As of October 10th 2022

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

Processing of Your Personal Data

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

We may process your personal data for:

• Answering any requests, queries or inquires you may submit on our website; but also,
• Enabling you log on certain restricted parts of our website,
• Managing your participation to online context.

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

• Maintaining and improving the website as well as to ensuring its security,
• Conducting customer satisfaction surveys,
• Manage the forums to which you may take part,
• Recruitment purposes when you submit a resume or a job application online; and,
• Compiling aggregate statistics regarding the use of the website.

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

GDPR & Your Rights

The GDPR establishes a harmonised regulatory framework across Europe that is directly applicable in each of the 27 Member States. This common language on the protection of personal data also applies to organisations outside the European Union that process data about data subjects located in the European Economic Area.

According to GDPR and applicable data protection legislation you have rights regarding your personal data.

Transparency of information and Data subjects’ Rights

• Right of access to the data relating to you,
• Right of rectification,
• Right to be forgotten,
• Right to restriction of processing,
• Right to data portability,
• Right to object,
• Right to lodge a complaint with a supervisory authority of your country or with the Luxembourg data protection authority which is the National Commission for Data Protection – make a complaint. In UK the supervisory authority is the ICO: Make a complaint | ICO

Registration and completing forms

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

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

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

Transferring/sharing your data

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

In some cases we must transfer your data outside of your country, for example information may be passed to and used by other subsidiaries of Sword Group (some of which may be outside the EU). Should this be the case, we will ensure that confidentiality measures and data processing agreements including standard contractual clauses of the European Commission in line with applicable data protection legislation are in place. You can obtain a copy of them by emailing to the privacy@sword-group.com address.

Cookies

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

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

Cookies and the law

Our approach, your choice.

European privacy laws came into force in 2002 which require websites to inform users and get consent from them when placing ‘cookies’ on visitors computers, mobiles or other devices.

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

 How we use cookies

Our website uses cookies to measure and analyse the website audience (visitor volume, pages viewed, average browsing time, etc.) to help us improve its performance.

 How to disable cookies

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

To manage cookies, go to the Cookie Settings

Data for direct marketing

We will not immediately enter personal data you provide to us on our marketing database. Where it may be relevant to do so and we feel you are interested in hearing more about our services you will be given an opportunity to opt-in to electronic marketing and select your own preferences.

At each further point of marketing communication individuals are given the opportunity to opt-out of receiving direct marketing activity. Where individuals want to receive marketing communication, we may provide information on:

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

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

Retention of Data

We will retain the data you provide to us for different periods depending on the purpose for which you provided the data, the need to retain the data and in accordance with our data retention policies. These deadlines will be guided by industry best practice and other relevant legislation.

Notification of changes to the Privacy Statement

We may change the content of the services offered on our site at any time without notice and therefore our privacy policy may change at any time in the future. Please check the version of the policy you are using.

Subject Data Requests

Please complete this form to submit a subject data request to the data protection officer: