Privacy policy.

This Policy on the processing of personal data contains information about when and how your personal data is collected, stored, processed, transferred, used and disclosed when you come into contact with us or use our services, in accordance with Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data, and repealing Directive 95/46/EC (the „Regulation”). Swolv reserves the right to modify the content of this Policy on the processing of personal data at any time.

The Policy on the processing of personal data forms part of the Terms and Conditions, together with the Agreement on the Processing of Personal Data.

While using the services, Swolv may provide links to other sites and/or integration with sites or applications of third parties. Please note that for the use of third-party services, other terms of use and other policies on the processing of personal data apply.

SWOLV S.R.L. („Swolv”) is a company operating in accordance with the laws of Romania, with its registered office at Str. Rocadei, no. 10-12, Camera 2, Et. Parter, Ap. 2, Sector 1, Bucharest, Romania, registered with the Bucharest Trade Register under no. J2026008262002, sole registration code 53813977.

Swolv may process your personal data if you belong to any of the following categories of data subjects:

• users of the services provided by Swolv;
• persons who have sent a request to SWOLV through the contact form, email, telephone or other such means;
• (potential) clients/partners/collaborators, natural persons;
• the legal representatives and/or contact persons within (potential) clients/partners/collaborators, legal entities or natural persons;
• visitors to the website.

Since its establishment, Swolv has had an internal data protection officer (DPO) whom you can contact if you have questions or concerns regarding Swolv' policies or practices on personal data. You can contact the Swolv DPO by email, at the address contact@swolv.ro.

We mainly collect the personal data that you provide to us directly, by completing the form that requests information about our products, on the swolv.ro site or while you visit us or meet with our representatives. Additional information is collected during telephone interviews conducted by our marketing department.

We also collect personal data from you or from your organisation during the execution of contracts.

Our process of collecting personal data may take place through: i) the website, mobile applications, email, digital media or software belonging to third parties, including recruitment portals; ii) contracts, applications, forms, call centre, remote technical support, sales and marketing units, cookies from websites, business cards, telephone, etc.; or iii) face-to-face interviews.

Swolv may process the following categories of personal data, as provided by you in your capacity as a data subject or by the client/partner/collaborator of Swolv within which you carry out your activity and/or by the representative and/or contact person within the client/partner/collaborator of Swolv, by a third party, automatically upon the use of the services provided by Swolv, or as obtained from other sources (public sources or other third-party sources):

• identification data (e.g. first and last name, home address, date of birth);
• contact data (e.g. email address, correspondence address, telephone number);
• data on profession, place of work;
• payment-related data (e.g. information regarding the bank account/credit card);
• testimonials regarding the use of the services;
• information collected automatically during the use of the services, such as the time and date the services were accessed, the IP address;
• information from correspondence (email, fax or any other online or offline means);
• any other information provided by you, where applicable.

It is important that you provide us only with the personal information that is strictly necessary.

Personal data is processed by Swolv for one of the following purposes, as applicable:

• providing the services to you or to the client/business partner/collaborator of Swolv within which you carry out your activity, including, without limitation: ensuring access to services (including the demo version), management of service provision, service maintenance, service invoicing, payment processing, carrying out any communications/notifications prior to or during the use of services and the implementation of contracts, debt recovery or any other operation reasonably necessary for the provision of services and the proper management of contract execution;
• formulating responses to any questions or requests made by you to SWOLV;
• fulfilling the legal obligations incumbent on SWOLV (e.g. the archiving obligation);
• improving and monitoring our site and ensuring its protection and security;
• establishing collaboration with potential clients/collaborators/partners;
• transmitting information about our products/services and/or the activity of SWOLV;
• the recruitment process, as well as, subsequently, if applicable, the conclusion of a contract with SWOLV.

Providing the personal data necessary for the purposes set out above may be mandatory. Refusal to provide us with such data may result in the impossibility of SWOLV to provide the services, to respond to your requests and/or to comply with the legal obligations incumbent on SWOLV.

We will not share your information with any third party outside our organisation, except where this is required by a legal obligation or where it is necessary to execute the contract concluded with you.

Your personal data may be transferred to the following third parties, located in the EU or abroad: audit firms (based on legal requests), consultants, judicial authorities or public authorities, resellers, companies that provide services, suppliers, shareholders and other companies in our group.

Where a transfer abroad is considered, we will ensure that it is made to a country that benefits from an adequacy decision issued by the European Commission or, alternatively, on the basis of approved standard contractual clauses.

Personal data may be processed by SWOLV through the following third parties, as applicable: (i) the email service provider, (ii) the invoicing and subscription software provider, (iii) the web analytics service provider, (iv) the accounting service provider, (v) banks, (vi) the IT service provider, (vii) partners, clients and collaborators, (viii) public authorities.

Personal data will be stored by SWOLV: (i) for the duration of the Terms of Use and the Agreement on the Processing of Personal Data and, subsequently, in accordance with legal provisions (e.g. for archiving purposes); (ii) for the period necessary to achieve the purpose for which the processing is carried out (including for the duration in which contractual liability could be engaged); (iii) for the period necessary to provide web analytics services.

As a data subject, under the GDPR, you have a series of rights regarding your personal data, and SWOLV, as data controller, is committed to respecting your privacy and to guaranteeing these rights.

You also have:

• the right not to be subject to a decision based solely on automated processing, including profiling;
• the right to lodge a complaint with the competent national authority for the supervision and processing of personal data (i.e. at national level, the National Supervisory Authority for Personal Data Processing).

You can exercise your rights by sending a request to the address contact@swolv.ro. We reserve the right to contact you, to ensure that the request indeed comes from you.

The response to your requests does not involve any cost, except where the requests are unfounded, repetitive or excessive, in which case we may charge you a fee based on the administrative costs related to your request.

Your requests will be answered as soon as possible, depending on the nature of the request and within a maximum of thirty days, except where we are obliged to extend this term, taking into account the complexity of the request and/or the number of requests.

In the course of an application, in the event of sharing incomplete or incorrect information or where the request is not clearly expressed, we may encounter difficulties in resolving your requests, which may lead to delays in the investigation process. Our company reserves all its legal rights in the case of incorrect applications, contrary to the facts/laws or made in bad faith.

If you consider that your personal data is being used incorrectly or that its processing by SWOLV contravenes the GDPR, please inform the DPO at the address contact@swolv.ro about the issues regarding the processing of your data and ask them to take the appropriate measures. If the issue cannot be resolved in this way, you may submit a complaint to the national supervisory authority, whose contact can be found on its website, www.dataprotection.ro.

Like most sites, the swolv.ro website automatically collects certain information and stores it in log files. The information may include internet protocol (IP) addresses, the general region or location from which your computer or device accesses the internet, the browser type, the operating system and other information about the use of the swolv.ro website, including a history of the pages you view. This information is used to better design our site in line with users' needs. We may also use your IP address to assist in diagnosing problems with our server and to administer our website, analyse trends, track visits to our web pages and collect general demographic information that helps us identify visitors' preferences.

The swolv.ro website also uses cookies and other similar technologies. These allow us to store your preferences, offer you options when connecting to our online platforms, deliver advertising through our partners based on your interests and also analyse how our website and platforms function.

For any questions or requests regarding your personal data, including in order to exercise the rights you have as a data subject, as mentioned in the previous section (e.g. requesting a copy of personal data, modification, deletion), you can contact us at the address: contact@swolv.ro.

SWOLV will provide the information in electronic format where possible, unless you request another format.

The information provided, as well as any communication and measures taken in the exercise by you of the above rights, are offered by SWOLV free of charge. However, where the requests made by you are unfounded or excessive, in particular due to their repetitive nature, SWOLV may: (i) either charge a fee taking into account the administrative costs of providing the information or communication or taking the requested measures; (ii) or refuse to act on the request.

Thank you!