Recruitment Privacy Notice

Last updated October 14, 2025

1. Introduction

1.1 This privacy notice ("Privacy Notice") informs you about how Swarmia Oy ("Company", "we", "us", or "our") processes information about you during our recruitment activities, including when you apply for an open position through our website, recruitment agencies and other available channels, and when we on our own initiative contact you as a potential candidate.

1.2 In this Privacy Notice, "you" refers to the job applicant whose personal data is processed. "Personal data" refers to your personal data that is processed under this Privacy Notice.

1.3 We are committed to respecting your privacy and to complying with applicable data protection and privacy laws and regulations. In this Privacy Notice, we explain what types of personal data we may process and for what purposes. We also explain the choices you have in relation to our processing of your personal data and how you can learn more about our processing and exercise your rights.

2. Data controller

2.1 Swarmia Oy is the data controller for the personal data covered by this Privacy Notice.

2.2 Our contact details are:

• Swarmia Oy
• Business ID: 3094736-9
• Address: Lapinlahdenkatu 16, 00180 Helsinki
• Email: hello@swarmia.com

2.3 If you have any questions about this Privacy Notice or how we handle your personal data, please contact us at careers@swarmia.com or our Data Protection Officer at hello@swarmia.com.

3. Categories of personal data processed

3.1 During the recruitment process, we collect personal data directly from you as well as from other available sources to the extent relevant and permitted by applicable local law. Your personal data that is processed under this Privacy Notice includes the following:

3.2 Information that you submit to us: When you submit an application to us or otherwise apply for an open position (either directly or through an agency or other third party), you may be asked or you may choose to provide us with your personal data, such as:

• your name, address, telephone number, email address, or other contact details;
• your nationality and date of birth;
• your photo (if you choose to include one, for example, in your application or CV);
• your salary request, competences, skills, experience and education (such as in your CV or cover letter), previous employments (such as certificate of employment), educational details and qualifications, as well as possible third-party references;
• possible records relating to your previous employments and education and information contained in such records;
• proof of work/residence permits, including information contained therein; and
• additional personal information that you may choose to provide, such as your hobbies and other interests, languages you speak, and your social media profiles and the like.

3.3 Information we get from other sources: Other information, such as information provided by the references you have nominated may be processed, depending on the position you are applying for. Such information will be processed only when and to the extent permitted by applicable legislation. We may also obtain contact details from public sources (such as your LinkedIn profile) for the purpose of contacting potential candidates.

3.4 Technical information: When you access our website or online application systems, our web servers automatically create records of your visit, including IP addresses and system usage data.

4. Purposes and legal basis for processing

4.1 Your personal data is collected, used, stored, and otherwise processed for the purposes of handling your job application and for other recruitment activities. Your personal data is not used for profiling or other automated decision-making nor direct marketing purposes.

4.2 We will process your personal data during the recruitment process for the following purposes:

• communicating with you during the recruitment process, including obtaining additional information from you, informing you of possible available vacancies, providing you with information relating to your application, and setting up and conducting interviews and assessments;
• managing our recruitment activities, including evaluating, selecting, and recruiting applicants, conducting background and credit checks and assessments as required or permitted by applicable legislation, and contacting third-party references you have nominated; and
• other purposes necessary in the context of our recruitment activities.

4.3 We may also use publicly available contact details for the purpose of contacting you and inquiring about your interest in applying for a job with us.

We do not regularly process any special categories of data, such as information about ethnic origin, sexual orientation, religion or status of health. However, if we process any such data you will be explicitly informed about it and we will process such data strictly for carrying out obligations and exercising specific rights in relation to the employment. The open career opportunities published on our website do not constitute an offer or promise of employment. We may remove or change without notice any aspect(s) of the employment positions, compensation, and benefit plans described on our careers website. Our website provides descriptions of possible positions at Swarmia Oy, and is not providing terms or conditions of employment. Any employment offer that may follow as a result of the recruitment process is in accordance with the specific terms of that offer

4.4 We perform anonymized statistical analysis of our recruitment-related processes. Such activity looks at processes rather than individuals. In this connection, limited information on all parties participating in recruitment may be processed in pseudonymous or anonymous format.

5. Legal grounds for processing

5.1 Applicants: When you submit your application or indicate your willingness to be considered for employment, we process certain personal data as necessary for entering into a contract (specifically, the activities of the recruitment process prior to entering into a potential employment relationship). Some data collected may be subject to another legal basis, such as data we are legally obliged to collect or additional data processed based on consent.

5.2 Sourcing passive candidates: Processing is carried out based on legitimate interest. We have the legitimate interest to search for and contact potential candidates and inquire about their interest to apply for a job. Should you not be interested in applying, we will discontinue processing your personal data for this purpose, unless you state that you wish for us to contact you again in the future.

5.3 Future job opportunities: Even if we do not initially enter an employment relationship, with your consent, we may continue to store your information for future recruitment purposes.

5.4 After the recruitment process: After conclusion of the active recruitment process, we store recruitment data for a limited time to safeguard our legitimate interests.

6. Why are you required to provide the data

6.1 Providing personal data is a requirement necessary to enter into a potential employment contract (in case you are selected) and therefore you will need to provide the personal data requested.

6.2 In case you choose not to provide all the personal data requested during the recruitment process, we will not be able to process your application or continue the recruitment process with you any further and may need to reject you as a candidate.

7. Access to personal data

7.1 Your personal data will be made available to those employees working at our company that are responsible for recruiting activities.

7.2 Your personal data may be made accessible to our service providers or other vendors that we use in the recruitment activities (such as recruiting agencies, providers of web/software services used in recruiting, and hosting providers) for the purpose of providing such services and assisting in the recruitment activities.

7.3 Where we take steps to sell, buy, merge, or otherwise reorganize our businesses, this may involve disclosing personal data to prospective or actual purchasers, sellers, or partners and their advisers. In such circumstances, we will take all reasonable steps to ensure that appropriate measures to protect personal data are taken.

8. Transfer and disclosures of your data

8.1 Where do we get your data from: We may acquire your personal data from your application, your acquaintance or contact referring you as a candidate, our events where you have indicated your interest, via agencies helping us with recruitment, or from publicly available profiles.

8.2 International transfers: Your personal data may be transferred to countries outside the European Economic Area where necessary for the recruitment process. When transferring your personal data outside the European Economic Area, we will ensure that the transfer is legal and safe by concluding an agreement based on the EU Commission's standard contractual clauses or taking other measures permissible under applicable legislation.

9. Retention

9.1 Application for a specific position: Your personal data will be processed for as long as it is necessary for the purpose of processing your application and carrying out the related recruitment activities.

9.2 After immediate activities relating to the recruitment process, we store the data for as long as we have a legitimate need to keep the data. The length of retention is based on specific statutory limitation periods and other legal requirements.

9.4 Future job opportunities: With your consent, we may continue to store your information for future recruitment purposes after the above retention periods have been exceeded.

10. Security

10.1 We are committed to keeping your personal data safe. We implement appropriate technical and organizational measures to ensure sufficient data security.

10.2 Sufficient security measures are put in place to prevent unauthorized access to and manipulation of your personal data. This includes restricting access to your personal data to authorized persons and hosting your personal data with service providers that demonstrate an adequate level of data security.

10.3 We take appropriate steps to address online security, physical security, risk of data loss, and other such risks, taking into consideration the risk represented by the processing and the nature of the data being protected.

11. Exercising your rights

11.1 You have the right to access your personal data processed under this Privacy Notice. You have the right to request correction and removal of your personal data.

11.2 In addition, you have the right to request the restriction of processing of your personal data and to object to the processing on grounds provided by the applicable legislation. You also have the right to receive the personal data you have provided to us and transmit it to another controller.

11.3 You can withdraw consent at any time in relation to processing based on consent.

11.4 You have the right to lodge a complaint to the supervisory authority The Data Protection Ombudsman at tietosuoja@om.fi in case you think that your rights have been violated.

11.5 To exercise your rights under the applicable legislation or if you have other questions about this Privacy Notice, contact us at careers@swarmia.com.

12. Reasonable adjustments

12.1 If you require any reasonable adjustments to the recruitment process due to a disability, please contact us as soon as possible so we can discuss how to accommodate your needs.

12.2 Any health information you provide for this purpose will be processed in accordance with this Privacy Notice and applicable data protection laws.

13. Changes

13.1 To keep this Privacy Notice up to date, we make changes and additions from time to time. We publish the updated notice on our website or on another channel where this notice has previously been made available.

13.2 Any changes apply from the date that we publish the revised Privacy Notice.