on third-party websites), when you interact with the Website. We use this information to: (i) track you within the Website; (ii) enhance user experience; (iii) conduct analytics to improve the Website; (iv) prevent fraudulent use of the Website; (v) diagnose and repair Website errors, and, in cases of abuse, track and mitigate the abuse; and (vi) market to you more effectively across different web pages and social media platforms (targeted advertising). For more information on these cookies, including a list of third-party marketing and analytics cookies, visit our Cookie Policy. To opt-out of the sharing of the personal information, visit Do Not Sell or Share My Personal Information. To the extent EU data protection law applies, the legal basis for this is your consent. 

To control the information collected about you using cookies and other technologies see our Cookie Policy. In general, to disable cookies and limit the collection and use of information through them, you can set your browser to refuse cookies or indicate when a cookie is being sent. When you opt-out an opt-out cookie will be placed on your device. The opt-out cookie is browser and device specific and will only last until cookies are cleared from your browser or device. You can also manage your cookie preferences via our cookie management platform Cookie Preferences.

 

C. When you, as a retailer, enquire and engage use to purchase our goods and services, we collect your personal information when you: 

• Communicate with us. When you communicate with us to purchase our goods and services, we will collect from you your identifiers (customer representative name, email address, business address, business telephone number). We will use this information to communicate with you about the products and services and to conduct business with you. To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you. Your name and address will be shared with our distribution partner to facilitate the shipment of the products to you. With your consent, we will use your phone number and email address to provide marketing text messages and emails regarding Swann Communications’ products and services that may be of interest to you. We will share your identifiers (name, telephone number and email address) with our SMS and email marketing providers to send you the SMS and email marketing messages. You can unsubscribe at any time by clicking on the “unsubscribe” link in each email or sending “STOP” to any SMS message. Please note that we will continue to send you email notifications necessary to the goods or services, or requested products or services, including periodic e-mails informing you of technical service issues related to a product or service you requested. Our communications contain tracking technologies to analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. For US residents, when you opt-in to our marketing communications, you are opting into the use of these technologies. You can avoid downloading the pixel by rejecting the download of images in the email. You can revoke your consent at any time with effect moving forward by emailing us at [email protected]. To the extent EU data protection law applies, the legal basis for this processing is your consent.
• Purchase our goods and services. When you purchase our goods and services, we will collect from you your identifiers (customer representative name, email address, business address, business telephone number), and financial account information (credit card number, expiration date, CVV, or account number and routing number). We will use this information to process your payment and facilitate the shipping of the goods. If you make payments by credit card, we will share your personal identifiers and payment card information with our payment processor. Your name and address will be shared with our distribution partner to facilitate the shipment of the products to you. To the extent EU data protection law applies, the legal basis for the processing of your personal data is the performance of a contract with you.

 

D. Generally, when you interact with our Services: 

• Contact us with an inquiry.
  • When you contact us or submit an inquiry by email, we collect your personal identifier (name and email address) and any other information you choose to include in your correspondence. We use this personal information to respond to your questions or inquiries, troubleshoot as necessary, and address any issues you have with our Services. We will share this personal information with our third-party customer service provider to assist us with handling customer service requests. We share this information with our email communication provider to facilitate our communication with you.   To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you.
  • When you call to speak with our customer service representatives, with your consent, we will record the telephone call and collect your identifiers (name, email address, telephone number), auditory information (recording of your voice), and any information you provide during the call (customer service ticket/case ID number, geographic location, product details). Your information will be shared with our third-party customer service provider to facilitate our customer service support. To the extent EU data protection law applies, the legal basis for this processing is your consent. If you decide to purchase goods or services over the phone, we will also collect your financial account information (bank account and routing number, or credit card number, expiration date, CVV, or account number and routing number). We will use this information to process your payment and facilitate the shipping of the goods. If you make payments by credit card, we will share your personal identifiers and payment card information with our payment processor. Your name and address will be shared with our distribution partner to facilitate the shipment of the products to you. To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you.
• Register an extended warranty. When you register an extended warranty, we collect your identifiers (name, email address, telephone number), and your product information. We will use this information to process your request in accordance with our contract with you. To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you.
• Enter competitions or promotions. When you enter a competition or promotion, we will collect your identifiers (name, email address, telephone number). We will use this information to enter you into the promotion or competition. Please review the Notice of Financial Incentive Section for more information promotions in which we obtain your information in exchange for a certain benefit to you. With your consent, we will use your email address to provide marketing emails regarding Swann Communications products and services that may be of interest to you. We will share your identifiers (name, telephone number and email address) with our SMS and email marketing providers to send you SMS and email marketing messages. You can unsubscribe at any time by clicking on the “unsubscribe” link in each email or sending “STOP” to any SMS message. Please note that we will continue to send you email notifications necessary to the goods or services, or requested products or services, including periodic e-mails informing you of technical service issues related to a product or service you requested. Our communications contain tracking technologies to analyze whether a predefined action took place by a recipient, such as opening our communications, in order to better adapt and distribute our communications. For US residents, when you opt-in to our marketing communications, you are opting into the use of these technologies. You can avoid downloading the pixel by rejecting the download of images in the email. You can revoke your consent at any time with effect moving forward by emailing us at [email protected]. To the extent EU data protection law applies, the legal basis for this processing is your consent.
• Request a repair. When you request a repair of our products, we will collect your identifiers (name, email address, mailing address), and any other information you include in your request. We use this information to process your repair request and troubleshoot potential issues. To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you. If you return goods to Swann Communications to be repaired, we will share this information with our repairs system administrator and authorized repairers. If you send goods to Swann Communications on which personal information is stored for a repair (for example, on a Security Recorder) and do not delete that personal information, we will delete this information at the commencement of the repair process. The onus is on the user to save personal information and video files prior to the repair process commencing.
• Return goods. When you return a product, we will collect your identifiers (name, email address, mailing address), and any other information you include in your return. We use this information to process your product return and troubleshoot potential issues. To the extent EU data protection law applies, the legal basis for this processing is to perform a contract with you. If you return goods to Swann Communications on which personal information is stored (for example, on a Security Recorder) and do not delete that personal information, we will delete this information on receipt of the returned goods. The onus is on the user to save personal information and video files prior to the return (e.g., warranty) process commencing.
• Utilize facial recognition functionality. Some Swann Communications products include facial recognition as an optional feature and if the user chooses to use that feature, they need to voluntarily select or ‘enroll’ the images of the faces they wish to include for recognition. The facial recognition data is stored locally on the device within the user’s premises and not sent across the network or to Swann’s cloud platform. The facial recognition processing is done on the User’s device itself, and Swann Communications has no access to such data.

 

E. When you apply for employment at Swann Communications:

• When you apply for employment with Swann Communications, we collect from you your personal identifiers (name, email address, and telephone number) your professional or employment information (resume, employment history, and LinkedIn Profile URL), criminal record information (if applicable), and protected classifications (gender, race, ethnicity, work authorization status, veteran status, and disability status (if provided)). We use this personal information to assess and manage your application with Swann Communications and as necessary to comply with the law. If the applicant joins Swann Communications their personal information will be retained in their personnel file and may be deleted upon request from the applicant. If the applicant is unsuccessful their personal information will be deleted. For additional information on our applicant privacy practices, please see our [Applicant Privacy Notice]. To the extent EU data protection law applies, the legal basis for this is performance of a contract with you.

 

3. HOW WE SHARE YOUR PERSONAL INFORMATION 

A. General Sharing 

Swann Communications shares personal information in the following instances: 

• Within Swann Communications. We share your personal information within Swann Communications for the legitimate business purposes of efficiently and effectively providing the Services, such as accounting, sales, manufacturing, and customer service support. Access to your personal information is limited to those on a need-to-know basis. To the extent EU data protection law applies, the legal basis for this is our legitimate interest in providing the Services more efficiently. 

• With service providers. We share personal information with service providers that assist us in providing the Services. These service providers are described more specifically in the PERSONAL INFORMATION WE COLLECT, HOW WE USE IT, HOW LONG WE KEEP IT, AND HOW WE SHARE IT section of this Notice, and the section below, “Sharing for a Business Purpose.” To the extent EU data protection law applies, the legal basis for this is our legitimate interest in providing the Services more efficiently. 

• In the event of a corporate reorganization. In the event that we enter into, or intend to enter into, a transaction that alters the structure of our business, such as a reorganization, merger, acquisition, sale, joint venture, assignment, consolidation, transfer, change of control, or other disposition of all or any portion of our business, assets or stock, we would share personal information with third parties, including the buyer or target (and their agents and advisors) for the purpose of facilitating and completing the transaction. We would also share personal information with third parties if we undergo bankruptcy or liquidation, in the course of such proceedings. To the extent EU data protection law applies, the legal basis for this is our legitimate interest in carrying out our business operations. 

• For legal purposes. We will share your personal information where we are legally required to do so, such as in response to court orders, law enforcement or legal process, including for national security purposes; to establish, protect, or exercise our legal rights, as required to enforce our terms of service or other contracts; to defend against legal claims or demands; to detect, investigate, prevent, or take action against illegal activities, fraud, or situations involving potential threats to the rights, property, or personal safety of any person; or to comply with the requirements of any applicable law. To the extent EU data protection law applies, the legal basis for this is compliance with legal obligations. 

• With your consent: Apart from the reasons identified above, we may request your permission to share your personal information for a specific purpose. We will notify you and request consent before you provide the personal information or before the personal information you have already provided is shared for such purpose. You may revoke your consent at any time. 

Swann Communications may also share anonymized and aggregated data (“De-Identified Information”) in marketing materials. Swann Communications may also use De-Identified Information for commercial collaborations with private companies for purposes such as product design or enhancement of programs we provide.

 

B. Sharing for a Business Purpose 

In the preceding 12 months, Swann Communications has disclosed the following personal information for a business purpose with the following categories of third parties: 

• We have disclosed your internet or other electronic network information collected by SDKs to optimize performance of our Mobile Apps.
• We have disclosed your internet or other electronic network information collected by cookies to our IT support to update, improve, and maintain the Website.
• We have disclosed your financial information with our payment processors and/ or financial institutions to facilitate your purchase through our Services.
• We have disclosed your identifiers, internet or other electronic network information, with our data infrastructure and cloud data storage and host provider to provide the functionality of the Services.
• We have disclosed your identifiers and anything else you include in your customer service inquiries with our customer service support providers to better provide our customer service to you.
• We have disclosed your identifiers and Swann Assistance communications with our third party live chat provider to provide the live chat functionality.
• We have disclosed your identifiers (name, phone number and email address) with our SMS and email marketing provider to send promotional messages to you.
• We have disclosed your name, phone number and mailing address to our distribution provider in order to ship the products you purchased to you.

 

C. Sale of Personal Information

 Swann Communications has shared your internet or other electronic network activity information collected via cookies, SDKs, and other tracking technologies with our data analytics providers, cookie providers, and ad networks to provide targeted advertising. Such sharing may be deemed a sale or sharing under the CPRA. To opt-out of this sale/sharing, please visit Do Not Sell or Share My Personal Information.

 

4. GENERAL INFORMATION CHOICES 

You have the following choices with respect to your personal information: 

• Correct or view your personal information. You may access your Swann Communications account profile to correct or view certain personal information of yours in our possession and which is associated with your profile. 

• Opt-out of marketing communications. You may opt-out of receiving marketing emails from us by clicking the “unsubscribe” link provided with each email. Please note that we will continue to send you emails necessary to the Services or any assistance you request. 

• Location settings.You can prevent your mobile device from sharing your location data by adjusting the permissions on your mobile device or within the Services. 

• Push notifications. If you have enabled push notifications, you may disable these at any time by updating your device settings. 

• Uninstall the Mobile Apps. You can stop further collection of your personal information through the Mobile Apps by uninstalling the Mobile Apps. 

• Opt Out of Other Cookies. To set your cookie preferences or opt out of the sale/sharing of your information via cookies, please see our Cookie Preferences. All session cookies are temporary and expire after you close your web browser. Persistent cookies can be removed by following your web browser’s directions. To find out how to see what cookies have been set on your computer or device, and how to reject and delete the cookies, please visit: https://www.aboutcookies.org/. Please note that each web browser is different. To find information relating to your browser, visit the browser developer’s Website and mobile application. If you reset your web browser to refuse all cookies or to indicate when a cookie is being sent, some features of our website may not function properly. If you choose to opt out, we will place an "opt-out cookie" on your device. The "opt-out cookie" is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for essential cookies. If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. By clicking on the “Opt-Out” links below, you will be directed to the respective third-party website where your computer will be scanned to determine who maintains cookies on you. At that time, you can either choose to opt out of all targeted advertising or you can choose to opt out of targeted advertising by selecting individual companies who maintain a cookie on your machine.
  • Association of National Advertisers opt-out registration: https://dmachoice.thedma.org/
  • Network Advertising Initiative (NAI) Opt-Out: https://www.networkadvertising.org/managing/opt_out.asp
  • Digital Advertising Alliance (DAA) Opt-Out: https://optout.aboutads.info
  • European Union (EU) /European Economic Area (EEA) Opt-Out: http://www.youronlinechoices.eu

 

5. PRIVACY LAW RIGHTS

 

A. RIGHTS OF INDIVIDUALS IN CALIFORNIA AND TEXAS

 

For any functions of the Service that we collect your personal information for our own purposes, the California Privacy Rights Act (CPRA) entitles California residents, and the Texas Data Privacy and Security Act (TDPSA) entitles Texas residents (effective July 1, 2024) to certain rights. To the extent the CPRA or TDPSA applies to our processing of your personal information, you are entitled to the following rights:

 

• Right to Access/Know. You have the right to request what personal information we have collected, used, disclosed, and sold about you, unless doing so proves impossible or would involve disproportionate effort.
• Right to Deletion. You have the right to request the deletion of your personal information that we collect or maintain, subject to certain exceptions. Once we receive your request to delete and confirm your identity, we will delete (and notify any service providers or third parties, who we have shared or sold your personal information to, to delete) your personal information, unless an exception applies under applicable law, including to comply with a legal obligation.
• Right to Opt-Out of Sale/Sharing. You have the right to opt-out of the sale or sharing of your personal information to third parties. Swann Communications does not have actual knowledge that it sells or shares personal information of minors under the age of sixteen (16) years. To exercise your right to opt-out of the sale or sharing of your personal information visit Do Not Sell or Share My Personal Information.
• Right to Non-Discrimination. You have the right to not receive discriminatory treatment if and when you exercise your rights to access, delete, opt-out, correct, or limit use of sensitive personal information under the CPRA. 
• Right to Correct. You have the right to correct inaccurate personal information that we collect or maintain.
• Right to Data Portability. You have the right to ask that we transfer the personal information you gave us, to you, or in certain cases, directly to another organization, in a format that is easily understandable and to the extent technically feasible, in a structured, commonly used, machine-readable format.
• Right to Opt Out of Profiling. You have the right to opt out of profiling of your personal information in furtherance of decisions that produce legal or similarly significant effect concerning a consumer.
• Right to Opt Out of Targeted Advertising. You have the right to opt out of the processing of your personal information for targeted advertising purposes. To exercise your right, you may submit a request by calling Swann Communications toll-free 1800 627 2799, completing our online Privacy Rights Request webform, or emailing us at [email protected].
• Right to limit use of sensitive personal information. You have the right to limit the use of how we use your sensitive personal information. We do not collect sensitive personal information, except financial account information, which we only use to process your purchase. However, Swann Communication’s use of your sensitive personal information, if any, does not give rise to this right.
• Right to Appeal and File a Complaint. You have the right to appeal an action taken (or not taken) by Swann Communications in response to your request. We will inform you of any action we have taken in response to your request without delay and, in any event, within forty-five (45) days after we receive your request. You can submit an appeal by calling Swann Communications toll-free 1800 267 2799, completing our online Privacy Rights Request webform, or emailing us at [email protected]. If you believe your privacy rights have been violated, you can submit a complaint to the California Privacy Protection Agency at https://cppa.ca.gov/webapplications/complaint, the California Attorney General at https://oag.ca.gov/contact/consumer-complaint-against-business-or-company, or the Texas Attorney General at https://www.texasattorneygeneral.gov/consumer-protection/file-consumer-complaint.

 

To exercise your rights, you may submit a request by calling Swann Communications toll-free 1800 267 2799, completing our online Privacy Rights Request webform, or emailing us at [email protected]. For requests submitted via telephone or email, you must provide us with sufficient information (your contact information, a description of the right to be exercised, and any details related to the exercise of that right) that allows us to reasonably verify you are the person about whom we collected the personal information and describe your request with sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and deletion requests with the information provided, we may ask you for additional pieces of information. 

To opt out of the sale or sharing of your personal information, visit Do Not Sell or Share My Personal Information, or utilize the opt out preference signal to instruct us to not sell or share any of your personal information collected online. The opt out preference signal will apply to the device, platform, app or browser in which you utilize it. You can utilize the opt out preference signal by turning on the signal in your device, platform, or browser settings. 

 

Using an Authorized Agent 

Only you, or a person that you authorize to act on your behalf, may make a request related to your personal information. If a consumer is using an authorized agent to submit a CCPA/CPRA privacy request to know (disclosure report) or delete their personal information, the following is required. 

• Using an authorized agent without power of attorney to submit a request to know or delete.
  • Signed permission from the consumer authorizing the agent to submit the CPRA privacy request(s) on their behalf. Describe the type of privacy request(s) being requesting (know/disclosure report and/or deletion).
  • The consumer must verify their own identity directly with the us by submitting information or documentation that provides sufficient proof of identification, such as a copy of a driver's license, an identification card issued by the motor vehicle administration, or any other government issued identification. 

• Using an authorized agent with power of attorney to submit a request to know or delete. If you have provided the authorized agent with power of attorney pursuant to California Probate Code sections 4000 to 4465, provide only the following: the valid power of attorney executed lawfully under California Probate Code sections 4121 to 4130.

• Using an authorized agent to submit an opt-out request. Please provide written permission, signed by the consumer, authorizing the agent to submit the opt-out request. 

 

Notice of Financial Incentive 

• Summary. We may offer discount codes or perks like a branded items in connection with you opting in to receive marketing emails, or participating in sweepstakes, contests, promotions, or surveys. You receive such discount codes or perks because we want to show you that we are excited you want to hear from us and because we hope you will want to buy our products. 

• Material Terms. The details of each program are contained in the program offering but in general, we invite you to provide us with your identifiers (name, email address, cell phone number, country, mailing address (as applicable)) to participate in sweepstakes, contests, promotions, or surveys and we provide you with a sign of our appreciation such as a discount code or a perk like a branded item. 

• How To Opt In. You can opt in using a prompt on our websites that links to this notice. 

• Right to Withdraw. You can opt out of receiving marketing communications from us at any time by clicking on the unsubscribe link contained in our emails, or you may email us at [email protected]. 

• Value of Financial Incentive. The incentives we offer in exchange for the opportunity to market to you may be a discount coupon that can be used when you buy products from us or a branded item. Details of the incentive will vary depending on market conditions at the time the incentive is offered, and the value of your data will also fluctuate. Under most circumstances, the value of your personal information is less than the incremental administrative costs of the marketing program, sweepstakes, contests, promotions, surveys, or research, including storage of your personal information. Retail prices for our products and branded items vary. 

 

B. RIGHTS OF INDIVIDUALS IN THE EU AND UK 

For any functions of the Service that we determine the purpose and means of the processing of your personal information, individuals in the EU and UK are entitled to certain rights under the General Data Protection Regulation (“GDPR”) and the UK GDPR. If our processing of your personal information is subject to the GDPR or UK GDPR, you may be entitled to the following rights: 

• Right to access.You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the personal information we process. 

• Right to rectification. You have the right to ask us to rectify personal information you think is inaccurate or incomplete. 

• Right to erasure. You have the right to ask us to erase your personal information in certain circumstances. 

• Right to restrict processing. You have the right to ask us to restrict the processing of your personal information in certain circumstances. 

• Right to object to processing. You have the right to object at any time, for reasons arising from your particular situation, to processing of your personal information, which is carried out on the basis of our legitimate interests. 

• Right to data portability.You have the right to ask that we transfer the personal information you gave us from one organization to another, or give it to you. Please note this only applies to personal information you have given us. 

• Right to lodge a complaint. You have the right to lodge a complaint with the relevant Supervisory Authority. 

To exercise these rights, please contact our DPO at [email protected].

 

C. RIGHTS OF INDIVIDUALS IN AUSTRALIA 

For any functions of the Service that we collect your personal information for our own purposes, individuals in Australia are entitled to certain rights under the Privacy Act and Australian Privacy Principles. If our processing of your personal information is subject to the Privacy Act and Australian Privacy Principles, you are entitled to the following rights: 

• Right to access. You can request access to your personal information, subject to certain exceptions set out in specific Government legislation, such as the Privacy Act 1988 (Australia). Swann Communications may charge reasonable costs for providing access to your personal information. Swann Communications will require some proof of your identify before providing information to you. 

• Right to correction. You may also request us to correct the personal information that Swann Communications holds about you. If you do so and we are satisfied that, having regard to a purpose for which the information is held, the information is inaccurate, out-of-date, incomplete, irrelevant or misleading, Swann Communications will take such steps as are reasonable in the circumstances to correct your personal information to ensure that, having regarding to the purpose for which it is held, the information is accurate, up-to-date, complete, relevant and not misleading.

• Right to lodge a complaint. If you are concerned that the way Swann Communications collects, holds, uses or discloses your personal information may be in breach of the government Privacy Principles in your country, please send written details of your complaint to The Privacy Officer, Swann Communications, via email to [email protected]
  • How Swann Communications will handle complaints. After receiving a complaint, we will consider whether we need any further information from you to properly consider and investigate the complaint, and may request such information from you. We will then:
    • conduct internal discussions with the relevant business units involved in the collection, holding, use or disclosure of your personal information which is the subject of your complaint, and evaluate whether we believe that such collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles; and
    • notify you of the results of our investigation of your complaint.

If the conclusion of our investigation is that our collection, holding, use or disclosure of your personal information was in breach of the Australian Privacy Principles, we will take steps to remedy the breach as soon as reasonably practicable. We will endeavor to notify you of the results of our investigation of your complaint within 30 days of receiving your complaint. However, if your complaint involves complex matters or requires extensive investigation and consultation, it may not be possible to respond within this timeframe. If you are not satisfied with our response to your complaint you are entitled to seek recourse as per the local privacy laws in your country. 

To exercise these rights, please contact us at [email protected].

 

D. RIGHT OF INDIVIDUALS IN CANADA 

If our processing of your personal data is subject to Canadian law, the following section applies to you:

• Accessing and correcting your personal data. You have a right to request access to your personal information and to request a correction to it if you believe it is inaccurate. If you would like to have access to the personal information we have about you, or if you would like to have it corrected, please contact us at [email protected], which will help us to handle your request properly. In some cases for Canada residents, we may not be able to allow you to access certain personal information in certain circumstances: for example, if it contains personal information of other persons, or for legal reasons. To help protect against fraudulent requests for access to your personal information, we may ask you for information to allow us to confirm that the person making the request is you or is authorized to access your information before granting access. You will need to provide us with sufficient information that allows us to reasonably verify that you are the person whose personal information we collected, and you must describe your request in sufficient detail to allow us to properly evaluate and respond to it. If we are not able to verify your identity for access and correction requests using the information provided, we may ask you for additional pieces of information.
• Right to withdraw consent. If you have given consent for the processing of your personal information, you may withdraw your consent with effect for the future. Your withdrawal of consent does not have retroactive effect, and there may be cases where we are permitted under the applicable law to process certain personal information without consent.
• Security. In order to help prevent unauthorized access to or disclosure of personal information, we have put in place physical, electronic, and organizational procedures to help safeguard and secure the personal information we collect. Personal information may be accessed by persons within our organization or our third-party service providers who require such access to carry out the purposes described in this Privacy Notice or are otherwise permitted or required by applicable law. Even though we have taken steps to help protect the personal information in our control, you should know that we cannot fully eliminate security risks associated with personal information. No security measures can provide absolute protection. We cannot ensure or warrant the security of any information you provide to us.

 To exercise these rights, please contact us at [email protected]

 

E. RIGHTS OF INDIVIDUALS IN NEVADA 

If you are a consumer in the State of Nevada, you may request to opt-out of the current or future sale of your personal information. We do not currently sell any of your personal information under Nevada law, nor do we plan to do so in the future. However, you can submit a request to opt-out of future sales by contacting us at [email protected]. Please include “Opt-Out Request Under Nevada Law” in the subject line of your message.

 

6. DO NOT TRACK 

We do not recognize “Do Not Track” requests for internet browsers. Do Not Track is a preference you can set to inform websites and applications that you do not want to be tracked.

 

7. SECURITY OF YOUR PERSONAL INFORMATION 

We implement and maintain reasonable security measures to protect the personal information we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. These security measures include encryption and access controls. For example, when you are ordering services via our website, we use the Internet encryption protocol Secure Sockets Layer (SSL) to protect the security of your personal information. The SSL protocol is also implemented for (i) guarding your account information when you are viewing your bills or orders on our websites, and (ii) securing all logs of settings and online services of your device(s). However, no security measure or modality of data transmission over the Internet is 100% secure and we are unable to guarantee the absolute security of the personal information we have collected from you from unauthorized actors. Swann Communications personnel are prohibited and prevented from accessing customer data and video and electronic surveillance data.

 

8. AGE RESTRICTION 

The Services are not intended for individuals under the age of sixteen (16). If we learn that we have collected or received personal information from a child under the age of sixteen (16), we will delete that information. If you believe we might have information from or about a child under the age of sixteen (16), please contact us at [email protected].

 

9. CROSS BORDER TRANSFER 

Swann Communications uses its best efforts to ensure, that personal information, including video and electronic surveillance data, remains in the country or region in which it originated. Swann Communications hosts its Services in the Sydney, Australia (ap-southeast-2), Oregon, USA, Paris, France. However, we may transfer your personal information to recipients in countries outside of the European Economic Area, Canada, Australia, or Japan that may have differing data protection laws for the administration of our business (financial, accounting, insurance, legal, regulatory, etc.), incidental access for support services, or aggregated information. Personal Information and video and electronic surveillance data originating in Australia will remain in Australia, unless (i) Swann is required transfer the information out of Australia to comply with applicable law, (ii) the information is accessed by financial, accounting, insurance, legal, regulatory, and other advisers, auditors, insurers, security trustees and financiers; (iii) there is only incidental access for support or maintenance services; or (iv) the information is aggregated before it is transferred out of Australia. When personal information is transferred, it may be transferred to countries which the privacy regulators of the EEA, Canada, Australia, and/or Japan does not consider having an adequate level of protection for personal data. If this occurs, we will ensure there is a legal ground for the transfer in accordance with applicable data protection legislation. You will also be informed about the legal ground, what safeguards were implemented, and where you can obtain a copy of information on these safeguards.Swann Communications abides by the safe harbor framework as set forth by the Canadian Ministry of Commerce regarding the collection, use, and retention of data from the European Union.

 

10. EXEMPTIONS 

Swann Communications sometimes handles personal information relying on exemptions under Government privacy legislation, for example in relation to (i) employee records; (ii) related bodies corporate; (iii) provision of services to Government authorities. Any permitted handling of personal information under such exemptions will take priority over this Privacy Notice to the extent of any inconsistency.

 

11. CHANGES TO THIS PRIVACY NOTICE 

We may amend this Privacy Notice in our sole discretion at any time. If we do, we will post the changes to this page, and will indicate the date the changes go into effect. We encourage you to review our Privacy Notice to stay informed. If we make changes that materially affect your privacy rights, we will notify you by prominent posting on the Website and/or via email, and request your consent, if required.

 

12. CONTACT US 

If you have any questions regarding this Privacy Notice, please contact us: 

By e-mail: [email protected] 

By mail: