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SWARM64 AS, Parkveien 41 B, 0258 Oslo, Norway (hereinafter “SWARM64”, “we” or “us”) operates the website under the domain www.swarm64.com (the “Website”).

SWARM64 protects the privacy of all users and strictly complies with all applicable data protection provisions, including the European General Data Protection Regulation (Datenschutzgrundverordnung) (“GDPR”) and the German Federal Data Protection Act (Bundesdatenschutzgesetz).

The following Privacy Policy informs about the processing of data in case you use our Website or apply for a job with SWARM64.

1) Accessing our website
When you call up our website, your browser will transfer certain data to our web server. This is done for technical reasons so that we can make the information you request available. In particular, the following data are collected, briefly stored and used:

  • • IP address
  • • Date and time of access
  • • Time zone difference to Greenwich Mean Time (GMT)
  • • Content of request (specific site)
  • • Browser, language settings, version of browser software operating system and surface

2) Processing of Data in Case of Communication towards us
Due to our statutory obligation under § 5 para. 3 of the German Telemedia Act (Telemediengesetz), the Website contains information which makes it possible to contact us quickly in electronic form and to directly communicate with us. If you decide to contact us, for example via e-mail or via the contact form or via a free trial request, the personal data you transmitted is automatically stored in order to process your request. The legal basis for such processing and storage is Art. 6 para. 1, lit. f) GDPR. The data you communicated will not be transferred to third parties. It will only be stored as long as we need to deal with your request (e.g. to answer your question).

3) Use of Log Files in Case of Errors
When you visit the Website, SWARM64 may collect the following usage data upon a crash or other malfunction of the Website and sends them to an internal logfile: anonymized IP address, browser information, computer information, network information. SWARM64 uses such data only to detect or to eliminate errors that prevent the Website from operating properly. The legal basis for such processing and storage is Art. 6 para. 1, lit. f) GDPR.

4) Use of Google Analytics Browser Cookie
This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Analytics, a web analytics service provided by Google, Inc., 1600 Amphitheatre Parkway, Mountain View, CA 94043, USA (“Google”).]
Google Analytics enables the website operator to analyze the behavior of website visitors. The website operator receives various usage data, such as page views, length of stay, operating systems used and the geographical origin of the user. This data may be summarized by Google in a profile that is assigned to the respective user or their device.
Google Analytics uses technologies that enable the user to be recognized for the purpose of analyzing user behavior (e.g. cookies or device fingerprinting). The information collected by Google about the use of this website is usually transmitted to a Google server in the USA and stored there.
The storage of Google Analytics cookies and the utilization of this analysis tool are based on Art. 6 Sect. 1 lit. f GDPR. The operator of this website has a legitimate interest in the analysis of user patterns to optimize both, the services offered online and the operator’s advertising activities. If a corresponding agreement has been requested (e.g. an agreement to the storage of cookies), the processing takes place exclusively on the basis of Art. 6 para. 1 lit. a GDPR; the agreement can be revoked at any time.
The data transfer to the USA is based on the standard contractual clauses of the EU Commission.
Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/.

IP anonymization
On this website, we have activated the IP anonymization function. As a result, your IP address will be abbreviated by Google within the member states of the European Union or in other states that have ratified the Convention on the European Economic Area prior to its transmission to the United States. The full IP address will be transmitted to one of Google’s servers in the United States and abbreviated there only in exceptional cases. On behalf of the operator of this website, Google shall use this information to analyze your use of this website to generate reports on website activities and to render other services to the operator of this website that are related to the use of the website and the Internet. The IP address transmitted in conjunction with Google Analytics from your browser shall not be merged with other data in Google’s possession.

Browser plug-in
You can prevent Google from collecting and processing your data by downloading and installing the browser plug-in available under the following link:
https://tools.google.com/dlpage/gaoptout?hl=en.

You can find more information on how Google Analytics handles user data in the Google Privacy Policy:
https://support.google.com/analytics/answer/6004245?hl=de.

Objection to the recording of data
You have the option to prevent the recording of your data by Google Analytics by clicking on the following link. This will result in the placement of an opt out cookie, which prevents the recording of your data during future visits to this website: Google Analytics deactivation.
For more information about the handling of user data by Google Analytics, please consult Google’s Data Privacy Declaration at: https://support.google.com/analytics/answer/6004245?hl=en.

Data Processing Agreement with Google Analytics
We have concluded a data processing Agreement with Google and fully implement the strict requirements of the German data protection authorities when using Google Analytics.

Archiving period
Data on the user or incident level stored by Google linked to cookies, user IDs or advertising IDs (e.g. DoubleClick cookies, Android advertising ID) will be anonymized or deleted after 14 months. For details please click the following link: https://support.google.com/analytics/answer/7667196?hl=en

5) Newsletter
If you would like to subscribe to the newsletter proposed on our website, we will need from you an e-mail address as well as any information that allow us to verify that you are the owner of the e-mail address provided and consent to the receipt of the newsletter. No further data shall be collected or shall be collected only on a voluntary basis. We shall use such data only for the sending of the requested information and shall not share such data with any third parties.

The processing of the information entered into the newsletter subscription form shall occur exclusively on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke the consent you have given to the archiving of data, the e-mail address and the use of this information for the sending of the newsletter at any time, for instance by clicking on the “Unsubscribe” link in the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place to date.

The data deposited with us for the purpose of subscribing to the newsletter will be stored by us until you unsubscribe from the newsletter and deleted from the newsletter distribution list after you unsubscribe from the newsletter. Data stored for other purposes with us remain unaffected.
After you unsubscribe from the newsletter distribution list, your e-mail address may be stored by us or the newsletter service provider in a blacklist to prevent future mailings. The data from the blacklist is used only for this purpose and not merged with other data. This serves both your interest and our interest in complying with the legal requirements when sending newsletters (legitimate interest within the meaning of Art. 6 para. 1 lit. f GDPR). The storage in the blacklist is indefinite. You may object to the storage if your interests outweigh our legitimate interest.

6) MailChimp with deactivated success measurement
This website uses the services of MailChimp to send out its newsletters. The provider is the Rocket Science Group LLC, 675 Ponce De Leon Ave NE, Suite 5000, Atlanta, GA 30308, USA.

MailChimp is a service that, among other things can be deployed to organize the sending of newsletters. When you enter data for the purpose of subscribing to a newsletter (for example your e-mail address), the information is stored on MailChimp servers in the United States. We have deactivated the success measurement of Mailchimp, so Mailchimp will not evaluate your behaviour when opening our newsletter.

In case you do not want MailChimp to receive your data, you must unsubscribe from the newsletter. There is a link provided for you to do this in every newsletter message.

The data is processed based on your consent (Art. 6 Sect. 1 lit. a GDPR). You may revoke any consent you have given at any time by unsubscribing from the newsletter. This shall be without prejudice to the lawfulness of any data processing transactions that have taken place prior to your revocation.

The data transfer to the USA is based on the standard contractual clauses of the EU Commission. Details can be found here: https://mailchimp.com/eu-us-data-transfer-statement/ and https://mailchimp.com/ legal/data-processing-addendum/#Annex_C_-_Standard_Contractual_Clauses.
We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in the USA. For example, US companies are obliged to surrender personal data to US Authorities without you as the person concerned being able to take legal action against this. It cannot therefore be ruled out that US authorities (e.g. secret services) process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence on these processing activities.

For more details, please consult the Data Privacy Policies of MailChimp at: https://mailchimp.com/legal/terms/.

We have executed a “Data Processing Agreement” with MailChimp, in which we mandate that MailChimp undertakes to protect the data of our customers and to refrain from sharing it with third parties.
For more details, please consult the Data Privacy Policies of MailChimp at: https://mailchimp.com/legal/terms/.

7) AutopilotHQ
We use “Auto Pilot” on our website, a service provided by AutopilotHQ, Inc., 140 2nd Street, 5th Floor, San Francisco, CA, 94105, USA (hereinafter referred to as: “Auto Pilot”). Auto Pilot stores and processes information about your user behavior on our website on its servers in the United States. Auto Pilot uses, among other things, cookies for this, i.e. small text files that are stored locally in the cache of your browser on your end device and that enable your use of our website to be analyzed.

We use Auto Pilot for marketing and optimization purposes, in particular to analyze the use of our website and to continuously improve individual functions and offers as well as the user experience. Through the statistical evaluation of user behavior, we can improve our offer and make it more interesting for you as a user. This also includes our legitimate interest in the processing of the above data by the third party provider. The legal basis is Art. 6 para. 1 lit. f GDPR.

You can prevent the installation of cookies by deleting existing cookies and deactivating the storage of cookies in the settings of your web browser. We would like to point out that in this case you may not be able to use all functions of our website to their full extent. You can object to the collection and forwarding of personal data or prevent the processing of this data by deactivating the execution of JavaScript in your browser. You can also prevent the execution of JavaScript code altogether by installing a JavaScript blocker (e.g. https://noscript.net/ or https://www.ghostery.com). We would like to point out that in this case you may not be able to use all functions of our website to their full extent.

Third-party information: AutopilotHQ, Inc., 140 2nd Street, 5th Floor, San Francisco, CA, 94105, USA

Further information from the third-party provider on data protection can be found on the following website: https://autopilothq.com/privacypolicy.html.

8) Salesforce.com
We use the CRM system “Salesforce.com” from the provider Salesforce.com 415 Mission Street, 3rd Floor San Francisco, CA 94105 United States – hereinafter referred to as “Salesforce” – as a cloud service; i.e. the data is processed in data centers at Salesforce. Salesforce primarily stores personal data in the United States.

Salesforce uses the user data exclusively for the technical processing of inquiries.

We use the system in particular to manage customers and prospects (leads) in order to be able to process user inquiries faster and more efficiently. This system is used on the basis of our legitimate interest in accordance with Article 6 Paragraph (1) lit.f GDPR.

Users can find more information on data protection in the Salesforce data protection declaration at https://www.salesforce.com/de/company/privacy/.

9) Data transfer to the USA
We would like to point out that no level of data protection comparable to that in the EU can be guaranteed in the USA. For example, US companies are obliged to surrender personal data to US Authorities without you as the person concerned being able to take legal action against this. It cannot therefore be ruled out that US authorities (e.g. secret services) process, evaluate and permanently store your data on US servers for monitoring purposes. We have no influence on these processing activities.

10) Processing of Data in case of a Job Application
a. Application Data
If you apply for a job with SWARM64, we may ask you in a first application round to provide at least your first name, last name, email address, CV (including your workplaces and education) and a cover letter stating your motivation, as well as the certificates, employer references or other documents that are necessary to verify or clarify skills and experiences you mention in your CV and/or cover letter.

The legal basis for such processing and storage is Art. 6 para. 1, lit. b) GDPR.

If you qualify for our second application round, we may ask for further information, such as your residence/address in order to determine your VISA needs, your desired annual salary, the prospective starting date, how you became aware of the job position, and which programming languages you master.

Other than that, we receive the data that you decided to share with us, such as your phone number, Skype ID, URL of your LinkedIn profile, URL of your Stack Overflow page, website or Github account, information on how you became aware of the position or any other personal data you deem appropriate and necessary to provide in the course of your application. If you provide your LinkedIn, Stack Overflow, Github or website URL, our recruiters may look at the information provided thereunder.

All data you shared in the course of your job application with us are hereinafter referred to as “Application Data”.

b. Processing of Application Data and Use of External Recruiters
We use your Application Data exclusively for the purposes of contacting and assessing your qualifications with regard to the position you applied for. Your Application Data will be transmitted only to selected employees of SWARM64 who are responsible for the hiring process. Only if necessary to evaluate your technical skills, selected questions will be delegated to our employees in technical positions.

We may also use external recruiters to evaluate your application. These recruiters work strictly based on our instructions within the process described above. We have concluded data processing agreements with such recruiters.

c. Use of Applicant Talent Pool
Only if you explicitly agreed that we store your Application Data in our talent pool, we store it for a longer period in order to determine whether you also fit into further open job positions (i.e. in another field or job positions that only open later) and contact you on such further job offers.

The legal basis for such processing and storage is Art. 6 para. 1, lit. a) GDPR.

d. Retention Periods for Applicant Data
Your application documents will be automatically deleted at the latest six months after completion of the application procedure. If your application is followed by the conclusion of an employment contract, your data may be processed for the purpose of the usual organizational and administrative process, in compliance with the relevant legal regulations.

If you have consented to be added to our talent pool, we store your Application Data as long as you do not withdraw such consent.

11) Your Rights under the GDPR
Under the EU General Data Protection Regulation, you are entitled to

  • • withdraw your consent to process your data granted towards SWARM64 (e.g. the consent to store your data in a talent pool) by contacting us via the contact details shown below;
  • • request which data SWARM64 processes and stores. However, in cases where we only stored anonymized use profiles (such as the ones generated by the use of the Google Analytics cookie), we cannot match such profiles with your individual details such as your name or address. Therefore, we can only fulfil your request if you grant us the information necessary to conduct such matching. We will inform you if fulfilment of your information request is only possible with such further information;
  • • request – under the statutory required preconditions – the completion, correction or deletion of your data;
  • • receive the necessary data in a structured, common and machine readable format as far as processing of your data is based on consent towards SWARM64; and
  • • object to any processing of data which is based on Art. 6 para. 1 lit. e) (e.g. when you contacted us via our email regarding problems with our Website) or Art. 6 para. 1 lit. f) GDPR (e.g. regarding the Google Analytics cookie), as far as the requirements of Art. 21 para. 1 GDPR are met (i.e. on grounds relating to your particular situation).

12) Right to Complaint
Additionally, you have the right to lodge a complaint with the data protection supervisory authority if you think that the processing of your data violates data protection law. You may approach the authority competent for your data controller or any other authority which will forward the request.

Data Protection Supervisory Authority
You may address questions and complaints to the Data Protection Supervisory Authority in charge:
Berliner Beauftragte für Datenschutz und Informationsfreiheit
Friedrichstr. 219
10969 Berlin
Telefon: 030 13889-0
Telefax: 030 2155050
E-Mail: mailbox@datenschutz-berlin.de

13) Information and Contact
You can contact SWARM64 under Parkveien 41 B, 0258 Oslo, Norway or under our German branch SWARM64 Hive, Ullsteinstr. 120, Neubau Turm C, 12109 Berlin
Germany, as well as via email webcontact@swarm64.com, or by using the form available under https://www.swarm64.com/contact.

14) Amendment of Privacy Policy
We may update our Privacy Policy from time to time and we will publish these updates on our website. They become effective upon publication. So we recommend you regularly visit the site to keep yourself informed on possible amendments.
This Privacy Policy was last updated on 1st July 2021.