Privacy Notice
How your personal data is collected and used
Effective date: 11 August 2026
Data Controller: HTC How To Company XYZ Limited, registered in Ireland with the Companies Registration Office, Company No. 741159
Location: Swords, Co. Dublin, Ireland
Contact: info@swordslive.ie
1. Who Is Responsible for Your Data
For this Privacy Notice, “HTC” means HTC How To Company XYZ Limited.
HTC owns and operates Swords Live and MapClick. Swords Live and MapClick are not separate legal entities.
Where this Notice refers to Swords Live or MapClick, HTC is the organisation responsible for the relevant processing of personal data unless another organisation is specifically identified as responsible.
This Notice explains how HTC collects and uses personal data when you use Swords Live, MapClick or related HTC services.
Ownership and permitted use of content you contribute are dealt with separately in the Swords Live Terms of Use.
2. What Personal Data We Collect
We collect only information reasonably needed to operate, protect and improve the Service.
Depending on how you use Swords Live or MapClick, this may include:
- account information, such as your email address and account identifier;
- Contributions, including text, photographs, audio, video, reports, observations, corrections and other material you submit;
- location information that you choose to provide or allow your device to provide;
- contribution information, including timestamps, location, authorship, provenance and contribution history;
- AI interactions, including prompts, messages, images or other information you submit to AI or conversational features;
- technical information, including IP address, device or browser information, identifiers, logs and timestamps;
- usage information about how the Service is used;
- communications you send to HTC, including support, contributor or other enquiries; and
- derived or inferred information where it relates to an identifiable user.
Swords Live may use random or pseudonymous identifiers rather than your name.
A pseudonymous identifier can still be personal data where it can be connected to an identifiable person.
Information that has been genuinely and irreversibly anonymised so that an individual can no longer be identified is not treated as personal data.
3. Why We Use Personal Data
HTC may process personal data to:
- provide Swords Live and MapClick;
- create and manage accounts;
- receive, publish and maintain Contributions;
- maintain provenance and contribution history;
- provide location-based features;
- process civic or other reports you ask us to submit;
- operate search, retrieval, recommendations and AI features;
- generate embeddings, classifications, summaries and other computational outputs;
- improve, test and develop Swords Live, MapClick and their AI and machine-learning systems;
- maintain the security and integrity of the Service;
- prevent fraud, abuse and unauthorised access;
- diagnose technical problems and monitor performance;
- communicate with you about the Service;
- enforce the Terms of Use;
- establish, exercise or defend legal rights; and
- comply with legal obligations.
HTC does not sell your personal data.
4. Our Legal Bases
HTC only processes personal data where there is a lawful basis for doing so.
Depending on the processing, HTC may rely on:
Contract
Where processing is necessary to provide a Service you have requested or to perform our agreement with you.
This includes operating accounts, accepting Contributions and providing features you choose to use.
Legitimate interests
HTC may process personal data where reasonably necessary for legitimate interests including:
- operating and improving Swords Live and MapClick;
- maintaining useful and reliable local records;
- preserving provenance and system integrity;
- developing and evaluating technology;
- protecting HTC, users and the Service;
- preventing misuse and fraud; and
- understanding and improving how the Service performs.
HTC will not rely on legitimate interests where those interests are overridden by your rights and freedoms.
Consent
Where a particular use requires your consent, HTC will ask for it.
You may withdraw consent at any time. Withdrawal does not make processing carried out before withdrawal unlawful.
Legal obligation
HTC may process or retain information where required by law.
5. Contributions, Public Records and MapClick
Some information submitted to Swords Live is intended to become part of a public, civic, operational or historical record.
If you contribute information, the Contribution itself, its location, date, source or other provenance information may therefore be publicly visible where that is part of the feature you are using.
MapClick may also process Contributions and other information to create:
- embeddings;
- indexes;
- classifications;
- resolved records;
- summaries;
- relationships;
- statistics;
- machine-generated metadata;
- analytical outputs; and
- other Derived Outputs.
A Derived Output may still be personal data if it can be linked to an identifiable person.
Where a Derived Output has been genuinely anonymised and no longer identifies anyone, it is no longer personal data.
The intellectual-property position concerning Contributions and Derived Outputs is governed by the Terms of Use.
6. AI and Automated Processing
Swords Live and MapClick use AI, machine learning and other automated processing.
Information you submit to an AI feature may be processed to:
- answer your request;
- understand or classify content;
- extract information from photographs or other media;
- generate metadata or summaries;
- retrieve relevant information;
- improve the Service; and
- develop, evaluate or improve HTC’s AI and machine-learning systems.
Automated processing may create inferences or other information from material supplied to the Service.
HTC does not treat an automated or AI-generated output as automatically accurate simply because it was produced by a computer.
Where personal data is processed through an external AI or technology provider acting for HTC, that provider receives only the information reasonably necessary to provide the relevant service and is subject to the applicable data-processing arrangements.
7. Sharing Personal Data
HTC may share personal data where reasonably necessary with:
- hosting, database, storage and infrastructure providers;
- email and communications providers;
- AI and technology providers;
- security, monitoring and technical service providers;
- professional advisers where required;
- public bodies where you use a feature intended to send information to them;
- law-enforcement, regulatory or other authorities where legally required; and
- a successor or purchaser where Swords Live, MapClick or the relevant HTC business is transferred or reorganised.
HTC does not give third parties personal data simply so they can market their unrelated products to you.
Civic reports
Where you choose to submit information through a Swords Live feature intended to make a report to a public body, HTC may send the information necessary to make that report.
For example, a Swoop report intended for Fingal County Council may be transmitted to the Council.
Once personal data has been received and processed by another organisation for its own purposes, that organisation may become a separate data controller and its own privacy notice will apply to that processing.
8. International Processing
HTC uses external technology and service providers and does not promise that all processing will always take place exclusively inside Ireland or the European Economic Area.
Where personal data is transferred outside the EEA, HTC will use a lawful transfer mechanism where required.
Depending on the destination and provider, this may include:
- an applicable European Commission adequacy decision;
- Standard Contractual Clauses; or
- another transfer mechanism permitted by data-protection law.
Additional safeguards may be used where appropriate.
You may contact HTC for information about safeguards applying to an international transfer involving your personal data.
9. How Long We Keep Information
HTC does not keep every category of personal data for the same period.
Retention depends on why the information exists.
In particular:
- account information is generally retained while the account remains active and for a reasonable period afterwards where required for security, legal or administrative purposes;
- public, civic, operational and historical Contributions may be retained long-term because maintaining history, provenance and the integrity of the record is part of the purpose of the Service;
- contribution and provenance records may remain where necessary to explain the history or source of a MapClick record;
- technical and security logs are retained only for the period reasonably required for security, diagnostics, abuse prevention and operational purposes, unless a longer period is required in connection with an incident or legal obligation;
- communications and support records are retained for as long as reasonably necessary to deal with the matter and any related legal or operational requirements; and
- information may be retained where necessary to establish, exercise or defend legal rights or comply with law.
Personal data will not be kept indefinitely merely because storage is technically possible.
Deletion of an account or Contribution does not necessarily require deletion of information that HTC has a separate lawful reason to retain.
Where information has been irreversibly anonymised, HTC may retain and use the anonymised information without a personal-data retention period.
10. Children, Schools and Clubs
Swords Live may work with schools, youth groups, sports clubs and other organisations on local, educational, environmental and civic activities.
HTC recognises that children require additional protection when their personal data is processed.
Where children participate, HTC will aim to collect only the personal data reasonably necessary for the activity.
School and club activities
Where participation is organised through a school, club or other organisation, HTC will make clear what information is being collected, what it will be used for, whether anything will be public, and the respective roles of HTC and the organisation.
Depending on how an activity is organised, HTC and the participating organisation may each be responsible for different parts of the processing or may jointly determine how particular personal data is used.
Contributions by children
Children may participate in activities such as:
- mapping or verifying local places and public assets;
- tree, biodiversity or environmental projects;
- civic or community projects;
- trails and local-history activities;
- photographs and observations; and
- other approved contribution programmes.
HTC does not require a child’s identity to be made public merely because the child contributes something.
Where reasonably possible, public Contributions from children will be associated with the place, object or activity rather than publicly identifying the individual child.
HTC will take particular care with:
- names and contact details;
- photographs or video identifying children;
- voice recordings;
- precise personal location information;
- account information; and
- information that could identify a child when combined with other information.
A location attached to a tree, public asset, civic report or other MapClick record does not need to identify the child who contributed it.
Consent and permission
Where HTC relies on consent for processing that legally requires parental or guardian authorisation, HTC will obtain that authorisation.
Where participation is arranged through a school, club or other organisation, the appropriate permission and data-protection arrangements may instead form part of that organised activity.
Children should also be given clear information appropriate to their age about what will happen to information they provide.
HTC may require a parent, guardian, school, club or other authorised adult to approve particular contribution, account, upload or location features.
HTC will not rely solely on a child’s acceptance of an online checkbox where additional adult authorisation is reasonably or legally required.
Publicity and photographs
Participation in a Swords Live activity does not automatically mean that a child’s name, photograph or other identifying information may be used for publicity.
Where separate permission is required for identifiable photographs, video, publicity or similar use, it will be dealt with separately from ordinary participation in the activity.
Children’s rights
Personal data relating to a child remains the child’s personal data.
Parents or guardians may contact HTC regarding a child’s personal data, but the child’s own rights and interests will also be considered.
Questions or requests concerning children’s data may be sent to:
11. Your Data Protection Rights
Depending on the circumstances, you may have the right to:
- obtain access to your personal data;
- correct inaccurate personal data;
- request deletion;
- restrict processing;
- receive certain personal data in a portable form;
- object to processing based on legitimate interests;
- withdraw consent where processing is based on consent; and
- raise concerns about automated decision-making where applicable.
These rights are not absolute. For example, HTC may lawfully retain information despite a deletion request where there is another legal basis or obligation requiring retention.
Requests can be made to:
HTC will normally respond within one month.
Where a request is particularly complex or numerous, the response period may be extended where permitted by law. HTC will tell you if that happens.
You may also make a complaint to the Data Protection Commission in Ireland.
12. Security
HTC uses appropriate technical and organisational measures intended to protect personal data.
These include measures relating to:
- access control;
- authentication;
- encryption in transit;
- system and infrastructure security;
- limiting internal access;
- backups and recovery; and
- monitoring and responding to security issues.
No internet-connected system can be guaranteed to be completely secure.
If HTC becomes aware of a personal-data breach, it will deal with the breach in accordance with applicable data-protection law.
13. Changes to This Notice
Swords Live and MapClick continue to develop, so the ways in which information is processed may change.
HTC may update this Privacy Notice when the Service, technology, suppliers, processing activities or law changes.
The current version and effective date will be published with the Notice.
Where required by law, HTC will provide additional notice or seek consent before beginning a materially different use of personal data.
14. Data Controller
HTC How To Company XYZ Limited
Registered in Ireland with the Companies Registration Office
Company No. 741159
Swords, Co. Dublin, Ireland
Email: info@swordslive.ie
HTC is the data controller for personal data processed through Swords Live and MapClick except where another controller is specifically identified.
© How To Company XYZ Limited. Original and derived Swords Live content owned by HTC is licensed under CC BY 4.0, unless otherwise stated.
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