Privacy Policy - NH Collection

1. INTRODUCTION

Last updated on 17th April 2025.

This privacy notice sets out how we process your personal data. It provides you with certain information that must be provided under data protection legislation. Personal data is information about individuals or information from which individuals can be identified (“personal data”).

2. WHAT KINDS OF INFORMATION DO WE COLLECT

Information you’ve provided to us: We collect information about you, such as your name, email address and opinions, when you provide such information to us, including when you create an online account, subscribe to one of our titles, order or register your interest in one of our products, post a comment under an article or sign up for a newsletter. This could be via your computer browser, via an app, by telephone, or by post.
Information about transactions made: If you purchase anything or make any other financial transactions on any of our websites/apps, we collect information about your purchase and ask for information including your name, e-mail address and delivery address to be forwarded on to the vendors who are responsible for delivering your order. This does not include payment information such as your credit/debit card number
Information from Partners: Where you have registered or created an account with one of our websites, we may obtain information about you from other companies who have obtained your permission (through their own privacy policies) to share information about you. For more information about this, please see “Personalisation/Identifying Your Interests” in Section 2 below.
Social Media: If you log-in to our websites through a social media site, such as Facebook, you are granting permission to Facebook to share your user information with us. This will include your name, email address, date of birth, location, plus any other information you have permitted Facebook to share with third parties. If you remove the app from your Facebook account, we will no longer have access to this information. We may also collect your personal data through our social media accounts when you use tools to tag us and mention us in your posts, statuses and comments through your accounts on these platforms, and when you provide us with your personal data on our accounts on these platforms, e.g. when you comment on one of our posts on Facebook.
Information about other people: By supplying us with information about someone else, you confirm that they have authorized you to provide us with their information (including sensitive personal data) on their behalf.
Before you use “email a friend” or “share this article” buttons please make sure that anyone you wish to email or share with are happy for this to occur and expect to receive the email or article. You may only share the details of another person with us where you have their express permission.

3. HOW WE MAY USE YOUR INFORMATION

Delivering Services: By using our websites, apps and other products and services, we may process your information for the purpose of entering into and/or performing our obligations under a contract we have with you, for example, for the provision of our products and services. This may include (without limitation):
- to set-up, administer and manage your account with us
- to send you service updates about our websites, apps and other products and services
Managing our relationship with you, which shall include (without limitation):
- contacting you were a checkout journey is not completed if you have provided your information;
- delivering customer services and support;
- ensuring the integrity of votes and polls;
- maintaining records of our communications with you if you get in contact with us;
- obtaining customer reviews and conducting market research.

Lawful basis for these processing activities: Legitimate Interests of ensuring our services and website are as useful as possible and legitimate interests of providing our products and services.

Communicating with you: We may process your personal data in responding to communications by you on the basis of your consent. For example, if you contact us with a query or in circumstances where it is appropriate for us to reply, we will proceed on the basis that you consent to us using your personal data to the extent required to respond to you.
Marketing: In accordance with your preferences and data protection legislation, we may use your information to send you direct marketing communications. This may include communications by post, telephone, email or SMS about our products and services, events and special offers, mobile phone notification.
We may also send you periodic newsletters about your chosen services, inform you of promotional offers that you might find interesting, and inform you about any changes to our products and services where we have permission to do so.
Lawful basis for processing this data: Consent/ Our legitimate Interests including our commercial interests in maintaining and expanding our operations.
Personalization/Identifying your Interests: We may use your information to provide you with a greater personalised experience when you visit/use our sites/apps, and for insight and marketing purposes. We provide personalisation by using data you submit to us, cookies, IP addresses, web beacons or similar technologies in relation to the devices you use. By doing so, we can provide you with editorial content and/or advertising that we believe is more relevant to your interests. Please see our cookie policy for more information on this. .
For more information on these partners and how you can opt-out of having your data shared with us from these sources for profiling purposes, please see the section entitled “Marketing Personalization” in Section 4 below.
Lawful basis for this processing activity: Legitimate Interests of providing you with a tailored experience, including our commercial interests in maintaining and expanding our operations.
Tailored advertising: We use advertising to fund some of our websites and apps. Some advertising is “contextual” meaning it is shown due to the particular web page you are presently viewing. Other advertising, known as “online behavioral advertising” is shown to you based upon your likely interests, which are inferred from your device’s browsing history. This information is collected through the use of cookies and similar technologies. For more information on controlling your tailored advertising preferences, please see our cookie policy.
Sometimes we allow advertisers to show advertisements directly on our website and apps, which are tailored to you based upon information they have obtained, such as your browsing history on their own websites.
Other times we will arrange for our customers to be shown advertisements on our own or other websites or apps. These advertisements are tailored to you with information we have obtained from your browsing on our websites and apps via cookies.
Where we arrange for our customers to be shown advertisements, we use technological and contractual mechanisms to protect your cookie data and to ensure that your browsing data used for advertising is not used by advertisers or other website owners for other purposes, such as linking online behavioral advertising data with your contact details, unless you have provided the advertiser or other website with your express permission to do this.
When you are shown an advertisement, our advertising systems do not know who you are or your contact details (such as your name, email address or postal address).
Demographic information from your registration on our websites and apps (such as your age, gender and city) may also be used to tailor the advertising we arrange to be shown. Your demographic information is not shared with advertisers. We may also target advertising on social media sites to specifically include customers who have registered for our products and services or previously visited our websites.
Contextual data is being collected by Primitive LLC
Legal basis for this processing activity: Consent
Location based services and advertising: Where we provide services that utilize your device’s location, such as local weather or news, your location will be determined either from a lookup of your IP address in a “GeoIP” database which lists information provided by your ISP (usually your closest town or borough) or your precise location directly from the device (such as through GPS or Wi-Fi on mobile devices) where you have granted permission for us to access this location information via your device settings. We use such information to provide you with a more tailored, relevant experiences when using our websites/apps. Where you have granted permission to access your device’s location and consented to us to use your data for advertising purposes, this location information may be used to tailor the advertising you receive, including showing you certain advertisements when you are in the vicinity of a particular location.
Lawful basis for this processing activity: Consent
Measurement and analytics: We may use certain information (such as the websites that you visit and advertisements you see or click on) to help advertisers and other promotional partners measure the effectiveness and distributions of their advertisements and promotions.
Lawful basis for this processing activity: Consent
Improving our services and products: We may use your information to monitor and improve our products, content and services. This may include (without limitation):
- developing the design and style of our products and services to make improvements
- carrying out statistical, technical and logistical analysis to inform our strategic development
- blocking disruptive use and ensuring the security of our products and services
If you have registered on our websites or apps, we may analyse the information we hold on you in aggregate with our other customers to improve our advertising systems.
Lawful basis for this processing activity: Legitimate Interests of ensuring our services and website are as useful as possible
Message boards, blogs and other public forums: Our websites may provide message boards, blogs and other user generated content facilities. Anything that you share will become public information. You should always be careful when deciding to disclose your personal information.
Lawful basis for this processing activity: Legitimate interests of promoting our products and services and running our everyday operations.
We may share your personal data with the Audit Bureau of Circulations Ltd so they can verify aggregated statistics about circulation and usage of our products or review our policies, processes and procedures for compliance with relevant standards.
Lawful basis for processing this data: Legitimate Interests of improving our services for recipients.
We may also process your personal data: (a) to comply with any legal obligation we are under; and (b) for additional purposes in the future, but only if such purposes are compatible with those listed above and if we believe that the same lawful basis applies.

In certain circumstances, failure to provide us with personal data that we have requested may impact the operation of our business or prevent us from performing any legal obligations to you. For example, if you make a data subject access request, we may need to verify who you are before providing personal data to you; if you do not provide the information we reasonably need to verify your identity, we may not be able to comply with the subject access request.

4. HOW WE MAY SHARE YOUR INFORMATION

Sharing with third parties
Vendors: We may your personal data with third parties, for example, service providers we use to help us in the running of our operations and the provision of our products and services, for example, organizations that provide us with technology related services.
Social media: Your personal data may be shared with other parties and/or on our social media accounts for the purposes and the legitimate interests of facilitating our operations and promoting our offerings including on Facebook and Instagram.
Industry Affiliates: We regularly partner with industry affiliates to bring you special deals on products and packages you may find of interest. These include a variety of industry specific providers. These providers collect marketing permissions for us and share data back with us about your purchases in order for us to measure the effectiveness of our marketing campaigns.
If you decide to book a holiday with an affiliate, use their advisory services or set up an account, or purchase a financial product, these affiliates will be data controllers of the information you have provided them in order to administer your relationship with them and will handle your information in accordance with their own privacy policies.
Functionality: We may share information about you with suppliers that we engage to help us provide our services and/or functionality of our websites and apps. For example, we share data with Google to prevent certain website functions from being abused. Where this happens, your data will be processed in accordance with Google’s Privacy Policy.
Advertisers: We may provide third party advertisers with reports containing aggregate statistical data about our customers’ use of our websites and apps to determine the kinds of people viewing their ads and how they are performing. This aggregated information may include demographic data such as age range and/or geographic location of groups of our customers.
This aggregated data does not include contact details (such as names, addresses or email addresses) that can be used to personally identify you or contact you. Marketing personalization. We can only obtain this information where they have your permission to share this information with us in line with their privacy policies. You can opt-out of having your personal information profiled in this way by contacting us or adjusting your account settings
Change of Control: We may transfer, sell or assign any of the information described in this Policy to third parties as a result of a sale, merger, consolidation, change of control, transfer of assets or reorganization of our business.
Other data sharing: There are other circumstances in which we may need to share your data with third parties. We may, for example, share your data in connection with legal proceedings or if we need to protect or defend our legal rights. We may also disclose your personal data to HMRC and / or law enforcement agencies in order to assist with any investigations and/or to companies that we have close links with, for example, elements of common ownership.

5. HOW YOU CAN EXERCISE YOUR DATA SUBJECT RIGHTS

Access: If you wish to exercise your right to access a free copy of your data, you can contact us at the contact details provided below at Section 12.
Deletion: To ask us to delete your personal data, please contact us at the contact details provided below at Section 12. However, there may be circumstances where we are legally entitled to retain it.
Rectification: If you wish to update or rectify your data, you can do this directly by accessing your account settings.
Revoke consent: If the lawful basis we rely on to process your personal data is consent you have the right to withdraw this consent. Please email us at swiftpickofficial@Gmail.com to withdraw consent for the processing of your personal data. If you wish to object to the processing of your data for direct marketing or online behavioral advertising purposes, you can opt-out by updating your settings or, for direct marketing, clicking on the “unsubscribe” link in any marketing email or newsletter you receive from us.
Objection to automated profiling: If you wish to opt-out of having your personal information profiled for personalization purposes you can adjusting your account settings or contact us directly.
Objection to legitimate interests: If you wish to object to our processing of your data where we are pursuing our legitimate interests or those of a third party please contacting us as at the contact details provided below stating the nature of and reasons for such objection.
Restriction: You may request a restriction on the processing we undertake on your personal data. This will only apply if we have no lawful basis to process your personal data, your personal data is inaccurate or to comply with an objection request.
Portability: You have the right to receive some of your personal data in machine readable format. This right extends to you being able to request that such data is sent to a third-party controller.
Complain: You also have the right to lodge a complaint about us with a supervisory authority. In the Bangladesh. here: https://mofa.gov.bd
If you are contacting us to exercise any of your data subject rights, you will have to provide valid proof of identification. We are required to respond to your request within 1 month.

6. DATA RETENTION AND ACCOUNT DELETION

We store your data for no longer than necessary in relation to the purpose under which such data was collected. This is determined on a cases by case basis and depends on things such as the nature of the data provided, why it was collected, the legal basis we rely upon to process the data, and our relevant legal or operation retention requirements. For example, if you request to delete your account we still have to retain some data for fraud prevention purposes and financial auditing

7. CHILDREN AND YOUNG PEOPLE

Our websites, apps and other products and services are not aimed at children. We do not target, intend to collect, or knowingly collect or otherwise process information from anyone under the age of 13.

If you are under the age of 13, we request that you do not provide us with your information and do not use our websites and apps.

If you are a parent or guardian of a child under 13, please contact us if you are aware that your child has used our websites or apps or otherwise provided their information to us without your consent. We will delete or otherwise cease processing your child’s personal information within a reasonable time.

If you are aged 13, 14 or 15, we request that you seek your parent or guardian’s permission before providing us with your information or using our websites or apps. In accordance with industry best practice guidelines, we may retain your information for a reasonable amount of time to make sure that we do not contact you in the future.

8. CHANGES TO THIS POLICY

We reserve the right to make changes to this Policy. Where changes are made, we will post the revised Policy here with an updated effective date. Please check regularly for any changes to this Policy.

9. HOW TO CONTACT US

If you have any queries or comments about this Policy or to exercise any of your data subject rights, please contact us by email at: swiftpickofficial@gmail.com

10. COMMON ID COOKIE

This site uses cookies and similar tracking technologies such as the Common ID cookie to provide its services. Cookies are important devices for measuring advertising effectiveness and ensuring a robust online advertising industry. The Common ID cookie stores a unique user id in the first party domain and is accessible to our ad partners. This simple ID that can be utilized to improve user matching, especially for delivering ads to iOS and MacOS browsers. Users can opt out of the Common ID tracking cookie by clicking

Summary

This Privacy Policy explains in depth how SwiftPick (“we”, “us”, “our”) collects, uses, shares, and protects your personal data under Bangladesh’s Digital Security Act 2018, Cyber Security Act 2023, and the forthcoming Personal Data Protection Ordinance 2025. It details the categories of data we gather, lawful bases for processing, cookie and tracking mechanisms (including the Common ID cookie), data-sharing practices, international transfers, security measures and retention, your rights as a data subject, protocols for children’s data, and our breach-notification commitments. Each section cites official sources to ensure transparency and legal compliance.

1. Introduction

Last updated: May 17, 2025
SwiftPick (“we”, “us”, “our”) respects your privacy and is committed to protecting your personal data. This Privacy Policy describes:

What personal data we collect and how we collect it;
The legal grounds on which we process your data under Bangladeshi law;
How we use cookies and tracking technologies (including the Common ID cookie);
With whom and under what circumstances we share your data;
How we secure and retain your data;
Your rights as a data subject and how to exercise them;
Our approach to children’s data; and
How to contact us with questions or data-protection requests.

2. Legal Framework

2.1 Digital Security Act, 2018

We process personal data in accordance with the Digital Security Act, 2018 (Act No. 46 of 2018), which established definitions and offences regarding digital content and identifies “personal data” or “identity information” as requiring explicit consent for collection and processing ICNL.

2.2 Cyber Security Act, 2023

On September 18, 2023, the Cyber Security Act, 2023 repealed the DSA 2018, retaining its core data-protection provisions while refining offences and penalties for digital misuse Refworld Bangladesh Laws. Section 2(1) of the CSA 2023 broadly defines “identification information” to include any data that can identify an individual, from biometric identifiers to IP addresses UniversePG.

2.3 Personal Data Protection Ordinance, 2025 (forthcoming)

The government is consulting on a comprehensive Personal Data Protection Ordinance, 2025 to establish an independent supervisory authority, detailed data-transfer restrictions, and stricter breach-notification rules Atlantic Council.

3. Categories of Data We Collect

3.1 Information You Provide Directly

Account Registration: name, email, chosen password, profile details.
Newsletter & Comments: email sign-ups, comment text, ratings, survey responses.
Customer Support: correspondence records and any information you submit to resolve issues.

3.2 Transaction & Payment Data

Orders & Purchases: product or service details, billing and delivery addresses; excludes full payment card numbers, which are processed by PCI-compliant third parties privacylibrary.ccgnlud.org.
Subscription Plans: if or when we introduce paid tiers, we will collect plan selections and payment confirmations.

3.3 Third-Party & Social-Login Data

When you choose social sign-on (e.g., via Facebook or Google), we collect your name, email, profile picture, and any other data you authorize through that platform Jural Acuity.

3.4 Cookies & Tracking Technologies

We use cookies and similar technologies, including:

Essential cookies: required for core functionality (session management, login).
Performance & Analytics cookies: to measure site usage and improve performance.
Marketing & Personalization cookies: to deliver tailored ads, including the Common ID cookie that stores a unique user ID and is shared with our ad partners for measurement and attribution DataGuidance.

4. Lawful Bases for Processing

4.1 Consent

We process data based on your explicit consent when you:

Sign up for newsletters.
Accept non-essential cookies via our Cookie Banner.
Participate in marketing campaigns.

4.2 Contractual Necessity

Processing is necessary to fulfill our contractual obligations, such as:

Creating and managing your account.
Providing you with paid or free services you request.

4.3 Legitimate Interests

We process data for our legitimate business interests, provided they do not override your fundamental rights, including:

Website security and fraud prevention.
Service improvements through analytics.
Tailored content and offers (unless you opt out) Jural Acuity.

4.4 Legal Compliance

We may process or disclose your data to comply with legal obligations, court orders, or to respond to lawful requests by public authorities.

5. How We Use Your Information

5.1 Service Delivery & Account Management

Create, verify, and maintain your account.
Provide customer support, service updates, and administrative messages.

5.2 Communications

Send transactional emails (e.g., account confirmations, password resets).
Respond to inquiries and feedback.

5.3 Marketing & Personalization

Send newsletters, promotional offers, and event invitations (with your consent).
Use behavioral cookies to display ads aligned with your interests on and off SwiftPick DataGuidance.

5.4 Analytics & Site Improvement

Analyze site usage patterns to optimize performance and content relevance.
Detect and prevent fraudulent or malicious activity.

5.5 Legal & Safety

Monitor compliance with our Terms & Conditions.
Investigate suspected wrongdoing or disputes.

6. Cookies & Tracking Details

6.1 Managing Cookies

You can manage or disable cookies via our Cookie Banner at first visit or adjust settings in your browser. Disabling non-essential cookies may affect site functionality or personalization features.

7. Data Sharing & International Transfers

7.1 Service Providers

We share your data with trusted vendors who support hosting, analytics, email delivery, payment processing, and customer support. All vendors are contractually bound to process data in line with this Policy.

7.2 Advertising & Affiliates

We provide aggregate, non-identifiable reports to advertisers and affiliates to measure campaign performance and website traffic.

7.3 Legal & Safety Disclosures

We may disclose personal data:

To comply with legal processes, court orders, or regulatory requests.
To protect our or others’ rights, property, or safety.

7.4 Change of Control

In the event of a merger, acquisition, or sale of assets, your data may transfer to the new owner under the same privacy protections.

7.5 Cross-Border Transfers

We do not routinely transfer personal data outside Bangladesh except under binding corporate rules or standard contractual clauses that ensure an adequate level of protection Atlantic Council.

8. Data Security & Retention

8.1 Security Measures

We implement industry-standard safeguards—encryption, access controls, intrusion detection—to protect your data from unauthorized access, alteration, or destruction Amnesty International Australia.

8.2 Breach Notification

Although Bangladeshi law currently lacks a statutory breach-notification requirement, we commit to notifying affected users and relevant authorities without undue delay upon discovering a data breach Jural Acuity.

8.3 Retention Periods

We retain personal data only as long as necessary for its processing purposes or as required by law, typically:

Account and transactional data: up to 7 years for auditing and fraud prevention.
Marketing consents: until you withdraw consent.
Cookies and analytics: up to 24 months unless you delete them sooner.

9. Your Rights as a Data Subject

Under Bangladeshi law—aligned with international best practices—you have the right to:

Access: Request a copy of your personal data.
Rectification: Correct inaccurate or incomplete data.
Deletion: Erase data when it’s no longer needed or you withdraw consent (subject to legal retention obligations).
Restriction: Limit processing in certain circumstances.
Data Portability: Receive data in a structured, machine-readable format.
Objection: Object to processing based on legitimate interests or direct marketing.
Withdraw Consent: At any time for consent-based processing.
Complain: Lodge a grievance with the Bangladesh Information Commission once established, or via the Ministry of Posts, Telecommunications & Information Technology DataGuidance.

Requests will be handled free of charge within 30 calendar days of receipt, unless we lawfully extend this period by up to two additional months for complex requests Tech Global Institute.

10. Children & Young People

10.1 Under-13 Policy

Our services are not directed at children under 13. We do not knowingly collect personal data from children under 13; if we learn that we have inadvertently done so, we will delete it promptly Jural Acuity.

10.2 Ages 13–15

Users aged 13–15 should obtain parental or guardian consent before submitting any personal data to us. We may retain minimal data for anti-circumvention purposes.

10.3 Parental Requests

Parents or guardians can request deletion of their child’s data by contacting us at swiftpickofficial@gmail.com. We will act on such requests within 30 days.

11. Changes to This Policy

We may update this Privacy Policy to reflect changes in our practices or legal requirements. We will post the revised policy here with a new “Last updated” date. Notifying you via email or site banner for material changes.

12. Contact Us

For any questions, to exercise your rights, or to lodge complaints, please contact:
Hunter Gadget Legal Team
Email: swiftpickofficial@gmail.com