This privacy policy (“Policy“) sets out how Swind Work processes information collected via our Platform and on our website at www.swind.work (the "Website"). It also sets out our practices regarding our use of such information, the steps we take to protect it, as well as the choices and rights that consumers (“users“, “you“, “your“) have regarding how we collect and process information about them.
In this Policy, we use the terms “Swind Work“, “our“, “us” and “we” to refer to Swind Work.
Swind Work is committed to protecting the privacy of consumers when we process information about them via our Platform and the users of our Website. We adhere to applicable industry guidelines, and will continue to review and update our Policy and procedures to ensure the safety and protection of personal information.
Swind Work complies with the DAA Self-Regulatory Principles for Online Behavioral Advertising and their Application to the Mobile Environment, and the 2015 NAI Codes of Conduct. We believe that these programs’ principles help protect individual consumer privacy.
In the course of delivering an ad to you via the Platform, Swind Work does not intentionally collect information that reveals your real-world identity, such as your name, address, phone number, or Social Security Number. Swind Work collects data about your computer or device through the use of cookies, web-beacons and other similar technologies, as explained below. This information is pseudonymous and is not considered to be personal information in many jurisdictions in which we operate. In some other jurisdictions in which we operate, in certain contexts, such information, including Internet Protocol (IP) addresses and other pseudonymous information, may be considered personal information.
The information Swind Work collects includes common information found in every communication sent over the Internet, from which we infer such things as: browser type (e.g., Chrome or Internet Explorer); operating system (e.g., Mac OS or Windows); browser language (e.g., English or Spanish); Internet Protocol (IP) address; Internet Service Provider (e.g., Comcast or Verizon); and mobile advertising identifier, for mobile devices such as smartphones and tablets.
Swind Work may also collect data regarding your interactions with our clients and partners, including your use of our clients’ sites and mobile apps, the sites and apps our clients advertise on, and other pages on the Internet. We may also capture additional data in order to calculate a statistical ID, as described below.
We may also receive Precise Location Data (as defined by the NAI) generated from your use of your mobile device, such as the latitude/longitude coordinates provided by a mobile app publisher or other media supply source in conjunction with the opportunity to purchase advertising inventory. Swind Work may transfer such Precise Location Data to clients and partners, including for use in targeting ads based on the current location of the device. When we process Precise Location Data, the mobile app publisher or other media supply source is responsible for enabling you to provide or withdraw consent with respect to the collection and use of your Precise Location Data.
We and our clients and partners use the information we collect to create data segments, and these data segments are generally based upon your interactions with our clients or other third party media suppliers, such as the websites that you visit and the mobile applications that you use.
We also receive pseudonymous information from third parties, when they choose to provide it to us. This information may include identifiers (like mobile advertising IDs) and interest-based advertising data tied to those identifiers, including segments provided by third-party data providers for our clients to use in targeting ads through the Platform. Swind Work does not use this data to personally identify you.
We use the information that we collect directly and the information that we obtain from third parties to create segments, run analytics, target ads, and measure the effectiveness of ads on behalf of Swind Work’s clients. We also use it to improve our Platform and the products and services that we provide to our clients, and to create new products and services. For these purposes we may share information with our clients, partners and service providers.
Swind Work does not knowingly collect data or create data segments that are based upon what we consider to be sensitive information (for example, we don’t create any data segments to determine credit worthiness, for insurance underwriting or similar purposes, nor do we create segments of EU consumers based on personal data considered to be sensitive in the EU, e.g. information about physical or mental health or condition, sexual orientation, race or ethnic origin, political opinions, religious or similar beliefs).
Like most digital marketing platforms, Swind Work uses mobile advertising identifiers, and other technologies to enhance users’ experiences on the web, to deliver more relevant ads, and for ad delivery and reporting via the Platform.
We use these technologies to help recognize a computer or device so that we and our clients are able to deliver relevant advertising to you, measure the impact of that advertising and better understand and recognize digital media usage patterns.
The types of technologies used via the Platform include:
Cookies – Cookies are small text files that contain a string of characters. Swind Work uses
● cookies to uniquely identify an Internet browser. Certain browsers or browser settings sometimes block cookies, and cookies may not work effectively on some mobile devices. For more information about cookies, please visit
http://www.allaboutcookies.org/.
● Mobile Advertising Identifiers – Mobile advertising IDs (e.g., Apple’s IDFA or Google’s AAID) are unique IDs that are associated with individual mobile devices and that do not reveal your real world identity. They usually are user-resettable
These technologies are used to identify a computer or device within a certain level of confidence that enables the Platform to function and serve more relevant ads.
You may opt out from Swind Work tracking and interest-based advertising at any time through one of the ways described below. If you wish to opt out of Swind Work tracking and interest-based advertising on both internet browsers and mobile applications, you need to opt out separately for each browser or device via the methods described below.
Two Reasons You May Not Want to Opt Out
Advertising supports the free Internet. It is the primary way that most website and app publishers make money in order to produce the content consumers want. Not all advertising shown to consumers is relevant to their interests, though. Interest-based advertising is advertising that tries to make the ads you see more interesting and relevant to you based on the types of sites you visit online and other information that does not personally identify you. We conduct interest-based advertising on our Website, and work with our clients to help them do the same on their websites and apps.
Without interest-based advertising, you will still see ads, but those ads are not likely to have anything to do with products or services you care about. With interest-based advertising, you receive ads and offers that are more likely to be useful to you.
There is also a second benefit to you: companies that create websites and apps rely on the revenue from interest-based advertising to support the rich array of content they produce. Without that revenue, the content would either be unavailable or consumers would have to pay for it.
In general, “opting out” means that you want Swind Work to limit the information it collects and stores about your computer or device and to not target ads that are based on your interests to your browser or device. Your opt-out is only applicable to the Swind Work Platform and does not opt you out from platforms provided by third-party companies. However, you can out from both Swind Work and many third-party companies at once; to do so, please see “Other ways to opt out” below.
If you use multiple browsers, computers or mobile devices and wish to limit the information Swind Work collects and stores or do not wish to receive Swind Work interest-based advertising on any of them, you must opt out from each browser, computer, and mobile device individually. Please note that if cookies are not enabled in your browser, or if you use certain ad-blocking tools, our opt-out mechanism may not work properly. Please also note that deleting your cookies does not opt you out.
When you opt out, we record the opt-out on our servers and in browser environments we will attempt to place an HTTP opt-out cookie onto your computer or device. When you opt out, Swind Work will collect and store information from your browser or device only as needed to honor your opt-out and for limited research and development purposes to improve our browser- and device-recognition technology, which also helps to improve our ability to honor your opt-out. When you opt out, Swind Work also stops targeting interest-based advertising to that browser. Please note that if you clear your cookies, or if you use a different browser or device, you will need to renew your opt-out choice.
You may opt out in mobile app environments using the “AppChoices” mobile application, which you can download to your mobile device from your App Store.
Please note that you will still see ads if you opt out. The ads delivered via Swind Work will just not be as relevant to you. When you opt out, Swind Work will collect and store information from your device only as needed to honor your opt-out and for limited research and development purposes to improve our device-recognition technology, which also helps to improve our ability to honor your opt-out. When you opt out, Swind Work also stops serving interest-based advertising in mobile apps on that device.
You may learn more about interest-based advertising and opt out of interest-based advertising from Swind Work and other online advertising companies that are also members of applicable self-regulatory organizations by visiting their opt-out links:
Network Advertising Initiative (NAI) – http://optout.networkadvertising.org
Digital Advertising Alliance (DAA) – http://optout.aboutads.info/
Digital Advertising Alliance Canada (DAAC) – http://youradchoices.ca/choices
Digital Advertising Alliance EU (EDAA) – http://www.youronlinechoices.com/
DAA AppChoices page – http://www.aboutads.info/appchoices
You may also limit ad tracking in mobile app environments on your device. For the most effective and up-to-date methods for doing so, you should consult instructions provided by those device manufacturers. We offer the following information solely for informational purposes, and we cannot guarantee that the methods below are the most current:
Apple instructions for how to Limit Ad Tracking on devices such as iPhones and iPads
Google instructions for how to express choice on Android devices
Where Swind Work receives a signal to limit ad tracking, we will collect and store information from your device only as needed to honor your choice and for limited research and development purposes to improve our device-recognition technology, which also helps to improve our ability to honor your choice. Where Swind Work receives a signal to limit ad tracking, Swind Work also will not serve interest-based advertising in the mobile app environment of that device.
If you have questions about how to opt out or limit mobile tracking, please contact us at bmsupport@swind.work.
The Swind Work Website, www.swind.work
Swind Work collects personal information on the Website when visitors choose to reveal it to us. For example, when you contact us to request a demonstration of our products or services or to otherwise send us questions, we will collect personal information such as your name and email address. Swind Work uses information from the Website log files to determine how you found out about us, what your interests are regarding our services, and how to further improve our site and our service towards you.
If you create an account on our Website, we will retain your information for as long as your account is active with us or for as long as you are receiving our services. After you have closed your account with us or ceased to use our services, we may retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.
When you sign up for our services on our Website, we will use your name and email address to send newsletters to you. You may choose to stop receiving our newsletter or marketing emails by following the unsubscribe instructions included in these emails or by contacting us via email at privacy@swind.work.
You may also provide us with your personal information on the publicly accessible blogs on our Website. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog or community forum, contact us at privacy@swind.work. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
We display testimonials from satisfied clients on the Website in addition to other endorsements. We will obtain our client’s permission before we place these testimonials on the Website. If you are a client who wishes to update or delete your testimonial, please contact us at privacy@swind.work.
When you sign up for our services on the Website, we may provide your personal information to companies that provide services to help us with our business activities, such as an email service provider to send emails on our behalf or a recruitment partner to process job application data. These companies are authorized to use your personal information only as necessary to provide these services to us.
As is true of most websites, we gather certain information automatically and store it in log files. This information may include IP address, browser type, Internet Service Provider (ISP), referring/exit pages, operating system, date/time stamp, and/or clickstream data. We do not link this automatically collected data to other information we collect about you. We collect information automatically through the use of various technologies including cookies. For further information on the cookies we use on the Website and how you can opt out, please see our Cookie Notice.
This Policy applies solely to the Platform and Website of Swind Work. Swind Work’s Website contains links to other sites, and the ads delivered by the Platform may run on a variety of other sites. Please be aware that Swind Work does not control these third party sites, ads and cookies and is not responsible for the privacy practices of such other sites. We encourage our users to be aware when they leave our Website and to read the privacy statements of third party websites to find out how they collect and use your personal information and to establish whether and for what purpose they use cookies.
Swind Work’s products and services are designed for those 13 years of age and older. We do not knowingly collect personal information from anyone under the age of 13. If we are made aware that we have received personal information from someone under 13, we will use reasonable efforts to remove that information from our records.
Swind Work implements technical and organizational measures to safeguard data in our possession against loss, theft, and unauthorized use, disclosure, or modification. No transmission of data over the Internet, however, is guaranteed to be completely secure. It may be possible for third parties not under the control of Swind Work to intercept or access transmissions or communications unlawfully. While we strive to protect your information, we cannot ensure or warrant the security of any information you transmit to us. Swind Work processes information in a way that is compatible with and relevant for the purpose for which it was collected. To the extent necessary for those purposes, we take reasonable steps to ensure that any information in our care is accurate, complete, current, and reliable for its intended use. If you have any questions about security on the Website or through the Platform, you can contact us at privacy@swind.work.
We may publish or otherwise make public anonymous, aggregate, or summary information regarding campaigns run on behalf of our clients.
We may share information (including personal information):
● With our group companies.
● With clients and partners, where this is necessary in order to operate the Platform and the Website, to provide our products and services, to improve our Platform, products and services and to create new products and services.
● With service providers who help with the operation of the Platform, the provision of our products and services and our business operations. We require our service providers to only use the information that we provide to them in connection with the services they perform for us.
● With third parties when we consider this to be necessary: to establish or protect the legal rights of Swind Work or its employees, agents and contractors, as well as the legal rights of its clients or other third parties; to protect the safety and security of users and visitors to our Website; to protect against fraud; or to comply with the law or legal process.
● When we are required to or allowed to do so by law (for example in response to subpoenas, to comply with a binding court order. legal process, or government requests, including in response to a public authority to meet national security or law enforcement requirements).
If Swind Work sells all or part of its business or makes a sale or transfer of assets or is otherwise involved in a merger or business transfer, we may transfer or assign the information to a third party as part of that transaction.
The information that we collect from you and about you may be transferred to and stored in a country other than your country of residence, such as the USA, which may not offer the same level of protection of personal information as your country of residence. However, we will take contractual and/or other measures to ensure your personal data is protected.
In addition to the above, we adhere to the principles of the EU-U.S. Privacy Shield and the Swiss-U.S. Privacy Shield.
If you are from the European Union or Switzerland and would like to gain access to, or request amendment, correction or deletion of information that Swind Work holds about you, please contact us using the details in the “Contact Us” section below. We will consider and respond to your request in accordance with, as applicable, the EU-U.S. or Swiss-U.S. Privacy Shield, and any applicable laws.
Swind Work acknowledges the individual’s right to access their personal data and will provide you access to the personal information we hold about you to the extent it is reasonably available and allow you to correct, amend, or delete inaccurate information, as required and permitted by applicable law. If you’d like us to correct, amend, or delete any other personal information that you have provided to us, please send your request to us at privacy@swind.work and we will respond to your request within 30 days.
You may request that we cease sending you any marketing communications (including by email and SMS) at any time by notifying us in writing using the contact details provided below or following any “unsubscribe” instructions included in any marketing communications which we send to you.
Swind Work has implemented processes to ensure compliance with this Policy and periodically verifies that the policy is accurate, comprehensive for the information intended to be covered, prominently displayed, completely implemented and accessible, and in conformity with the NAI Code of Conduct. We encourage interested persons to raise any concerns by emailing privacy@swind.work and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.
From time to time Swind Work may revise this Policy. The date of the last update can be found at the top of this Policy. If we make revisions that materially change or affect whether or how we collect or use personal information we will notify you by email (if, as a user of our Website, you have provided us your email address) or by means of a notice on our Website prior to the change becoming effective. Therefore, you should review the Website periodically so that you are up-to-date on our most current policies and practices.
If you have any questions about this Policy, please contact us at privacy@swind.work