1. Who We Are

The Swan is managed by Swan Clewer Community Interest Company (SCCIC) which is the data controller for personal data collected via this website. We are committed to protecting the privacy of all website users, customers, volunteers, donors, shareholders, and members of the local community.

2. Information We Collect

We may collect personal data when you:

• Sign up for newsletters, events, or volunteer roles (such as name, email address, and contact number).
• Make donations or community investments (including payment details, donation amounts, and tax-related information). Payment details are processed securely by our payment providers and are not stored directly on our systems.
• Interact with our website (IP address, browser type, device information, and referring websites through cookies or analytics tools).
• Contact us by phone, email, or online forms (including messages, emails, and attachments).
• Attend events or quiz nights (for lottery draws, raffle entries, or attendance tracking).

3. How We Use Your Data

We use personal data to:

• Send newsletters, event reminders, and supporter updates.
• Send volunteer coordination messages.
• Process donations, manage shareholding records, and handle community investments.
• Improve website performance and user experience through analytics.
• Respond to enquiries, feedback, or messages submitted to us.
• Meet legal, regulatory, and financial obligations as a Community Interest Company.

4. Legal Basis for Processing

We process personal data under the following lawful bases:

• Consent (for example, newsletter sign-ups and event registrations).
• Legal obligations (including annual reporting and fundraising regulations).
• Legitimate interests (such as the day to day running of the pub, community engagement, volunteer coordination, and improving our services, where these interests do not override your rights).

5. Disclosure of Your Data

Your personal data may be shared with:

• Trusted third-party service providers (such as email platforms, website hosting providers, and payment processors).
• Authorities, where legally required.
• Volunteers and staff members, where necessary for event organisation, fundraising, or governance.

All third-party service providers are required to process personal data in accordance with data protection legislation and only on our instructions.

We do not sell or share personal data with external parties for marketing purposes.

6. Cookies & Analytics

We use essential cookies that are necessary for the operation of our website.

We may also use non‑essential cookies, such as analytics cookies, to help us understand how visitors use our website and to improve its performance and functionality. Non‑essential cookies are used only where permitted by law.

Cookies and analytics information may include pages visited, session duration, and basic device or location data.

You can manage or disable cookies at any time through your browser settings. Where applicable, you may also be given the option to manage cookie preferences when visiting our website.

7. Data Retention

We retain personal data as follows:

• Newsletter and event sign-ups: until you unsubscribe or request deletion.
• Donation and shareholding records: in line with financial and regulatory requirements (typically 6–7 years).
• Analytics data: anonymised or aggregated after two years.

8. Your Rights

Under UK GDPR, you have the right to:

• Access, correct, or request deletion of your personal data.
• Restrict or object to how your data is processed.
• Withdraw consent for communications such as newsletters and event updates.
• Request data portability in a machine-readable format.

To exercise any of these rights, please contact us at data@theswanwindsor.co.uk.

You also have the right to lodge a complaint with the Information Commissioner’s Office (ICO). Exercising your rights will not result in any disadvantage or discrimination.

9. Security

Access to personal data is restricted to authorised individuals, and we use secure hosting, strong access controls, and encrypted connections where appropriate.

10. Children’s Privacy

We do not knowingly collect personal data relating to children under the age of 13. If you believe that personal data relating to someone under the age of 13 has been collected, please contact us so we can correct or delete the information at data@theswanwindsor.co.uk.

11. Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in legislation or our practices. Any updates will be published on our website along with a revised “Last Updated” date.

12. Contact Information

For any questions or concerns regarding this Privacy Policy or how your data is handled, please contact:

Swan Clewer Community Interest Company (CIC) via info@theswanwindsor.co.uk

Data Protection Contact: Swan Clewer CIC Board via data@theswanwindsor.co.uk 

Swan Clewer Community Interest Company Registration Number: ZB220272

Last Updated: April 2026