1. INTRODUCTION

1.1            Important information and who we are

Welcome to eSwapp’s Privacy and Data Protection Policy (“Privacy Policy”).

At eSwapp (“we”, “us”, or “our”) we are committed to protecting and respecting your privacy and Personal Data in compliance with the United Kingdom General Data Protection Regulation (“GDPR”), the Data Protection Act 2018 and all other mandatory laws and regulations of the United Kingdom.

This Privacy Policy explains how we collect, process and keep your data safe. The Privacy Policy will tell you about your privacy rights, how the law protects you, and inform our employees and staff members of all their obligations and protocols when processing data.

The individuals from which we may gather and use data can include:

1. 1. • Customers
      • Visitors to our website who sign up to use our product(s)
      • Anyone who uses our product(s).

and any other people that the organisation has a relationship with or may need to contact.

This Privacy Policy applies to all our employees and staff members and all Personal Data processed at any time by us.

1.2           Who is Your Data Controller and Information Security Officer

eSwapp is your Data Controller and responsible for your Personal Data.

We have appointed an Information Security Officer (“ISO”) who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights surrounding your Personal Data please contact the ISO using the details set out below:

Full name: Ghazal Diani

Email address: info@eswapp.com

Postal address: 24 Holborn Viaduct, London, EC1A 2BN, United Kingdom

You have the right to make a complaint at any time to the Information Commissioner’s Office (ICO), the UK supervisory authority for data protection issues (www.ico.org.uk). We would, however, appreciate the chance to deal with your concerns before you approach the ICO so please contact us in the first instance.

1.3           Processing Data on Behalf of a Controller and Processors’ responsibility to you

In discharging our responsibilities as a Data Controller we have employees who will deal with your data on our behalf (known as “Processors”). Therefore, the responsibilities described below may be assigned to an individual, or may be taken to apply to the organisation as a whole. The Data Controller and our Processors have the following responsibilities:

• • • Ensure that all processing of Personal Data is governed by one of the legal bases laid out in the GDPR (see 2.2 below for more information on those bases);
    • Ensure that Processors authorised to process Personal Data have committed themselves to confidentiality or are under an appropriate statutory obligation of confidentiality;
    • Implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk associated with the processing of Personal Data;
    • Obtain the prior specific or general authorisation of the Controller before engaging another Processor;
    • Assist the Controller in the fulfilment of the Controller’s obligation to respond to requests for exercising the data subject’s rights;
    • Make available to the Controller all information necessary to demonstrate compliance with the obligations laid down in the GDPR and allow for and contribute to audits, including inspections, conducted by the Controller or another auditor mandated by the Controller;
    • Maintain a record of all categories of processing activities carried out on behalf of a Controller;
    • Cooperate, on request, with the supervisory authority in the performance of its tasks;
    • Ensure that any person acting under the authority of the Processor who has access to Personal Data does not process Personal Data except on instructions from the Controller;
    • Notify the Controller without undue delay after becoming aware of a Personal Data Breach;
    • Designate a data protection officer where required by the GDPR, publish their details and communicate them to the supervisory authority; and
    • Support the data protection officer in performing their tasks by providing resources necessary to carry out those tasks and access to Personal Data and processing operations, and to maintain their expert knowledge;

1.4           Third Party Processors

Our carefully selected partners and service providers may process personal information about you on our behalf as described below:

Digital Marketing Service Providers

We may periodically appoint digital marketing agents to conduct marketing activity on our behalf, such activity may result in the compliant processing of personal information. Our appointed data processor is as follows:

Prospect Global Ltd (trading as Sopro) Reg. UK Co. 09648733.

You can contact Sopro and view their privacy policy here: http://sopro.io. Sopro are registered with the ICO Reg: ZA346877 their Data Protection Officer can be emailed at: dpo@sopro.io.