I. Principles

1. Joint controllers of personal data

The purposes and means of processing personal data when visiting our Facebook page https://www.facebook.com/SwiftActLLC/ (“Facebook page”) are jointly determined by SWIFT-ACT LLC , B107 Smart Village, KM 28 Cairo – Alexandria Desert Rd, 12577, Giza, Egypt (“SWIFT-ACT LLC”) and Meta Platforms Ireland Ltd. (“Facebook”) in accordance with Art. 26 of the EU General Data Protection Regulation (GDPR). This results from the fact that SWIFT-ACT LLC, as the operator of the Facebook page, by setting up such a page, allows Facebook to place cookies on the computer or any other device of the person visiting the Facebook page (“Visitor”), regardless of whether the Visitor has a Facebook account or not.

Facebook assumes primary responsibility under the GDPR for the processing of Insights data and fulfils all obligations under the GDPR with regard to the processing of Insights data (including Articles 12 and 13 GDPR, Articles 15 to 22 GDPR and Articles 32 to 34 GDPR). In addition, Facebook makes the essentials of this Page Insights supplement available to the data subjects (the corresponding “Page Insights Controller Addendum” can be found here:

https://en-gb.facebook.com/legal/terms/page_controller_addendum).

Below you will find a description of how SWIFT-ACT LLC and Facebook handle your personal data when you visit the Facebook page. However, since SWIFT-ACT LLC generally or to a large extent has no influence on the data collected by Facebook and its processing by Facebook, we are currently unable to provide any conclusive information on the purpose and scope of the processing of your data by Facebook. However, we will monitor further developments in this regard and adapt this privacy policy accordingly if necessary.

We would like to point out that you use this Facebook page and its functions within your own responsibility. This applies in particular to the use of interactive functionalities (e.g. commenting, sharing, rating).

2. Name and address of the joint controllers

a) The primary controller is:

Facebook
Meta Platforms Ireland Ltd.
4 Grand Canal Square
Grand Canal Harbour
Dublin 2 Ireland

b) The other controller is:

SWIFT-ACT LLC
B107 Smart Village, KM 28 Cairo -Alexandria Desert Rd, 12577, Giza.
Egypt

Tel: +2-0106-2621-177 +2-0155-2199-552
Email: info@swift-act.com
Website: https://swift-act.com/

3. How to contact the data protection officer of Facebook

You can contact the data protection officer of the primary controller Facebook under the following link:

https://www.facebook.com/help/contact/540977946302970

4. Legal basis for the processing of personal data

If the consent of the data subject is obtained for the processing of personal data, Art. 6 (1) (1) (a) GDPR serves as the legal basis for the processing of personal data.

Art. 6 (1) (1) (b) GDPR serves as a legal basis for the processing of personal data required for the performance of a contract to which the data subject is a party. This also applies to processing operations required to carry out pre-contractual activities.

If the processing of personal data is necessary to fulfil a legal obligation to which SWIFT-ACT LLC or Facebook is subject, Art. 6 (1) (1) (c) GDPR serves as the legal basis.

If vital interests of the data subject or another natural person require the processing of personal data, Art. 6 (1) (1) (d) GDPR serves as the legal basis.

If the processing is necessary to safeguard a legitimate interest of SWIFT-ACT LLC, Facebook or a third party and if the interests, fundamental rights and freedoms of the data subject do not outweigh the legitimate interest, Art. 6 (1) (1) (f) GDPR serves as the legal basis for the processing.

5. Possibility of objection and removal

The visitor has the possibility to withdraw his consent to the processing of personal data at any time (see also rights of the data subjects). If the visitor contacts us by email, he can object to the storage of his personal data at any time.

The collection of data for the provision of the Facebook page and the storage of data in log files is mandatory for the operation of the Facebook page. Consequently, there is no possibility for the visitor to object.

6. Rights of the data subject

If personal data is processed by you, you are the data subject within the meaning of the GDPR and you are entitled to the following rights regarding those responsible:

  • Right to information about your personal data stored at SWIFT-ACT LLC or Facebook;
  • Right to correction, deletion or restriction of the processing of your personal data;
  • Right to object to a processing that serves the legitimate interest of SWIFT-ACT LLC or Facebook, a public interest or profiling, unless SWIFT-ACT LLC or Facebook can prove compelling legitimate reasons for the processing that outweigh your interests, rights and freedoms, or the processing serves the assertion, exercise or defence of legal claims;
  • Right to data portability;
  • Right to complain to a supervisory authority;
  • Right to withdraw your consent to the collection, processing, and use of your personal data at any time with effect for the future.

If you wish to make use of your rights, you can address your request to SWIFT-ACT LLC as well as Facebook. For this you can use for example the contact possibilities listed above. If you contact us, we will forward your request to Facebook as far as questions regarding the processing of Insights data are concerned. Facebook will respond to enquiries in accordance with our obligations under the Page Insights Supplement.

II. Processing of personal data by SWIFT-ACT LLC

1. Purpose of the data processing

SWIFT-ACT LLC maintains web profiles within social networks in order to communicate with interested parties and active users and to inform about our products, events and news.

When you access our Facebook page (regardless of whether you are logged into your Facebook account or not), your browser transmits certain technical data to the web server for which Facebook is responsible. Facebook also uses so-called “cookies”. Cookies are small text files that are stored in the memory of your device via your browser. Cookies set by Facebook are intended, among other things, to enable SWIFT-ACT LLC, as the operator of the Facebook page, to obtain statistics for the purpose of controlling the marketing of our activities, which Facebook compiles on the basis of visits to this page.

2. Description and scope of data processing

As the operator of the Facebook page, SWIFT-ACT LLC can use the Facebook Page Insights function, which Facebook makes available to us free of charge as an indispensable part of the user relationship, to obtain anonymous statistical data regarding visitors to our Facebook page. This data is collected by using cookies set by Facebook, which each contain a unique user code and that are stored by Facebook on the visitor’s device. The user code that can be linked to the login information of those users that are registered on Facebook is collected and processed when they visit the Facebook Page.

In particular, the Facebook official page operator may receive demographic information provided by Facebook about its target audience -and thus the processing of that information -including trends in age, gender, relationship status, and professional situation, information about the lifestyle and interests of its target audience, and information about the purchases and online purchasing behavior of visitors to its site, the categories of goods or services that interest them most, and geographic information that informs it of where to conduct special promotions or organize events and generally enables it to target its information offering as effectively as possible.

Although the visitor statistics compiled by Facebook are transmitted exclusively in anonymous form to SWIFT-ACT LLC as the operator of the Facebook page, the compilation of these statistics is based on the previous survey -using cookies set by Facebook on the visitor’s device -and the processing of the personal data of these visitors for these statistical purposes. More information about Facebook Page Insights can be found at:

https://www.facebook.com/legal/terms/information_about_page_insights_data

https://en-gb.facebook.com/help/pages/insights

It also provides information about the Facebook groups associated with our Facebook page. Due to the constant development of Facebook, the availability and processing of data is changing, so that we refer you for further details in this regard to the privacy policy provided by Facebook in the previous paragraph and subsequently under “PROCESSING PERSON-RELATED DATA BY FACEBOOK”.

We use this aggregated information to make our contributions and activities on our Facebook page more attractive to users. For example, we use the age and gender distributions for an adaptive customer approach and the preferred visiting times of the users to optimize the planning and timing of our postings. Information about the type of devices used by visitors helps us to adapt the contributions optically and creatively. In accordance with Facebook’s Terms of Use, which each user has agreed to when creating a Facebook profile, we may identify subscribers and fans of the site and view their profiles and other shared information from them.

In addition to this automatically collected anonymous data, we also process the data that you have voluntarily provided us with, e.g. comments on posts or contacts.

If you click on the link https://swift-act.com/fbpp/ (you are currently on this page), which is on the Facebook official page of SWIFT-ACT LLC, you will be taken to a subpage of the SWIFT-ACT LLC website. Personal data is also processed on this page. You can find the privacy policy applicable to the website here: https://swift-act.com/privacy-policy/

3. Data removal and storage duration

Personal data will be deleted or blocked as soon as the purpose of storage no longer applies. Storage may also be necessary if provided for by European or national lawmakers in Union regulations, laws or other rules to which SWIFT-ACT LLC is subject. The data shall also be deleted or the processing shall be restricted if a storage period prescribed by the aforementioned standards expires, unless it is necessary for further storage of the data for the conclusion or performance of a contract.

III. Processing of personal data by Facebook

How Facebook uses the data from visits to Facebook pages for its own purposes, to what extent activities on the Facebook page are assigned to individual users, how long Facebook stores this data and whether data from a visit to the Facebook page is passed on to third parties, is not conclusively and clearly stated by Facebook and is not fully known to us. However, we will monitor further developments in this regard and adapt this privacy policy accordingly if necessary. The following information is based on information publicly provided by Facebook regarding the processing of personal data when using Facebook products.

1. Purpose of the data processing

Facebook processes visitors’ personal data according to its own specifications for the following purposes:

  • Deployment, personalisation and enhancement of Facebook products;
  • Provision of metrics, analysis and other Facebook services;
  • Promotion of protection, integrity and security;
  • Communication with Facebook users;
  • Research and innovation for social purposes.

For more information about Facebook’s data processing purposes, please see the Facebook privacy Policy:

https://en-gb.facebook.com/policy.php

Further information on Facebook’s legitimate interests with regard to the processing of personal data can be found here:

https://www.facebook.com/about/privacy/legal_bases

When you access our Facebook page (regardless of whether you are logged into your Facebook account or not), your browser transmits certain technical data to the web server for which Facebook is responsible. Facebook also uses “cookies”. Facebook uses cookies, among other things, to provide SWIFT-ACT LLC as the operator of the Facebook page with statistics for the purpose of controlling the marketing of our activities. For more information about Facebook’s use of cookies, see the Facebook Cookie Policy: https://en-gb.facebook.com/policies/cookies/

2. Description and scope of data processing

a) What type of information does Facebook process?

To provide Facebook products, it is necessary for Facebook to process information about visitors. The types of information that Facebook collects depends on how visitors use Facebook products. The following information can be processed by Facebook:

Anything generated and provided by visitors and others, such as information about how the visitor uses Facebook products, information about transactions done on Facebook products, or information about the people, pages, accounts, hashtags, and groups with which the visitor is connected.

Device information such as device properties, identifiers, network and connections, and cookie data.

Partner information that allows advertisers, app developers and publishers to send information to Facebook through the Facebook business tools they use, including social plugins (such as the “Like” button), Facebook login or Facebook pixel. These partners provide Facebook with information about the visitor’s activities outside Facebook.

In addition, Facebook uses cookies that are set on the visitor’s device when the Facebook page is accessed, regardless of whether the visitor is logged into his Facebook account or not. Facebook also processes the information stored in cookies when a person uses the Facebook services, services provided by other members of the Facebook corporate group, and services provided by other companies that use the Facebook services. In addition, other sites, such as Facebook partners and other third parties, may use cookies on Facebook Services to provide services to Facebook or companies advertising on Facebook. For more information about Facebook’s use of cookies, see the Facebook Cookie Policy:

https://en-gb.facebook.com/policies/cookies/

When you access a Facebook page, the IP address assigned to your device is transmitted to Facebook. According to Facebook, this IP address is anonymized (for “German” IP addresses) and deleted after 90 days. In addition, Facebook stores information about its users’ devices (e.g. as part of the “registration notification” function); Facebook may thus be able to assign IP addresses to individual users.

If you want to avoid this, you should log out of Facebook or deactivate the function “stay logged in”, delete the cookies on your device and close and restart your browser. Thus, information that Facebook can use to identify you is deleted. This allows you to use our Facebook page without revealing your Facebook account. When you access the interactive features of the page (like, comment, share, news, etc.), a Facebook login screen appears. After an eventual login, you will again be recognisable for Facebook as a specific user.

For information on how to manage or delete existing information about you, please visit the following Facebook Support pages:

https://en-gb.facebook.com/about/privacy

For more information about the type of information that Facebook processes, please see the Facebook Privacy Policy:

https://en-gb.facebook.com/about/privacy

b) How is the information processed by Facebook shared with others?

Facebook works with third-party partners who help Facebook deliver and enhance its products or use Facebook business tools to grow business. Facebook may share information with the following third parties:

  • Partners who use Facebook analysis services;
  • Advertisers;
  • Partner for metrics;
  • Partners who offer goods and services in Facebook products;
  • Vendors and service providers;
  • Researchers and scientists;
  • Law enforcement authorities or legal inquiries.

For more information about the information that Facebook may share with third parties, please see the Facebook Privacy Policy:

https://en-gb.facebook.com/about/privacy

c) How does Facebook process and transmit data as part of its global services?

Facebook shares information worldwide, both internally between Facebook companies and externally with its partners, as well as with those individuals or organisations with whom the visitor connects around the world and with whom the visitor shares something. Data may also be transferred to and processed in the USA or other third countries that do not have an adequate level of data protection. In this regard, Facebook uses standard contractual clauses approved by the European Commission or relies on the European Commission’s adequacy decisions regarding certain countries.

For more information about Facebook data submissions, please see the Facebook privacy Policy:

https://en-gb.facebook.com/about/privacy

3. Data removal and storage duration

Facebook stores data until it is no longer needed to provide its services and Facebook products, or until the user’s Facebook account is deleted, whichever comes first. This is a case-by-case determination and depends on such things as the nature of the data, why it is collected and processed, and the relevant legal or operational storage needs.

For more information about data erasure and retention times, please see the Facebook privacy Policy:

https://en-gb.facebook.com/about/privacy

For more information about how long cookies set by Facebook are stored, see the Facebook Cookie Policy: https://en-gb.facebook.com/policies/cookies/

This privacy policy has been created with the assistance of DataGuard.