Publication Date: March 10 2017, V2
Swann Communications Ltd recognises that your personal information is important to you and that you are concerned with its collection, use and disclosure. We are committed to protecting your privacy and to developing technology that gives you the most powerful and secure online experience.
This policy contains information about:
- when you can deal with Swann Communications anonymously;
- the purposes for which Swann Communications collects, holds, uses and discloses personal information;
- the types of personal information that Swann Communications collects;
- how Swann Communications collects and holds personal information;
- how you may access the personal information that Swann Communications holds about you, and how you may seek correction of that personal information; and
- how you may complain about a breach of the Privacy Principles by Swann Communications and how Swann Communications will deal with such a complaint.
We may also use your personal information for other purposes related to those described above which would be reasonably expected by you.
When can you deal with Swann Communications anonymously?
Generally, you can deal with Swann Communications anonymously (i.e. without identifying yourself). In certain circumstances however, Swann Communications will ask you to provide personal information because it is required by law to do so, or because it would be impracticable to deal with you anonymously.
These circumstances include where you order goods online, where you register an extended warranty on a product online, where you download one of our mobile device apps, where you return goods for repair, where you purchase goods to be delivered or installed, where you create a Swann Communications account, where you join Swann Communications email database (Swann Mail), where you enter one of our competitions, when you submit a request, enquiry, complaint and a consumer guarantee or warranty claim.
Why does Swann Communications collect, hold, use and disclose personal information?
Swann Communications collects, holds, uses and discloses personal information for a number of purposes connected with our business operations, which include:
- providing you with products and/or services requested;
- dealing with requests, enquiries, complaints, consumer guarantee or warranty claims, and other customer care related activities;
- marketing our products and services and providing advice on our products;
- developing and improving our products and services;
- in connection with our email programmes and competitions;
- the operation and administration of accounts or subscriptions that you have with us (including certain features of Swann Apps to remotely view or use via smartphone or tablet);
- payment processing;
- carrying out certain checks (for example, for our fraud or theft prevention processes);
- interacting with companies or organisations with whom Swann Communications has a business relationship (where you work for, or otherwise represent, such an organisation);
- reconciling payments due to Swann Communications from suppliers in relation to goods or services provided to you by those suppliers;
- purposes relating to any third party acquisition or potential acquisition of an interest in Swann Communications or its assets;
We may also use and disclose your personal information for other purposes related to those described above which would be reasonably expected by you. Documents (including hard copy documents and electronic documents such as emails) which coincidentally contain personal information will also be retained in accordance with Swann Communications normal document retention practices for accounting, legal and business purposes.
Generally, you have no obligation to provide any personal information requested by us. However, if you choose not to do so where we require this information, we are unlikely to be able to provide you with the goods and services that you want.
What personal information does Swann Communications collect?
The kinds of personal information we collect or which we may hold about you may include:
- your name;
- your address;
- your date of birth;
- your telephone number(s);
- your e-mail address;
- payment information;
- transaction information;
- your user name and password;
- information on how you use our products and services;
- your Internet Protocol ("IP") address, server address, domain name and information on your browsing activity when visiting one of our websites;
- your user name for social networking sites that you use, to refer to, or in conjunction with, our goods and services; and
- personal preferences regarding products and services.
How does Swann Communications collect and hold your personal information?
We collect personal information in a number of ways including:
- when you order goods or services from us (either online or over the telephone);
- when you set up an account with us;
- when you commence using a Swann mobile App
- when you purchase certain products or register for an extended warranty from us;
- when you subscribe to our mailing list (Swann Mail);
- when you create a Swann Communications user account online;
- when you enter competitions or promotions that we run;
- when you provide us your details for customer care purposes;
- when you submit an enquiry using one of our websites;
- when you complete surveys or provide online feedback or product reviews; and
- when you publicly comment about us on social media sites (for example so that we can answer questions about our products).
Generally, Swann Communications will collect your personal information directly from you. However, Swann Communications also holds information, collected incidentally, concerning individuals who work for companies or organisations that have a business relationship with Swann Communications. Additionally, if you apply for a job with Swann Communications, we may collect personal information about you from any third parties that you nominate as your referees in your application. Swann Communications holds personal information in a number of ways, including:
- as part of customer records and other electronic documents on which personal information is contained which are stored on our information technology systems and servers operated by third parties who provide services to us in connection with our business; and
- by securely storing hard copy documents on which personal information is contained, at our various premises and using third party document management and archiving services.
How do we keep your personal information Secure?
We maintain a variety of physical, electronic, and procedural safeguards to protect your personal information. When you are ordering services via our website, we use the Internet encryption protocol Secure Sockets Layer (SSL) to protect the security of your personal information. The SSL protocol is also implemented for (i) guarding your account information when you are viewing your bills or orders on our websites, and (ii) securing all logs of settings and online services of your device(s).
Swann Communications will continue to revise its policies and implement additional security features as new technologies become available. However, no system or service can provide an absolute assurance of security, especially services that rely to some extent on the Internet. Therefore, by using our services and website(s), you acknowledge the risk that third parties may gain unauthorised access to your information. If we determine that a security breach has occurred and that such breach creates a risk of identity theft or service disruption, we will make reasonable attempts to notify you.
You should understand data via online transmission is not completely secure. We cannot guarantee full protection and security data, only that we take all reasonable action to protect information sent to us electronically. Transmission of any data by you is at your own risk. Where applicable you may be given access to sections of our site that require a username and password. You are responsible for the username and password’s safety and confidentiality.
When you create an account with us your details will be added to our marketing database to receive information relating to Swann Communications and our products. You may also choose to receive such information by subscribing to our marketing database via one of our websites.
To opt-out of receiving Swann Communications marketing materials, you will need to unsubscribe from our marketing database. To do this, simply select the "unsubscribe" option in one of the emails that you receive from us. Please note that if you have an account with Swann Communications, we may still need to send you essential information about your account or service updates.
Sharing your personal information
Swann Communications may disclose or receive personal information or documents about you to / from: organisations that provide services to us in connection with our business, including customer support, payment processing, administration, archival, data storage, hosting, research, mail and delivery, installation, distribution, logistics, marketing, auditing, share registry, consulting, financial and legal advisory, banking, debt collection, security or technical services and the operation of the Swann Communications mobile App services and other Swann Communications websites. In some cases these service providers may collect your personal information on our behalf;
- if you return goods to Swann Communications to be repaired, our repairs system administrator and authorised repairers;
- law enforcement agencies to assist in the prevention, investigation and prosecution of criminal activities;
- parties involved in any third party acquisition or potential acquisition of an interest in Swann Communications or its assets;
- our insurers and insurance brokers; and
- to other third parties where you have specifically consented to the disclosure of information to these third parties.
Additionally, if you return goods to Swann Communications on which personal information is stored for repair (for example, on a Security Recorder) and do not delete that personal information.
Disclosure of personal information to overseas recipients
Swann Communications is likely to disclose the personal information that it collects and holds about you to third parties who are not in Australia (such as third parties who are located in the United States of America, the United Kingdom, Canada, Hong Kong and New Zealand).
Your information may be stored and processed in the Australia/United States/United Kingdom or any other country in which Swann Communications or its affiliates, subsidiaries or agents maintain facilities, and by using this site, you consent to any such transfer of information outside of your country. Swann Communications abides by the safe harbor framework as set forth by the Canadian Ministry of Commerce regarding the collection, use, and retention of data from the European Union.
Control of your Personal Information
When you register, or otherwise give us personal information, Swann Communications will not share that information with third parties without your permission, other than for the limited exceptions already listed. It will only be used for the purposes stated above. Registering also allows you to tell us how or whether you want Swann Communications to communicate with you.
Swann Communications occasionally allows other companies to offer our registered customers information about their products and services, using postal mail only. Swann Communications may send out periodic e-mails informing you of technical service issues related to a product or service you requested. You will not be able to choose to unsubscribe to these mailings, as they are considered an essential part of the service you have chosen.
How to access, correct and update your personal information
We will provide you with the means to ensure that your personal information is correct and current. You may review and update this information at any time by contacting us at email@example.com
View and edit personal information you have already given us at www.swann.com. Tell us whether you want to send you marketing information. Choose whether you want third parties to send you their offers by postal mail. Subscribe, or cancel subscriptions, to newsletters about our services and products.
Upon your request, Swann Communications will provide access to your personal information that we hold (except in certain circumstances set out in specific Government legislation such as the Privacy Act 1988 (Australia). Swann Communications will require some proof of your identify before providing information to you.
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.
To request access to the personal information that Swann Communications holds about you, or to update or correct that personal information, please send a written request to The Privacy Officer, Swann Communications Limited by email to firstname.lastname@example.org
How to make 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@example.com
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 endeavour 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.
Additional information for users of our websites
If you visit www.swann.com, www.swann.com/au, www.swann.com/us, www.swann.com/uk or any other Swann Communications websites (the "Websites") to read, browse or download information, our system may record information such as the date and time of your visit to the Website, the pages accessed and any information downloaded. This information is used (i) for statistical and reporting purposes; (ii) for website administration, security and maintenance purposes; and (iii) to direct you to material on our Websites that we believe will be of interest to you.
Like many websites, our Website may use "cookies" from time to time. Cookies are small text files that we transfer to your computer's hard drive through your web browser to enable our systems to recognise your browser and your log-in status. Cookies may also be used to record non-personal information such as the date, time or duration of your visit, or the pages accessed, for website administration, statistical and maintenance purposes. Any such information will be aggregated and not linked to particular individuals. The default settings of browsers like Internet Explorer usually allow cookies, but users can easily erase cookies from their hard-drive, block all cookies, or receive a warning before a cookie is stored. Please note that some parts of the Website may not function fully for users that disallow cookies.
While we take great care to protect your personal information on our Website and use state-of-the-art data transmission encryption, unfortunately no data transmission over the Internet can be guaranteed to be 100% secure. Accordingly, we cannot ensure or warrant the security of any information that you send to us or receive from us online. This is particularly true for information you send to us via email. We have no way of protecting that information until it reaches us. Once we receive your transmission, we use our best efforts to ensure its security in our possession. The Websites may contain links or plug-ins to other 3rd party sites. We are not responsible for content of, or the privacy practices or policies of, those sites.
Additional information for users of our mobile Apps
If you have any queries or concerns, further information can be obtained by contacting our Privacy Officer by email to firstname.lastname@example.org
Swann Communications Ltd