Privacy policy.
Last updated: [2023/05/05]
Table of contents
1. What does SWM Health do?
2. Personal information we collect and process
3. How we use your personal information (our purposes) and our legal basis for processing it
4. Who we share your personal information with
5. Cookies and similar tracking technology
6. How we keep your personal information secure
7. International data transfers
8. Data retention
9. Your data protection rights
10. Updates to this Privacy Notice
11. How to contact us
We recommend that you read this Privacy Notice in full to ensure you are completely informed about your personal data. However, if you only want to access a particular section of this Privacy Notice, then you can click on the relevant link above to jump to that section.
SWM Health Ltd ("SWM", "we", "us" or "our") respects your right to privacy. This Privacy Notice explains who we are, how we collect, share and use personal information about you and how you can exercise your privacy rights. This Privacy Notice only applies to personal information that we collect through our website at https://www.swm.agency/ (“Website”). The data controller is SWM Health Limited of Chiswick High Road 190 W4 1PP London .
If you have any questions or concerns about our use of your personal information, then please contact us using the contact details under the “Contact us” heading below.
1. What does SWM do?
SWM is a leading online destination for healthcare and pharmaceutical industry news, insight and debate and is a forum where the pharmaceutical industry can share learnings, insights and more to advance the field. SWM operates in the UK, Europe and around the world.
For more information about SWM, please see the “About Us” section of our Website at https://swm.agency/about.
2. Personal information we collect and process
a) The personal information we collect from you, either directly or indirectly, will depend on how you interact with us and with our Website. We collect personal information about you from the following different sources:
Information that you provide directly
We collect personal information directly from you when you choose to provide us with this information online This will be information that You provide by filling in forms on our site, including Your personal registration, company registration (with a person as the company contact), site surveys, registration for events and/or other promotional materials and competitions or promotions.
Certain parts of our Website ask you to provide personal information when you engage with the following services:
a) information provided at the time of registering to use Our Site, and subscribing to Our services;
b) information when You post material on the site or request further services;
c) details when You report a problem with Our Site;
d) information when You complete surveys that We may ask You about and which We use for research purposes, although You do not have to respond to them;
e) details of transactions You carry out through our Site and of the fulfilment of Your orders;
f) details of Your visits to our Site including, but not limited to, traffic data, location data, weblogs and other communication data, whether this is required for our own billing purposes or otherwise, and the resources that You access.
Information that we collect indirectly
We collect personal information about you indirectly, including through automated means from your device when you use our Website. Some of the information we collect indirectly is captured using cookies and other tracking technologies, as explained further in the Cookies and similar tracking technology section below.
Information from third parties
We also collect information about you from third party sources that provide operational assistance, email, marketing and analytics services, payment services and social media platforms. Information received from third parties will be checked to ensure that the third party either has your consent or are otherwise legally permitted or required to disclose your personal information to us.
If you choose to register for a Website account with us via a social media account you hold, we will collect your email from your social media account to set up your account with us and to confirm whether you logged into our Website using your social media account. We do not access your personal account settings on your social media account.
b) The table below describes the categories of personal information we collect from and about you through our online services and activities on our Website and on social media.
| Personal Data Description | Source |
|---|---|
Identity and Contact Data such as your name, email address and password and telephone number and delivery address. |
• Directly from you (online or offline) • Third parties • Automatic Collection |
| Account Data such as your Login information (email and password) and Profile Information (contact details including your name, surname, postcode, phone, optionally - your gender (includes 'prefer not to say' option) and birthday, student status or other status relevant to your eligibility for discounts. | • Directly from you • Third parties |
| Transaction Data such as truncated credit or debit card details, payment method, transaction statements, your billing address, your delivery address or the delivery address of the intended recipient of your order, payments and orders to and from you, and other details of products that you have supplied to or purchased through the Website. We do not collect or store your full credit or debit card details (which are processed by payment service providers who are separate controllers of your data. Please refer to your payment service provider's privacy notice for further details on their data collection practices). |
• Third parties |
| Social Media/External Account Data such as social media handle and log in details where you choose to log in to the Website using your social media account or when you otherwise interact with us via an external service application. | • Third parties |
| Communications Data such as your feedback on our products and services or the performance of our Website and other communications with us (including when you interact with our customer service agents offline), any queries you raise, competition and survey entries, chat, email or call history on the Website or with third party service providers. This will include information as to how you contact customer services and the channel of communication that you use or any information that you send to us (for example, if you complain about the performance of our Website and send us screenshots). | • Directly from you • Third parties |
| Marketing and Advertising Data such as your interests based on your use of our Website and other websites and online services, your purchases, survey responses, promotions you enter, preferences in relation to receiving marketing materials from us, communication preferences, your preferences for particular products or services and your subscription details. | • Directly from you • Third parties • Automatic Collection |
| Device Data collected using tags and pixels, including your IP address, your ISP, and the browser you use to visit our Website, device type, unique device identification numbers or other identifiers. | • Automatic Collection |
| Website Usage Data such as activity and Website page interaction, information that we capture using cookies and similar technologies (see section 5 below). This will include page views and searches, log-in information, clicks, operating system, information about content viewed, watched or downloaded for offline access, length of visits to certain pages, length of App use, purchase history and other functional information on Website performance (for example, application version information, diagnostics, and crash logs). | • Automatic Collection |
| Location Data collected using IP Address from which we can identify your precise geographic location, e.g., technical information that associates your location to your use of the https://www.swm.agency/ such as to provide you with the information about deals near your actual location. | • Automatic Collection |
| Uploaded Content such as any personal data in photographs / videos or audio recordings that you upload onto our Website (such as Website profile pictures) or provide as part of product reviews or when sharing content as part of the socialisation functions on the Website, requests for assistance from customer service, or when you take part in competitions, or upload photos to social media (where you allow us to use such images). | • Directly from you • Third parties |
We do not collect any sensitive personal information about you, such as health-related information or information about your race or ethnicity, or sexual orientation.
3. How we use your personal information (our purposes) and our legal basis for processing it
We use the personal information that we collect from and about you only for the purposes described in this Privacy Notice or for purposes that we explain to you at the time we collect your information. Depending on our purpose for collecting your information, we rely on one of the following legal bases:
Contract - we require certain personal information in order to provide and support the goods and services you purchase or request from us;
Consent – in certain circumstances, we may ask for your consent (separately from any contract between us) before we collect, use, or disclose your personal information, in which case you can voluntarily choose to give or deny your consent without any negative consequences to you;
Legitimate interests – we may use or disclose your personal information for the legitimate business interests of either SWM or a third party, but only when we are confident that your privacy rights will remain appropriately protected. If we rely on our (or a third party's) legitimate interests, these interests will normally be to: operate, provide and improve our business, including our Website; communicate with you and respond to your questions; improve our Website or use the insights to improve or develop marketing activities and promote our products and services; detect or prevent illegal activities (for example, fraud); and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors and visitors; or
Legal obligation – there may be instances where we must process and retain your personal information to comply with laws or to fulfil certain legal obligations.
The following table provides more details on our purposes for processing your personal information and the related legal bases. The legal basis under which your personal information is processed will depend on the data concerned and the specific context in which we collect it.
Where we require your data to pursue our legitimate interests or the legitimate interests of a third party, it will be in a way which is reasonable for you to expect as part of the running of our business and which does not materially affect your rights and freedoms. We have identified below what our legitimate interests are and information from the associated balancing test.
| Purpose/Activity | Type of data | Lawful basis for processing including basis of legitimate interest |
|---|---|---|
| Register your account on our Website, to manage and administer your account. | • Account Data • Communication Data • Device Data • Location Data |
• Performance of a contract with you. • Consent (in the case of processing of Location Data) |
| Respond to your communications regarding our services, send you service updates, confirmations, invoices, technical notices, updates, security alerts, and administrative messages, responding to your enquiries, requests or complaints. | • Identity and Contact Data • Account Data • Communication Data • Uploaded Content • Device Data • Website Usage Data |
• Performance of a contract with you. • Otherwise, as necessary for our legitimate interests (to operate, provide and improve our business; to communicate with you) – where our communications are not necessary to perform or enter into a contract with you. |
| Reviewing communications with you for customer support and quality assurance and related record keeping. |
• Identity and Contact Data • Account Data • Communication Data • Uploaded Content • Device Data • Website Usage Data |
• Necessary for our legitimate interests (to operate, provide and improve our business; to communicate with you) – where our communications are not necessary to perform or enter into a contract with you. |
| Keep our business, including our Website, and our employees, customers, vendors, and visitors secure and address threats to your safety or the safety of others; to detect and prevent fraud (online). For example, online we may use malware and spyware monitoring tools to detect suspicious activity and algorithms to detect unauthorised access. | • Identity and Contact Data • Account Data • Device Data • Website Usage Data • Communication Data • Location Data |
• Necessary for our and our third parties' legitimate interests (to operate and provide our business, including our Website; to detect or prevent illegal activities (e.g. fraud) and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors, and visitors). |
| Manage compliance with our terms of service. | • Identity and Contact Data • Account Data • Communication Data • Uploaded Content |
• Performance of a contract with you. • Otherwise, as necessary for our legitimate interests (to operate, provide and improve our business, including our Website; to detect or prevent illegal activities (e.g. fraud) and/or to manage the security of our IT infrastructure, and the safety and security of our employees, customers, vendors, and visitors. • Legal obligations. |
| To administer and maintain our Website and our IT systems (including monitoring, troubleshooting, data analysis, testing, system maintenance, repair and support, reporting and hosting of data). | • Identity and Contact Data • Account Data • Device Data • Website Usage Data |
• Legitimate interests (to operate, provide and improve our business, including our Website; to detect or prevent Illegal activities (e.g. fraud) and/or to manage the security of our IT infrastructure). |
| Manage our use of tracking technologies such as cookies (including enabling you to manage your cookie preferences) and analyse collected data to learn about our Website, to improve our Website, and to develop new services. This includes website analytics, identifying browsing trends and patterns and evaluating this information on an aggregated, group(s) basis (Marketing Data) and individual basis (Account Data, Device Data, Location Data and Website Usage Data). | • Account Data • Device Data • Website Usage Data • Location Data • Marketing and Communications Data |
• Consent (where required under applicable law – see cookie consent tool on our website). • Otherwise (for strictly necessary cookies) legitimate interests to operate, provide and improve our business, including our Website, to improve our Website or use the insights to improve or develop marketing activities and promote our products and services. |
| Analyse data including metrics related to user behaviour, to assess trends and the effectiveness of our advertising and marketing campaigns, to help us understand your needs and provide you with better service and offers, to drive customer engagement, promote our brand, and inform other business decisions by understanding consumer behaviour. | • Account Data • Website Usage Data • Marketing and Communications Data |
• Consent (where required under applicable law). • Otherwise legitimate interests (to operate, provide and improve our business, including our Website, to improve our Website or use the insights to improve or develop marketing activities and promote our products and services). |
| Contact current and prospective clients (including Website visitors) about our services, promotions, competitions and events we think may be of interest, including our newsletter and other promotional mailers and electronic communications. | • Account Data • Website Usage Data • Marketing Data • Communication Data • Uploaded Content Data |
• Consent (where required under applicable law). • Otherwise legitimate interests (to operate, provide and improve our business; to communicate with you). |
| Personalise and customise your experience, including to provide local or otherwise targeted content and information for customers, and to tailor the content and advertising served on our Website. | • Account Data • Marketing Data • Website Usage Data • Device Data |
• Consent (where consent is required under applicable law). • Otherwise legitimate interests (to operate, provide and improve our business, including our Website, to use the insights to improve or develop marketing activities and promote our products and services). |
| Personalise, target, and deliver advertising for our services on third party websites, apps, and other online services(including to identify audiences and individuals like you to better tailor our marketing campaigns and communications), and measure the effectiveness of our campaigns and adjust our methods. | • Account Data • Marketing Data • Website Usage Data • Contact Device Data |
• Consent (where consent is required under applicable law. • Otherwise legitimate interests (to improve our business, to promote our products and services and to use the insights to improve or develop our marketing activities). |
| Analyse social media performance metrics to evaluate and execute social media campaigns, including to interact with our current and prospective customers on various social media channels to promote our services, run contests and promotions, answer questions and otherwise drive and monitor client engagement and satisfaction. | • Social media/External • Account Data |
• Consent (where consent is required under applicable law). • Otherwise legitimate interests (to improve our business, to promote our products and services and to use the insights to improve or develop marketing activities). |
| Administer surveys. | • Identity and Contact Data • Account Data • Communication Data • Uploaded Content Data |
• Legitimate interests (to drive customer engagement and to collect user perceptions and measure satisfaction). |
| Comply with legal and regulatory obligations to which we are subject, including our obligations to respond to your requests under data protection law. | • Identity and Contact Data • Account Data • Website Usage Data • Communication Data • Location Data • Uploaded Content Data |
• Legal obligation. |
| Protect our legal rights (including where necessary, to share information with law enforcement and others), for example to defend claims against us and to conduct litigation to defend our interests. |
• Identity and Contact Data • Account Data • Location Data • Website Usage Data • Communication Data |
• Legitimate interests to protect our business interests. |
To obtain further information about how we balance our legitimate interests against your rights and freedoms where applicable, please contact us using the contact details provided under the “Contact us” heading below.
4. Who we share your personal information with
We share your personal information with the following categories of recipients:
our group companies, who provide data processing services necessary to provide you with our goods and services (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes described in this Privacy Notice. Our group companies, to which we transfer your personal information, operate in recruitment and marketing sectors;
third party service providers and partners who provide data processing services to us as necessary to provide you with our goods and/or services (to support the delivery of, provide functionality on, or help to enhance the security of our Website), or who otherwise process personal information for purposes that are described in this Privacy Notice.
third party services when you use third party services linked through our Website, for example, third party payment services, your personal information will be collected by the provider of such services. Please note that when you use third party services, their own terms and privacy policies will govern your use of their services;
any competent law enforcement body, regulatory, government agency, court or other third party (our professional advisers) where we believe disclosure is necessary (i) as a matter of applicable law or regulation, (ii) to exercise, establish or defend our legal rights, or (iii) to protect your vital interests or those of any other person;
a buyer (and its agents and advisers) in connection with any actual or proposed purchase, merger or acquisition of any part of our business, provided that we inform the buyer it must use your personal information only for the purposes disclosed in this Privacy Notice; or
any other person with your consent to the disclosure (obtained separately from any contract between us).
5. Cookies and similar tracking technology
We use cookies and similar tracking technology (collectively, “Cookies”) to collect and use personal information about you. For further information about the types of Cookies we use, why, and how you can control Cookies, please see our Cookie Notice. [link to cookie notice]
6. How we keep your personal information secure
We use appropriate technical and organisational measures to protect the personal information that we collect and process about you. The measures are designed to provide a level of security appropriate to the risk of processing your personal information (i.e., Encryption on access information, password, advance malware protections).
7. International data transfers
In some cases, where your personal information is transferred to SWM affiliates, it is processed in countries other than the country in which you are resident. These countries may have data protection laws that are different to the laws of your country (and, in some cases, may not be as protective).
Specifically, our Website servers are located in West Europe, and our group companies in UK. Our third party service providers and partners operate around the world. This means that when we collect your personal information we will process it in any of these countries.
Where we transfer your personal information to countries and territories outside of the European Economic Area and the UK, which have been formally recognised as providing an adequate level of protection for personal information, we rely on the relevant “adequacy decisions” from the European Commission and “adequacy regulations" (data bridges) from the Secretary of State in the UK.
Where the transfer is not subject to an adequacy decision or regulations, we have taken appropriate safeguards to require that your personal information will remain protected in accordance with this Privacy Notice and applicable laws. The safeguards we use to transfer personal data are in case of both our group companies and third party service providers and partners, [the European Commission’s Standard Contractual Clauses as issued on 4 June 2021 under Article 46(2) for controller to controller and controller to processor transfers, including the UK Addendum permitted under Article 46(2) of the UK GDPR for the transfer of data originating in the UK.
8. Data retention
We retain the personal information we collect from you where we have an ongoing legitimate business need to do so (for example, to provide you with a service you have requested or to comply with applicable legal, tax or accounting requirements). In certain circumstances, we will need to keep your information for legal reasons after our contractual relationship has ended. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement. For example: we keep your information when we have a legal obligation to do so (for example such as, if a court order is received about your account, we would retained your data for longer than the usual retention period when an account is deleted.); to deal with and resolve requests and complaints (for example, if there is an ongoing complaint with respect to our services), to protect individuals' rights and property and for litigation or regulatory matters (for example we would retain your information if there was an ongoing legal claim and the information was relevant to the claim. This information would be retained until the legal claim had been concluded.).
When we have no ongoing legitimate business need or legal reason to process your personal information, we will either delete or anonymise it or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.
9. Your data protection rights
Individuals located in the UK and EEA have the following data protection rights. To exercise any of them see specific instructions below or contact us using the contact details provided under the “Contact us” heading below.
You may access, correct, update or request deletion of your personal information.
You can object to processing of your personal information, ask us to restrict processing of your personal information [or request portability of your personal information, (i.e. your data to be transferred in a readable and standardised format].
You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us (using the contact details indicated below). If you choose to opt out of marketing communications, we may still send you non-promotional emails, such as emails about your account or our ongoing business relations.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a supervisory authority about our collection and use of your personal information. For more information, please contact your local supervisory authority. (Contact details for supervisory authorities in Europe are available here and for the UK here.) Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.
We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws.
10. Updates to this Privacy Notice
We may update this Privacy Notice from time to time in response to changing legal, regulatory, technical or business developments. When we update our Privacy Notice, we will take appropriate measures to inform you, consistent with the significance of the changes we make via mail. We will obtain your consent to any material Privacy Notice changes if, and where, required by applicable data protection laws.
You can see when this Privacy Notice was last updated by checking the “last updated” date displayed at the top of this Privacy Notice.
11. How to contact us
If you have any questions or concerns about our use of your personal information, please contact us using the details available here: https://www.swm.agency/contact.