Personal Data Usage Policy

Last updated: September 1, 2024

If you are a customer, prospect, partner, or if you are an executive, an employee using a Swytouch service, Swytouch may process personal data concerning you. This is the case when you visit the website, when you communicate or interact with Swytouch (by phone, email, or via your Swytouch account, through online forms or other communication tools such as Chatbots and others), when you participate in Swytouch events, or when you use Swytouch services.

The purpose of this policy is to describe all the personal data processing concerning you carried out by Swytouch and to specify the conditions.

This policy applies to the processing of personal data implemented by Swytouch as a data controller, that is, those for which Swytouch determines the means and purposes. The conditions of processing carried out by Swytouch as a data processor, particularly on instructions from its clients, are detailed in Part I of the Appendix "Swytouch Personal Data Processing".

The terms defined by Regulation (EU) 2016/679 of the European Parliament and of the Council on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, or "GDPR" (for example "personal data", "data controller", "data processor", etc.) have the same meaning when used in the context of this policy.

1. Description of personal data processing

Swytouch processes data concerning you for various purposes, in particular:

1. Contract management
2. Service execution
3. Marketing activities and commercial prospecting
4. Compliance with legal obligations
5. Pursuit of legitimate interests

2. Conditions for carrying out processing

1. Commitments
2. Technical and organizational security measures
3. Anonymization
4. Subcontracting
5. Data transfers outside the European Union
6. Processing of authority requests
7. Rights of data subjects