1 REVISION HISTORY AND VERSION DETAILS

Change DetailsRevision NumberRelease Date
Initial Release01Sep-2022
Update to billing information collected02Oct-2022

2 INTRODUCTION

At Swallowing Technologies (Company), we understand the importance of privacy and the protection of your personal information and non-personal information. Swallowing Technologies complies with applicable laws to ensure delivery of privacy and protection.

3 PURPOSE

This Privacy Policy addresses privacy with the Company’s website (Website) and its associated social media e.g., LinkedIn.

4 EFFECTIVE DATE

The Privacy Policy is effective from September 2022.

5 WHAT DATA DO WE COLLECT AND WHY DO WE COLLECT IT?

The Company collects both information identifiable about an individual e.g., name, email (Personal Information) and information that doesn’t personally identify an individual or information that has been anonymized (Non-Personal Information) for the reasons described below.

Disclosure of information by You to the Company is voluntary. Choosing not to permit collection of information by the Company may lead to poorer experiences with the Website or an inability to access Swallowing Technologies Products and/or Services.

5.1 BILLING INFORMATION

We collect the following personal information:
• First Name
• Last Name
• Company Name
• Billing Address
• Phone Number
• Email Address
• Credit or Debit Card Information
• Customer IP Address
We collect Your Personal Information when You purchase one (1) or more Products and/or Services from our Website.
We also collect this information to maintain a database of end users to support performing post-market vigilance and post-market surveillance activities in accordance with medical device regulatory requirements e.g., Regulation 2017/745

5.2 NEWSLETTER SUBSCRIPTION INFORMATION

We collect your personal information when You voluntarily subscribe to the Company’s newsletter. This is a form of direct marketing. You can opt-out at any time, refer to the instructions in Section 11.

We collect the following personal information: email address.

We collect your email address so that we can send You a copy of the Company’s newsletter.

5.3 ENQUIRIES

We collect your personal information when You voluntarily contact the Company.

There are two (2) ways for You to contact the Company.

5.3.1 ONLINE CONTACT FORM

We collect the following Personal Information through the online contact form:

We collect this information so that we can address any enquiries in full and it allows us use more than one (1) method of contacting You if any information is transcribed incorrectly

5.3.2 EMAIL

We collect the following Personal Information when You email the Company directly:

5.4 COOKIES

We indirectly collect your Non-Personal Information through cookies.

We collect this information so that we can:

We do not collect IP addresses.

6 WHO WILL COLLECT AND HOLD THE INFORMATION?

Where data is processed in Europe, Swallowing Technologies are Joint Controllers with the following parties in accordance with the GDPR.

Obligation Under GDPRJoint Controllers (Trade Names)
Article 6: Requirement of legal basis for Joint ProcessingSwallowing Technologies
University of Canterbury
LinkedIn
Facebook
Instagram
Twitter
Articles 13,14: Providing information on Joint Processing of Personal DataSwallowing Technologies
University of Canterbury
Article 26(2): Making available the essence of the arrangementSwallowing Technologies
University of Canterbury
Articles 15-20: Rights of the Data Subject with regard to the Personal Data stored after the Joint ProcessingSwallowing Technologies
University of Canterbury
LinkedIn
Facebook
Instagram
Twitter
Article 21: Right to object insofar as the Joint Processing is based on Article 6(1)(f)Swallowing Technologies
University of Canterbury
LinkedIn
Facebook
Instagram
Twitter
Article 32: Security of the Joint ProcessingSwallowing Technologies
University of Canterbury
LinkedIn
Facebook
Instagram
Twitter
Articles 33, 34: Personal Data Breaches concerning the Joint ProcessingSwallowing Technologies
University of Canterbury
LinkedIn
Facebook
Instagram
Twitter
NameTrading Name(s)Address
Swallowing Technologies LimitedSwallowing TechnologiesLeinster Chambers,
Level 1,
249 Papanui Road,
Strowan,
Christchurch 8014
New Zealand
University of CanterburyUniversity of Canterbury20 Kirkwood Avenue,
Upper Riccarton,
Christchurch 8041
New Zealand
LinkedIn Ireland Unlimited CompanyLinkedInWilton Place,
Dublin 2
Ireland
Facebook Ireland LimitedFacebook
Instagram
4 Grand Canal Square,
Grand Canal Harbour,
Dublin 2
Ireland
Twitter International Unlimited CompanyTwitterThe Academy,
42 Pearse Street,
Dublin 2
Ireland

7 WHO WILL HAVE ACCESS TO THE INFORMATION?

The intended recipients of the collected data will be:

NameAddress
Swallowing Technologies Limited
(BiSSkiT Distributor)
Leinster Chambers,
Level 1,
249 Papanui Road,
Strowan,
Christchurch 8014
New Zealand
University of Canterbury
(BiSSkIT Manufacturer)
20 Kirkwood Avenue,
Upper Riccarton,
Christchurch 8041
New Zealand

Swallowing Technologies shall use the following Data Processors:

Data ProcessorPurpose
Swallowing TechnologiesCollection of personal information for newsletters and contact forms to support direct marketing.
Hubspot Inc.Collection of personal information for newsletters and contact forms to support direct marketing.
StripeCollection of personal information for billing customers to enable access of Products and Services.
GoogleCollection of non-personal information (cookies) to understand how our website is used.
LinkedInCollection of non-personal information to understand the visitor volume, demographics, user engagement with page.
FacebookCollection of non-personal information to understand people reached, post engagements and user engagement with page.
InstagramCollection of non-personal information to understand people reached, post engagements and user engagement with page.
TwitterCollection of non-personal information to understand people reached, post engagements and user engagement with page.

To enable delivery of Products and/or Services, the Company may disclose collected data to third parties such as our suppliers, consultants, and other representatives who may be based outside of Australia, New Zealand and Europe.

The Company shall not sell or rent your Personal Information.

8 PROTECTION OF INFORMATION

All information is protected against loss, unauthorised access, modification or disclosure and other misuse through security and storage in our database. Our database has restricted access to Company staff only who can only use your Personal or Non-Personal Information for the permitted reasons described in Section 5.

Any parties authorized by the Company to process Personal Information have demonstrated security measures which ensure full compliance with applicable data protection laws e.g., GDPR.

Information provided to any parties in connection with the provision of Products and/or Services, the Company will do everything reasonably within its power to prevent unauthorised access or disclosure of the information.

If there is a violation in our security systems, leading to non-permitted access to your Personal Information, we will contact You by email on the basis it has been provided upon registration.

9 ACCURACY OF INFORMATION

Personal Information collected by the Company is voluntarily provided by You. As such, the accuracy of the Personal Information we receive is dependent on what You provide.

The Company shall endeavour to ensure that any information that is incorrect is corrected and updated when specific requests to do so are made in accordance with Section 11.

Where Personal Information is disclosed to further the use of Products and/or Services, the Company shall ensure that the information is accurate, up to date, complete, relevant, and not misleading.

10 RETENTION OF PERSONAL INFORMATION

The Company shall not retain Personal Information for longer than is required for the purposes for which the information may be lawfully used.

11 INFORMATION RIGHTS

You have the right to consent to the Company collecting Your Personal and Non-Personal information.

You have the right to confirm if the Company holds any Personal Information about You.

You have the right to access, correct, erase, or restrict processing of Your Personal Information at any time.

A formal request shall be made in writing addressing Privacy Officer at privacy@swaltech.com

There may be instances that the Company may require additional information to confirm Your identity

The Company shall provide the information free of charge unless the request is manifestly unfounded or excessive. If the request is found to be the latter, the Company shall provide rationale for either:

  1. Charging You for the request to account for administrative costs of providing the information
  2. Refusing to act on Your request

There may be instances where the Company is unable to identify You. If this instance occurs, then the Company may be unable to act upon Your request.

If dissatisfied with how the Company manages your request, You have the right to lodge a formal complaint with the appropriate authority.

LocationAuthority
EuropeMember State Supervisory Authority
AustraliaOffice of the Australian Information Commissioner
New ZealandPrivacy Commissioner
SWALLOWING TECHNOLOGIES LIMITED 

ALL RIGHTS RESERVED 2022