SWYM Enterprises, Inc. (“SWYM”) processes certain personal data under the legal basis of legitimate interests in accordance with Article 6(1)(f) of the GDPR.

1. Purpose of Processing

SWYM processes data to:

• Measure advertising performance
• Analyze and improve campaign efficiency
• Develop statistical models to optimize media buying
• Detect fraud and ensure system security

2. Nature of Data

Data processed may include:

• IP address
• Device and browser information
• General location data
• Advertising event data (e.g., impressions, clicks, conversions)

SWYM receives this data from partners via server-to-server integrations and does not collect it directly from user devices.

3. Necessity of Processing

Processing is necessary to:

• Enable accurate campaign measurement
• Improve the efficiency and effectiveness of digital advertising
• Reduce fraud and waste in the advertising ecosystem

Without this processing, these services would not function effectively.

4. Balancing of Interests

SWYM has assessed that its legitimate interests are not overridden by the rights and freedoms of individuals because:

• Processing is limited to advertising-related data
• Data is not used to directly identify individuals
• Processing is primarily statistical and aggregated in nature
• No device storage or intrusive tracking technologies are used

5. Safeguards

SWYM applies safeguards including:

• Data minimization
• Limited retention periods
• Aggregation and statistical processing where possible
• Security and access controls

6. User Rights

Individuals have the right to object to processing based on legitimate interests.

To exercise this right, contact:
📧 info@swym.ai

7. TCF Participation

SWYM participates in the IAB Europe Transparency & Consent Framework (TCF) and processes data in accordance with applicable consent and legitimate interest signals provided by partners.