Swarm Privacy Statement

Swarm (“We”, “us”, or “our”) respects the privacy of individuals as we transform how candidates find jobs and how companies hire talent. While we center on the candidate experience, we ensure that we remain transparent in how we manage information personal data -- which refers to personal information, sensitive personal information, and privileged information that are defined according to the Philippines’ privacy law, the Data Privacy Act of 2012 (“DPA”) and its Implementing Rules and Regulations and/or Thailand' privacy law, the Personal Data Protection Act, B.E. 2562 (2019) ("PDPA") -- collectively, “Information”, we collect about you, as a user (“User”), in connection with our recruitment processes and your use of our products and services, including the Swarm Platform (“Platform”). Our commitment to privacy concerns not only the protection of your data through appropriate measures but also the use of these data in accordance with our declared purposes. You are required to read and understand this statement, before giving your consent for us to collect, use, disclose and otherwise process your personal data. If you are less than 20 years old, your parental consent is additionally required.

When registered users or site visitors use our products and services or our website, we receive Information shared to us, which we collect and process in accordance with this Privacy Policy in adherence with Republic Act No. 10173, otherwise known as the Data Privacy Act of 2012 (“DPA”) and also Personal Data Protection Act (PDPA) (collectively, “Data Privacy Laws"). Our processes are further guided by the Implementing Rules and Regulations of the DPA and PDPA, and relevant issuances by the local regulator on data privacy. Our policy on the collection, use, and disclosure of Information is guided by the privacy principles of transparency, legitimate purpose, and proportionality.

Scope and Limitation

Privacy Principles that Guide Our Use of Your Information


Legitimate Purpose


Swarm’s Participation with the National Privacy Commission (NPC)

Swarm upholds the protection of the privacy of Filipino citizens enshrined in the DPA. Swarm also recognizes the role of the NPC, and its mandate to implement the DPA, and other related laws. Swarm is committed to complete and continuously comply with the requirements of NPC.

Collection of Information

We will collect & process your Information only through a valid consent you have provided to us. You may withdraw the same at any time by using the available features on our Platform or by contacting us at privacy@swarm.work.

When a User registers and creates his/her profile in the Platform, the User understands, agrees, and consents to the collection, use, and storage of the following personal information: name, phone/mobile number, email address, photo, educational background, work experiences, educational or professional awards/recognitions, projects involvement, distinctions conferred by entities, and a resume document including other academic or professional references. Any assessment on skills, ability, qualification, or knowledge that you undertake with Swarm may be linked to and may form part of your profile. We require that all registered users be identified based on an elected email address. Swarm shall not be responsible for assigning or making an email account for you to register to our Platform.

The categories of Information we collect are determined by the prevailing laws where processing will occur. We will not require the collection of personal information that is considered sensitive such as your ethnicity, health, religion, or sexual orientation, unless you disclose the same to us, or the law requires or permits the same. We will not collect financial information from you or about you in connection with your use of our products and services nor will we require payment nor charge fees for the provision of technical assistance to you.

Note that you have control over the disclosure of your Information, including its accuracy, however, omission or withholding of Information may affect the outcome or success of a project proposal and the overall user experience. You may also consider that a complete and updated profile will enhance the user experience. Any Information, including sensitive personal information, you submit to us to form part of your profile even if it is beyond what we request for in the Platform may be accessed by other Users. Swarm is not responsible for ensuring that such Information will be used in accordance with its policies and the declared purposes. In case you will disclose to Swarm personal data that does not relate to you, you warrant that you are authorized to do the same and have advised the data subject the disclosure of their personal information to Swarm, the purpose for processing the same, their rights as data subject, and that you have obtained the necessary consent to disclose the same to Swarm, as required under the DPA and PDPA.

Any communication, message, including feedback, comment, or suggestion you provide us over the Platform, email, or any other website will be treated as non-confidential information to the extent permitted by applicable laws. Swarm has the right to publish, use, or disseminate such communication without liability.

We may also collect and store your personal data in the following ways:

Automated Data Collection Technologies

We may collect further Information from you, your devices, or other third parties including government agencies or professional recruitment firms for the lawful purposes of job matching, information verification, improving the functionality and security of our services, or otherwise fulfilling our legal or contractual obligations to which we may be subject to or as required by law or by a regulator. Additional information such as the User’s IP address and cookies (transient), may be collected in aggregate form, and these may be shared with Google Analytics or similar online tracking tools, in a manner that is proportionate and not in excess of the purposes declared above.

We may collect log data, including, but not limited to:

Purpose of Collection

We use and process your Information in our capacity as a personal information controller for connecting Users with projects, discussions, and other Users as allowed for valid and legitimate purposes declared herein, including providing and administering our products and services, including other activities proportionate and necessary to improve the overall user experience. It is also the means of the Swarm Platform to confirm the identity of the User who signed up with the Swarm Platform; as such, Swarm is assured that it is engaging with a real person.

The ultimate purpose of the collection of these information is to process the same in order to match the User to the qualifications provided in a job post or hiring requirements of our clients/partners, to provide, manage and operate our services to you, to process and administer your request and application. You may use the Swarm Platform to engage in discussions, make proposals to projects, or connect to with other Users. You shall be provided access to your activities within the Swarm Platform including projects you have marked or flagged, projects that you have submitted proposals or applied to, the status of your proposals, and communication with clients and other Users which you have sent via the Swarm Platform. Activity information that you have not shared with a User such as your flagging of a project or your searches, including your account set-up such as your password and account settings, will not be displayed in your profile for viewing of said User and other clients/partners. Note that survey results about your performance on projects, may be an additional reference about you in your profile, which other Users may use in connection with reviewing a project proposal, based on their proposal evaluation needs.

The collection and processing, including the use, sharing, and retention of Information shall only be for valid purposes and to the extent necessary to achieve those purposes. Swarm or its representatives may contact you through your provided email address or mobile number or other contact information when you authorize the same.

Swarm may further use your information to contact you about changes to its products or services that may affect your use of our products and services, suggest job posts which you may be interested in or are relevant to your profile, or for marketing research advanced data analytics and statistical purposes or for reporting or financial assessment or to design new or improve or enhance our existing products/services or to provide technical supports or for purposes of corporate reorganisations and corporate transactions, for investigation of suspected misconduct or illegal activities or internal and external audit reviews and regulatory compliance of its business, to meet requirements imposed by applicable laws, rules, regulations, government authorities and to perform other necessary activities directly relating to any of the above purposes. With your consent, Swarm may additionally use your information for direct marketing purposes or send you surveys through phone, mail, email, SMS.

For purposes other than those stated in this privacy statement, we shall obtain consent from you if we wish to use your personal data, unless otherwise permitted by applicable laws and regulations.

Processing of Information

Swarm uses a variety of technologies, processes/methodologies, and techniques in its Platform and business processes to better serve User. The success in the use of the Platform anchors on the system’s ability to create the best match for a User with the most relevant discussions, projects, or other Users to connect with. These technologies, methodologies, and techniques are proprietary features of the Platform and operate within the limits of applicable laws.

We use your contact information for automated processing to notify you of updates to our product, selected changes in your profile, and job applications including messages from other Users, when you have provided your consent for the same.

Swarm may further outsource processing of your Information with other entities to fulfill the purposes declared above, or as may be required by law, or to protect the interests of Swarm. Such engagements shall take place in line with the requirements of the DPA or PDPA, i.e., through an Agreement, and to prevent the occurence of crimes or violations to applicable laws that Swarm is subject to. Note that subcontracting of personal information processing shall likewise occur within the limits of applicable laws.

We may further use your Information in anonymized or statistical form for our research to help us improve our processes and systems or our business processes.

Information Sharing / Information Access

Users of the Platform must be aware that their profile and other relevant Information they voluntarily disclose are shared with other Users that may be clients/partners who are looking for consultants to work on their projects. It is by this understanding that any User who signs up with the Platform has agreed with this condition and that in order to facilitate the submission and evaluation of a proposal, Information sharing is necessary.

Swarm provides access or shares the profile of the User only to other Users who have provided Swarm with the assurance that they shall observe the prevailing data privacy laws, observe the privacy principles espoused by Swarm, and have done so through appropriate and sufficient means and instruments as may be required by law, i.e., an agreement or contract. The Platform allows a User to directly communicate with another User by facilitating discussions via a forum, or private message. Furthermore, we encourage you to maximize the features and tools in the Platform to enhance your overall user experience.

Swarm shall not be responsible, under this Policy, for the availability, accessibility, and storage of Information outside its Platform or wherein Swarm is not a party to such arrangements.  Please note that information you independently disclose to other Users outside of the Platform or wherein Swarm’s Policy does not apply shall not be covered by our Privacy Statement and our privacy policies.

Note that your Information may be shared and disclosed to, and further processed and stored by our subsidiaries, affiliates, any member of the Swarm Group and entities engaged by Swarm, which may include entities outside the Philippines wherein prevailing data privacy laws may differ from the level of security provided under the DPA and the PDPA, in line with the purposes declared herein. Nonetheless, Swarm shall share Information only with entities who provide the assurance that they employ security measures to protect personal data. Swarm shall also allow the sharing of Information to other entities such as third party service providers, including but not limited to service providers who provide administration services, data processing services, technology services, cloud services, outsourcing services, call center services, storage services, data analytics services, marketing services, research services, crisis management services and other services in connection with the operation of Swarm’s business, engaged by Swarm or to any regulator, authority, or court, when required to fulfill the purposes declared herein, or as may be required by applicable laws or regulations that may be necessary for the protection of the privacy and to serve the interests and/or requests from the User.

Your Information is required to be kept confidential by those authorized by Swarm to have access to such Information, and are required to use or process the same only in line with the purposes declared in this Privacy Statement and to ensure that they will protect your privacy and keep your personal information secure. Swarm takes necessary measures to ensure that your Information are used only for specified purposes and not disclosed, shared, or processed for purposes not in line with these purposes. As such, appropriate physical, organizational, and technical security measures are employed by Swarm against unauthorized or unlawful use, processing, disclosure, access, or modification. These standards and responsibilities for the protection of data consistent with our privacy policy and practices are also imposed to the entities with which we have shared your Information.

Note that our IT, tools, processes, and Swarm Platform maintenance personnel, including third party service providers, may have limited access to your Information, for repairs and bug fixes or to ensure, maintain, and restore the integrity of its databases, servers, and your Information, but they may be required to process your Information based on this Privacy Statement and through appropriate security measures. Swarm may also share your personal information to our professional advisors such as lawyers, auditors or consultants or any other party permitted under applicable law and any party to whom you have consented the disclosure of your personal data.

Changes to the capacity exercised by Swarm as a personal information controller may occur as a result of organizational changes such as merger, acquisition, transfer of assignment, or any other similar arrangements.

Storage, Retention, and Deletion

A User profile that consists of Information is stored in a secured facility such as Google Cloud Platform in which several levels of security and authentication features are in place. Information herein is retrieved only by authorized personnel and those that may be authorized under the DPA or PDPA; this includes those authorized by Swarm through an appropriate agreement on data sharing, access, or processing.

Before Information is anonymized, deleted, or disposed, User Information will be retained by Swarm until the expiry of the retention period set by Swarm, unless sooner requested to be deleted by the User. Typically, User information will be stored until three (3) years from date of inactivity (dormancy period). Within one (1) day after the expiry of such period, the User shall be sent a notification and be prompted to update the profile and allow the User to keep using the Platform. The system will allow a period of seven (7) days after the notification is sent for the User to take a positive action and that the User agrees with the existing policy provisions of the Platform. Should the dormancy period persist continuously, the User is notified that the records of his/her Information shall no longer be available and the profile shall no longer be accessible.

Cross-Border Transfer

Your personal data may be transferred to, stored or otherwise processed by Swarm, or provided to any of the above persons who may be located or who may provide services, in or outside the Philippines.

Where required under relevant law, we may seek your consent to the transfer of such information outside countries to our facilities or to those third parties with whom we transfer and disclose your personal data as described above. Your personal data will only be transferred to other locations, where we are satisfied that adequate levels of protection exist to protect the integrity and security of your personal data, which as minimum are comparable to the jurisdiction or territory in which you provided such personal data and we will comply with the law of destination and shall abide by any other related legislations.

Data Breach

We value the trust of the Users and are committed to protecting the personal data that are entrusted to us and submitted to us through our Platform. We shall thus ensure that the Information we collect, hold, process, and store are kept secure from unauthorized or unlawful use, processing, sharing, and other forms of personal data breaches. Swarm shall duly investigate in order to resolve data breaches in adherence to the breach management procedures prescribed by the local law and regulations, in addition to implementing our own protocols in handling breaches. If you have information or reason to believe that your personal data that we hold about you is subject of a personal data breach, you may contact us at privacy@swarm.work.

Acknowledgement of Rights

In addition to any rights a User may have under this policy, Users of our Platform, whether registered users or visitors, have the following rights under the Data Privacy Laws:

  1. The right to verify whether Swarm holds any personal data about you.
  2. The right to reasonable access to the personal information that we hold about you and about how Swarm uses or discloses your personal data.
  3. The right to make corrections or updates to the personal information we hold or otherwise process about you.
  4. The right to object to the processing of your personal information in line with our declared purpose.
  5. The right to erasure or blocking of your personal information from our records and systems or deletion of your profile.
  6. The right to request a temporarily suspension of the processing of your personal data under certain circumstances
  7. The right to withdraw your consent or request a change to your scope of consent;
  8. The right to make a complaint about Swarm’s data handling
  9. The right to enquire about Swarm’s policies and practices in relation to personal data;
  10. The right to be informed of the processing of your personal information, including the existence of the automated decision-making and profiling. Data subjects may be notified of personal data breaches in accordance with the requirements and procedures set out by the law.
  11. The right to be indemnified in case processing of your personal information violates the law.
  12. The right to portability of your data in your profile, in jobs you have applied for, and communication with a recruiter in an exported format from our Platform.
  13. The right to lodge a complaint before the competent body or regulator for the Data Privacy Laws.

For any concerns on how you can exercise your rights as a data subject, you may contact us at privacy@swarm.work.

To the fullest extent permitted by law, you further agree to keep us fully indemnified from and against any and all damages, losses, costs, legal fees, penalties and proceedings, arising out of or in connection with your acts or omission, or negligence in your performing obligations.


You may withdraw your consent to collect, use, process or disclose your personal data as set out in this privacy statement by giving us a notification in writing through our email or other available features on our platform. However, it will not affect any actions that have been done by us.

When you send us a request to withdraw your consent to collect, use, process or disclose your personal data, we may be unable to process and/or manage your account with us.


From time to time, we may acquire or dispose of one or more of businesses (or portions thereof) and for this purpose, to the extent permitted by applicable law, your personal data may be transferred or disclosed as a part of the purchase or sale or a proposed purchase or sale.

In the event that we purchase a business, the personal data received with that business would be treated in accordance with this privacy statement, if it is practicable and permissible to do so. In the event that we sell a business, we will include provisions in the selling contract requiring the purchaser to treat your personal data in the same manner required by this privacy statement.

Swarm may retain your personal data for as long as necessary to fulfil the purpose(s) for which it is collected or a longer period as otherwise required to ensure compliance with applicable laws and regulations.

Reasonable steps will be taken to delete or destroy your personal data when it is no longer necessary for any of the purposes above.

Last updated March 22, 2021

Please note that this Privacy Statement may be modified by Swarm at any time without prior notice. Relevant changes will be made available on this page or communicated or made available to Users through reasonably proportionate means.

Where required by applicable law, we may notify you in the event of material changes to this privacy statement and, where required, seek your consent to those changes.

If you object to our Privacy Policy, you may delete your account/profile by accessing your Account Information.

If you wish to change your notifications or unsubscribe to further communications, please email us at privacy@swarm.work.

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