Employee Privacy

This Employee Privacy Notice (“Privacy Notice”) describes the collection, use, retention, and sharing of your personal data through the course of your tenure with 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”, “we”, “us”, “our”) and its subsidiaries and affiliates. For additional information, please see our global Privacy Policy. 

This Privacy Notice explains: 

• applicability to personal data;
• our role in data processing;
• the personal data we collect and why;
• how we share your personal data;
• information security and retention of your personal data;
• your rights with respect to personal data; and
• where to address your questions or complaints.

 

APPLICABILITY 

This Privacy Notice applies to personal data, which is any information that relates to an identified or identifiable natural person, collected from or concerning personnel of Swann. The term “personnel” includes current employees and those that work on a non-permanent basis, such as temporary workers that are assigned to us through a temporary staffing agency.

 

OUR ROLE IN DATA PROCESSING 

The entity responsible for the collection and use (processing) of your personal data is Swann Communication Ltd’s Human Resources ([email protected]), which, for the purpose of the European Union’s General Data Protection Regulation (“GDPR”) and the United Kingdom’s Data Protection Act 2018 (“DPA”), is the data controller. 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.

 

PERSONAL DATA WE COLLECT, HOW WE USE IT, HOW LONG WE KEEP IT, AND HOW WE SHARE IT 

During the course of your tenure with Swann, we collect personal data about you, as well as personal data related to your dependents and beneficiaries (collectively, “Dependents”), where there is a legitimate reason to do so in connection with our relationship with you. To the extent we collect personal data on your Dependents, you should inform your Dependents that you are providing this information to us and why, and make sure that it is acceptable to them. 

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 during your tenure with Swann. 

• Administer salary and benefits. We collect, from you, as well as from governmental entities, and benefit providers your identifiers (name, telephone number, physical address, email address, date of birth, signature), driver’s license number, state identification number, and passport (if provided)), your financial information (bank account and routing number, salary information, withholding tax and insurance information), and your employment information (level of employment, position, role, tasks, workspace, etc.). We use this information to administer payroll and employee benefit plans, including enrollment and claims handling. The legal basis for this processing is the performance of our employment contract with you. The processing condition for the processing of the sensitive information is carrying out our obligations in the field of employment (Art. 9(2)(b) GDPR) e.g., for setting up your employee records and payment. We also collect, from you, the identifiers (name, date of birth) and sensitive identifiers (Social Security number) of Dependents. We use the Dependent information to process their eligibility as your Dependents for the purpose of benefits. The legal basis for this processing is that it is necessary for the performance of a contract. The processing condition for the processing of the sensitive information is, depending on the laws of the relevant member state, carrying out our obligations in the field of employment (Art. 9(2)(b) GDPR), or your consent. We retain compensation, benefit, and retirement plans indefinitely.

• Conduct employee onboarding. When you first join Swann, we collect, from you, your identifiers (name, telephone number, physical address, email address, date of birth, signature), your sensitive identifiers (Social Security number, driver’s license number, state identification number, and passport (if provided)), your protected classifications (marital status, age, gender, disability status (if provided), veteran status (if provided)), your sensitive protected classifications (race, ethnicity, (if provided)), and your financial information (bank account and routing number, salary information, withholding tax and insurance information). We use this information to onboard you as an employee of Swann. The legal basis for this processing is to administer our employment contract with you. We use this protected classification and sensitive protected classification information for government reporting purposes, to comply with legal requirements, to analyze requested disability accommodations as applicable, and to document any accommodations we have provided to accommodate your needs. The processing condition for the processing of the sensitive information is, depending on the laws of the relevant member state, the safeguarding of your rights (Art. 9(2)(b) GDPR) or assessing your work capacity as an employee (Art. 9(2)(h) GDPR). We also collect, from you, the identifiers (name, telephone number, email address, physical address) of your emergency contacts to communicate with these contacts in the event of an emergency. The legal basis for this processing is to protect your vital interests. We use this information, in the aggregate, to conduct internal analytics and benchmarking. The legal basis for this processing is our legitimate interest in the more efficient management of our employment operations or, where applicable, to comply with our legal obligations or our legitimate interest in compliance with non-EU legal obligations that apply to Swann.

• Create a personnel file. When you first join Swann and throughout your tenure with us, we collect, from you, your identifiers (name, date of birth, telephone number, physical address) and professional information (licenses, credentials, employment history, educational history, resume/CV, disciplinary evaluations, performance reviews, terms and conditions of employment, salary (including retirement accounts, pensions, or insurance coverage), skills, qualifications, experience, travel history, professional/occupational memberships, and time-off work). We use this personal data to maintain your personnel file, create personnel biographies, and for internal recruitment purposes (assessing your eligibility for other positions within Swann). The legal basis for this processing is to administer our employment contract with you or, where applicable, for example for internal recruitment, our legitimate interest in the efficient management of our employment operations. We retain this information for seven (7) years after termination. Swann does not view personal medical information beyond election choices in the employee health insurance portal. Swann may receive notes from providers with medical information included for leaves of absence from work however this is explicitly requested not to be shared. 

• Apply for tuition reimbursement. When you apply for tuition reimbursement, we collect, from you, your education information (transcripts). We use this information to assess your eligibility for tuition reimbursement. The legal basis for this processing is the performance of our contract with you. 

• Manage business and travel expenses. When you travel in connection with your tenure with Swann, we collect from you or from our travel and expense management service provider, your identifiers (name, email address, country), corporate financial information (travel and expense details, cost center), and the identifiers (name) of your manager. We use this information to manage business and travel expenses incurred during the course of your tenure. The legal basis for this processing is the performance of our contract with you. 

• Process workers’ compensation and health insurance claims. If you file a workers’ compensation or health insurance claim, we collect, from you, your medical information (job restrictions, workplace illness, injury information) and your sensitive information (health information). We use this information to investigate and process workers’ compensation claims, process health insurance claims, and to conduct and process employment testing. The legal basis for this processing is to defend against legal claims. The processing condition for the processing of sensitive information is to assess your work capacity as an employee (Art 9(2)(h) GDPR). We retain this information for seven (7) years. 

• Professional development. We collect, from you, your identifiers (name) and professional information (licenses, credentials, employment history, educational history, resume/CV, disciplinary evaluations, performance data, training data). We use this information to identify, deliver, and track training needs and outcomes, to help with career development, succession planning, and workforce management and to manage professional requirements, certifications and memberships and to manage relationships with vendors. The legal basis for this processing is our legitimate interest in the efficient management of our employment practices and management of the workforce. We retain this information for seven (7) years after termination. 

• Monitor work-related licenses and credentials. When you first join Swann and throughout your tenure, we collect from you as well as from educational institutions, personal and professional references your personal identifiers (name) and your professional information (licenses, credentials, employment history, educational history, resume/CV). We use this information to manage work-related licenses and credentials. The legal basis for this processing is to enforce our employment contract with you. 

• Conduct IT security and management. When you access our computer network, information systems, digital assets, or use Swann-owned electronic devices, we collect, from you, your personal identifiers (username, IP address, device identifiers), your electronic network activity information (logins, accesses, browsing history, search history, websites visited, interactions with websites), and your sensitive information (password). We use this information to ensure compliance with Swann’s policies and procedures, to protect Swann’s computer network, for authentication purposes, to provide IT support, and to prevent loss of Swann property. The legal basis for this processing is our legitimate interest in ensuring compliance with our policies and procedures, as well as the security of our systems. When you log into our computer network, we also collect your geolocation data (country or city and state) automatically through our behavioral analytics solution to confirm the login is associated with a known location. The legal basis for this processing is our legitimate interest in ensuring the security of our systems. For more information, please see the Swann Code of Conduct and Business Ethics, specifically, the section titled “We Protect Swann Assets and Confidential Information.” Please also see Swann’s Communication and Information Systems Appropriate Use Policy. 

• Assess performance at work. Throughout your tenure with Swann, we collect, from you, your identifiers (name) and employment information (skills, working hours and achievement of set goals). We use this to: (i) conduct performance reviews; (ii) issue probation reviews and professional development reviews; (iii) maintain disciplinary measures; (iv) verify compliance and effectiveness; and (v) ensure employee productivity and adherence to Swann’s policies. The legal basis for this processing is to enforce our employment contract with you or, for example re productivity analysis, the legal basis is our legitimate interest in the efficient management of our workforce. 

• Handle general human resources functions. Throughout your tenure with Swann, we collect, from you, your identifiers (name, personnel ID, email address, telephone number, physical address) and emergency contact information. We use this information to handle general human resources functions, such as communication, personnel development, performance management, promotions and succession planning, internal communication and management of industrial relations, personnel surveys, mobility management including international assignment and personnel travel administration, appraisal/review, accounting, attendance and absence management, administration of sick leave, administration of annual leave, promotions, transfers, secondments, creating internal personnel directories, termination, and emergency contact procedures. The legal basis for this processing is to administer or enforce our employment contract with you, or, as applicable to comply with our legal obligations or, where relevant (for example re the planning) – our legitimate interest in the efficient management of our workforce. 

• Process your vacation and leave. If you take a vacation or leave, we collect, from you, your identifiers (name, physical address), your sensitive identifiers (Social Security number), your medical information (health status, doctor’s notices, accident reports, birth announcement), protected classifications (disability details, disability of Dependents), employment information (work time information, holiday information, employment position/role, leave of absence information including religious, military and family obligations). We use this information to process your leave or vacation. The legal basis for this processing is the performance of our contract with you. The processing condition for the sensitive information is safeguarding of your fundamental rights (Art. 9(2)(b) GDR) or assessing your work capacity as an employee (Art. 9(2)(h) GDPR). 

• Issue tax forms. Throughout your tenure with Swann, we collect, from you, your identifiers (name, physical address), your sensitive identifiers (Social Security number) and your tax information (withholding details). We use this information to issue tax forms and comply with tax reporting requirements. We retain your tax information indefinitely. The legal basis for this processing is to comply with our legal obligations. 

• Evaluate need for reasonable accommodations. If you request reasonable accommodations, we collect, from you, your identifiers (name, email address, telephone number, physical address), your medical information (doctor’s notes, requests for accommodations) and your protected classifications (religious or philosophical beliefs, any disabilities you may have). We use this information to evaluate, upon request, the need such accommodations and to process them. The legal basis for this processing is the performance of our contract with you. The processing condition for the sensitive information is safeguarding of your rights (Art. 9(2)(b) GDR) or assessing your work capacity as an employee (Art. 9(2)(h) GDPR). 

• Comply with legal obligations. Throughout your tenure with Swann, we collect, from you, as well as from benefits providers, governmental entities, and background check providers, your protected classifications (ethnicity, nationality, citizenship status, gender, military or veteran status (if provided), any disabilities you may have (if provided)). We use this information to comply with our obligations under applicable state and federal labor laws, employment laws, equal opportunity and anti-discrimination laws, workers’ compensation laws, workplace safety laws, tax benefits laws and related laws. The legal basis for this processing is to comply with our legal obligations. The processing condition for the sensitive information is safeguarding of your rights (Art. 9(2)(b) GDR). 

• On-site Security.When you attend our on-site facilities, we utilize CCTV cameras and therefore collect, automatically, video of you through our CCTV cameras. We use this information to maintain the safety and security of our employees, clients, and facilities. The legal basis for this processing is our legitimate interest in maintaining the safety and security of our employees, clients, and facilities. 

• Aggregate data. We aggregate the data we collect for benchmarking purposes and for internal analytics. The legal basis for this processing is our legitimate interest in the improvement of our processes. 

Swann will also use the personal data we collect as described in this section to comply with the law, to efficiently maintain our business, and for other limited circumstances as described in SHARING OF YOUR PERSONAL DATA.

 

SHARING OF YOUR PERSONAL DATA

A. General Sharing. We share your personal data as follows: 

• Within Swann. We share personnel personal data within Swann to receive IT services/security, Human Resources, tax and accounting, payroll, and general business and employment management. Access to personal data is limited to those on a need-to-know basis. The legal basis for this sharing is our legitimate interest in carrying out our business efficiently. 

• For legal purposes. We may share your personal data with third parties, such as legal advisors, law enforcement agencies, or governmental/regulatory bodies in order to protect our legal interests and other rights, protect against fraud or other illegal activities, for risk management purposes, and to comply with our legal obligations. The legal basis for this sharing is compliance with legal obligations and our legitimate interest in compliance with Non-EU laws applicable to Swann. 

• During 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, we may share personal data. The legal basis for this sharing is our legitimate interest in the efficient operation of our business or, consent, where this is required. 

• With service providers. We share your personal identifiers, protected classifications, professional or employment related information, internet or other electronic network information, and your customer records information to service providers that help us perform employment-related functions. These service providers include IT support, background check companies, payroll processors, financial services, compensation management providers, employee travel and expense management services, expense processors, health insurance providers, benefits providers and similar providers engaged to assist us in carrying out business activities and HR-related functions. When we transfer personal data from the European Economic Area (EEA), the United Kingdom (UK) or Switzerland for processing in countries outside the EEA, UK, or Switzerland which are not recognized by the EU, Switzerland or the UK as providing an adequate level of protection to personal data, for example, to the United States, we rely on approved data transfer mechanisms, such as Standard Contractual Clauses. 

• With IT support. We share your personal identifiers and internet or other electronic network information to IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, to identify and repair errors that impair functionality, and to improve, upgrade, or enhance Swann devices. The legal basis for this sharing is our legitimate interest in the efficient operation of our business. 

• With your consent. Apart from the reasons identified above, we may request your permission to share your personal data for a specific purpose. We will notify you and request consent before you provide the personal data or before the personal data you have already provided is shared for such purpose. You may revoke your consent at any time with effect moving forward and may do so by contacting us via email at [email protected].

 

B. Sharing in the Preceding Twelve (12) Months

For Business Purposes. In the preceding twelve (12) months, Swann has disclosed the following categories of personal information for a business purpose to the following categories of third parties:

• We have disclosed your personal identifiers, protected classifications, professional or employment related information, internet or other electronic network information, and your customer records information to service providers that help us perform employment-related functions. These service providers include IT support, background check companies, payroll processors, compensation management providers, expense processors, health insurance providers, and benefits providers.
• We have disclosed your personal identifiers and internet or other electronic network information to IT support to detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, to identify and repair errors that impair functionality, and to improve, upgrade, or enhance Swann devices.

C. Sale of Personal Information

Swann does not sell personnel personal information, nor does it share this information with third parties for cross-context behavioral advertising (i.e. targeted advertising).

 

INFORMATION SECURITY

We implement appropriate technical and organizational security measures, such as access controls and encryption and 24-7 threat monitoring, to protect the personal data that we collect and maintain from unauthorized access, destruction, use, modification, or disclosure. However, no security measure or modality of data transmission is 100% secure, and we are unable to guarantee the absolute security of the personal data we have collected from you.

 

RIGHTS OF INDIVIDUALS IN CALIFORNIA 

The California Privacy Rights Act (CPRA) entitles California employees to certain rights. To the extent the CPRA 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. Swann does not sell/share its employees’ 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. Swann does not conduct targeted advertising on its employees.
• 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,.

 

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.

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 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.

 

RIGHTS OF INDIVIDUALS IN THE EUROPEAN UNION AND UNITED KINGDOM

Individuals in the European Union and United Kingdom are entitled to certain rights under General Data Protection Regulation (“GDPR”) and the Data Protection Act 2018 (“DPA”), respectively. To the extent these laws apply to our processing of your personal data, you are entitled to the following rights:

• Right to access. You have the right to ask us for copies of your personal data, regardless of the legal basis for the processing. However, this right has some exemptions, which means you may not always receive all the personal data we process. 

• Right to rectification. You have the right to ask us to rectify personal data you think is inaccurate or incomplete, regardless of the legal basis for the processing. 

• Right to erasure. You have the right to ask us to erase your personal data except when the legal basis for the processing is to fulfill our legal obligations or to carry out a task in the public’s interest. 

• You have the right to ask us to restrict the processing of your personal data, regardless of the legal basis for the processing. 

• Right to object to processing. You have the right to object to our processing of your personal data when the legal basis for the processing is pursuant to our legitimate interests or to carry out a task in the public’s interest. 

• Right to data portability. You have the right to ask that we transfer the personal data you gave us from one organization to another or give it to you. However, this right only applies when: (i) you have provided your personal data to us; (ii) the legal basis for the processing is your consent or for the performance of a contract; and (iii) the processing is carried out by automated means. 

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

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

 

RIGHTS OF INDIVIDUALS IN AUSTRALIA

For employees in Australia, you 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].

 

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].

 

CHANGES TO THIS PRIVACY NOTICE 

Swann reserves the right to update or modify this Privacy Notice in our sole discretion at any time without prior notice. If we do, we will post the changes to this site, 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 Swann’s intranet, and obtain your consent, if required.

 

 CONTACT US 

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

By e-mail: [email protected] 

By mail: