Privacy & Cookies Policy
Effective date: May 25, 2018
Sway Ventures and its affiliates (“SWAY,” “WE,” OR “US”) and its employees place a high priority on protecting sensitive personal and financial information. We do not disclose clients’ confidential information, or that of former clients, except as permitted by you or required by law.
Particularly Important Information
Who we are: For the purpose of applicable data protection legislation, the data controller of your personal data is Sway Ventures of 325 Pacific Avenue, Suite 1 San Francisco, CA 94111.
Must Read Sections: We draw your attention in particular to the sections entitled “International Transfer of Data” and “Your choices in relation to personal data.”
What type of personal data do we collect and from where do we get it?
Why do we need your personal data?
We will only process your personal data in accordance with applicable data protection and privacy laws. We need certain personal data in order to provide our services. To process your personal data as outlined below, we rely on the following legal bases:
- Contractual Performance: We may process your personal data in order perform a contract that you have with us or in order to take steps before entering into a contract with you.
- Legitimate Interests: We may also use your personal data where we have legitimate interests to do so. For instance, we process personal data for administrative, fraud detection and other legal purposes.
How do we collect personal information?
We may collect and process information that you provide during your correspondence with us. This could include, but is not limited to, any of the following ways:
- Giving information directly to us by methods including filling in forms either on our website, online platforms or via other electronic media
- Requesting any of our goods, services, downloads or other information
- Communicating with us through methods including but not limited to e-mail, telephone and written correspondence
We automatically log information about you and your computer or mobile device when you visit our websites. For example, we may log your computer or mobile device operating system name and version, manufacturer and model, browser type, browser language, screen resolution, the website you visited before browsing to our websites, pages you viewed, how long you spent on a page, access times and information about your use of and actions on our websites. We use Google Analytics for this purpose. You can find out more information about Google Analytics “cookies” here: https://developers.google.com/analytics/resources/concepts/gaConceptsCookies and how Google protects your data here: www.google.com/analytics/learn/privacy.html. You can prevent the use of Google Analytics relating to your use of our websites by downloading and installing the browser plugin available via this link: http://tools.google.com/dlpage/gaoptout?hl=en-GB.
We may also get information about you from other sources, for example, if you have agreed to share information with one of our partners.
How do we use personal data?
Unless expressly agreed otherwise, we may disclose the information described above to custodians, fund administrators, investment managers, and other nonaffiliated companies or individuals, such as legal, audit, and tax advisors, in the manner and to the extent permitted by you or as required by law. We may also disclose the information described above to other nonaffiliated service providers, such as providers of reporting data, data storage and fund monitoring services for our everyday business purposes in supporting our provision of services. We may also share your personal data with marketing agencies who help us promote ourselves or deliver our services, as well as printer/email service providers or other suppliers who help us to send our newsletters and communications. We require third parties to respect the security of your data and to treat it in accordance with the law. We will share your personal data with third parties where required by law.
Our affiliates may also use nonpublic personal data about you to determine eligibility for services and to make marketing solicitations. This information is only provided with the understanding that it will be maintained in confidence. To opt out of affiliate use of your personal data for eligibility or marketing solicitation, please send such request to email@example.com.
We do not use your personal data for the purposes of automated decision-making. However, we may do so in order to fulfil obligations imposed by law, in which case we will inform you of any such processing and provide you with an opportunity to object.
International Transfer of Data
Sway may send your data outside the jurisdiction from which it originated or was collected, including, but not limited to the United States, where data protection and privacy regulations may not offer the same level of protection as in other parts of the world. Where personal data is transferred or accessed outside of a specific jurisdiction, we require that appropriate safeguards are in place to comply with any applicable data protection regulations.
Your choices in relation to personal data
It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us. You also have rights and choices which you can exercise with respect to the data we hold on you. You have the right to:
- Obtain access to your personal data
- Withdraw consent
- Object to direct marketing
- Ask us to correct any errors or delete the information we hold
- Object or restrict our processing of your information, including with respect to automated decision-making and/or profiling, our collection of sensitive personal data, and the transfer of your personal data outside the European Economic Area (EEA)
- Request a copy of your personal data and move your personal data
Retention and destruction of personal data
We take reasonable steps to ensure the accuracy of the information we hold about you. We will not use your personal data unless it is (to our knowledge) accurate and up to date. We typically will only retain your personal data for as long as necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, accounting or reporting requirements. To determine the appropriate retention period for personal data, we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means and the applicable legal requirements.
In some circumstances we may anonymize your personal data so that it can no longer be associated with you, in which case we may use such information without further notice to you. When the purposes for which we have collected the data for have ended we will retain and securely destroy your personal data in accordance with our policy, applicable laws and regulations.
Unfortunately, the transmission of data over the internet is not completely secure. Although we will use our reasonable commercial efforts to protect your personal data, we cannot guarantee its security. Once we have received your data we will use strict security measures to try to protect it against loss, misuse, unauthorized alterations or interception when transferred electronically. The firm maintains physical, electronic and procedural safeguards including the use of encryption technologies to protect your confidential information.