Swarm Vision Privacy Policy
April 5, 2017

Swarm Vision, Inc. (formerly known as “Totem”) complies with the EU-US Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries.  Swarm Vision (“Swarm Vision”) has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfer, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement and Liability.  If there is any conflict between the policies in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern.  To learn more about the Privacy Shield program, and to view our certification page, please visit: https://www.privacyshield.gov.

This privacy policy outlines our general policy and practices for implementing the Principles, including the types of information we gather, how we use it and the notice and choice affected individuals have regarding our use of and their ability to correct that information. This privacy policy applies to all personal information received by the Company whether in electronic, paper or verbal format.

“Personal Information” or “Information” means information that (1) is transferred from the EU to the United States; (2) is recorded in any form; (3) is about, or pertains to a specific individual; and (4) can be linked to that individual.

“Sensitive Personal Information” means personal information that reveals race, ethnic origin, sexual orientation, political opinions, religious or philosophical beliefs, trade union membership or that concerns an individual’s health.

This Privacy Policy is subject to the investigatory and enforcement powers of the FTC (US Federal Trade Commission).

Principles

Notice: Swarm Vision collects minimum personal information on users of our websites for purposes such as registering for a crowdsourcing community or campaign; transmitting prizes to winners of crowdsourcing campaigns; or for innovation profiling assessments. The Company may disclose personal information to its clients on an aggregated level (e.g. number of members by country). Swarm Vision does not collect sensitive information (i.e., personal information specifying medical or health conditions, racial or ethnic origin, political opinions, religious or philosophical beliefs, trade union membership or information specifying the sex life of the individual.) Results of the Swarm Innovation Profiler for Enterprise may be shared with your employer. You will be notified before the Company uses or discloses the Information for a purpose other the purpose for which it was originally collected.

Choice: Individuals can choose (opt out) whether their Personal Information is (1) to be disclosed to a third party or (2) to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. For Sensitive Personal Information, the Company will give individuals the opportunity to affirmatively or explicitly (opt out) consent to the disclosure of the
information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. Company shall treat Sensitive Personal Information received from an individual the same as the individual would treat and identify it as Sensitive Personal Information.

Accountability for Onward Transfer: Prior to disclosing Personal Information to a third party, Company shall notify the individual of such disclosure and allow the individual the choice (opt out) of such disclosure. Company shall ensure that any third party for which Personal Information may be disclosed subscribes to the Principles or are subject to law providing the same level of privacy protection as is
required by the Principles and agree in writing to provide an adequate level of privacy protection.

Company may be liable for certain onward transfers to third parties. Notwithstanding the above, Swarm Vision is required to disclose personal information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

Data Security: Company shall take reasonable steps to protect the Information from loss, misuse and unauthorized access, disclosure, alteration and destruction. Company has put in place appropriate physical, electronic and managerial procedures to safeguard and secure the Information from loss, misuse, unauthorized access or disclosure, alteration or destruction. Company cannot guarantee the security of Information on or transmitted via the Internet.

Data Integrity and Purpose Limitation: Company shall only process Personal Information in a way that is compatible with and relevant for the purpose for which it was collected or authorized by the individual.

To the extent necessary for those purposes, Company shall take reasonable steps to ensure that Personal Information is accurate, complete, current and reliable for its intended use.

Access: Company shall allow an individual access to their Personal Information and allow the individual to correct, amend or delete inaccurate information, except where the burden or expense of providing access would be disproportionate to the risks to the privacy of the individual in the case in question or where the rights of persons other than the individual would be violated. Individuals may not amend their Innovation Profiler assessments once a page has been submitted.

Recourse, Enforcement and Liability: Company uses a self-assessment approach to assure compliance with this privacy 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 Principles. We encourage interested persons to raise any concerns using the contact information provided and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of Personal Information in accordance with the Principles. If a complaint or dispute cannot be resolved through our internal process, we agree to dispute resolution using (an independent resource mechanism) as a third party resolution provider. Under certain limited conditions, individuals may invoke binding arbitration before the Privacy Shield Panel to be created by the U.S. Department of Commerce and the European Commission.

Amendments: This privacy policy may be amended from time to time consistent with the requirements of the Privacy Shield. We will post any revised policy on this website.

EU Residents

In compliance with the EU-US Privacy Shield Principles, Swarm Vision commits to resolve complaints about your privacy and our collection or use of your personal information.  European Union individuals with inquiries or complaints regarding this privacy policy should first contact Swarm Vision at:

Swarm Vision, Inc.
PO Box 806
Los Altos CA 94023
inquiry@SwarmVision.com

Swarm Vision has further committed to refer unresolved privacy complaints under the EU-US Privacy Shield Principles BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint.

Last Updated: April 5, 2017