Thank you for joining swift-integration.nl. We at Swift Software Ltd. (“Swift Software Ltd.”, “we”, “us”) respect your privacy and want you to understand how we collect, use, and share data about you. This Privacy Policy covers our data collection practices and describes your rights regarding your personal data.

Unless we link to a different policy or state otherwise, this Privacy Policy applies when you visit or use swift-integration.nl's websites, mobile applications, or related services (the “Services”).

By using the Services, you agree to the terms of this Privacy Policy. You shouldn't use the Services if you don't agree with this Privacy Policy or any other agreement that governs your use of the Services.

Table of Contents

• 1. What Data We Get
• 2. How We Get Data About You
• 3. What We Use Your Data For
• 4. Who We Share Your Data With
• 5. Security
• 6. Your Rights
• 7. Jurisdiction-Specific Rules
• 8. Updates & Contact Info

1. What Data We Get

1.1 Data You Provide to Us

We may collect different data from or about you depending on how you use the Services. Below are some examples to help you better understand the data we collect.

When you create an account and use the Services, including through a third-party platform, we collect any data you provide directly, including:

The data listed above is stored by us and associated with your account. Swift Software Ltd.'s use and transfer to any other app of information received from Google APIs, will adhere to Google API Services User Data Policy, including the Limited Use requirements.

1.2 Data We Collect through Automated Means

When you access the Services (including browsing content), we collect certain data by automated means, including:

The data listed above is collected through the use of server log files and tracking technologies, as detailed in the “Cookies and Data Collection Tools” section below. It is stored by us and associated with your account.

2. How We Get Data About You

2.1 Cookies and Data Collection Tools

We use cookies, which are small text files stored by your browser, to collect and store necessary data for the functioning of our Services. They allow us to remember things about your visits to swift-integration.nl, like your preferred language, and to make the site easier to use. To learn more about cookies, visit https://cookiepedia.co.uk/all-about-cookies.

Swift Software Ltd. and service providers acting on our behalf (like Google Analytics and third-party advertisers) use server log files and automated data collection tools like cookies, tags, scripts, customized links, device or browser fingerprints, and web beacons (together, “Data Collection Tools“) when you access and use the Services. These Data Collection Tools automatically track and collect certain System Data and Usage Data (as detailed in Section 1) when you use the Services. In some cases, we tie data gathered through those Data Collection Tools to other data that we collect as described in this Privacy Policy.

2.2 Why We Use Data Collection Tools

Swift Software Ltd. uses the following types of Data Collection Tools for the purposes described:

• Strictly Necessary: These Data Collection Tools enable you to access the site, provide basic functionality (like logging in or accessing content), secure the site, protect against fraudulent logins, and detect and prevent abuse or unauthorized use of your account. These are required for the Services to work properly, so if you disable them, parts of the site will break or be unavailable.
• Functional: These Data Collection Tools remember data about your browser and your preferences, provide additional site functionality, customize content to be more relevant to you, and remember settings affecting the appearance and behavior of the Services (like your preferred language or volume level for video playback).
• Performance: These Data Collection Tools help measure and improve the Services by providing usage and performance data, visit counts, traffic sources, or where an application was downloaded from. These tools can help us test different versions of swift-integration.nl to see which features or content users prefer.

You can set your web browser to alert you about attempts to place cookies on your computer, limit the types of cookies you allow, or refuse cookies altogether. If you do, you may not be able to use some or all features of the Services, and your experience may be different or less functional. To learn more about managing Data Collection Tools, refer to Section 6.1 (Your Choices About the Use of Your Data) below.

3. What We Use Your Data For

We use the data we collect through your use of the Services to:

• Provide and administer the Services, including to facilitate participation in educational content and display customized content (Account Data; Shared Content; Learning Data; System Data; Usage Data; Approximate Geographic Data);
• Process payments (Student Payment Data);
• Process your requests and orders for educational content, products, specific services, information, or features (Account Data; Learning Data; Student Payment Data; System Data; Communications and Support);
• Communicate with you about your account by (Account Data; Learning Data; Surveys; System Data; Communications and Support):
  • Responding to your questions and concerns;
  • Sending you administrative messages and information; notifications about changes to our Service; and updates to our agreements;
• Manage your account and account preferences and personalize your experience (Account Data; Learning Data; Student Payment Data; System Data, Usage Data, Cookie Data);
• Facilitate the Services' technical functioning, including troubleshooting and resolving issues, securing the Services, and preventing fraud and abuse (Account Data; Student Payment Data; Communications and Support; System Data; Approximate Geographic Location);
• Solicit feedback from users (Account Data; Communications and Support);
• Surveys (Account Data; Learning Data; Surveys; Usage Data; Cookie Data);
• Identify unique users across devices (Account Data; System Data; Cookie Data);
• Improve our Services and develop new products, services, and features (all data categories).
• Analyze trends and traffic, track purchases, and track usage data (Account Data; Learning Data; Student Payment Data; Communications and Support; System Data; Usage Data; Approximate Geographic Data; Cookie Data);
• As required or permitted by law (all data categories); or
• As we, in our sole discretion, otherwise determine to be necessary to ensure the safety or integrity of our users, employees, third parties, the public, or our Services (all data categories).

We may process your inputs into the AI Assistant chatbot or other generative artificial intelligence (GenAI) features using GenAI in order to respond to your question or request, but we do not use your personal data to train or fine tune GenAI models.

4. Who We Share Your Data With

We may share your data with third parties under the following circumstances or as otherwise described in this Privacy Policy:

• With Service Providers, Contractors, and Agents: We may share your data with third-party companies who perform services on our behalf, like payment processing, fraud and abuse prevention and data analysis. These service providers may access your personal data and are required to use it solely as we direct, to provide our requested service. (All data categories)
• With Business Partners: We have agreements with other websites and platforms to distribute our Services and drive traffic to swift-integration.nl. Depending on your location, we may share your location data with these trusted partners. (Account Data; Learning Data; Communications and Support; System Data)
• With Analytics Services: As part of our use of third-party analytics tools like Google Analytics, we share certain contact information or de-identified data. De-identified data means data where we’ve removed things like your name and email address and replaced it with a token ID. This allows these providers to provide analytics services or match your data with publicly-available database information (including contact and social information from other sources). We do this to communicate with you in a more effective and customized manner. (Account Data; System Data; Usage Data; Cookie Data)
• To Administer Surveys: We may share your data as necessary to administer surveys you choose to participate in, as required by applicable law (like to make required filings), or in accordance with the rules of the survey. (Account Data; Surveys)
• For Security and Legal Compliance: We may disclose your data (all data categories) to third parties if we (in our sole discretion) have a good faith belief that the disclosure is:
  • Requested as part of a judicial, governmental, or legal inquiry, order, or proceeding;
  • Reasonably necessary as part of a valid subpoena, warrant, or other legally-valid request;
  • Reasonably necessary to enforce our Terms of Use, Privacy Policy, and other legal agreements;
  • Required to detect, prevent, or address fraud, abuse, misuse, potential violations of law (or rule or regulation), or security or technical issues;
  • Reasonably necessary in our discretion to protect against imminent harm to the rights, property, or safety of Swift Software Ltd., our users, employees, members of the public, or our Services;
  • We may also disclose data about you to our auditors and legal advisors in order to assess our disclosure obligations and rights under this Privacy Policy; or
  • Required or permitted by law.
• During a Change in Control: If Swift Software Ltd. undergoes a business transaction like a merger, acquisition, corporate divestiture, or dissolution (including bankruptcy), or a sale of all or some of its assets, we may share, disclose, or transfer all of your data to the successor organization during such transition or in contemplation of a transition (including during due diligence). (All data categories)
• After Aggregation/De-identification: We may disclose or use aggregated or de-identified data for any purpose.
• With Your Permission: With your consent, we may share data to third parties outside the scope of this Privacy Policy. (All data categories)

If you click on any links to third-party sites, the collection, use, and disclosure of your personal data is governed by the third-party's privacy policy.

5. Security

Swift Software Ltd. uses appropriate security measures to protect against unauthorized access, alteration, disclosure, or destruction of your personal data that we collect and store. These measures vary based on the type and sensitivity of the data. Unfortunately, however, no system can be 100% secured, so we cannot guarantee that communications between you and Swift, the Services, or any information provided to us in connection with the data we collect through the Services will be free from unauthorized access by third parties. Your password is an important part of our security system, and it is your responsibility to protect it. You should not share your password with any third party, and if you believe your password or account has been compromised, you should change it immediately and contact our Support Team with any concerns.

6. Your Rights

If you have any questions about your data, our use of it, or your rights, contact us at support@swift-integration.nl.

6.1 Accessing, Updating, and Deleting Your Personal Data

You can access and update your personal data that Swift Software Ltd. collects and maintains as follows:

• To update data you provide directly, log into your account and update your account at any time.
• To terminate your account:
  • If you wish to remove all your personal data, you can visit your profile settings page and click the 'Delete Account' button..
  • If you have any issues terminating your account, please contact our Support Team.
  • Please note: Even after your account is terminated, we retain your data for as long as we have a legitimate purpose to do so (and in accordance with applicable law), including to assist with legal obligations, resolve disputes, and enforce our agreements. We may retain and disclose such data pursuant to this Privacy Policy after your account has been terminated.
• To request to access, correct, or delete your personal data, please use our online form here. You can also submit these requests by emailing support@swift-integration.nl. For your protection, we may require that the request be sent through the email address associated with your account, and we may need to verify your identity before implementing your request. Please note that we retain certain data where we have a lawful basis to do so, including for mandatory record-keeping and to complete transactions.

6.2 Our Policy Concerning Children

We recognize the privacy interests of children and encourage parents and guardians to take an active role in their children's online activities and interests. Individuals younger than 18 years of age, but of the required age for consent to use online services where they live (for example, 13 in the US or 16 in Ireland), may not set up an account, but may have a parent or guardian open an account and help them access appropriate content. Individuals younger than the required age for consent to use online services may not use the Services. If we learn that we’ve collected personal data from a child under those ages, we will take reasonable steps to delete it.

Parents who believe that Swift Software Ltd. may have collected personal data from a child under those ages can submit a request that it be removed to support@swift-integration.nl.

7. Jurisdiction-Specific Rules

7.1 Users in the European Economic Area (“EEA”) and United Kingdom (“UK”)

If you are located in the EEA or UK, you have the right to request access to your data in a portable format and to request the rectification, erasure, restriction of processing, or objection to processing of your personal data. You may use the information in Section 6 to submit your request. Additionally, if you are located in the EEA, UK, or Switzerland, you also have the right to lodge a complaint with your supervisory authority.

Personal data is also processed outside of the UK, Switzerland, and the EEA by us, or our service providers, including to process transactions, facilitate payments, and provide support services as described in Section 4. We use the Controller-to-Processor Standard Contractual Clauses adopted by the European Commission to facilitate transfers of personal data from the EEA to third countries and have entered into data processing agreements with our service providers to restrict and regulate their processing of your data. By submitting your data or using our Services, you consent to this transfer, storage, and processing by Swift Software Ltd. and its processors.

8. Updates & Contact Info

8.1 Modifications to This Privacy Policy

From time to time, we may update this Privacy Policy. If we make any material change to it, we will notify you via email, through a notification posted on the Services, or as required by applicable law. We will also include a summary of the key changes. Unless stated otherwise, modifications will become effective on the day they are posted.

As permitted by applicable law, if you continue to use the Services after the effective date of any change, then your access and/or use will be deemed an acceptance of (and agreement to follow and be bound by) the revised Privacy Policy. The revised Privacy Policy supersedes all previous Privacy Policies.

8.2 Interpretation

Any capitalized terms not defined in this policy are defined as specified in Swift Software Ltd.'s Terms of Use. Any version of this Privacy Policy in a language other than English is provided for convenience. If there is any conflict with a non-English version, you agree that the English language version will control.

8.3 Questions

If you have any questions, concerns, or disputes regarding our Privacy Policy, please feel free to contact our privacy team (including our Data Protection Officer) at support@swift-integration.nl.