Privacy Policy

Powered Collectively

Last Updated: October 2025

Your privacy matters. This Privacy Policy explains how Swarmly (ABN 46 139 600 411) collects, uses, discloses, and protects your personal information in accordance with the Australian Privacy Principles (APPs) under the Privacy Act 1988 (Cth).

1. About Swarmly

Swarmly is a Darwin-based business consultancy operating as a business of Swarm Impact. We provide team development, leadership coaching, strategic planning, operational improvement, and training services to commercial businesses and non-profit organisations across the Northern Territory.

Contact Details:

2. Information We Collect

2.1 Personal Information

We may collect the following types of personal information:

2.2 How We Collect Information

We collect personal information through:

3. How We Use Your Information

We use your personal information for the following purposes:

Marketing Communications: We will only send you marketing communications if you have provided consent. You can opt out at any time by clicking "unsubscribe" in our emails or contacting us directly.

4. Social Media & LinkedIn Pages

4.1 LinkedIn Company Page

Swarmly operates a LinkedIn Company Page. When you interact with our LinkedIn Page:

4.2 Joint Controllers

For LinkedIn Page Insights, Swarmly and LinkedIn are joint controllers of personal data under GDPR (for visitors from the EU/EEA). LinkedIn is primarily responsible for enabling you to exercise your rights regarding Page Insights data. See LinkedIn's Privacy Policy for details.

4.3 Social Media Interaction

When you interact with our social media presence:

5. Information Sharing & Disclosure

We respect your privacy and limit information sharing to:

5.1 Service Providers

We may share information with trusted service providers who assist our business operations:

All service providers are required to protect your information and use it only for specified purposes.

5.2 Legal Requirements

We may disclose personal information when required by law or to:

5.3 Business Transfers

If Swarmly is involved in a merger, acquisition, or sale of assets, your information may be transferred to the new entity, subject to this Privacy Policy.

5.4 With Your Consent

We may share information with third parties when you have provided explicit consent.

6. Data Security

We take reasonable steps to protect your personal information from:

Security Measures Include:

Important: While we implement security measures, no method of transmission or storage is 100% secure. We cannot guarantee absolute security of your information.

7. Data Retention

We retain personal information only as long as necessary for:

When information is no longer required, we securely delete or anonymise it.

8. Your Rights

Under the Australian Privacy Principles, you have the right to:

8.1 Access Your Information

Request access to the personal information we hold about you. We will provide this within a reasonable timeframe, usually 30 days.

8.2 Correction

Request correction of inaccurate, incomplete, or out-of-date information. We will take reasonable steps to correct information upon request.

8.3 Erasure

Request deletion of your personal information, subject to legal retention requirements.

8.4 Restrict Processing

Request restriction of how we use your information in certain circumstances.

8.5 Object to Processing

Object to our processing of your information for marketing purposes.

8.6 Data Portability

Request transfer of your information to another service provider where technically feasible.

8.7 Withdraw Consent

Withdraw consent for processing where consent is the legal basis (e.g., marketing communications).

8.8 Complain

Make a complaint about how we handle your personal information. See Section 11 below.

How to Exercise Your Rights

To exercise any of these rights, contact us:

We will respond to your request within 30 days. We may need to verify your identity before processing your request.

9. Cookies & Website Analytics

9.1 What Are Cookies?

Cookies are small text files stored on your device when you visit our website. They help us understand how visitors use our site.

9.2 Cookies We Use

9.3 Third-Party Services

Our website may use:

9.4 Managing Cookies

You can control cookies through your browser settings. Note that disabling cookies may affect website functionality.

10. International Data Transfers

Your information is primarily stored and processed in Australia. However, some service providers (e.g., cloud services, email platforms) may store data on servers outside Australia.

When we transfer data internationally:

By using our services, you consent to these international transfers.

11. Complaints & Disputes

11.1 Making a Complaint

If you believe we have breached your privacy, please contact us first:

11.2 Our Response Process

  1. We will acknowledge your complaint within 7 days
  2. We will investigate the matter thoroughly
  3. We will provide a written response within 30 days
  4. If you're unsatisfied, we will work with you to find a resolution

11.3 External Complaints

If you're not satisfied with our response, you can lodge a complaint with:

Office of the Australian Information Commissioner (OAIC)

Website: www.oaic.gov.au

Phone: 1300 363 992

Email: enquiries@oaic.gov.au

Mail: GPO Box 5218, Sydney NSW 2001

12. Children's Privacy

Our services are designed for businesses and professional adults. We do not knowingly collect personal information from individuals under 18 years of age. If we become aware that we have inadvertently collected information from a minor, we will take steps to delete it promptly.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect:

When we make changes:

We encourage you to review this policy periodically.

14. Contact Us

Questions About This Privacy Policy?

If you have questions, concerns, or requests regarding this Privacy Policy or how we handle your personal information, please contact:

Swarmly
Business of Swarm Impact
ABN 46 139 600 411

Email: jeremie@swarmly.com.au
Location: Darwin, Northern Territory, Australia

We aim to respond to all enquiries within 7 business days.

15. Consent

By using our services, visiting our website, or engaging with our LinkedIn Page, you acknowledge that you have read and understood this Privacy Policy and consent to the collection, use, and disclosure of your personal information as described herein.

Your trust matters to us. At Swarmly, we believe in collective intelligence and that includes respecting the privacy of every individual in our professional community. We're committed to protecting your information and using it responsibly to serve you better.

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