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Privacy Policy 
Swarm Organisation

Date: Februari, 2020

At Swarm Organisation B.V. we always strive to keep things as simple and straightforward as possible, certainly when it’s about policies and legal items.  We want you to understand what information we collect, how we use it, and what choices you have. To know everything well, you evidently should read the full policy. But we understand that you just like to use the website and don’t spend hours reading lengthy and complicated legal stuff. So here is a brief summary of the most important items we believe you should know.


Your personal data will not be sold to anyone. 


  • It is completely up to you to decide what you want to share with us. The data that you share by visiting and using our website, is the only data we see. You are even allowed to use a pseudonym, if you like.

  • You may choose to share additional information with us by creating an account. But, even without logging in, we will receive some information from you. This is mainly about the type of device you’re using and your IP address. We may use such information for keeping our website secure and functional.

  • You may request to receive our newsletters, updates or your account details. You can delete all your info entirely at any time. If you want a copy of the information you’ve submitted, please write us a mail and we’ll gladly provide it. We will however always need to make absolutely sure you are who you say you are. 

  • We use your answers to our Swarm Scan TM to determine what the overall properties and challenges of your organisation are, and how you relate to that organisation. You’re free to decide which tests to take or programs to follow.

  • If you have any questions or comments about our policy, please don’t hesitate to get in touch!


What Information do we collect

We store and use only the information you share on our website. Of course, we store your e-mail address to communicate with you. But we also store any other information you choose to enter on the website. You cannot post personal information of another person on our website, unless you have that person’s explicit consent to both the disclosure and storing of this data as defined in this privacy policy. This is your responsibility.

When you purchase something on our website, we must collect payment and tax information, contact and delivery information and details of what you bought. Like most websites do, we may also store some technical information about your website use. Such information may include the device you use, your visits to our website, browser type and IP address. We may also ask you to use cookies which help us to store and retrieve your login status, Swarm Scan TM results and website settings. Some of the cookies are account-specific while others are not. 


More about cookies

Some of the functionality on our website requires us to use cookies. By using our website, you consent to our use of cookies as described in this policy. Some cookies we use will remain on your device. These so called “persistent” cookies will stay on your device until deleted or until they reach a specified expiry date. We use other cookies to make our website to ‘recognise’ you. These cookies will keep track of your preferences on our website. Like most websites, we use Google Analytics to monitor the use of our website. This third-party service may use its own cookies to collect technical data about your internet behaviour and used devices. For details about this, please read Google’s privacy policy. You can also decide to reject this tracking at any time. Most browsers give you the option to reject or allow cookies. But please note that blocking cookies may have a negative influence on the functionality of a website, including ours.


Why certain information needs to be provided by you

Contact - and other relevant information, is sometimes required so we can communicate with you and provide our website services. At the point of collecting information, we’ll inform you about what information we need from you. Evidently, you may deny us this information but that may cause that we are unable to provide services that need such information. 


How we use the collected information

We use the collected information to deliver personal content and services to you. Therefore, it is necessary for us to use your information to:

  • present your Swarm Scan TM results

  • ensure the security of your account 

  • send your account information (i.e. password recovery e-mails, etc.)

  • help you connect with other members 

  • respond to your questions or complaints


This information is necessary for us because it enables us to make our services and content more relevant to you. But we also have an interest to maintain a good relationship with you, by improving our website and protecting both you and other users. Therefore, we also use your information to:

  • conduct analytics on how you use our website so we can optimize our service to better fit your needs

  • improve our website and develop new functionalities

  • conduct internal analysis and scientific / statistical research to improve our Swarm Scan TM tool 

  • keep the website secure and prevent fraud 

  • keep both you and other users safe, this may include working with law enforcement

  • verify compliance with the terms and conditions governing the use of the website


While our interests cover a lot of what we do, there may be circumstances where legal grounds determine how we process your personal data, i.e.:

  • where we explicitly require your consent for the processing of such data

  • where we provide services to you as a member – in which case we’ll process your data in accordance with our contract with you (see Terms and Conditions of Use). 

  • where other (very rare) legal grounds apply


Finally, in addition to what we discussed above, we’ll only use your information with your consent, i.e.:

  • to send you e-mail newsletters, if you’ve specifically agreed to receive them

  • where the Swarm Scan TM, for which you’re supplying us with personal data, relates to “special category” personal data


Please note that you may withdraw your consent at any time. Where you supply us with special category personal data we may further process this data for research purposes – this data will always be anonymized so that it ceases to be personal data. In this case we’ll also rely on Article 9.2(j) of the General Data Protection Regulation (GDPR) to the extent the processing of personal data is involved. As a general rule, we won’t provide your personal information to any third parties for the purpose of direct marketing by those parties.


Where your information may reside

The Swarm Organisation website constitutes a worldwide digital service. In order to operate our website and make our services available online, we need to work with several providers, that sometimes are located outside the European Economic Area (EEA). Also, some of our staff operates outside the EEA. This means that your personal data may be transferred and/or located outside the EEA at any point in time. It is important to realise that some of such countries may have different protection laws than to those in force in the EEA.


It is virtually impossible to guarantee 100% secure data protection. But we’ll ensure that the transfer of personal information will be subject to the appropriate or suitable relevant safeguards as permitted under the GDPR. These measures are designed to help safeguard your privacy rights and give you remedies in the unlikely event of a misuse of your personal information. These are third party providers may be exposed to your information, if necessary:

  •, host and editor engine provider for our website

  • WIX data, database for our members site

  • WIX shout-out, e-mail marketing engine to reach prospects and our members

  • Google Analytics, to analyse the performance of our website as well as the behaviour of our visitors


We’ve listed our third party providers because we like to be as transparent as possible. In reality, “sharing” is a generous term when it comes to us transferring your information outside our company.  We use all reasonable security and access control measures to secure our accounts on third party websites and the data stored therein. Keep in mind that information you publish on our website (such as your profile name or posts) may be available around the world. We can’t prevent the use or misuse of such information by others.


What information can you manage

If you have an account on our website, you can use the ‘your account’ section to change most of your personal details. For instance, you can:

  • update your e-mail address;

  • edit your profile name or make it private

  • manage instant notifications

  • delete your profile


If you choose to remove your profile, we will anonymize your user record, i.e.:  your e-mail address, name, age, etc. However, we can’t remove your discussions, posts and message to other members. We also can’t remove your responses to our Swarm Scan TM and log records. This data needs to remain for a number of valid reasons. If you choose to remove your profile, make sure you first save or retrieve all data from our site that you want to keep. We will have no possibilities to recover your data.



How your Information is shared

Anyone can see your public profile. And that profile will show your user name, any personal details you like to share and the posts you share with others. In the overview section of your account, you can see what others see from your profile. 

If you post content anywhere on our website, you should assume that anyone will be able to read that information, except when you limited it to yourself or a specific user (i.e., in private messages). 

You also have to assume that the professionals behind the Swarm Organisation website, have access to your information because they need this information to manage the system. And this may apply to all companies under the Swarm Organisation organisation. Furthermore, there may be situations where we may need to reveal some of this information, i.e.:

  • where we’re obliged by law or legal proceedings

  • in case of an acquisition, merger, reorganisation or similar situation 

  • in any case where we believe you or someone else is in immediate physical danger

But as a general rule, we don’t share your personal information with any third parties.


How long do we keep your information

Your information is only retained by us for as long as we need it to deliver services to you and fulfil the purposes described in this policy. Or as otherwise described in our Terms and Conditions of Use. Or as required by law. Some examples of certain data and their periods of retention:

  • payment and order data – 10 years

  • activity logs, minus the above – 1 year

  • transient activity records, such as e-mail invites or password reset requests – 3 months;

  • account details – unlimited

  • content such as comments or forum posts – unlimited.

We’ll regularly delete accounts that don’t show activity for more than two years.


When we no longer need it to comply with legal or regulatory obligations, we’ll remove your information entirely from our systems under conditions described in this policy.


Information from children

Conform our Terms & Conditions of Use, we don’t allow the use of our website for children under 15 years, or any higher age required by local laws. Parents that discover their child using our website, are strongly requested to get in touch with us. Swarm Organisation BV does not have the resources to track or monitor parental consent. It is therefore the responsibility of parents to monitor your child’s behaviour. If for any reason we believe a child under 15 is using our website, we will block the account immediately.  


Request to access your information

The GDPR allows you a number of important rights free of charge, i.e.:

  • that we are fair in how we use and process your information and give ample transparency about it, hence this Privacy Policy

  • that we give you full access to your personal information

  • that we correct any mistakes in the information which we hold from you

  • that we erase your personal information if requested 

  • that we deliver your personal information in a structured, commonly used and machine-readable format if requested

  • that you may object to processing of personal information for direct marketing

  • that you may object to automated means of decision making which may produce legal effects concerning you

  • that you may restrict our processing of your personal information

  • that you may withdraw your consent to our processing 

  • that you have the right to issue a complaint with a supervisory authority


Please send us an e-mail us if you want to exercise any of the above mentioned rights. Evidently we will have to make sure your request is legitimate and only about your personal data.


Securing your information

As said before, a 100% guaranteed security of data is simply an impossible promise. So, at any time always think twice before you post private or sensitive data. Swarm Organisation BV strives to prevent the loss and misuse of your personal information, within technical and organisational limits. We will use all reasonable available systems and methods to secure your data.


How to contact us

The best way to get in contact with us is by using our web contact form. Swarm Organisation BV is still a small organisation with limited resources bu we always strive to respond within 48hrs. 

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