Swoop Privacy Policy

Who we are?

Swoop Finance Limited (company number:11163382) is registered at The Stable Yard Vicarage Road, Stony Stratford, Milton Keynes, Buckinghamshire, England, MK111BN. We act as a comparison site for business banking. Swoop Finance Limited is regulated by the FCA under FRN 833145.

What is the purpose of this document?

Swoop Finance Limited (referred to as “Swoop Finance Limited”, “we”, “all” or “our” in this privacy notice) is the data controller and responsible for your personal data. This means that we are responsible for deciding how we hold and use personal information about you. We are required under data protection legislation to notify you of the information contained in this privacy notice.

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.

Changes to the privacy notice and your duty to inform us of changes

This version was last updated on 9th 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 with us. You can notify us of any changes at admingdpr@swoopfunding.com.

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:

  • Contact Data: includes email address.
  • Transaction Data: includes details about the types of banking services and transaction types your business uses and the frequency of use
  • Usage Data: includes date and time of your visit to our site and the time you spent on the website pages

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 transaction type data to calculate the percentage of customers accessing particular banking services in a given . 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 notice.

If you fail to provide personal data

Where we need to collect personal data by law, or under the terms of any contract we have with you or in order to properly provide our services to you and you fail to provide that data when requested, we may not be able to perform contract we have or are trying to enter into with you (for example, to provide you with services) or otherwise properly provide our services to you. In this case, we may have to cancel service you have with us but we will notify you if this is the case at the time.

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 Contact data by filling in your email address field or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you; – request a copy of your personalised comparison report to be sent to you; – request to be contacted due to a complaint or query.
  • Automated technologies or interactions – as you interact with our website, we will automatically collect Technical Data about your equipment, browsing action and patterns. We collect this personal information by using cookies and other similar technologies.

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:

(a) Consent: the individual has given clear consent to process their personal data for a specific purpose.

(b) Contract: the processing is necessary for a contract we have with the individual, or because they have asked us to take specific steps before entering into a contract.

(c) Legal obligation: the processing is necessary for us to comply with the law (not including contractual obligations).

(d) Public task: the processing is necessary for us to perform a task in the public interest or for our official functions, and the task or function has a clear basis in law.

(e) Legitimate interests: the processing is necessary for our legitimate interests or the legitimate interests of a third party unless there is a good reason to protect the individual’s personal data which overrides those legitimate interests.

The situations in which we will process your personal information are listed below. Please see Schedule 1 to this privacy notice in which we have set out, 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 at ciaran@swoopfunding.com 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 in the table below.

We will process your personal information for the following reasons:

  • to calculate your personalised cost of banking with RBS and the participating banks in the Business Banking Switch scheme;
  • to calculate your personalised cost of banking with RBS and the participating banks in the Business Banking Switch scheme;
  • to provide a pdf copy of the personalised bank comparison report on your request; and

Automated Calculations and Comparison

Automated calculations and comparison take place when an electronic system uses personal information to display comparison results without human intervention. We are allowed to use automated calculation and comparison in the following circumstances:

  • where you request the comparison to be performed and you have given your consent;
  • where it is necessary to perform the contract with you and appropriate measures are in place to safeguard your rights; or
  • in limited circumstances, with your explicit written consent and where appropriate measures are in place to safeguard your rights

If we make an automated comparison on the basis of any particularly sensitive personal information, we must have either your explicit written consent or it must be justified in the public interest, and we must also put in place appropriate measures to safeguard your rights

Why might we share your information with third parties?

We will share your personal information with third parties where required by law, where it is necessary to administer the contractual relationship with you or where we have another legitimate interest in doing so.

“Third parties” includes third-party service providers (including contractors and designated agents) and other entities within our group. The following third-party service providers process personal information about you for the following purposes:

  • RBS for the purposes of RBS meeting their regulatory obligations.
  • our IT hosting and maintenance, this information is located on servers within the European Union.
  • Regulatory bodies such as The Financial Conduct Authority for the purposes of meeting our regulatory obligations.
  • Other members of our group where needed to process your application.
  • Fraud prevention agencies where we are required to do so.
  • Third party product providers where you have given us your prior consent to do so.

We have a Data Protection regime in place to oversee the effective and secure processing of your personal data. More information on this framework can be found on our website.

How long we keep your information

We do not retain your personal information once we have processed your comparison report. We retain the date and time of the calculation, the calculation workings and a unique platform generated ID code associated to the calculation for the purposes of satisfying any legal, compliance, or customer complaint requirements. Details of retention periods for different aspects of your personal information are available in our retention policy which is available from ciaran@swoopfunding.com. 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.

In some circumstances we may anonymise your personal information so that it can no longer be associated with you, in which case we may use such information without further notice to you

International transfers

We do not transfer your personal data outside the European Economic Area (EEA).

What are your rights?

Under certain circumstances, by law you have the right to:

  • Request access to your personal information (commonly known as a “data subject access request”). This enables you to receive a copy of the personal information we hold about you and to check that we are lawfully processing it;
  • Request correction of the personal information that we hold about you. This enables you to have any incomplete or inaccurate information we hold about you corrected;
  • Request erasure of your personal information. This enables you to ask us to delete or remove personal information 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 information where you have exercised your right to object to processing (see below);
  • Object to processing of your personal information 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. You also have the right to object where we are processing your personal information for direct marketing purposes;
  • Request the restriction of processing of your personal information. This enables you to ask us to suspend the processing of personal information about you, for example if you want us to establish its accuracy or the reason for processing it;
  • Request the transfer of your personal information to another party.
  • Withdraw consent: In the limited circumstances where you may have provided your consent to the collection, processing and transfer of your personal information for a specific purpose, you have the right to withdraw your consent for that specific processing at any time. To withdraw your consent, please contact andrea@swoopfunding.com. Once we have received notification that you have withdrawn your consent, we will no longer process your information for the purpose or purposes you originally agreed to, unless we have another legitimate basis for doing so in law

If you want to review, verify, correct or request erasure of your personal information, object to the processing of your personal data, or request that we transfer a copy of your personal information to another party, please contact ciaran@swoopfunding.com

You will not have to pay a fee to access your personal information (or to exercise any of the other rights). However, we may charge a reasonable fee if your request for access is clearly unfounded or excessive.

Alternatively, we may refuse to comply with the request in such circumstances

We may need to request specific information from you to help us confirm your identity and ensure your right to access the information (or to exercise any of your other rights). This is another appropriate security measure to ensure that personal information is not disclosed to any person who has no right to receive it.

If you wish to raise a complaint on how we have handled your personal data, you can contact our Data Protection Officer who will investigate the matter.

If you are not satisfied with our response or believe we are processing your personal data not in accordance with the law you can complain to the Information Commissioner’s Office (ICO).

Our Data Protection Officer is Ciaran Burke and you can contact him at ciaran@swoopfunding.com

ActivityType of dataLawful basis for processing including basis of legitimate interest
To calculate the transaction types, frequency and associated fees to provide a cost of banking calculation and comparison.(a) Transactions– Contractual – Legitimate interest – to provide cost and savings information for banking that we believe may be of interest to you to enable a personalised comparison of participating banks and RBS.
To provide a copy of the personalised comparison report on request. – Contractual
To provide audit information with regards to the calculations upon request from you – Contractual – Legitimate interest – to provide a pdf copy of the personalised comparison report to the business upon request.
To meet our regulatory responsibilities.(a) Transaction types(b) calculations– Legal Obligation

Information on this page is provided by Swoop an independent company which is not part of the Royal Bank of Scotland. Swoop have prepared this comparison based on your historic banking usage and offer and fees data provided by participating banks. The results provide an indication of potential savings and do not represent an endorsement or recommendation of these offers. Customers must consider their current and future banking needs, and seek independent advice where necessary. Available offers and fees may change and offers may be withdrawn at any time. Each participating bank’s own application criteria and conditions apply.

Customer Analytics FAQ

We use Hotjar to understand our users’ needs better and to optimize our service and user experience. Hotjar is a technology service that helps us better understand our users’ experience (e.g. how much time they spend on which pages, which links they choose to click, what users do and don’t like, etc.) and this enables us to build and maintain our service with user feedback.

What information is tracked and stored about me with Hotjar user behaviour tracking tool when I use the website?

All data is anonymously collected unless you give explicit consent to collect personal information. All the collected data will be stored electronically in Ireland, Europe on the Amazon Web Services infrastructure, eu-est1 datacenter. The database containing visitor and usage data is only accessible from the application servers, and no outside sources are allowed to connect to the database. Hotjar engineers who require access to perform their job efficiently will be given this type of access. Site visitors are assigned a user identifier, UUID, so that Hotjar can keep track of returning visitors without ever relying on any personal information, such as the IP-address. Neither Hotjar nor we will ever use this information to identify individual users or to match it with further data on a particular user. 

How can I view the information that is recorded and stored about me with the user behaviour tracking tool Hotjar?

If you wish to view your personal information, please send a request to our user data management team gdpr@swoopfunding.com and we will send a request to Hotjar requesting your information. Please note that this process can take up to a few days.

How can I request deletion of the information that is stored about me?

According to GDPR, all users have the right to have their stored information deleted in entirety. Customers shall send an email request to gdpr@swoopfunding.com asking to delete all the information that Hotjar has stored about them. An assigned Swoop representative will immediately send a request to Hotjar. Please note that the process can take up to 24 hours, and the information will then be erased within the next 30-day cycle of the database erasures. Finally, the user will receive a confirmation report, saying that all the data has been deleted.

For further details, please see Hotjar’s privacy policy by clicking on this link. You can opt-out to the creation of a user profile, Hotjar’s storing of data about your usage of our site and Hotjar’s use of tracking cookies on other websites by following this opt-out link.