Introduction

This Privacy Policy explains how we collect, use, store, and protect personal data when you visit our website, communicate with us, or use our services. It applies to Swenum OÜ (“Swenum”, “we”, “us”, “our”) and covers all visitors, prospective clients, and customers interacting with our B2B AI solutions.

By using our website or services, you agree to the practices described in this Privacy Policy. If you do not agree, please discontinue use of our website and services.

Who We Are

Swenum is a B2B AI solutions company that designs and deploys custom machine learning and analytics systems across sectors such as finance, iGaming, sales and marketing. We act primarily as a data controller for personal data collected via our website, sales, and marketing activities, and as a data processor when we handle data on behalf of clients under a written agreement.

If you have questions about this policy or our data practices, you can contact us at:

• Company: Swenum OÜ
• Email: info@swenum.com
• Registered office: Uus-Sadama tn 16-9, Kesklinna linnaosa, 10120 Tallinn, Harju maakond, Estonia

Personal Data We Collect

We may collect and process the following categories of personal data, depending on how you interact with us:

• Contact information: name, business email, phone number, job title, company name.
• Communication: messages you send via contact forms, email, chat, or other channels.
• Usage and technical: IP address, device and browser information, pages visited, referring URLs, timestamps, and interaction logs collected via analytics tools and server logs.
• Account and project: login details (if applicable), project requirements, and configuration details related to proof-of-concepts, pilots, or deployed solutions.
• Marketing preferences: your subscription status, communication preferences, and engagement with our campaigns or newsletters.
• Client-provided: datasets, logs, or other information shared by our clients for the purpose of building and operating AI solutions (processed according to the respective service agreement or DPA).

How We Use Personal Data

We use personal data for the following purposes:

• Providing and improving our services: delivering proposals, pilots, and production systems; managing projects; providing support; and optimizing performance and reliability.
• Communication: responding to inquiries, scheduling meetings or demos, sending administrative information (such as contract updates, service notifications, or security alerts).
• Sales and marketing: informing you about relevant services, use cases, events, and resources, in accordance with your communication preferences and applicable laws.
• Analytics and product development: understanding how our website and services are used to improve user experience, security, and functionality.
• Security and fraud prevention: protecting our infrastructure, investigating suspicious activity, and enforcing our terms and agreements.
• Legal and compliance: fulfilling legal obligations, responding to regulatory requests, asserting or defending legal claims, and maintaining appropriate business records.

Legal Bases for Processing

Where required by applicable data protection laws (such as the GDPR), we rely on one or more of the following legal bases:

• Performance of a contract: when processing is necessary to enter into or fulfill an agreement with you or your organization.
• Legitimate interests: to operate, secure, and improve our business and services, provided that these interests are not overridden by your rights and interests.
• Consent: when you have given us explicit permission, for example for certain marketing communications or optional cookies (you may withdraw consent at any time).
• Legal obligations: where processing is required to comply with laws, regulations, or court orders.

Cookies & Analytics

We may use cookies, pixels, and similar technologies to operate our website, understand usage patterns, and improve performance. These may include strictly necessary cookies (for security and core functionality), as well as analytics or performance cookies.

Where required by law, we ask for your consent before using non-essential cookies. You can manage or disable cookies through your browser settings; however, some features of the site may not function properly if certain cookies are disabled.

How We Share Personal Data

We do not sell personal data. We may share personal data in the following situations:

• Service providers: trusted third parties who help us deliver services (e.g., cloud hosting, analytics, email delivery, CRM, collaboration tools) under data protection and confidentiality obligations.
• Clients and partners: as necessary to perform a contract or proof-of-concept where your organization is involved or where collaboration between multiple vendors is required.
• Legal and regulatory: when required by law, regulation, legal process, or governmental request, or to protect the rights, property, or safety of Swenum, our users, or others.
• Business transfers: in connection with any merger, acquisition, asset sale, or restructuring; we will take steps to ensure your data remains protected and notify you where required by law.

International Data Transfers

As a B2B AI company working with clients and infrastructure providers in different regions, personal data may be transferred and processed outside your country, including to countries that may not provide the same level of data protection as your jurisdiction.

Where required, we implement appropriate safeguards for such transfers (for example, using standard contractual clauses approved by the European Commission or other equivalent mechanisms) and ensure that recipients provide adequate protection for personal data.

Data Security & Retention

We use technical and organizational measures designed to protect personal data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access. These measures may include access controls, encryption, secure development practices, logging, and regular reviews of our infrastructure and vendors.

We retain personal data only for as long as necessary to fulfill the purposes described in this Privacy Policy, to comply with legal, accounting, or reporting requirements, or as specified in our contracts with clients. When data is no longer needed, we will delete or anonymize it where feasible.

Your Rights

Depending on your jurisdiction, you may have certain rights regarding your personal data, which may include:

• Right to access the personal data we hold about you.
• Right to request correction of inaccurate or incomplete data.
• Right to request deletion of your personal data, subject to legal or contractual obligations.
• Right to object to or restrict certain types of processing, including direct marketing.
• Right to data portability, where technically feasible.
• Right to withdraw consent at any time when processing is based on your consent.
• Right to lodge a complaint with a supervisory or data protection authority in your country or region.

To exercise any of these rights, please contact us at privacy@swenum.com (replace with your actual address). We may need to verify your identity before fulfilling your request.

Children’s Privacy

Our website and services are intended for business users and are not directed to children. We do not knowingly collect personal data from children under the age of 16 (or lower age as defined by applicable law). If we become aware that we have collected such data, we will take steps to delete it promptly.

Changes to This Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technologies, or legal requirements. When we do, we will revise the “Last updated” date at the top of the policy and, where required, notify you through our website or direct communication.

We encourage you to review this page periodically to stay informed about how we protect your data.

Contact Us

If you have any questions, concerns, or requests related to this Privacy Policy or our data practices, please contact us at:

• Email: info@swenum.com
• Address: Uus-Sadama tn 16-9, Kesklinna linnaosa, 10120 Tallinn, Harju maakond, Estonia