Privacy Policy

Date updated: 12/01/2025

Introduction

Your privacy is important to us. Through this document, we explain how Swell collects, uses, and protects your personal data when you use our website, platform, or services that link to this Privacy Policy.

We will never ask for more information than necessary for the services requested; we will never share it with third parties except by legal obligation, court order, or your prior authorisation; and we will never use your data for any purpose not previously disclosed.

Clients: Those who contract our services and/or products. We may collect company name, tax or billing address, billing information, email, phone number, IP address, and, where appropriate, social media usernames of employees with whom Swell interacts.

You should read this Privacy Policy carefully on a regular basis and whenever you submit personal data, as it may be updated periodically to comply with applicable laws or to reflect changes in our practices. Any changes will be published on our website.

Processing of Data for Residents in Jersey, the EEA, UK, and Switzerland

Controller:
Identity: Swell
Postal address: 9 Bond Street, St Helier, Jersey, JE23NP
Email: privacy@swell.je

Swell processes your personal data in accordance with the Data Protection (Jersey) Law 2018, the UK GDPR, the EU GDPR, and other applicable laws. Swell has implemented appropriate technical and organisational measures to ensure the confidentiality, integrity, and availability of your data.

Method of Data Collection and Data We Collect

We collect data through:
- Contact forms: name, surname, email, job position.
- Chat: name, email, phone number.
- Newsletter subscription: email address.
- CV submission: name, surname, email, ID, phone, address, profession, experience, CV details.

Purpose of Processing

Your personal data will be used only for the following purposes:

- Responding to queries and providing requested information.
- Creating user accounts for our web platform.
- Sending marketing or informational communications (with consent).
- Managing recruitment processes and evaluating candidates.
- Performing administrative, fiscal, and accounting procedures as required by law.
- Improving our services and website usability through cookies.
- Managing social media interactions.

You can withdraw your consent at any time by emailing privacy@swell.je with the subject “Unsubscribe.” Swell does not engage in unsolicited communications or spam.

Legal Basis for Processing

The legal basis for processing is your consent provided when submitting data.
Where a contract exists, the legal basis is the performance of that contract.
Processing necessary to comply with legal obligations or legitimate interests will be conducted in line with applicable law.

Data Retention

Your data will be retained for as long as necessary to fulfil the purposes outlined in this policy, or until you exercise your right to deletion or objection. Certain data may be retained longer where legally required.

Recipients and International Transfers

Swell does not transfer data outside Jersey, the UK, or the EEA unless necessary for service provision and subject to appropriate safeguards.

Data may be shared with:

- Law enforcement or regulatory authorities when legally required.
- Trusted service providers (hosting, analytics, marketing, recruitment) under confidentiality agreements.

Your Rights

You may exercise your rights by contacting privacy@swell.je or writing to Swell, 9 Bond Street, St Helier, Jersey, JE23NP.

Rights include:

- Access
- Rectification
- Erasure
- Objection
- Restriction of processing
- Data portability
- Not to be subject to automated decisions

Complaints may be filed with the Office of the Information Commissioner (Jersey): https://oicjersey.org/

Security Measures

Your data is processed confidentially and securely. Swell adopts technical and organisational safeguards to protect against unauthorised access, alteration, loss, or destruction of data.

Language

The language applicable to this Privacy Policy is English. In the event of discrepancies, the English version shall prevail.

Google Merchant Center Integration

If you connect your Google Merchant Center account to our platform, Swell will access limited data necessary to provide services in compliance with Google’s API User Data Policy. You may revoke access at any time.

Social Networks

Swell may maintain profiles on social networks. Data from interactions will be processed per this policy and network terms. Unlawful or inappropriate content may be removed without notice.

CV Submissions

If you submit your CV via our platform, it will be processed for recruitment purposes and retained for up to one year unless renewed.

Changes to this Policy

Swell may update this Privacy Policy at any time. Updates will be indicated by the date above, and significant changes may be communicated separately.

Revocation of Consent

You may withdraw consent at any time by emailing privacy@swell.je. Withdrawal will not affect processing already performed.

Governing Law and Jurisdiction

This Privacy Policy is governed by the laws of Jersey. The courts of St Helier, Jersey, shall have exclusive jurisdiction.