Privacy Policy
1. Scope
This Privacy Policy explains how Swiftlet Labs Ltd, a company registered in England and Wales ("Swiftlet Labs", "we", "us"), handles personal information. It covers swiftletlabs.com, wire.swiftletlabs.com, and the services we operate, except where a service publishes its own notice, in which case that notice governs for that service.
This policy is incorporated into the Terms of Service and forms part of the agreement between you and us. Where it conflicts with those Terms in respect of personal information, this policy governs.
2. Information we collect
Information you provide. Account information such as your name and email address. Billing information where you hold a paid service. The contents of any message you send us.
Information a service requires in order to operate. This varies by service. A messaging service necessarily processes the messages you send and receive and the routing information required to deliver them. A service that stores data on your own device may hold almost nothing. The documentation for each service describes what that service holds.
Technical and security information. Our servers record connection information, including IP address, request time, and the resource requested. We use it to operate the services, to investigate faults, and to detect and prevent abuse.
Payment information. Payment card details are collected and processed by our payment processor and are not stored by us. We retain transaction records, which include billing address and the amount and date of each transaction, for accounting, tax, and fraud prevention purposes.
3. What we do not do
Our websites load no third-party scripts, no analytics, no advertising pixels, and no social media trackers. Our pages request nothing from another company's servers.
We do not sell personal information. We do not share personal information for cross-context behavioural advertising. We do not use your content to train machine learning models.
4. Cookies
We set one cookie, and only where you ask us to: a theme preference recorded
when you use the light and dark switch. It holds a single word, is read only by
your browser, and is transmitted nowhere for analysis.
Where a service requires additional cookies in order to function, such as a session cookie to keep you signed in, that service's documentation describes them. We do not set cookies for advertising or analytics.
5. Why we process personal information
We process personal information in order to:
| Purpose | Basis |
|---|---|
| Provide the services you have requested | Performance of our contract with you |
| Bill you and maintain financial records | Contract, and compliance with legal obligations |
| Secure the services and prevent abuse | Our legitimate interest in operating them safely |
| Respond to your enquiries and support requests | Contract, and our legitimate interest |
| Comply with tax, accounting, and other legal obligations | Compliance with legal obligations |
| Anything we have separately asked you to agree to | Your consent, which you may withdraw |
6. When we disclose personal information
We disclose personal information to service providers who assist us in operating the services, including infrastructure hosting, payment processing, and message delivery. Each receives only what it requires, and each acts on our instructions.
We may disclose personal information where required by law, by a valid legal process, or by a competent authority. Where we are permitted to notify you of such a request, we will do so.
We may disclose personal information where necessary to investigate suspected abuse of the services, to protect the rights, property, or safety of any person, or to establish or defend a legal claim.
If Swiftlet Labs is involved in a merger, acquisition, or sale of assets, we will give notice before personal information becomes subject to a different policy.
7. Transfers outside the United Kingdom
Some of the service providers described above operate outside the United Kingdom, so your personal information may be transferred to and stored in another country.
Where we make such a transfer, we rely on one of the safeguards the UK GDPR permits: a transfer to a country the UK has found to provide an adequate level of protection, or the International Data Transfer Agreement (or the UK Addendum to the European Commission's standard contractual clauses) together with any additional measures the transfer requires.
You may ask us for a copy of the safeguard we rely on for a particular transfer by writing to privacy@swiftletlabs.com.
8. How long we keep it
We keep account information for as long as your account is open, and for a short period afterwards so that the account may be recovered.
Connection and security logs are kept briefly and then discarded, save where a log is relevant to an ongoing investigation.
Deleted content may persist in routine backups for a period after deletion, after which it is overwritten in the ordinary course.
Records we are required to retain for legal, tax, or accounting purposes are kept for the period the law requires.
9. Your rights
Under the UK GDPR you have the right to access the personal information we hold about you, to have it corrected, to have it erased, to obtain a portable copy, to restrict or object to particular processing, and to withdraw any consent you have given. Where we rely on legitimate interests, you may object to that processing at any time.
To exercise any of these rights, write to privacy@swiftletlabs.com. We will respond within one month, which we may extend by two further months for complex requests, and we will tell you if we do. We may need to verify your identity before acting. Exercising a right is free and we will not treat you differently for it.
10. Children
The services are not directed at children, and holding an account requires you to be at least 18. We do not knowingly collect personal information from children. If you believe a child has provided us with personal information, write to privacy@swiftletlabs.com and we will delete it.
11. Security
We protect personal information in transit and at rest using encryption appropriate to its sensitivity, and we restrict internal access to those who require it in order to operate the services.
No system is perfectly secure, and we do not represent that ours is. Report a suspected vulnerability to security@swiftletlabs.com; Section 9 of the Acceptable Use Policy describes how we treat good-faith research.
12. Changes to this policy
We may update this policy. Where a change is material, we will give notice before it takes effect. The date at the top of this document reflects the current version.
13. Contact
Privacy enquiries and requests to exercise your rights go to privacy@swiftletlabs.com. Other legal enquiries go to legal@swiftletlabs.com.
Questions about this document? Write to legal@swiftletlabs.com.