Type text here
Type text hereIntroductio
Welcome to Swift First Aid Training privacy and cookies notice. Swift First Aid
Training respects your privacy and is committed to protecting your personal
data. This privacy notice will inform you as to how we look after your personal
data when you visit our website (regardless of where you visit it from) as well
as where we interact in the course of our business and tell you about your
privacy rights and how the law protects you.
Please also use the Glossary to understand the meaning of some of the terms used in
this privacy notice.
1. Important information and who we are purpose of this privacy notice
This privacy notice aims to give you information on how Swift First Aid Training
collects and processes your personal data through your use of this website,
including any data you may provide through this website when you sign up to our
newsletter or downloadable content, utilise our ‘contact us’ form or take part
in a competition. This privacy notice also provides information as to how Swift
First Aid Training collects and processes your personal data during the course
of our business, including any data you may provide at exhibitions, networking
events and by telephone, email or post.
This website is not intended for children and we do not knowingly collect data
relating to children.
It is important that you read this privacy notice together with any other privacy
notice or fair processing notice we may provide on specific occasions when we
are collecting or processing personal data about you so that you are fully
aware of how and why we are using your data. This privacy notice supplements
the other notices and is not intended to override them.
Swift First Aid Training is the controller and responsible for your personal data
(collectively referred to as "Swift First Aid Training",
"we", "us" or "our" in this privacy notice).
We have appointed a data privacy manager who is responsible for overseeing questions in
relations to this privacy notice. If you have any questions about this privacy
notice, including any requests to exercise your legal rights, please contact
the data privacy manager using the details set out below.
Our full details are:
of legal entity: Swift First Aid Training Ltd.
Name or title of Data Privacy Manager: Eddie Medina
Email address: email@example.com
Postal address: Office 4, Unit 2, Conqueror Court, Vellum Drive, Sittingbourne,
Kent, ME10 5BH
Telephone number: 07484 546338
You have the right to make a complaint at any time to the Information Commissioner's
Office (ICO), the UK supervisory authority for data protection issues
(www.ico.org.uk). We would, however, appreciate the chance to deal with your
concerns before you approach the ICO so please contact us in the first
Changes to the privacy notice and your duty to inform us of changes
This version was last updated on 16th September 2019.
The data protection law in the UK changed on 25 May 2018.
It is important that the personal data we hold about you is accurate and current.
Please keep us informed if your personal data changes during your relationship
This website may include links to third-party websites, plug-ins and applications.
Clicking on those links or enabling those connections may allow third parties
to collect or share data about you. We do not control these third-party
websites and are not responsible for their privacy statements. When you leave
our website, we encourage you to read the privacy notice of every website you
2. The data we collect about you
Personal data, or personal information, means any information about an individual from
which that person can be identified. It does not include data where the
identity has been removed (anonymous data).
We may collect, use, store and transfer different kinds of personal data about
you which we have grouped together follows:
Identity Data includes first name, last name or company.
Contact Data includes billing address, delivery address,
email address and telephone numbers.
Financial Data includes bank account and payment card details.
Transaction Data includes details about payments to and from you
and other details of products and services you
have purchased from us.
Technical Data includes internet protocol
(IP) address, browser type and version, time zone setting and location,
browser plug-in types and versions, operating system and platform and
other technology on the devices you use to access this website.
Profile Data includes your username and
password, purchases or orders made by you, your interests, preferences,
feedback and survey responses.
Usage Data includes information about
how you use our website, products and services.
Marketing and Communications Data
includes your preferences in receiving marketing from us and our third
parties and your communication preferences.
We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
personal data but is not considered personal data in law as this data does not
directly or indirectly reveal your identity. For example, we may aggregate your
Usage Data to calculate the percentage of users accessing a specific website
feature. However, if we combine or connect Aggregated Data with your personal
data so that it can directly or indirectly identify you, we treat the combined
data as personal data which will be used in accordance with this privacy
We do not collect any Special Categories of Personal Data about you (this includes
details about your race or ethnicity, religious or philosophical beliefs, sex
life, sexual orientation, political opinions, trade union membership,
information about your health and genetic and biometric data). Nor do we collect
any information about criminal convictions and offences.
If you fail to provide personal data
Where we need to collect personal data by law, or under the terms of a contract we have
with you and you fail to provide that data when requested, we may not be able
to perform the contract we have or are trying to enter into with you (for
example, to provide you with our services). In this case, we may have to cancel
a service you have with us but we will notify you if this is the case at the
3. How is
your personal data collected?
We use different methods to collect data from and about you including through:
Direct interactions. You may
give us your Identity, Contact and Financial Data by filling in forms or by
corresponding with us by post, phone, email or otherwise. This includes
personal data you provide when you:
apply for our services;
subscribe to our service or
request marketing to be sent
leave a comment on our
enter a competition,
promotion or survey; or
give us some feedback.
Automated technologies or interactions. As you interact with our website, we may
automatically collect Technical Data about your equipment, browsing actions and
patterns. We collect this personal data by using cookies and other similar
technologies. We may also receive Technical Data about you if you visit other
Third parties or publicly available sources. We may receive personal data about you from
various third parties and public sources as set out below:
Technical Data from the
(a) analytics providers, such as Google Analytics based in the US;
(b) advertising networks; and
(c) search information providers
Identity and Contact Data
from publicly available sources such as Companies House and the Electoral
Register based inside the EU.
Identity and Contact Data
provided at events such as business cards or attendee lists.
Identity and Contact Data
from data brokers or aggregators based inside the EU.
4. How we use your personal data
We will only use your personal data when the law allows us to.
Most commonly, we will use your personal data in the following circumstances:
Where we need to perform the contract, we are about to enter
into or have entered into with you.
Where it is necessary for our legitimate interests (or those of a third party) and your interests
and fundamental rights do not override those interests.
Where we need to comply with a legal or regulatory obligation.
We rely on consent as one of the legal bases for processing your personal data where
you have given it. In relation to sending third party direct marketing
communications to you via email or text message we will only rely upon consent.
You have the right to withdraw consent to marketing at any time by contacting
Purposes for which we will use your personal data
We have set out below, in a table format, a description of all the ways we plan to use
your personal data, and which of the legal bases we rely on to do so. We have
also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on
the specific purpose for which we are using your data. Please contact us if you
need details about the specific legal ground, we are relying on to process your
personal data where more than one ground has been set out below:
We strive to provide you with choices regarding certain personal data uses, particularly
around marketing and advertising.
We have established the following personal data control mechanisms:
Promotional offers from us
We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on
what we think you may want or need, or what may be of interest to you. This is
how we decide which products, services and offers may be relevant for you (we
call this marketing).
You will receive marketing communications from us where you have opted to do so or where
you have requested information from us or purchased services from us or if you
provided us with your details when you entered a competition and, in each case,
you have not opted out of receiving that marketing.
We will get your express opt-in consent before we share your personal data with any company
outside Swift First Aid Training for marketing purposes.
You can ask us or third parties to stop sending you marketing messages at any time by
following the opt-out or unsubscribe links on any marketing message sent to you
or by contacting us at any time.
We will need to maintain a restricted record of Contact and Identity Data where you
have opted out of receiving marketing and this is to prevent any future
marketing being carried out and, unless otherwise informed, no other processing
shall be carried out in relation to this information.
You can set your browser to refuse all or some browser cookies, or to alert you when
that some parts of this website may become inaccessible or not function
properly. For more information about the cookies we use, please see our cookies
policy at the end of this privacy notice.
Change of purpose
We will only use your personal data for the purposes for which we collected it, unless we
reasonably consider that we need to use it for another reason and that reason
is compatible with the original purpose. If you wish to get an explanation as
to how the processing for the new purpose is compatible with the original
purpose, please contact us.
If we need to use your personal data for an unrelated purpose, we will notify you and
we will explain the legal basis which allows us to do so.
Please note that we may process your personal data without your knowledge or consent,
in compliance with the above rules, where this is required or permitted by law.
5. Disclosures of your personal data
We may have to share your personal data with the parties set out below for the
purposes set out in the table in paragraph 4 above.
External Third Parties as
set out in the Glossary.
Third parties to whom we may
choose to sell, transfer, or merge parts of our business or our assets.
Alternatively, we may seek to acquire other businesses or merge with them.
If a change happens to our business, then the new owners may use your
personal data in the same way as set out in this privacy notice.
We require all third parties
to respect the security of your personal data and to treat it in
accordance with the law. We do not allow our third-party service providers
to use your personal data for their own purposes and only permit them to
process your personal data for specified purposes and in accordance with
6. International transfers
We may use external third parties who are based outside the European Economic Area
(EEA) and their processing of your personal data will involve a transfer of
data outside the EEA.
Whenever we transfer your personal data out of the EEA, we ensure a similar degree of
protection is afforded to it by ensuring at least one of the following
safeguards is implemented:
We will only transfer your personal data to countries that have been deemed to provide an adequate
level of protection for personal data by the European Commission. For
further details, see European Commission: Adequacy of the protection of
personal data in non-EU countries.
Where we use providers based in the US, we may transfer data to them if they are part of the Privacy
Shield which requires them to provide similar protection to personal data
shared between the Europe and the US. For further details, see European
Commission: EU-US Privacy Shield.
Please contact us if you want further information on the specific mechanism used by us when
transferring your personal data out of the EEA.
7. Data security
We have put in place appropriate security measures to prevent your personal data from
being accidentally lost, used or accessed in an unauthorised way, altered or
disclosed. In addition, we limit access to your personal data to those
employees, agents, contractors and other third parties who have a business need
to know. They will only process your personal data on our instructions, and
they are subject to a duty of confidentiality.
We have put in place procedures to deal with any suspected personal data breach and
will notify you and any applicable regulator of a breach where we are legally
required to do so.
8. Data retention
How long will you use my personal data for?
We will only retain your personal data for as long as necessary to fulfil the purposes
we collected it for, including for the purposes of satisfying any legal,
accounting, or reporting requirements.
To determine the appropriate retention period for personal data, we consider the
amount, nature, and sensitivity of the personal data, the potential risk of
harm from unauthorised use or disclosure of your personal data, the purposes
for which we process your personal data and whether we can achieve those
purposes through other means, and the applicable legal requirements.
9. YOUR LEGAL RIGHTS
You have the right to:
Request access to your
personal data (commonly known as a "data subject access request").
This enables you to receive a copy of the personal data we hold about you and
to check that we are lawfully processing it.
Request correction of the
personal data that we hold about you. This enables you to have any incomplete
or inaccurate data we hold about you corrected, though we may need to verify
the accuracy of the new data you provide to us.
Request erasure of your
personal data. This enables you to ask us to delete or remove personal data
where there is no good reason for us continuing to process it. You also have
the right to ask us to delete or remove your personal data where you have
successfully exercised your right to object to processing (see below), where we
may have processed your information unlawfully or where we are required to
erase your personal data to comply with local law. Note, however, that we may
not always be able to comply with your request of erasure for specific legal
reasons which will be notified to you, if applicable, at the time of your
Object to processing of your
personal data where we are relying on a legitimate interest (or those of a
third party) and there is something about your particular situation which makes
you want to object to processing on this ground as you feel it impacts on your
fundamental rights and freedoms. You also have the right to object where we are
processing your personal data for direct marketing purposes. In some cases, we
may demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.
object to direct marketing we shall maintain a restricted record of Contact and
Identity Data recording that you have opted out of receiving marketing and we
can ensure that no future marketing is carried out. Unless otherwise informed
no other processing shall be carried out in relation to this restricted record.
We will need to maintain where you have opted out of receiving marketing and
this is to prevent any future marketing being carried out and, unless otherwise
informed, no other processing shall be carried out in relation to this
restriction of processing of your personal data. This enables you to ask us to suspend the
processing of your personal data in the following scenarios: (a) if you want us
to establish the data's accuracy; (b) where our use of the data is unlawful but
you do not want us to erase it; (c) where you need us to hold the data even if
we no longer require it as you need it to establish, exercise or defend legal
claims; or (d) you have objected to our use of your data but we need to verify
whether we have overriding legitimate grounds to use it.
the transfer of your
personal data to you or to a third party. We will provide to you, or a third
party you have chosen, your personal data in a structured, commonly used,
machine-readable format. Note that this right only applies to automated
information which you initially provided consent for us to use or where we used
the information to perform a contract with you.
consent at any time where we
are relying on consent to process your personal data. However, this will not
affect the lawfulness of any processing carried out before you withdraw your
consent. If you withdraw your consent, we may not be able to provide certain
products or services to you. We will advise you if this is the case at the time
you withdraw your consent.
If you wish to exercise any of the rights set out above, please contact us.
No fee usually required
You will not have to pay a fee to access your personal data (or to exercise any of the
other rights). However, we may charge a reasonable fee if your request is
clearly unfounded, repetitive or excessive. Alternatively, we may refuse to
comply with your request in these circumstances.
What we may need from you
We may need to request specific information from you to help us confirm your identity
and ensure your right to access your personal data (or to exercise any of your
other rights). This is a security measure to ensure that personal data is not
disclosed to any person who has no right to receive it. We may also contact you
to ask you for further information in relation to your request to speed up our
Time limit to respond
We try to respond to all legitimate requests within one month. Occasionally it may take
us longer than a month if your request is particularly complex or you have made
several requests. In this case, we will notify you and keep you updated.
Legitimate Interest means
the interest of our business in conducting and managing our business to enable
us to give you the best service/product and the best and most secure
experience. We make sure we consider and balance any potential impact on you
(both positive and negative) and your rights before we process your personal
data for our legitimate interests. We do not use your personal data for
activities where our interests are overridden by the impact on you (unless we
have your consent or are otherwise required or permitted to by law). You can
obtain further information about how we assess our legitimate interests against
any potential impact on you in respect of specific activities by contacting us
Performance of Contract means
processing your data where it is necessary for the performance of a contract to
which you are a party or to take steps at your request before entering into
such a contract.
with a legal or regulatory obligation means processing your personal data where it is
necessary for compliance with a legal or regulatory obligation that we are
Service providers acting as
processors based in the United Kingdom who provide IT and system
Professional advisers acting
as processors or joint controllers including lawyers, bankers, auditors
and insurers based in the United Kingdom who provide consultancy, banking,
legal, insurance and accounting services.
HM Revenue & Customs,
regulators and other authorities based in the United Kingdom who require
reporting of processing activities in certain circumstances.
platforms, acting as a processor, such as The Rocket Science Group LLC t/a
MailChimp based in the US who provide email marketing automation services.
Survey development and
distribution platforms, acting as a processor, such as Survey Monkey Inc.
and SurveyMonkey Europe UC t/a SurveyMonkey, based in the US and within
the EEA who provide online survey development services.
Social media platforms
acting as processor or joint controllers.
helps us to provide you with a good experience when you browse our website and
allows us to improve our site. By continuing to browse the site, you are
is a small file of letters and numbers that we store on your browser or the
hard drive of your computer if you agree. Cookies contain information that is
transferred to your computer's hard drive.
We use the following cookies:
Strictly necessary cookies. These are cookies that are
required for the operation of our website. They include, for example,
cookies that enable you to log into secure areas of our website, use a
shopping cart or make use of e-billing services.
They allow us to recognise and count the number of visitors and to see how
visitors move around our website when they are using it. This helps us to
improve the way our website works, for example, by ensuring that users are
finding what they are looking for easily.
These are used to
recognise you when you return to our website. This enables us to
personalise our content for you, greet you by name and remember your
preferences (for example, your choice of language or region).
These cookies record your
visit to our website, the pages you have visited and the links you have
followed. We will use this information to make our website and the
advertising displayed on it more relevant to your interests. We may also
share this information with third parties for this purpose.
Please note that third parties (including, for example, advertising networks and
providers of external services like web traffic analysis services) may also use
cookies, over which we have no control. These cookies are likely to be
analytical/performance cookies or targeting cookies.
As well as cookies we may use pixels which are similar to cookies however are relevant
in a social media context (such as Facebook). A pixel is an analytics tool
which measures the effectiveness of advertisements and enables us to provide
advertisements which are relevant to you.
You can block cookies by activating the setting on your browser that allows you to
refuse the setting of all or some cookies. However, if you use your browser
settings to block all cookies (including essential cookies) you may not be able
to access all or parts of our site.
can expire at the end of a browser session or they can be stored for longer.
Your browser settings can also enable you to clear cookies on exit from