We, SnapDragon Monitoring Limited (“SnapDragon”, “we”, “our”, “us”) are committed to protecting and respecting the privacy of our customers. We will only collect and use personal data in ways which are described here and in a manner that is consistent with our obligations and your rights under law.

SnapDragon has established this Privacy Statement to assist you to understand what information we collect when you use our Swoop portal (“Swoop”) and how that information is used.

References to “you” throughout the policy are to you the customer/visitor.

Who we are and how to contact us

Where SnapDragon collects and processes your personal data, it is the data controller for the purpose of the General Data Protection Regulation (Regulation (EU) 2016/679), the Data Protection Act 2018 and / or any applicable legislation adopted by the United Kingdom post the United Kingdom ceasing to be a Member State of the European Union (“Data Protection Legislation”).

If you have any questions regarding the Privacy Statement you can contact us by:

      • writing to us at SnapDragon Monitoring Limited, The Lair, Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS, UK; and/or

    If you are unhappy with how we handle your personal information you can:

        • submit a complaint in writing for the attention of the Data control Team, SnapDragon Monitoring Limited, The Lair, Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS, UK; and / or

        • notify the Information Commissioner’s Office (ICO) by calling their helpline on: 0303 123 1113.

      What personal information does SnapDragon collect about you?

      Personal Information is information that can be used to identify or contact a specific individual, such as a name, address, telephone number or email address.

      We may collect and process the following information about you when you use Swoop or contact us:

      Information which is given by you We collect information you give to us when you register for or log in to Swoop, complete forms on Swoop or searches, report problems or contact us by e-mail or otherwise. The information you give us may include your name, email address, address, telephone number, username and password and credit card or other payment information.
      Credit card or other payment information.
      Information we collect about you

      With each of your visits to Swoop (regardless of whether you register or log in during your visit) we will automatically collect the following information:

      • technical information (e.g. your Internet Protocol (IP) address, log in information, browser type and version, time zone and setting, browser plug in types and version; operating system and platform;
      • information about your visit, including the city and country you accessed Swoop from, page response times, download errors.

      If you contact us, we may keep a record of that correspondence or telephone call.

      Information we collect about you when you subscribe to receive marketing communications from us

      When you subscribe to receive marketing communications from us we will collect the following personal data from you:

      • name; and
      • email address.

      Legal basis for processing personal information

      Processing is necessary for the performance of a contract. We will use your personal information for the above ‘subscription and services’ purposes as is it necessary for the performance of a contract that we have with you (the “Subscription Agreement”). If you do not wish to provide the personal information requested you may not be able to proceed with the Subscription Agreement.

      Processing is necessary for compliance with a legal obligation to which we are subject. We may be required to share your personal information to comply with legal and/or regulatory requirements or, in the event of a dispute, with the relevant dispute resolution body.

      Consent. In certain situations we can process your information with your consent. For example, to issue to you newsletters or other direct marketing materials.

      Legitimate Interests. The processing is necessary for the purposes of our legitimate interests, such as financial interests, operational and administrative interests, maintaining our relationship with you.

      Compliance with legal obligations. We may process your data where it is necessary for us to comply with our legal obligations.

      How SnapDragon uses your information

      On the basis of the legal grounds outlined above, we will use your personal information to:

          • administer your subscription account (legal basis: performance of our contract with you and our legitimate interests);

          • communicate with you in relation to your subscription account and the services we are providing(legal basis: performance of our contract with you and our legitimate interests);

          • deliver services to you (legal basis: performance of our contract with you);

          • bill you for your subscription/services purchased (legal basis: performance of our contract with you;

          • provide ongoing services and support(legal basis: performance of our contract with you); and

          • provide you with our newsletter and information about services and activities (legal basis: consent where we contact you by electronic means (email, SMS) and our legitimate interests for non-electronic forms of communication).

        You may have a legal right to ask us to delete or destroy your information. Please contact us by online form, or in writing at SnapDragon Monitoring Limited, The Lair, Suite 2, Ground Floor, Orchard Brae House, 30 Queensferry Road, Edinburgh, EH4 2HS, UK for further information.

        With whom SnapDragon shares your personal info with

        SnapDragon contracts with third party service providers and suppliers to provide certain services and customer solutions.

        We may share your personal data with the following parties for the purposes noted below:

            • the party which provides email hosting services to us; which is currently Microsoft 365;

            • the parties which provide marketing support services to us; and

            • Xero which provides our accounting software to support our business systems.

          Except as provided above, SnapDragon will not share personal information with any other third parties without your permission, unless required by, or in connection with, law enforcement action, subpoena or other litigation, or applicable law.

          SnapDragon will not sell, trade or lease your personal information to others.

          Where we store personal data

          The information which we collect about you will usually be stored inside the UK or European Economic Area (EEA). However, we may transfer personal data outside the UK or EEA where our service providers host, process or store data outside the UK or EEA. Where we do this, we will ensure that the transfer is to a country covered by the decision of the European Commission or is otherwise made in circumstances which we have put appropriate safeguards in place to protect your data in accordance with the Data Protection Legislation.

          Retention periods

          We will not hold your personal information for any longer than is necessary for the “uses” outlined above, unless we are required to keep your personal data to comply with the law and any regulatory requirements.

          We will retain your information in accordance with the timelines outlined in our Data Retention Policy.

          Data subject’s rights

          You have certain rights under the Data Protection Legislation which can be exercised by contacting us:

              • the right to access the personal data held about the you by making a subject access request in accordance with the Data Protection Legislation. We may charge a reasonable fee when a request is manifestly unfounded or excessive;

              • the right to have your personal data rectified if it is inaccurate or incomplete;

              • the right to have your personal data deleted in certain specific circumstances as set out in the Data Protection Legislation;

              • the right to restrict the processing of your personal data in certain specific circumstances as set out in the Data Protection Legislation;

              • the right to ask us not to process your personal data for marketing purposes or for purposes based on our legitimate interests; and

              • where you have provided consent, to withdraw such consent at any time.

            Security of personal information

            To protect the privacy of any personal information you may have provided, SnapDragon employs industry-standard controls including physical access controls, Internet firewalls, intrusion detection, and network monitoring.

            Unfortunately, the transmission of information via the internet is not completely secure and although we will do our best to protect your personal data, we cannot guarantee the security of your data transmitted via Swoop; any transmission is at your own risk.

            Your account is password protected for your security and we accordingly advise that you maintain the privacy of your password and change this occasionally to maintain this level of security.

            Third party links

            As part of the services provided via Swoop, we may provide links to third-party websites for your convenience and information. If you access those links, you will leave Swoop. SnapDragon does not control those sites or their privacy practices, which may differ from SnapDragon’s. We do not endorse or make any representations about third party websites. The personal data you choose to give to unrelated third parties is not covered by the SnapDragon Privacy Statement. We encourage you to review the privacy policy of any company before submitting your personal information. Some third party companies may choose to share their personal data with SnapDragon; that sharing is governed by that third party company’s privacy policy.

            When we provide clients with the Swoop reports including seller lists, it is the responsibility of the client to comply with the Data Protection Legislation and use all data collected for its original purpose: to identify counterfeit products and report these products for removal from the online platform.


            SnapDragon will engage in periodic self-assessment to verify that it continues to be in compliance with this Privacy Statement.


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            This Privacy Statement was last updated on 10th June 2024.