Swap My City Pad Ltd (“Swap My City Pad”, “we”, “our”, “us”) is committed to ensuring that members’ (“Bronze Members”, “Silver/Gold Members”) and users’ (“Users”, “you”, “your”) privacy is protected. This Privacy Policy explains how we intend to and will use the Data (as defined below) we collect about Bronze Members and/or Silver Gold Members on our websites with URLs www.swapmycitypad.com and www.swapmycitypad.co.uk (“the Websites”), how Bronze Members and/or Silver/Gold Members can instruct us if Bronze Members and/or Silver Gold/Members prefer to limit the use of their Data and the procedures that we have in place to safeguard Bronze Members and/or Silver Gold/Members’ privacy. Swap My City Pad has notified the Information Commissioner’s Office in the United Kingdom. All Data collected by Swap My City Pad will be processed in accordance with the UK laws on data protection, in line with the Eight Data Protection Principles (see section 3 below) as laid out in the Data Protection Act 1998 (as amended) (“the Act”). Swap My City Pad is the Data Controller as defined in the Act. Swap My City Pad’s registered address is situated at 72 Napier Road, London, E11 3JZ.
The definitions in this Privacy Policy are clearly defined in our Terms and Conditions at www.swapmycitypad.com (full website not currently available).
You should read this Privacy Policy in its entirety.
1. Personal Information
1.1 Account Activity
1.1.1 When you initially visit the Websites, you are required to register as a Bronze Member, Silver Member and/or Gold Member, before you can contribute to the Websites:
“Bronze Members’ Features” - Upload content relating to Bronze Member’s property.
“Silver/Gold Members’ Features” - Upload content relating to Silver/Gold Members property;
- Leave feedback;
- Post comments advising on swapping properties;
- Post comments advising on recommendations; or
- Communicate with other Members.
1.1.2 During the registration process, we will collect personal data about a User: including your name, postal address, e-mail address, photos and telephone number, description of your property and local neighbourhood, general information about you, and your occupation (“Data”). For the avoidance of doubt, Swap My City Pad will not store any financial information relating to Bronze Members and/or Silver/Gold Members. By registering on the Websites, the User is consenting to the use of the User’s Data by Swap My City Pad in accordance with our Terms and Conditions, our Rules, and this Privacy Policy.
1.1.3 We gather this Data to allow Swap My City Pad to keep a record of User’s that are responsible for using the Bronze Members’ Features and the Silver/Gold Members’ Features and to protect the User’s account from unauthorised access. The Data a User provides to Swap My City Pad will also be used by Swap My City Pad to communicate with the User with regards to the operation, maintenance, and functionality of the Websites.
1.1.4 Data will be stored on Swap My City Pad’s servers in a database for the duration of your registration, after which time the Data will be archived and kept for seven years.
1.1.5 Some Data, including, but not limited to, Housebooks and contact information, will not be available to Silver/Gold Members unless a swap of properties is confirmed between two Silver/Gold Members.
1.2 Non Account Activity
1.2.1 Users of the Websites wishing only to view content relating to Bronze Members and/or Silver/Gold Members’ properties and/or comments posted by Bronze Members and/or Silver/Gold Members are not required to register as Bronze Members and/or Silver/Gold Members. However, such Users are not allowed to use the Bronze Members’ Features and/or the Silver/Gold Members’ Features on the Websites. Bronze Members will not be able to access the Silver/Gold Members’ Features.
2. Company Use and Disclosure
2.1 If a User submits Data to Swap My City Pad, we may use the information and relevant statistical data to monitor the Websites’ usage by Users, Bronze Members and/or Silver/Gold Members and to help Swap My City Pad develop the Websites and Swap My City Pad’s services from time to time. These statistics will not include information that can be used to identify a User and/or Bronze Members and/or Silver/Gold Members as an individual.
2.2 Users user name will be displayed to other Users when Bronze Members use the Bronze Members’ Features or the Silver/Gold Members use the Silver/Gold Members’ Features on the Websites. Silver/Gold Members can contact Bronze Members and Silver/Gold Members through the Websites. Any use of the Bronze Members Features by Bronze Members or the Silver/Gold Members’ Features by Silver/Gold Members are viewable by the general public and accordingly content Uploaded by Bronze Members and/or Silver/Gold Members may be redistributed through the Internet and other media channels.
2.3 All Users of the Websites may subscribe to receive our Newsletter. Swap My City Pad may provide, via our newsletter, Users, as well as the Bronze Members or the Silver/Gold Members with information about special features of the Websites or any other services or products we think might be of interest to Users, the Bronze Members and/or the Silver/Gold Members. If Users, the Bronze Members or the Silver/Gold Members would rather not receive this information, please send a blank e-mail message to info@swapmycitypad.com with the subject line “Please unsubscribe me from the Swap My City Pad Newsletter“.
2.4 In the event Swap My City Pad wishes to contact you about our services via our mailing list or via our Newsletter from time to time, Bronze Members and Siliver/Gold Member should “opt-in” by clicking on the relevant link upon registration. Swap My City Pad may also provide Bronze Members or the Silver/Gold Members with related information from carefully selected third parties we think might be of interest to the Bronze Members or the Silver/Gold Members. If the Bronze Members or the Silver/Gold Members would rather not receive this information, please send an e-mail to info@swapmycitypad.com.
3. The Data Protection Principles
For the avoidance of doubt, the Company will only use the Data in accordance with the eight Data Protection Principles as listed below:
3.1 Purpose limitation: Data will be processed and subsequently used or further communicated only for purposes described in this Privacy Policy or subsequently authorised by the Bronze Members and/or the Silver/Gold Members.
3.2 Data quality and proportionality: Data will be accurate and, where necessary, kept up to date. The Data will be adequate, relevant and not excessive in relation to the purposes of the Websites and for which it is transferred and processed.
3.3 Transparency: Bronze Members and Silver/Gold Members are provided with information in this Privacy Policy to ensure fair processing.
3.4 Security and confidentiality: Technical and organisational security measures are taken by Swap My City Pad to ensure the Bronze Members and Silver/Gold Members’ security and confidentiality, including measures to prevent against accidental or unlawful destruction or accidental loss, alteration, unauthorised disclosure or access, presented by the processing. Any person acting under the authority of Swap My City Pad will not process the Data except on instructions from Swap My City Pad.
3.5 Rights of access, rectification, deletion and objection: As provided in Article 12 of Directive 95/46/EC, Bronze Members and/or Silver/Gold Members are provided with information in this Privacy Policy regarding the Data that Swap My City Pad may hold. Bronze Members and/or Silver/Gold Members can rectify, amend, or delete the Data where the Data is inaccurate or processed against these principles. Bronze Members and/or Silver/Gold Members may, upon notice to Swap My City Pad, object to the processing of the Data in the event there are compelling legitimate grounds relating to the Bronze Members and/or Silver/Gold Members’ particular situation.
3.6 Sensitive Data: Swap My City Pad shall not be processing personal sensitive Data.
3.7 Data used for marketing purposes: Where Data is processed for the purposes of direct marketing, Swap My City Pad has in place effective procedures allowing Bronze Members and/or the Silver/Gold Members the right to at any time “opt out” from having the Data used for such purposes.
3.8 Automated Decisions: For purposes of this Privacy Policy “Automated Decision” shall mean a decision by Swap My City Pad which produces legal effects concerning Bronze Members and/or Silver/Gold Members or significantly affects Bronze Members and/or a Silver/Gold Members and which is based solely on automated processing of the Data. Swap My City Pad shall not make any automated decisions concerning Bronze Members and/or Silver/Gold Members, except when required by law.
4. Third Party Advertisements
4.1 Swap My City Pad may allow other companies called “third-party ad servers” or “ad networks” to serve advertisements within the Websites. These third parties may use technology to send, directly to the Bronze Members’ and/or Silver/Gold Members’ browsers, the advertisements and links that appear on the Websites. They will automatically receive the Bronze Members and/or Silver/Gold Members’ IP addresses when this happens they may employ other technologies such as cookies to measure the effectiveness and/or personalise the advertisements. Any Data received from a third party ad server in relation to the Bronze Members and/or Silver/Gold Members’ account will be handled in accordance with this Privacy Policy.
4.2 Swap My City Pad will not provide the Data to third party ad servers without consent, except as a part of a feature of the Websites which Bronze Members and/or Silver/Gold Members will have the option to “opt out” of before such disclosure.
5. Use of cookies
5.1 The use of cookies is common in the computer industry. A cookie is data sent to your computer by a Web server that records your actions on a certain website. When a User, Bronze Member or Silver/Gold Member visits the site again after being sent the cookie, the site will load certain pages according to the information stored in the cookie. We use cookies in two ways:
5.2 Per-session cookies: These are used while User are logged on to the Websites and when Users visit the Websites to help Swap My City Pad monitor traffic through the Websites and do not store any Data; and
5.3 Auto logon cookies: These store Data in order to allow, Bronze Members and/or Silver/Gold Members to log on automatically when the, Bronze Members and/or Silver/Gold Members visit the Websites.
5.4 With most web browsers it is possible to configure the User’s, Bronze Member’s or Silver/Gold Member’s Internet browser so that it can refuse new cookies, prompt the User, Bronze Member or Silver/Gold Member to accept a cookie or disable cookies altogether. How the User, Bronze Member or Silver/Gold Member do this will depend on the Internet browser used (For example Internet Explorer 7, Netscape, Firefox, Opera, Chrome). By refusing to accept Swap My City Pad’s cookies the Websites will not operate correctly. For further details on cookies we recommend that you visit www.allaboutcookies.org.
5.5 Cookies relating to the Websites will be stored on the computer being used. Unless otherwise indicated, auto logon cookies will be stored on Bronze Members and/or Silver/Gold Members computers for a period of one month.
6. Sale or Merger of Business
6.1 If Swap My City Pad is sold or integrated with another business, the Data may be disclosed to the Swap My City Pad’s advisers and any prospective purchasers, their advisers and new owners of the business. We will handle the transfer of Data securely in accordance with this Privacy Policy.
7. Protecting Your Information
7.1 Internet security is not absolute; therefore, security controls are built into the Websites to offer the User, Bronze Member and/or Silver/Gold Member a greater degree of protection. We also keep the Data confidential subject to the purposes for which the details were collected. The internal procedures of the Data Controller cover the storage, access and disclosure of the Data.
8. Updating Personal Information
8.1 The Bronze Member and/or Silver/Gold Member may update or correct the Bronze Members and/or Silver/Gold Members’ personal profile information by accessing the Bronze Members and/or Silver/Gold Members’ private user profile on the Websites. The Bronze Members and/or Silver/Gold Members may amend their settings, update their profile and change their password.
9. Bronze Member’s or Silver/Gold Member’s Consent
9.1 By submitting the Data the Bronze Members and/or Silver/Gold Members consent to the use of the Data as set out in this Privacy Policy and as set out in the Websites’ Terms and Conditions. If we change our Privacy Policy we will post the changes on this page, and may place notices on other pages of the Websites, so that Users, Bronze Members and/or Silver/Gold Members may be kept informed of the Data we collect and how we use the Data at all times. Continued use of the service will signify that the Users, Bronze Members and/or Silver/Gold Members agree to any such changes.
9.2 Owing to the global nature of the Internet infrastructure, the Data provided may be transferred in transit to countries outside the European Economic Area that do not have similar protections in place regarding the Data and its use as set out in this Privacy Policy. By submitting the Data, the Bronze Members and/or the Silver/Gold Members consent to these transfers and agree that Swap My City Pad will not be held liable for any loss, damage, and inconvenience suffered as a result of such transfers of Data.
This Privacy Policy was last updated on 11th December 2009.