Privacy Policy

Definitions

Service means any services provided by the Company, including Swift's Xero conversion work and JournalFlow accounting-data automation services.

Personal Information means information about an identifiable individual, as defined by applicable privacy law.

Privacy Officer means the individual designated responsibility for helping ensure that the Company complies with this Privacy Policy and applicable privacy obligations.

Usage Data means data collected automatically either through use of the Site or from the Site or Service infrastructure itself, such as IP address, browser information, requested pages, and date and time of access.

Personal Information We Collect

The Company collects Personal Information when you voluntarily provide it through our Site or when you provide it to us through other means. For example, we may collect Personal Information when you:

• contact us by email or other correspondence;
• request a demo, workflow assessment, Xero conversion, or other Service;
• provide reports, source files, accounting records, exports, emails, attachments, or other business information for assessment, conversion, automation, processing, support, or troubleshooting; or
• authorize us to connect to Xero or another service needed to provide an agreed Service.

The Personal Information we may collect depends on the Service requested and may include your name, company, role, email address, other contact information, information contained in business reports or accounting records, connected-service information, processing history, support information, and other information you choose to provide.

Business reports and accounting records may contain Personal Information about employees, customers, suppliers, or other individuals. Where a client provides information about another person, the client is responsible for having the authority to provide that information and for any notices or consents required by applicable law.

Personal Information Collected by Technological Means

When you visit our Site, information may be sent to us automatically by your web browser or recorded by our hosting infrastructure. This information may include your domain name, numerical IP address, browser or device type, pages requested, files requested, and date and time of access.

We may use this information to understand how the Site is used, operate and secure the Site, troubleshoot technical issues, and improve the Site and Services.

The Site may use cookies or similar technologies where reasonably necessary for functionality or security. The current public Swift website does not use advertising or behavioural-tracking cookies and does not currently use Google Analytics or another advertising or analytics platform. If that changes materially, this Privacy Policy will be updated.

Uses, Transfer and Disclosure of Personal Information

The Personal Information we collect may be used for the purposes for which it was collected, as provided in this Privacy Policy, or for other purposes that are disclosed to you and permitted by applicable law.

For example, we may use information to:

• provide and maintain our Services;
• respond to enquiries, demo requests, and workflow assessments;
• verify client identity or authority where appropriate;
• configure, operate, review, support, and troubleshoot JournalFlow workflows;
• perform Xero conversions and related accounting-data services;
• send approved results to Xero or another connected service at the client's direction;
• notify you about changes to our Services;
• provide customer support;
• monitor, secure, and improve the Site and Services;
• detect, prevent, and address technical, security, or fraud issues;
• maintain business, support, audit, accounting, or compliance records; and
• meet legal, regulatory, contractual, or dispute-resolution requirements.

We do not sell Personal Information.

Transfer of Information

Some or all of the Personal Information we collect may be stored or processed in jurisdictions outside British Columbia or outside Canada, including through service providers or connected services. As a result, information may be subject to lawful access by governments, courts, or law-enforcement authorities in those jurisdictions according to the laws that apply there.

If you are located outside Canada and choose to provide information to us, that information may be transferred to Canada for processing and may also be processed by service providers or connected services in other jurisdictions.

The Company takes reasonable steps appropriate to the circumstances to select and manage service providers and to protect Personal Information in accordance with this Privacy Policy and applicable law.

Disclosure of Information

We may disclose Personal Information with consent, at a client's direction, where reasonably necessary to provide the Service, or where permitted or required by applicable law.

This may include disclosure to:

• Xero or another connected accounting or technology service when you authorize the connection or direct us to send data there;
• service providers that support hosting, email, storage, security, backups, communications, or other technology used to operate Swift and JournalFlow;
• professional advisers, including lawyers, accountants, insurers, or security advisers, where reasonably necessary; and
• government, regulatory, law-enforcement, or other parties where disclosure is permitted or required by law.

The Company may also disclose Personal Information without consent where permitted or required by law, including where reasonably necessary to protect the rights or property of the Company, respond to an emergency threatening life, health, or security, obtain legal advice, collect a debt, protect against fraud, or investigate an anticipated breach of an agreement or contravention of law.

Business Transaction

If the Company is involved in a merger, acquisition, financing, reorganization, sale of assets, or similar business transaction, Personal Information may be transferred as part of that transaction where permitted by law. Where appropriate, we will take reasonable steps to ensure that Personal Information remains subject to appropriate protection.

Protection of Personal Information

The security of Personal Information is important to us. We maintain physical, organizational, administrative, and technological safeguards appropriate to the sensitivity of the information and the nature of the Service.

Personal Information is intended to be accessible only to persons or service providers who reasonably require access for the purposes described in this Privacy Policy. No internet transmission, hosting environment, or information system can be guaranteed to be completely secure.

Service Providers

We may employ third parties to facilitate the Site or Services, provide services on our behalf, perform Service-related functions, or assist us in operating and securing our business and technology.

Those service providers may have access to Personal Information only to the extent reasonably necessary to perform the applicable functions, subject to their contractual and legal obligations.

Analytics

The current public Swift website does not use Google Analytics or another advertising or analytics platform. Our hosting infrastructure may still create ordinary server logs for security and operational purposes. If we introduce an analytics service in the future, we will update this Privacy Policy as appropriate.

Links to Other Sites

Our Site and Services may contain links to sites or services that are not operated by us, including Xero. If you follow a third-party link, you will be directed to that third party's site or service.

We have no control over and assume no responsibility for the content, privacy policies, or practices of third-party sites or services. We encourage you to review the privacy policy of any third-party service you use.

Privacy of Minors

Our Site and Services are intended for business use and we do not knowingly collect Personal Information directly from anyone under the age of 18 for account registration or ordinary service use. If you believe a minor has provided Personal Information to us without appropriate authority or consent, please contact our Privacy Officer.

Retention of Personal Information

We retain Personal Information only as long as reasonably necessary for the purposes for which it was collected or for legal, contractual, accounting, security, support, audit, dispute-resolution, or other legitimate requirements.

JournalFlow source files and processing history may be retained after processing where they are still needed for review, troubleshooting, auditability, verification, support, or another legitimate service purpose. We do not promise a fixed automatic deletion period unless a specific retention arrangement has been agreed with you.

When Personal Information is no longer reasonably required and there is no legal or business reason to retain it, we take reasonable steps to destroy, delete, or de-identify it as appropriate.

If we use Personal Information to make a decision that directly affects an individual, we will retain that Personal Information for at least one year where required by applicable privacy law so that the individual has a reasonable opportunity to request access to it.

Access and Rectification

Subject to applicable law, you may request access to Personal Information that the Company holds about you and may request correction if you believe the information is inaccurate or incomplete.

We may need to verify your identity before responding to a request. Some information may be withheld, retained, or otherwise handled differently where permitted or required by law. To make a request, contact our Privacy Officer using the information below.