Last updated: 01 October 2025

This Privacy Policy explains how Swayton DOO ("Swayton", "we", "us") collects, uses, shares, and protects personal data when you visit https://swayton.com (the "Site") or engage us for advertising and marketing services (the "Services"). It also describes your privacy rights and how to exercise them.

Entity responsible (Controller for Site & marketing):

Swayton DOO, 11000 Belgrade, Studentski trg 4, Republic of Serbia

Contact: [email protected]

Quick summary

• We collect only what we need to operate the Site, answer inquiries, and deliver Services.
• For client projects we usually act as a processor; for our own Site, sales, and marketing we act as a controller.
• We use analytics and advertising tools (e.g., Google/Meta/TikTok) subject to consent where required.
• You can opt out of marketing at any time and manage cookies via our Cookie Notice and consent tools.
• Your rights include access, correction, deletion, restriction, portability, and objection.
• Serbian law and the EU GDPR principles guide our practices.

1) Scope & roles

• Website & marketing: Swayton DOO is the controller of personal data collected via the Site, contact forms, newsletters, events, downloads, and general sales outreach.
• Client Services: For personal data we process on documented instructions from a client (e.g., audience lists, conversion data, platform access), Swayton is a processor (or sub‑processor). Where both parties decide purposes and means together (e.g., joint campaigns), the parties may be joint controllers as agreed in the SOW/DPA.

2) What data we collect

We collect the following categories depending on your interactions:

• Identifiers & contact details: name, business email, phone, employer, role, billing contacts.
• Site/device data: IP address, device/user agent, cookie identifiers, pages viewed, referrers, timestamps, approximate location (city/region), language settings.
• Lead & support data: messages, meeting notes, RFPs, scopes, and preferences you submit.
• Account & project data (clients): platform IDs (e.g., Google Ads, DV360, Meta), conversion/event data, creative assets, targeting instructions.
• Compliance & security data: access logs, permissioning, audit trails.

We do not intentionally collect special categories (sensitive data) via the Site. If your project requires processing such data (e.g., health/finance categories), this will be expressly scoped, justified, and safeguarded in the DPA/SOW.

3) Sources of data

• Directly from you (forms, calls, emails, contracts).