1.Who are we?
- We are Swogo Limited. For privacy queries, you can contact us at email@example.com.
Other contact details are on our website.
2.What’s the point of this policy?
- It tells you what to expect when we collect your personal information via our
own website or when end-users use our service on our clients’
websites. Our service involves providing users the option to buy related
products (e.g., “products frequently bought together”).
- Generally, the policy covers only information provided to us. If you give personal
information to other people, such as our clients or other websites, please check their
3.Might the policy change?
- Yes. Please check it whenever you visit our website.
4.What do we collect?
- On our own website, information which you upload or otherwise give us such as:
- your name and contact details if you request a demo;
- contact or other information which you give or allow us to use for
newsletters or other marketing; and
- automated information about your use of our website such as: the internet
protocol (IP) address used to connect your device to the internet,
connection information such as browser type and version, information about
your device including device-type and device identifier, operating system
and platform, mobile network data, a unique reference number linked to the
data you enter on our system, login details, the site from which you arrived
at our service, details of your activity with date / time stamps including
pages you visited.
- On our clients’ sites, we may collect (using a cookie – see section 10 below):
- information about an end-user’s visibility of, or interaction with, our
suggested related products including adding them to a basket or selecting
different versions of the product;
- information about an end user’s interaction with a basket that includes any
related products; and
- any related and other products bought by the end-user as well as the
associated order number or identifier generated on our client’s website.
5.What’s our reason / legal basis for collecting the information?
- Because it’s necessary to take steps at your request to enter into a
contract with you and/or to perform such a contract. This applies to initial
enquiries and to contact details.
- Because it’s in our “legitimate interests”, e.g., to manage and improve our
service including tracking usage patterns, enhancing optimisation and
preventing or detecting fraud or abuse. This applies to automated usage
- Because you’ve specifically agreed on our service (e.g, by ticking a consent
box). This applies to contact or other information which you give or allow
us to use for newsletters or other marketing. You can withdraw permission at
any time as explained on our service or by emailing us at the above email
6.How long do we keep personal information?
- In relation to our own site:
- we will keep names and contact details until any contract with you has ended
(or for 24 months if you don’t enter a contract with us);
- we may hold on to some of your information for longer (typically up to six
years) if reasonably needed for legal, regulatory or tax reasons;
- we will keep your information which we use only for newsletters or other
marketing until you tell us to stop sending you such messages; and
- we will generally keep automated browsing information for up to 26 months.
- In relation to end-user information collected on our clients’ sites: we will keep
end-user data for up to two years.
7.To whom do we send or make available your personal information?
- To other people who supply us with a service, e.g. website hosts, cloud providers
and businesses which help us send communications or monitor our website and which
provide us with analytics and other IT services.
- In relation to end-user purchase information collected on our clients’ sites, to the
client on whose site we collected the data (to enable performance-reporting, payment
- To regulators, the police and other law enforcement authorities to help deal with
fraud and abuse and/or comply with legal requirements.
- To insurers and professional advisers in connection with our insurance cover or to
deal with legal claims.
- To potential buyers so far as reasonably necessary, in the case of an actual or
proposed (including negotiations for a) sale or merger or business combination
involving all or the relevant part of our business.
8.Do we send your information outside the EU?
- Your personal information which we collect is stored within the EU and is not
transferred to any third countries except as follows.
- In relation to our our own site, your personal information (e.g., IP address, browsing
information) may be transferred to the US by Google for analytics. Transfer is on
the basis of a contracts with EU-mandated standard contractual clauses designed to
provide adequate safeguards for your personal information. Google was formerly
certified under the EU-US Privacy Shield Framework which is no longer applicable due
to a court decision; we understand that the authorities are working on a replacement
and we aim to update our policy to reflect this in due course.
9.What rights do you have?
- If the legal requirements are met: To ask us for access to your personal
information, to rectify it if there are mistakes, to delete it or restrict its use
in certain circumstances or to “data portability” or to withdraw any consent you’ve
given (e.g. marketing).
- You may also have the right to object to use of your personal information in certain
- If you have a complaint about how we are dealing with your personal information,
please contact us via the email address above. If you are not happy with our
response or think we are not handling your personal information in accordance with
the law, you have the right to complain to the Information Commissioner’s Office
- For more information about your rights, visit the ICO’s website: www.ico.org.uk.
10.What about cookies?
website. A cookie is an identifier (a small file of letters and numbers) that is
sent to your web browser. Cookies are widely used to make websites work, or work
more efficiently, as well as to provide information to the website owner or others.
Some are session temporary “session” cookies that remain in the cookie file of your
browser only until your browser is closed. Whereas persistent cookies stay for
longer (depending on the lifetime of the specific cookie). For further information
on cookies, including how to use your browser to block them and how to delete
existing cookies, visit: www.allaboutcookies.org. Our site’s
functionality will be limited if you configure your browser to reject cookies.
- On our own website, we may place a cookie notice cookie to store your response to
our cookie notice.
- Google also places cookies on our own website in connection with its Google
Analytics (“GA”) service. These kinds of cookies recognise and count the number of
website visitors as well as providing other information about the visit such as
duration, route through the website and where the visitor came from. This
information helps us to improve the way our website works, for example by making
sure users find what they need easily. More information:
- We place cookies on our clients’ sites called “swogoTransactionId”,
“swogoVariantIdx”, “swogoSkusAddedToCart” and “swogoReferral”. The purpose of these
cookies is to help us generate lists of related products and to enable us to collect
the end-user information explained above (see section 4). The cookies themselves do
not include any personal information. We regard these cookies as essential for our
service. They are placed at the point when the end-user first visits the page that
includes related products. The cookies are deleted either when the end-user makes a
purchase or, if no purchase is made, within 30 days. Our clients can adjust end-user
consent and opt-out settings for our cookies.