PERSONAL DATA PROCESSING POLICY
1. General Provisions
1.1 SWI Inc. (hereinafter referred to as the Operator) considers the observance of the rights and
freedoms of the citizens to be one of the essential conditions for implementing its activity.
1.2 The Operator’s Policy on the processing of Personal data (hereinafter referred to as the Policy) applies to all information that the Operator can gain about visitors to the Site.
1.3. The Operator performs the cross-border transfer of each User’s Personal data, taking whatever measures are necessary for their protection.
2. Key Terms and Concepts Used in the Policy:
2.1 Site – a set of graphic and information materials, as well as the computer programs and databases,
enabling their availability on the Internet at the following web-address: http://swc-sale.tilda.ws/en;
2.2 User – any visitor of the Site;
2.3 Personal data – any information related to the User of the Site;
2.4 Personal data processing - any action with Personal data done using computers, as well as without using them;
2.5 Anonymization of Personal data – actions that result in the inability to determine the ownership
of Personal data to a particular User or person without the use of additional information;
2.6 Dissemination of Personal data – any actions that result in the disclosure of Personal data to an
indefinite number of persons;
2.7 Provision of Personal data – any actions which result into disclosure of Personal data to certain
number of people;
2.8 Destruction of personal data – any actions that lead to irretrievable destruction of Personal data on
computers or any other carriers.
3. The Operator Can Process the Following Personal Data:
# Personal Data Procedure for Using
3.1 Name to identify the User
3.2 Phone Number is used for notifications and security confirmation
3.3 E-mail address is used for notifications and information, for system entry
3.4 IP-address security (login history)
3.5 Language for communication with the User in his/her language
3.6 Internal ID of the User for identifying the User in the system
# Personal Data Procedure for Using
3.7 Date of registration is used for maintenance of statistics
3.8 Check indicator for internal use
3.9 Status system status identifying the engagement rate
3.10 Inviter's first and last name (if any) is used for referral structure
3.11 Citizenship for statistics
3.12 Country for statistics
3.13 City for statistics
3.14 Date of birth for verification
3.15 Country of birth for verification
3.16 Sex for verification
3.17 Scanned copy/photo of the passport for verification
3.18 Address for verification
3.20 Confirmation of the address for verification
3.21 Additional phone number at the User’s wishes
3.22 Additional address at the Operator’s request
3.23 Skype installation data at the User’s wishes
3.24 Client’s current address for delivery of certificates, requested by the Operator if different
from verification address
3.25 Confirmation of parental
rights
for making investments for children
3.26 Additional E-mail address at the User’s wishes
3.27 There also occurs the collection and processing of the anonymized data about the visitors
(including “cookie” files), using the web statistics services (Yandex.Metrica and Google Analytics
and others).
4. Purpose of the Personal Data Processing
4. The purpose of the User’s Personal data processing is the information interaction with the User for concluding the User Agreement, Client Agreement, as well as the other agreements, where the User is represented as the party; however, the Personal data is not distributed, neither it is provided to third parties without the User’s consent and is used by the Operator exclusively for conducting the specified transactions (agreements) and making the transaction (agreements) with the User.
The Operator also has the right under the User Agreement to send notifications to the User about new
products and services, special offers and various events. The User can always refuse to receive
informational messages by sending a letter to the Operator at PrivacyPolicy@skyway.capital
or the Information Security Officer at dpo@skyway.capital.
4.2 Anonymized data of the Users, collected using web statistics services, is used to collect
information about the actions of the Users on the Site, improve the quality of the Site and its content.
5. Legal Grounds for the Personal Data Processing
5.1 The Operator processes the Personal data of the User only if it is sent by the User through the
forms on the Site. By submitting their Personal Data to the Operator, the User agrees with this
Policy.
5.2 The Operator processes anonymized User’s data if it is allowed in the User’s browser settings (includes file retention and JavaScript technology).
6. Procedure for Collection, Storage, Transfer and Other Types of Personal Data Processing
6.1 The Operator ensures the safety of Personal data and takes all possible measures to exclude access
to the Personal data of unauthorized persons.
6.2 The Operator has the right to entrust the processing of Personal data to a third party with the consent of the User. 6.3 The third party, processing Personal data at the request of the Operator must comply with the principles and rules for processing Personal data provided by the Personal Data Act, ensuring the confidentiality and security of Personal data when processing it. The Operator monitors compliance with the Regulation # 2016/679 of the European Parliament and the Council of the European Union “On the Protection of Individuals in Personal Data Processing and Free Circulation of Such Data, as Well as the Repeal of Directive 95/46 / EC (General Protection Regulation of Personal Data)”.
6.4 If inaccuracies are detected in Personal data, the User can actualize them by sending a notification
to the Operator’s e-mail PrivacyPolicy@skyway.capital, or to the Information Security Officer at
dpo@skyway.capital, marked “Actualization of Personal Data”
6.5 The Personal data processing period is unlimited. The User can withdraw his consent to the
processing of Personal data by sending a notification to the Operator at any time via e-mail to the
Operator’s email address PrivacyPolicy@skyway.capital or to the Information Security Officer at
dpo@skyway.capital, marked ("Revocation of Consent to the Processing of Personal Data."
7 Final Provisions
7.1 The User can receive any clarifications on issues of interest related to the processing of their
Personal data by contacting the Operator via e-mail PrivacyPolicy@skyway.capital or the
Information Security Officer at dpo@skyway.capital or for any other questions support@skyway.capital.
7.2 This document will reflect any changes in the Operator’s Personal data processing Policy. In case of significant changes, the User can be sent information to the email address specified by him/her.