Privacy Policy

 

POLICY
Privacy Policy
Document Number:	STL-POL-007	Revision No:	03	Revision Date:	Oct-2024

1         Revision History and Change Details

Change Details	Revision Number	Release Date
Initial Release	01	Sep-2022
Update to billing information collected	02	Oct-2022
Update address, data processors and information collected	03	Oct-2024

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 October 2024.

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       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.

 

5.2       Enquiries

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

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

5.2.1        Online Contact Form / Booking a Demo

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

• First Name
• Last Name
• Email Address
• Phone Number
• Company Name
• Country
• Message

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

5.2.2        Email

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

• Sender Name
• Sender Email Address
• Message
• Phone Number (if provided)
• Company Name (if provided)
• Country (if provided)

5.3       Cookies

We indirectly collect your Non-Personal Information through cookies.

We collect this information so that we can:

• Measure the number of the visitors to our Website
• Record how visitors interact with our Website
• Improve the usability of our Website

We do not collect IP addresses.

 

5.4       Website Analytics

We use Website Analytics to collect information about your visit to our website, such as:

• Page Views
• Device and Browser Information
• Referral Sources
• Geolocation

 

We do not collect any information that can be used to track or identify individuals.

 

 

6         Who Will Collect and Hold Information?

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

Obligation under GDPR	Website	Social Media
	Swallowing Technologies	LinkedIn	Facebook	Instagram	Twitter
Article 6: Requirement of legal basis for Joint Processing	X	X	X	X	X
Articles 13,14: Providing information on Joint Processing of Personal Data	X
Article 26(2): Making available the essence of the arrangement	X
Articles 15-20: Rights of the Data Subject with regard to the Personal Data stored after the Joint Processing	X	X	X	X	X
Article 21: Right to object insofar as the Joint Processing is based on Article 6(1)(f)	X	X	X	X	X
Article 32: Security of the Joint Processing	X	X	X	X	X
Articles 33, 34: Personal Data Breaches concerning the Joint Processing	X	X	X	X	X

 

 

Name	Trade Name	Address
Swallowing Technologies Limited	Swallowing Technologies	58 Langdons Road, Papanui, Christchurch 8053 New Zealand
LinkedIn Ireland Unlimited Company	LinkedIn	Wilton Place, Dublin 2 Ireland
Facebook Ireland Limited	Facebook Instagram	4 Grand Canal Square, Grand Canal Harbour, Dublin 2 Ireland
Twitter International Unlimited Company	Twitter	The Academy, 42 Pearse Street, Dublin 2 Ireland

 

7         Who Will Have Access to the Information?

The intended recipients of the collected data will be:

Recipient Name	Recipient Address
Swallowing Technologies Limited	58 Langdons Road, Papanui, Christchurch 8053. NEW ZEALAND.

 

Swallowing Technologies shall use the following Data Processors:

Data Processor	Purpose
Swallowing Technologies	Collection 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.
Google	Collection of non-personal information (cookies) to understand how our website is used.
Fathom Analytics	Collection of non-personal information to understand how our website is used.
LinkedIn	Collection of non-personal information to understand the visitor volume, demographics, user engagement with page.
Facebook	Collection of non-personal information to understand people reached, post engagements and user engagement with page.
Instagram	Collection of non-personal information to understand people reached, post engagements and user engagement with page.
Twitter	Collection 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.

 

Location	Authority
Europe	Member State Supervisory Authority
Australia	Office of the Australian Information Commissioner
New Zealand	Privacy Commissioner

 

You have the right to object to the processing of your Personal Information at any point in the process. Once an objection is made, the Company shall no longer process your Personal Information.