Privacy Policy

Last updated: October 13, 2025

This Privacy Policy describes the policies and procedures of Sware, Inc., 867 Boylston St., 5th Floor #1295, Boston, MA 02116, United States (“Sware,” “we,” “our,” or “us”) on the collection, use and disclosure of your information when you interact with our website at www.sware.com (our “Service”) and tells you about your privacy rights. We use our Service primarily to promote Sware’s proprietary computer system validation tools (collectively, our “Tools”), which are subject to their own separate privacy policy.

 

Data Controller and Data Protection Roles

Sware, Inc. operates in two distinct capacities depending on the context of the personal data we handle:

• For Customer Data (e.g., data processed through the Res_Q platform): Sware acts as a Data Processor on behalf of its customers. In this role, Sware processes limited personal data (such as user names, email addresses, and access credentials) solely for the purpose of providing, maintaining, and supporting our SaaS platform. The customer remains the Data Controller, determining the purpose and means of processing.
• For Sware’s Own Business Operations: Sware acts as a Data Controller with respect to the personal data it collects directly, such as data from its employees, job applicants, vendors, and marketing contacts. This includes managing recruitment, internal HR processes, business communications, and website inquiries.

 

Data Protection Officer

Sware has appointed a Data Protection Officer responsible for overseeing our data protection strategy and ensuring compliance with applicable privacy laws. You may contact our Data Protection Officer (DPO) at DPO@Sware.com for questions related to this Privacy Policy or your data protection rights.

 

Collecting and Using Your Personal Data

 

Types of Data Collected

 

Personal Data Collected Directly from You

While using our Service, we may ask you to directly provide us with certain personally data in order to contact us or request a demonstration of our Tools, including, but not limited to:

• Email address
• First name and last name
• Phone number
• Address, State, Province, ZIP/Postal code, City
• Professional Title
• Company

 

Usage Data Collected Automatically

Usage Data is collected automatically when you use or access the Service.

Usage Data may include information such as your device's Internet Protocol address (e.g. IP address), browser type, browser version, the pages of our Service that you visit, the time and date of your visit, the time spent on those pages, unique device identifiers and other diagnostic data.

When you access the Service by or through a mobile device, we may collect certain information automatically, including, but not limited to, the type of mobile device you use, your mobile device unique ID, the IP address of your mobile device, your mobile operating system, the type of mobile Internet browser you use, unique device identifiers and other diagnostic data.

We may also collect information that your browser sends whenever you visit our Service or when you access the Service by or through a mobile device. 

 

Tracking Technologies and Cookies

We use cookies and similar tracking technologies to track the activity on our Service and store certain information. A cookie is a small file placed on your device. You can instruct your browser to refuse all cookies or to indicate when a cookie is being sent. However, if you do not accept cookies, you may not be able to use some parts of our Service. Unless you have adjusted Your browser setting so that it will refuse cookies, our Service may use cookies. Tracking technologies used are beacons, tags, and scripts to collect and track information and to improve and analyze our Service. Certain sections of our Service and our emails may contain small electronic files known as web beacons (also referred to as clear gifs, pixel tags, and single-pixel gifs) that permit Sware, for example, to count users who have visited those pages or opened an email and for other related website statistics (for example, recording the popularity of a certain section and verifying system and server integrity).

Some of the most common cookies we use on our Service are: 

 

Use of Your Personal Data

We use the personal information collected directly from you primarily to respond to the request you have placed through our Service when you submit information to us through the “Contact Us” form or in requesting a demonstration of our Tools, and with respect to residents in countries where a lawful basis for processing is required, the lawful basis for our processing is that it is necessary to perform the services you are requesting from us.

We use your usage data collected automatically primarily to help us understand how you use our Service and with respect to residents in countries where a lawful basis for processing is required, the lawful basis for our processing is our legitimate interests, namely, because Sware has a legitimate interest in understanding how its visitors use its Service that is not outweighed by your interests or fundamental rights and freedoms.

Sware may use personal data for the following additional purposes: 

To provide you with news, special offers and general information about other goods, services and events which we offer that are similar to those that you have already purchased or enquired about unless you have opted not to receive such information. With respect to residents in countries where a lawful basis for processing is required, the lawful basis for our processing is our legitimate interests, namely, because Sware has a legitimate interest to provide you with information marketing our services that is not outweighed by your interests or fundamental rights and freedoms.

Compliance: We may use your information to meet our other compliance and regulatory duties, for example to retain certain records, because it is necessary for compliance with a legal obligation to which Sware is subject.

For business transfers: We may use your information to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal data held by us about our Service users is among the assets transferred. With respect to residents in countries where a lawful basis for processing is required, the lawful basis for our processing is our legitimate interests, namely, because Sware has a legitimate interest to evaluate or conduct a business transfer that is not outweighed by your interests or fundamental rights and freedoms

Where permitted by applicable law, we may also use anonymous, de-identified, or aggregate information that does not reasonably identify you for any purpose.

 

Sharing Your Personal Data

We may share your personal information in the following situations: 

• With Service Providers: We may share your personal data with service providers to monitor and analyze the use of our Service, to contact you. Our service providers only access, process or store your information in the course of performing their duties to us.
• For business transfers: We may share or transfer your personal data in connection with, or during negotiations of, any merger, sale of our assets, financing, or acquisition of all or a portion of our business to another company.
• With Law enforcement: Under certain circumstances, Sware may be required to disclose your personal data if required to do so by law or in response to valid requests by public authorities (e.g. a court or a government agency).
• To satisfy other legal requirements: Sware may disclose your personal data in the good faith belief that such action is necessary to Sware with a legal obligation, protect and defend the rights or property of Sware, prevent or investigate possible wrongdoing in connection with the Service, protect the personal safety of other users of the Service or the public, or protect against legal liability.

 

Lawful Bases for Processing

 In compliance with the General Data Protection Regulation (GDPR), we rely on the following legal bases when processing personal data of EEA, UK, and Swiss residents: 

Purpose of Processing	Lawful Basis under GDPR
Responding to demo requests / inquiries	Contract (Art. 6(1)(b))Retention of Your Personal Data
Providing customer communications, updates, and support	Contract / Legitimate Interest
Marketing communications	Consent (Art. 6(1)(a)) for EEA/UK residents
Analytics and website improvements	Legitimate Interest (Art. 6(1)(f))
Compliance with legal obligations	Legal Obligation (Art. 6(1)(c))

 

Where we rely on consent, you may withdraw consent at any time without affecting the lawfulness of processing carried out before withdrawal.

 

Retention of Your Personal Data

Sware will retain your personal data only for as long as is necessary for the purposes set out in this Privacy Policy. We may retain and use your personal data for longer periods to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies.

 

Transfer of Your Personal Data

Sware is based in, and operates from, the United States. If you are located in other jurisdictions, including the EEA, UK, or Switzerland, please note:

• We transfer personal data outside these regions only where appropriate safeguards are in place, such as:
  • The European Commission’s Standard Contractual Clauses (SCCs);
  • UK International Data Transfer Addendum;
  • Other mechanisms approved under applicable data protection laws.
• These safeguards are intended to ensure that your data is afforded a level of protection essentially equivalent to that guaranteed under GDPR.

By submitting your personal information to us through our Service, you acknowledge these transfers as necessary to provide our services. For more information, please contact us.

 

Security of Your Personal Data

We maintain industry standard administrative, technical, and physical safeguards to protect your personal information from loss, misuse, unauthorized access, disclosure, alteration and destruction. With that said, the security of your personal data is important to us, but remember that no method of transmission over the Internet, or method of electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your personal data, we cannot guarantee its absolute security.

 

Your Rights and Choices

You have several choices regarding the use and disclosure of your information:

Information You Provide. If you do not want your information collected, please do not submit it to us. If you have already submitted information and would like to review, correct, or remove it from our records, please contact us.

Marketing Messages. We may send you marketing communications, about our services that may interest you. You can opt out of our marketing communications at any time by contacting us. Please understand though that some non-marketing communications are not subject to this opt-out, such as communications relating to services we are providing you, sales transactions, software updates and other support related information, patches and fixes.

If you are a resident of the EEA, UK, or Switzerland, you have the following rights:

• Right of access – Request a copy of your personal data.
• Right to rectification – Request correction of inaccurate data.
• Right to erasure – Request deletion of your personal data when no longer necessary.
• Right to restrict processing – Request restriction where accuracy is contested or processing is unlawful.
• Right to object – Object to processing based on legitimate interests, including direct marketing.
• Right to data portability – Receive your data in a structured, commonly used, machine-readable format.
• Right to withdraw consent – Withdraw consent at any time when processing is based on consent.

We respond to all valid requests within one month, free of charge (unless requests are manifestly unfounded or excessive).

You also have the right to lodge a complaint with your local supervisory authority if you believe our processing infringes data protection law.

 

"Do Not Track" Policy

Our Service does not respond to Do Not Track signals. However, some third-party websites do keep track of your browsing activities. If you are visiting such websites, you can set your preferences in your web browser to inform websites that you do not want to be tracked. You can enable or disable DNT by visiting the preferences or settings page of your web browser. 

 

Children's Privacy

Our Service does not address anyone under the age of 13. For residents of the EEA, UK, and Switzerland, we do not knowingly collect personal data from children under the age of 16 unless parental consent is provided, as required by GDPR (Member States may set a lower age, not below 13). 

 

Profiling and Automated Decision-Making

We do not engage in automated decision-making, including profiling, that produces legal effects concerning you or similarly significantly affects you. Where we use profiling tools (such as marketing automation platforms) to tailor communications, these activities are limited in scope and you may opt out at any time.

 

Links to Other Websites

Our Service may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third-party sites or services.

 

Subprocessor Policy

To support the delivery of our services, Sware uses third-parties and vendors to process Customer Data (which may include personal data).

All subprocessors engaged by SWARE are contractually bound to comply with applicable data protection laws and security measures to ensure the protection of customer Personally Identifiable Information (PII). Subprocessors are strictly prohibited from using customer data for any purpose other than to support Sware.

SWARE will notify customers in writing of any intended changes concerning the addition or replacement of subprocessors that process PII at least 15 days in advance. If a customer raises a valid objection within 5 days of receiving the notice, SWARE will take responsible steps to address the concern, which may include:

• Providing additional assurances about the subprocessor’s compliance with applicable data protection regulations.
• If no resolution is reached, allowing the customer to terminate the affected service without penalty. 

 

Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. If we make material changes, we will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the "Last updated" date at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page.

 

Contact Us

If you have any questions about this Privacy Policy, you can contact us:

• By email: info@sware.com