BACKGROUND

Swam Energy Limited understands that your privacy is important to you and that you care about how your personal data is used. We respect and value the privacy of everyone who visits this website, www.swarm.eco (“our Site”) and will only collect and use personal data in ways that are described here, and in a way that is consistent with our obligations and your rights under the law.

Please read this Privacy Policy carefully and ensure that you understand it.

1 – Definitions and Interpretation

In this Policy the following terms shall have the following meanings: 

“Account”	means an account required to access and/or use certain areas and features of our Site;
“Cookie”	means a small text file placed on your computer or device by our Site when you visit certain parts of our Site and/or when you use certain features of our Site. Details of the Cookies used by our Site are set out in Part 14, below; and
“Cookie Law”	means the relevant parts of the Privacy and Electronic Communications (EC Directive) Regulations 2003;]

2 – Information About Us

Our Site is operated by Swam Energy Limited, a Limited Company registered in England under company number 14588066.

Registered address: Unit 4. The Old Forge Hoults Yard, Walker Road, Newcastle Upon Tyne, England, NE6 2HL.

Main trading address:Unit 4. The Old Forge Hoults Yard, Walker Road, Newcastle Upon Tyne, England, NE6 2HL.

• VAT number: 435 1352 20.
• Data Protection Officer: Anthony Piggott.
• Email address: dpo@swarm.eco.
• Telephone number: 0333 242 3405.
• Postal address: Unit 4. The Old Forge Hoults Yard, Walker Road, Newcastle Upon Tyne, England, NE6 2HL.

Representative: Anthony Piggott.

• Email address: dpo@swarm.eco.
• Telephone number: 0333 242 3405.
• Postal address: Unit 4. The Old Forge Hoults Yard, Walker Road, Newcastle Upon Tyne, England, NE6 2HL.

3 – What Does This Policy Cover?

This Privacy Policy applies only to your use of our Site. our Site may contain links to other websites. Please note that wehave no control over how your data is collected, stored, or used by other websites and we advise you to check the privacy policies of any such websites before providing any data to them.

4 – What Is Personal Data?

Personal data is defined by the UK GDPR and the Data Protection Act 2018 (collectively, “the Data Protection Legislation”) as ‘any information relating to an identifiable person who can be directly or indirectly identified in particular by reference to an identifier’.

Personal data is, in simpler terms, any information about you that enables you to be identified. Personal data covers obvious information such as your name and contact details, but it also covers less obvious information such as identification numbers, electronic location data, and other online identifiers.

5 – What Are My Rights?

Under the Data Protection Legislation, you have the following rights, which we will always work to uphold:

1. The right to be informed about our collection and use of your personal data. This Privacy Policy should tell you everything you need to know, but you can always contact us to find out more or to ask any questions using the details in Part 15.
2. The right to access the personal data wehold about you. Part 13 will tell you how to do this.
3. The right to have your personal data rectified if any of your personal data held by us is inaccurate or incomplete. Please contact us using the details in Part 15 to find out more.
4. The right to be forgotten, i.e. the right to ask usto delete or otherwise dispose of any of your personal data that we hold. Please contact ususing the details in Part 15 to find out more.
5. The right to restrict (i.e. prevent) the processing of your personal data.
6. The right to object to us using your personal data for a particular purpose or purposes.
7. The right to withdraw consent. This means that, if we are relying on your consent as the legal basis for using your personal data, you are free to withdraw that consent at any time.
8. The right to data portability. This means that, if you have provided personal data to us directly, we are using it with your consent or for the performance of a contract, and that data is processed using automated means, you can ask us for a copy of that personal data to re-use with another service or business in many cases.
9. Rights relating to automated decision-making and profiling. We do not use your personal data in this way.

For more information about ouruse of your personal data or exercising your rights as outlined above, please contact ususing the details provided in Part 15.

It is important that your personal data is kept accurate and up-to-date. If any of the personal data wehold about you changes, please keep us informed as long as wehave that data.

Further information about your rights can also be obtained from the Information Commissioner’s Office or your local Citizens Advice Bureau.

If you have any cause for complaint about our use of your personal data, you have the right to lodge a complaint with the Information Commissioner’s Office. We would welcome the opportunity to resolve your concerns ourselves, however, so please contact usfirst, using the details in Part 15.

6 – What Data Do You Collect and How?

Depending upon your use of our Site, we may collect and hold some or all of the personal and non-personal data set out in the table below, using the methods also set out in the table. Please also see Part 14 for more information about our use of Cookies and similar technologies. We do not collect any ‘special category’ or ‘sensitive’ personal data or personal data relating to children or data relating to criminal convictions and/or offences.

Data Collected	How We Collect the Data
Identity Information including title, first & name.	Collected when contacting Swarm through our forms or purchasing from us.
Contact information including email address and telephone number.	Collected when contacting Swarm through our forms or purchasing from us.
Business information including business name and job title.	Collected when contacting Swarm through our forms or purchasing from us.
Payment information including card or bank details.	Collected when purchasing from Swarm, through our payment provider Stripe.
Profile information including preferences, purchase history and login details.	Collected when purchasing from Swarm or interacting with our app.
Technical information including IP address, operating system and browser type.	Collected when interacting with swarm.eco.
Renewable technical information including renewable devices, energy usage, energy habbits.	Collected when creating an account with swarm.eco and when using our device hub:one.

7 – How Do You Use My Personal Data?

Under the Data Protection Legislation, we must always have a lawful basis for using personal data. The following table describes how we may use your personal data, and our lawful bases for doing so:

What We Do	What Data We Use	Our Lawful Basis
Registering you on our Site for a purchase.	– Email address – Full name – Shipping address – Billing address	Consent basis for processing
When registering your Swarm Account	– Email address – Full name – Shipping address – Billing address – Renewable devices – Meter readings	Contract basis for processing
Providing and managing your access to our Site.	– IP address – Cookie preference	Legitimate interest basis for process: When you visit our site we may automatically log your IP address. We will not use your IP address to identify you in any way. Information collected is used to improve our website’s
Administering our Site.	– IP address – On-site browsing habits – On-site usage – Source of visit – Cookie identifier	Legitimate interest basis for process: When you visit our site we may automatically log your IP address. We will not use your IP address to identify you in any way. Information collected is used to improve our website’s and for follow-up marketing efforts.
Supplying ourproducts and services to you.	– Email address – Full name -Shipping address -Billing address -Renewable devices -Energy usage	Contract basis for processing
Managing payments for our products and services.	– Email address -Full name -Shipping address -Billing address	Consent and contract basis for processing
Communicating with you.	– Email address – Full name -Telephone number	Consent basis for processing
Supplying you with information by email and/or post that you have opted-in-to (you may opt-out at any time by contacting us at hello@swarm.eco)	– Email address – Full name -Telephone number -Shipping address	Consent basis for processing

With your permission and/or where permitted by law, we may also use your personal data for marketing purposes, which may include contacting you by email or telephone or text message or post with information, news, and offers on our products or services. You will not be sent any unlawful marketing or spam. We will always work to fully protect your rights and comply with our obligations under the Data Protection Legislation and the Privacy and Electronic Communications (EC Directive) Regulations 2003, and you will always have the opportunity to opt-out. We will always obtain your express opt-in consent before sharing your personal data with third parties for marketing purposes and you will be able to opt-out at any time.

Third Parties (including Google LLC, tawk.to inc, Facebook, CookieYes) whose content appears on our Site may use third-party Cookies, as detailed below in Part 14. Please refer to Part 14 for more information on controlling cookies. Please note that we do not control the activities of such third parties, nor the data that they collect and use themselves, and we advise you to check the privacy policies of any such third parties.

We use the following automated system for carrying out certain kinds of decision-making and profiling. If at any point you wish to query any action that we take on the basis of this or wish to request ‘human intervention’ (i.e. have someone review the action themselves, rather than relying only on the automated method), the Data Protection Legislation gives you the right to do so. Please contact us to find out more using the details in Part 15.

• The following automated decision-making method(s) may be used:
  • Targeting of Google Search and Google Display Facebook adverts based on previous visit to our website.
  • Targeting of Facebook adverts based on previous visit to our website.

We will only use your personal data for the purpose(s) for which it was originally collected unless we reasonably believe that another purpose is compatible with that or those original purpose(s) and need to use your personal data for that purpose. If we do use your personal data in this way and you wish us to explain how the new purpose is compatible with the original, please contact us using the details in Part 15.

If weneed to use your personal data for a purpose that is unrelated to, or incompatible with, the purpose(s) for which it was originally collected, wewill inform you and explain the legal basis which allows usto do so.

In some circumstances, where permitted or required by law, we may process your personal data without your knowledge or consent. This will only be done within the bounds of the Data Protection Legislation and your legal rights.

8 – How Long Will You Keep My Personal Data?

We will not keep your personal data for any longer than is necessary in light of the reason(s) for which it was first collected. Your personal data will therefore be kept for the following periods (or, where there is no fixed period, the following factors will be used to determine how long it is kept):

Type of Data	How Long We Keep It
Identity Information including title, first name and last name.	If a Contracted Customer (someone who has a contract with Swarm Energy Limited for the operation of the hub:one), your identity information, unless otherwise requested, is kept for 2 years after your Account’s deactivation, to allow for easy reactivation. If a Potential Customer (someone who has opted in to marketing communications from Swarm Energy Limited), unless otherwise requested, is kept for 6 months from the point of interaction (e.g. email open, email click…).
Contact information including address, email address and telephone.	If a Contracted Customer (someone who has a contract with Swarm Energy Limited for the operation of the hub:one), your identity information, unless otherwise requested, is kept for 2 years after your Account’s deactivation, to allow for easy reactivation. If a Potential Customer (someone who has opted in to marketing communications from Swarm Energy Limited), unless otherwise requested, is kept for 6 months from the point of interaction (e.g. email open, email click…).
Business information including Business Name and Job title.	A Partner of Swarm Energy Limited (someone who has a contract with Swarm Energy Limited for the operation of the hub:one), your identity information, unless otherwise requested, is kept for 2 years after your Account’s deactivation, to allow for easy reactivation.
Payment information including bank account number and card details.	A Contracted Customer (someone who has a contract with Swarm Energy Limited for the operation of the hub:one), your payment  information, unless otherwise requested, is kept for 2 years after your Account’s deactivation, to allow for easy reactivation.
Profile information including preference, device usage, username and password.	A Contracted Customer (someone who has a contract with Swarm Energy Limited for the operation of the hub:one), your profile  information, unless otherwise requested, is kept for 2 years after your Account’s deactivation, to allow for easy reactivation.
Technical information including IP address, browser type and operating system.	14 months from last interaction with website.

9 – How and Where Do You Store or Transfer My Personal Data?

Wewill store some of your personal datain the UK. This means that it will be fully protected under the Data Protection Legislation.

We may store some or all of your personal data in countries outside of the UK. These are known as “third countries”. We will take additional steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation as follows:

We ensure that your personal data is protected under binding corporate rules. Binding corporate rules are a set of common rules which all our group companies are required to follow when processing personal data. For further information, please refer to the Information Commissioner’s Office.

10 – Do You Share My Personal Data?

We will not share any of your personal data with any third parties for any purposes, subject to the following exceptions.

If wesell, transfer, or merge parts of ourbusiness or assets, your personal data may be transferred to a third party. Any new owner of ourbusiness may continue to use your personal data in the same way(s) that wehave used it, as specified in this Privacy Policy.

In some limited circumstances, wemay be legally required to share certain personal data, which might include yours, if we areinvolved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

Recipient	Activity Carried Out	Sector	Data Location
The Rocket Science Group LLC d/b/a Mailchimp	Sending of email campaigns.	Marketing technology	United States of America
Zoho Corporation	Customer Relationship Management	Marketing technology	United Kingdom

If any of your personal data is shared with a third party, as described above, wewill take steps to ensure that your personal data is handled safely, securely, and in accordance with your rights, our obligations, and the third party’s obligations under the law, as described above in Part 9.

If any personal data is transferred outside of the UK, we will take suitable steps in order to ensure that your personal data is treated just as safely and securely as it would be within the UK and under the Data Protection Legislation, as explained above in Part 9.

If we sell, transfer, or merge parts of our business or assets, your personal data may be transferred to a third party. Any new owner of our business may continue to use your personal data in the same way(s) that we have used it, as specified in this Privacy Policy.

In some limited circumstances, we may be legally required to share certain personal data, which might include yours, if we are involved in legal proceedings or complying with legal obligations, a court order, or the instructions of a government authority.

11 – How Can I Control My Personal Data?

1. In addition to your rights under the Data Protection Legislation, set out in Part 5, whenyou submit personal data via our Site, you may be given options to restrict ouruse of your personal data. In particular, weaim to give you strong controls on our use of your data for direct marketing purposes (including the ability to opt-out of receiving emails from us which you may do by unsubscribing using the links provided in ouremailsandat the point of providing your details and by managing your Account)

1. You may also wish to sign up to one or more of the preference services operating in the UK: The Telephone Preference Service (“the TPS”), the Corporate Telephone Preference Service (“the CTPS”), and the Mailing Preference Service (“the MPS”). These may help to prevent you receiving unsolicited marketing. Please note, however, that these services will not prevent you from receiving marketing communications that you have consented to receiving.

12 – Can I Access This Site Without Providing Personal Information?

You may access certain areas of our Site without providing any personal data at all. However, to use all features and functions available on our Site you may be required to submit or allow for the collection of certain data.

You may restrict ouruse of Cookies. For more information, see Part 14.

13 – How Can I Access My Personal Data?

If you want to know what personal data we have about you, you can ask us  for details of that personal data and for a copy of it (where any such personal data is held). This is known as a “subject access request”.

All subject access requests should be made in writing and sent to the email or postal addresses shown in Part 15. To make this as easy as possible for you, a Subject Access Request Form is available for you to use. You do not have to use this form, but it is the easiest way to tell us everything we need to know to respond to your request as quickly as possible.

There is not normally any charge for a subject access request. If your request is ‘manifestly unfounded or excessive’ (for example, if you make repetitive requests) a fee may be charged to cover our administrative costs in responding.

We will respond to your subject access request within 3 weeks and, in any case, not more than one month of receiving it. Normally, we aim to provide a complete response, including a copy of your personal data within that time. In some cases, however, particularly if your request is more complex, more time may be required up to a maximum of three months from the date we receive your request. You will be kept fully informed of our progress.

14 – How Do You Use Cookies?

Our Site may place and access certain first-party Cookies on your computer or device. First-party Cookies are those placed directly by us and are used only by us. We use Cookies to facilitate and improve your experience of our Site and to provide and improve our products AND services. We have carefully chosen these Cookies and have taken steps to ensure that your privacy and personal data is protected and respected at all times.

By using our Site, you may also receive certain third-party Cookies on your computer or device. Third-party Cookies are those placed by websites, services, and/or parties other than us. For more details, please refer to the table below. These Cookies are not integral to the functioning of our Site and your use and experience of our Site will not be impaired by refusing consent to them.

All Cookies used by and on our Site are used in accordance with current Cookie Law.

Before Cookies are placed on your computer or device, you will be shown a pop in requesting your consent to set those Cookies. By giving your consent to the placing of Cookies you are enabling us to provide the best possible experience and service to you. You may, if you wish, deny consent to the placing of Cookies; however certain features of our Site may not function fully or as intended. [You will be given the opportunity to allow only first-party Cookies and block third-party Cookies.]

Certain features of our Site depend on Cookies to function. Cookie Law deems these Cookies to be “strictly necessary”. These Cookies are shown in the table below. Your consent will not be sought to place these Cookies, but it is still important that you are aware of them. You may still block these Cookies by changing your internet browser’s settings as detailed below, but please be aware that our Site may not work properly if you do so. We] have taken great care to ensure that your privacy is not at risk by allowing them.

The following first-party Cookies may be placed on your computer or device:

Name of Cookie	Purpose	Strictly Necessary
cookieyes-consent	Used to track your consent choice with our cookie consent tool cookieyes	Yes
_gid, _ga, _ga,	Used by Google Analytics to track user behaviour on our website.	No
_pk_id	Used by our local javascript tracking for anonymised usage metrics.	No

and the following third-party Cookies may be placed on your computer or device:

Name of Cookie	Provider	Purpose
_gid, _ga, _ga, _ZJL9LF36Z8, twk_uuid_521727297ca1334016000005, _fbp, _clck, _hp2_id.404162694	Used by our Live Chat partner Tawk.io, to enable function of	No
_fb	Used by Facebook to track the efficiency of our advertising campaigns.	No

Our Site uses analytics services provided by Google Analytics. Website analytics refers to a set of tools used to collect and analyse anonymous usage information, enabling us to better understand how our Site is used. This, in turn, enables us to improve our Site and the products and services offered through it.

The analytics service(s) used by our Site use(s) Cookies to gather the required information. You do not have to allow us to use these Cookies, however whilst our use of them does not pose any risk to your privacy or your safe use of our Site, it does enable us to continually improve our Site, making it a better and more useful experience for you.

The analytics service(s) used by our Site use(s) the following Cookies:

Name of Cookie	First / Third Party	Provider	Purpose
_gid	First Party	Google Analytics	A unique, anonymised session ID.
_ga	First Party	Google Analytics	A unique, anonymised session ID.

In addition to the controls that we provide, you can choose to enable or disable Cookies in your internet browser. Most internet browsers also enable you to choose whether you wish to disable all Cookies or only third-party Cookies. By default, most internet browsers accept Cookies, but this can be changed. For further details, please consult the help menu in your internet browser or the documentation that came with your device.

You can choose to delete Cookies on your computer or device at any time, however you may lose any information that enables you to access Our Site more quickly and efficiently including, but not limited to, login and personalisation settings.

It is recommended that you keep your internet browser and operating system up-to-date and that you consult the help and guidance provided by the developer of your internet browser and manufacturer of your computer or device if you are unsure about adjusting your privacy settings.

15 – How Do I Contact You?

To contact us about anything to do with your personal data and data protection, including to make a subject access request, please use the following details [(for the attention of Anthony Piggott)]:

Email address: dpo@swarm.eco

Telephone number: 0333 242 3405.

Postal Address: Unit 4. The Old Forge Hoults Yard, Walker Road, Newcastle Upon Tyne, England, NE6 2HL.

16 – Changes to this Privacy Policy

We may change this Privacy Policy from time to time. This may be necessary, for example, if the law changes, or if we change our business in a way that affects personal data protection.

Any changes will be immediately posted on our Site and you will be deemed to have accepted the terms of the Privacy Policy on your first use of our Site following the alterations. We recommend that you check this page regularly to keep up-to-date. This Privacy Policy was last updated on 13/12/2023.

17 – Attribution

This Privacy Policy has been created using a document template from www.simply-docs.co.uk.