Privacy Policy

Swimsol GmbH (“Swimsol”, “us”, “our”, “we”) is committed to safeguarding your privacy.

This document describes how and why we may collect, use, store, share (“processing”) your information when you use our services (“Services”):

-visit our website www.swimsol.com, or our pages on social media channels (Facebook, Twitter, Instagram) or other websites that link to this policy

-communicate with us in other ways (email, phone, chat services (Facebook messenger, Instagram, or use our web-chat service on our website).

-click on our online advertisements

By using this site or/and our services, you consent to the Processing of your Personal Data as described in this Privacy Policy.

Table of Contents

1. Definitions used in this Policy
2. Data protection principles we follow
3. What rights do you have regarding your Personal Data
4. What Personal Data we gather about you
5. Who else has access to your Personal Data
6. How we secure your data
7. Information about cookies
8. Contact information

1. Definitions

• Personal Data – any information relating to an identified or identifiable natural person.
• Processing – any operation or set of operations which is performed on Personal Data or on sets of Personal Data.
• Data subject – a natural person whose Personal Data is being Processed.
• Child – a natural person under 16 years of age.
• We/us (either capitalized or not) – Swimsol GmbH
• Social media platforms – Facebook, X, Meta, Instagram, Messenger, Pipedrive webchat,

2. Data Protection Principles

We promise to follow the following data protection principles:

• Processing is lawful, fair, transparent. Our Processing activities have lawful grounds. We always consider your rights before Processing Personal Data. We will provide you information regarding Processing upon request.
• Processing is limited to the purpose. Our Processing activities fit the purpose for which Personal Data was gathered.
• Processing is done with minimal data. We only gather and Process the minimal amount of Personal Data required for any purpose.
• Processing is limited with a time period. We will not store your personal data for longer than needed.
• We will do our best to ensure the accuracy of data.
• We will do our best to ensure the integrity and confidentiality of data.

3. Data Subject’s rights

The Data Subject has the following rights:

1. Right to information – meaning you have to right to know whether your Personal Data is being processed; what data is gathered, from where it is obtained and why and by whom it is processed.
2. Right to access – meaning you have the right to access the data collected from/about you. This includes your right to request and obtain a copy of your Personal Data gathered.
3. Right to rectification – meaning you have the right to request rectification or erasure of your Personal Data that is inaccurate or incomplete.
4. Right to erasure – meaning in certain circumstances you can request for your Personal Data to be erased from our records.
5. Right to restrict processing – meaning where certain conditions apply, you have the right to restrict the Processing of your Personal Data.
6. Right to object to processing – meaning in certain cases you have the right to object to Processing of your Personal Data, for example in the case of direct marketing.
7. Right to object to automated Processing – meaning you have the right to object to automated Processing, including profiling; and not to be subject to a decision based solely on automated Processing. This right you can exercise whenever there is an outcome of the profiling that produces legal effects concerning or significantly affecting you.
8. Right to data portability – you have the right to obtain your Personal Data in a machine-readable format or if it is feasible, as a direct transfer from one Processor to another.
9. Right to lodge a complaint – in the event that we refuse your request under the Rights of Access, we will provide you with a reason as to why. If you are not satisfied with the way your request has been handled please contact us.
10. Right for the help of supervisory authority – meaning you have the right for the help of a supervisory authority and the right for other legal remedies such as claiming damages.
11. Right to withdraw consent – you have the right withdraw any given consent for Processing of your Personal Data, and/or to unsubscribe from marketing communications, for instructions click here.

4. Data we gather

Information you have provided us with:

This might be your

• e-mail address
• name
• phone number
• any other details that you willingly provide/submit in the “Contact Us” form or via email or messaging platforms (Facebook Messenger, Instagram direct messages) – i.e. information that is necessary for delivering you our service or to enhance your customer experience with us. We save the information you provide us in order to contact you and provide you with a informative response regarding a your inquiry. This information includes, for example, your name, username, e-mail address, phone number, and non personal information such as available rooftop area for solar panels in m² or ft², average monthly energy consumption, country for the installation, coordinates of desired solar power installation (Latitude & Longitude) and any other information that you willingly provide in the contact form, via email or social media messaging platforms.

Sensitive information
We do not process sensitive information.

Information automatically collected about you
When you use our services or look at the contents of our website, your activities may be anonymised and logged. This includes information that is automatically stored by cookies and other session tools. This information does not reveal your identity (i.e. name or contact details), however may include details about your device and usage – i.e. browser, timing and time spent, operating system, referring URLs, searches, the pages you view, as well as country, location and other technical information. This information is used to maintain our services, improve general customer experience, analytics and for internal reporting.

Information from our partners
We may gather limited information from our trusted partners with confirmation that they have legal grounds to share that information with us. This is either information you have provided them directly with or that they have gathered about you on other legal grounds. See the list of our partners here.

Publicly available information
We might gather information about you that is publicly available.

We use your Personal Data in order to:

• provide and improve our service to you. This includes for example answering your query; providing you with products and services that you have requested; providing you with promotional items or information at your request and communicating with you in relation to those products and services; communicating and interacting with you; and notifying you of changes to any services.
• enhance your customer experience, request feedback, monitor usage trends, evaluate effectiveness of our marketing campaigns
• to send you marketing and promotional communication material, provided that we have your consent (subscription via website, email, or messaging platforms), we may send you occasional marketing materials. You can always opt out of these, by replying “unsubscribe” or clicking a designated unsubscribe link in our emails.
• to deliver targeted advertising to you. We may process your information to display personalized content and adverts tailored to your location, interests, etc.

We use your Personal Data on legitimate grounds and/or with your Consent.

On the ground of legitimate interest, we Process your Personal Data for the following purposes:

• to send you personalised offers
• to administer and analyse our client base in order to improve the quality, variety, and availability of products/ services offered/provided;
• to conduct questionnaires concerning client satisfaction;
• to create and provide personalized advertising for our users;
• to support our marketing activities;
• to identify problems and prevent fraudulent acts;

As long as you have not informed us otherwise, we consider offering you products/services that are similar or same to your purchasing history/browsing behaviour to be our legitimate interest.

With your consent we Process your Personal Data for the following purposes:

• to send you newsletters and campaign offers;
• for other purposes we have asked your consent for;

You have the right to withdraw your consent at any time by emailing us at dpo_[at]_swimsol_[dot]_com and requesting to withdraw consent.

We Process your Personal Data in order to fulfil obligation rising from law and/or use your Personal Data for options provided by law. We reserve the right to anonymise Personal Data gathered and to use any such data. We may use data outside the scope of this Policy only when it is anonymised.

We might process your Personal Data for additional purposes that are not mentioned here, but are compatible with the original purpose for which the data was gathered. To do this, we will ensure that:

• the link between purposes, context and nature of Personal Data is suitable for further Processing;
• the further Processing would not harm your interests and
• there would be appropriate safeguard for Processing.

We will inform you of any further Processing and purposes.

5. With whom do we share your Personal Data

We do not share your Personal Data with strangers. Personal Data about you is in some cases provided to our trusted partners in order to either make providing the service to you possible or to enhance your customer experience. We proccess your data with:

Our processing partners:

• Mailchimp (newsletter service)
• Google Analytics (monitoring of performance of our website services)
• Google Tag Manager (monitoring of anonymous user behavior for improvement of our services and marketing)
• Google Ads (remarketing)
• SendPulse (chatbot service)
• Pipedrive (customer relations management)

We only work with Processing partners who are able to ensure adequate level of protection to your Personal Data. We disclose your Personal Data to third parties or public officials when we are legally obliged to do so. We might disclose your Personal Data to third parties if you have consented to it or if there are other legal grounds for it.

We may also need to share your personal data under following circumstances:

• Business ownership changes. We may share/transfer your information under circumstances of a merger, sale of company assets, financing, acquisition of our business to another company (partial or complete).

6. How we secure your data

We do our best to keep your Personal Data safe. We only use safe protocols for communication and transferring data (such as HTTPS). We use anonymising and pseudonymising where suitable. We monitor our systems for possible vulnerabilities and attacks.

Even though we try our best we can not guarantee the security of information. We aim to protect your personal information through a system of organizational and technical security measures. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. No electronic transmission over the Internet or information storage technology is guaranteed to be 100% secure, therefore we cannot promise or guarantee that cybercriminals, or unauthorized third parties will not be able to break our security and improperly collect, access, steal, or modify your information. You should only access the Services within a secure environment.

However, we promise to notify suitable authorities of data breaches. We will also notify you if there is a threat to your rights or interests. We will do everything we reasonably can to prevent security breaches and to assist authorities should any breaches occur.

If you have an account with us, note that you have to keep your username and password secret.

Cookies and other technologies we use

Our website uses cookies, as almost all websites do, to help provide you with the best experience we can. Cookies are small text files that are placed on your computer or mobile phone when you browse websites. Only we can access the cookies created by our website. You can control your cookies at the browser level. Choosing to disable cookies may hinder your use of certain functions.

Our cookies help us:

• Make our website work as you’d expect
• Remember your settings during and between visits
• Improve the speed/security of the site
• Allow you to share pages with social networks like Facebook
• Continuously improve our website for you
• Make our marketing more efficient

We do not use cookies to:

• Collect any personally identifiable information (without your express permission)
• Collect any sensitive information (without your express permission)
• Pass data to advertising networks
• Pass personally identifiable data to third parties
• Pay sales commissions

7. We use these cookies for the following purposes:

Cookie	Purpose	Personal data?	Data type	Storage time
_ga	Google Analytics	anonymous	text	2 years
_gat_*	Google Analytics	anonymous	boolean	1 day
_gid	Google Analytics	anonymous	boolean	1 day
NID	Google Analytics	anonymous	text	6 month
CONSENT	Youtube Video	anonymous	text	13 month
SOCS	Google	anonymous	text	13 month
__cf_bm	Vimeo Player	anonymous	text	1 year
vuid	Vimeo Player	anonymous	text	2 years
player	Vimeo Player	anonymous	text	1 year
_GRECAPTCHA	Google reCAPTCHA	anonymous	text	6 month
privacy_embeds	GDPR Privacy Consent	anonymous	text	90 days

• Necessary cookies – these cookies are required for you to be able to use some important features on our website, such as logging in. These cookies don’t collect any personal information.
• Functionality cookies – these cookies provide functionality that makes using our service more convenient and makes providing more personalised features possible. Our site, like most websites, includes functionality provided by third parties – for example an embedded YouTube video.
• Analytics cookies – these cookies are used to track the use and performance of our website and services

You can remove cookies stored in your computer via your browser settings. Alternatively, you can control some 3rd party cookies by using a privacy enhancement platform such as optout.aboutads.info or youronlinechoices.com. For more information about cookies, visit allaboutcookies.org.

We use Google Analytics to measure traffic on our website. Google has their own Privacy Policy which you can review here. If you’d like to opt out of tracking by Google Analytics, visit the Google Analytics opt-out page.

We use SendPulse to provide chatbots via Facebook Messenger and Instagram DM. SendPulse has their own Privacy Policy which you can review sendpulse.com/legal/pp

We use MailChimp (Intuit) to provide newsletters and email marketing. Mailchimp (Intuit ) has their own Privacy Policy which you can review intuit.com/privacy/statement/

We use Pipedrive to manage customer relationships. Pipedrive has their own Privacy Policy which you can review pipedrive.com/en/privacy

We use Facebook (Meta), Instagram (Meta), LinkedIn and Twitter to reach, communicate and advertise to users of these Social media platforms. All of these platforms have their own privacy policies:

Meta: facebook.com/privacy/policy/?entry_point=data_policy

LinkedIn: linkedin.com/legal/privacy-policy

Twitter: twitter.com/en/privacy

Updates to this notice:

We may update this privacy policy from time to time. If needed, we may inform you about the updates. We suggest you review this policy regularly to stay informed about how we protect your information.

8. Contact information: Data Protection Officer

If you have any questions regarding Processing your Personal Data, your rights regarding your Personal Data or this Privacy Policy, contact our Data Protection Officer at dpo_AT_swimsol_DOT_com