1. Introduction
Titan Consulting (“Titan Consulting”, “we”, “us”, or “our”) is committed to protecting the privacy and security of the personal data of our users, clients, and website visitors. This Privacy Policy describes how we collect, use, store, share, and protect your personal data when you access or use our software-as-a-service platform and related services (the “Service”).
This Privacy Policy is issued in compliance with the Swiss Federal Act on Data Protection (FADP) and, where applicable, the EU General Data Protection Regulation (GDPR).
By accessing or using the Service, you acknowledge that you have read and understood this Privacy Policy.
2. Data Controller
The data controller responsible for the processing of your personal data is:
Titan Consulting
Email: info@swarmix.ai
3. Personal Data We Collect
3.1 Data You Provide Directly
- Account registration data: name, email address, company name, job title
- Billing and payment data: billing address, payment method details (processed by our third-party payment processor)
- Communications: any messages, enquiries, or feedback you send to us
- Content: any data, files, documents, or other materials you upload to the Service
3.2 Data Collected Automatically
- Device and browser information: IP address, browser type, operating system, device identifiers
- Usage data: pages visited, features used, actions taken, session duration, timestamps
- Log data: server logs, error reports, and diagnostic information
- Cookies and similar technologies: as described in Section 13 of this Policy
3.3 Data from Third Parties
We may receive personal data from third-party sources, such as authentication providers and analytics providers. We process this data only in accordance with this Privacy Policy and applicable law.
4. Purposes and Legal Bases for Processing
We process your personal data for the following purposes:
- Providing and maintaining the Service (performance of contract)
- Account management and authentication (performance of contract)
- Billing and payment processing (performance of contract / legal obligation)
- Customer support (performance of contract / legitimate interest)
- Service improvement and analytics (legitimate interest)
- Security and fraud prevention (legitimate interest / legal obligation)
- Marketing communications with consent (consent)
- Legal compliance and regulatory obligations (legal obligation)
5. Data Sharing and Disclosure
Titan Consulting does not sell your personal data. We may share your personal data with:
- Service providers: Trusted third parties performing functions on our behalf (cloud hosting, payment processing, analytics, email delivery)
- Business transfers: In the event of a merger, acquisition, or sale of assets
- Legal requirements: When required by law, court order, or governmental regulation
- With your consent: When you have given explicit consent
6. International Data Transfers
Your personal data may be transferred to countries outside Switzerland or the EEA. When doing so, we ensure appropriate safeguards are in place, including Standard Contractual Clauses (SCCs) and transfers to countries with adequate data protection levels.
7. Data Retention
- Account data: retained for the duration of your Account and a reasonable period following closure
- Billing data: retained for a minimum of ten (10) years in accordance with Swiss law
- Usage and log data: retained for a reasonable period for analytics and security
- Content: deleted within thirty (30) days following Account termination
8. Data Security
We implement appropriate technical and organisational measures to protect your personal data, including:
- Encryption of data in transit (TLS/SSL) and at rest (AES-256)
- Access controls and multi-factor authentication
- Regular security assessments and penetration testing
- Incident response procedures for data breach notification
9. Data Breach Notification
In the event of a personal data breach, we will notify the competent supervisory authority within seventy-two (72) hours. Where the breach is likely to result in a high risk to your rights, we will also notify you directly.
10. Agent Coordination and Data Processing
The Service operates as a coordination layer for AI coding agents using the Model Context Protocol (MCP):
- No embedded AI models: The Service does not include or operate any large language models
- Conversation and proposal data: Stored in our database for coordination functionality. Not used to train any AI models
- Agent metadata: Agent identifiers, roles, and repository associations used solely for coordination and access control
- No data sent to third-party AI providers: All data processing occurs within our own infrastructure
11. Sub-Processors
We engage cloud hosting providers, payment processors, email delivery services, and analytics services (subject to cookie consent). A current list of specific sub-processors is available upon request by contacting info@swarmix.ai.
12. Your Rights
Under the Swiss FADP
- Right of access to your personal data
- Right to rectification of inaccurate data
- Right to deletion, subject to legal retention obligations
- Right to data portability in a machine-readable format
- Right to object to processing under certain circumstances
Under the GDPR (for EU/EEA Residents)
- Right to restriction of processing
- Right to withdraw consent at any time
- Right not to be subject to automated decision-making
- Right to lodge a complaint with a supervisory authority
To exercise any of these rights, contact us at info@swarmix.ai. We will respond within thirty (30) days.
13. Cookies and Similar Technologies
Our Service uses cookies:
- Strictly necessary: Essential for functionality, security, authentication (no consent required)
- Performance / Analytics: Measure usage, improve performance (consent required)
- Functional: Remember preferences and settings (consent required)
You can manage cookie preferences through your browser settings or our cookie consent tool.
14. Children's Privacy
The Service is not intended for use by individuals under the age of sixteen (16). We do not knowingly collect personal data from children.
15. Automated Decision-Making
Titan Consulting does not use automated decision-making or profiling that produces legal effects or similarly significantly affects you.
16. Changes to This Privacy Policy
We may update this Privacy Policy from time to time. When we make material changes, we will notify you at least thirty (30) days before they take effect.
17. Contact Information
For questions regarding this Privacy Policy or the processing of your personal data:
Titan Consulting — Data Protection
Email: info@swarmix.ai
Swiss Federal Data Protection and Information Commissioner (FDPIC):
Feldeggweg 1, CH-3003 Bern
www.edoeb.admin.ch