Cookie Policy

1. Introduction

This Cookie Policy explains how Swarm Capital LLC ("Swarm Capital," "we," "us," or "our") uses cookies and similar tracking technologies when you visit our website at swarm-us.com (the "Site"). This policy explains what these technologies are and why we use them, as well as your rights to control their use.

Cookies are small data files placed on your device (computer, tablet, or mobile phone) when you visit a website. Cookies are widely used by website owners to make their websites work, or to work more efficiently, as well as to provide reporting information. Cookies set by Swarm Capital directly are called "first-party cookies." Cookies set by parties other than Swarm Capital are called "third-party cookies." Third-party cookies enable third-party features or functionality to be provided on or through our Site, such as analytics, interactive content, and advertising.

2. Why We Use Cookies

We use cookies for several purposes. Some cookies are required for technical reasons in order for our Site to operate, and we refer to these as "essential" or "strictly necessary" cookies. Other cookies enable us to understand how visitors interact with our Site, which helps us improve the user experience. Still others help us deliver relevant content and measure the effectiveness of our communications.

Specifically, we use cookies and similar tracking technologies to:

• Remember your preferences and settings to provide a better user experience
• Understand how you navigate the Site so we can improve it
• Analyze aggregate statistics about Site usage (e.g., page views, visit duration, traffic sources)
• Maintain the security and integrity of the Site
• Store information about your cookie consent preferences
• Enable basic Site functionality that requires session state management
• Deliver content that is relevant to your interests (where applicable)
• Measure the effectiveness of our marketing communications (where applicable)

3. Types of Cookies We Use

The following table describes the categories of cookies used on the Site, their purpose, and their retention duration:

Cookie Category	Purpose	Retention	Can be Disabled?
Strictly Necessary / Essential	Required for the Site to function. These cookies enable basic features like page navigation, form submissions, and security. The Site cannot function properly without these cookies.	Session to 1 year	No — required for Site operation
Functional / Preference	Enable the Site to remember information that changes the way the Site behaves or looks, such as your preferred language, region, or display settings. These cookies enhance the functionality and personalization of the Site.	Up to 1 year	Yes — may affect functionality
Analytics / Performance	Collect aggregated, anonymized information about how visitors use the Site, such as which pages are visited most frequently and whether visitors receive error messages. This information helps us improve the Site and optimize user experience. We use Google Analytics for this purpose.	Up to 2 years	Yes — opt out available
Marketing / Advertising	Track visitors across websites to display relevant advertisements on third-party websites. These cookies are set by us or our advertising partners and may be used to build a profile of your interests. Currently, Swarm Capital uses limited third-party marketing cookies associated with LinkedIn Insight Tag for professional audience analytics.	Up to 90 days	Yes — opt out available

4. Specific Cookies and Tracking Technologies

4.1 Essential Cookies

Cookie Name	Provider	Purpose	Expiration
sc_session	swarm-us.com	Maintains user session state, including form data and navigation state	Session (deleted when browser closes)
sc_csrf	swarm-us.com	Cross-Site Request Forgery (CSRF) protection token to prevent unauthorized form submissions	Session
sc_consent	swarm-us.com	Stores your cookie consent preferences to avoid repeatedly showing the consent banner	1 year
sc_security	swarm-us.com	Maintains security state and authentication for protected areas of the Site	Session

4.2 Analytics Cookies

Cookie Name	Provider	Purpose	Expiration
_ga	Google Analytics	Distinguishes unique users by assigning a randomly generated number as a client identifier. Included in each page request in a site and used to calculate visitor, session, and campaign data for the sites analytics reports.	2 years
_gid	Google Analytics	Stores and updates a unique value for each page visited and is used to distinguish users	24 hours
_gat	Google Analytics	Used to throttle request rate (limits data collection on high-traffic sites)	1 minute
_gac_*	Google Analytics	Contains campaign related information for the user. If you have linked your Google Analytics and Google Ads accounts, this cookie is used to track conversions	90 days

4.3 Functional Cookies

Cookie Name	Provider	Purpose	Expiration
sc_lang	swarm-us.com	Stores your preferred language setting	1 year
sc_theme	swarm-us.com	Stores your preferred display theme (if applicable)	1 year
sc_notify_dismissed	swarm-us.com	Records whether you have dismissed a Site notification	30 days

4.4 Marketing and Third-Party Cookies

Cookie Name	Provider	Purpose	Expiration
li_fat_id	LinkedIn	LinkedIn Insight Tag — Member indirect identifier for cross-device tracking for LinkedIn advertising and analytics	30 days
AnalyticsSyncHistory	LinkedIn	Used to store information about the time a sync took place with the lms_analytics cookie	30 days
UserMatchHistory	LinkedIn	LinkedIn Ads ID syncing for LinkedIn member matching	30 days
lidc	LinkedIn	Facilitates data center selection for routing new site visitor activity	24 hours

5. Similar Tracking Technologies

In addition to cookies, we may use other tracking technologies on the Site, including:

• Web Beacons / Pixel Tags: Small graphic images (also known as "clear GIFs" or "pixel tags") embedded in web pages or emails that collect information about how you interact with those pages or emails. Web beacons can be used to determine, for example, whether a message has been opened.
• Local Storage and Session Storage: Technologies built into modern browsers that allow websites to store data on your device. Unlike cookies, data stored in local storage is not transmitted to our servers with every request, but remains on your device until it is cleared.
• Browser Fingerprinting: A technique that creates a unique identifier for your browser based on its characteristics, such as its type, version, installed plugins, and other settings. We do not currently use browser fingerprinting for tracking purposes.
• IP Address Tracking: We collect your IP address as part of standard web server logging. IP addresses may be used to determine your approximate geographic location and to detect fraudulent or suspicious activity.

6. How to Manage and Control Cookies

You have several options for managing and controlling how cookies are used when you visit our Site.

6.1 Cookie Consent Banner

When you first visit our Site, you will see a cookie consent banner that allows you to accept or decline non-essential cookies. You can change your preferences at any time by clicking the "Cookie Preferences" link in the footer of our Site. Please note that declining non-essential cookies may affect the functionality of the Site.

6.2 Browser Settings

Most web browsers allow you to control cookies through their settings. You can typically find these settings in the "options" or "preferences" menu of your browser. You can set your browser to:

• Notify you when you receive a cookie, which gives you the chance to decide whether to accept it
• Turn off all cookies
• Block third-party cookies
• Delete all cookies when you close your browser (using a "private" or "incognito" mode)
• Block cookies from specific sites

For instructions on how to manage cookies in your browser, please refer to your browser's help documentation:

• Google Chrome: Settings > Privacy and Security > Cookies and other site data
• Mozilla Firefox: Options > Privacy & Security > Cookies and Site Data
• Safari: Preferences > Privacy > Cookies and website data
• Microsoft Edge: Settings > Cookies and site permissions > Cookies and site data

Please note that if you disable cookies, some features of the Site may not function properly. Disabling essential cookies will significantly impair your ability to use the Site.

6.3 Google Analytics Opt-Out

To opt out of Google Analytics tracking across all websites, you can install the Google Analytics Opt-out Browser Add-on, available at https://tools.google.com/dlpage/gaoptout. You can also opt out of Google Analytics for the Site by clicking the "Cookie Preferences" link and disabling analytics cookies.

6.4 LinkedIn Insight Tag Opt-Out

You can opt out of LinkedIn's Insight Tag tracking by visiting . Alternatively, you can disable marketing cookies through our Cookie Preferences center.

6.5 Industry-Level Opt-Out Tools

You can opt out of interest-based advertising from participating companies through the following industry opt-out tools:

• Digital Advertising Alliance (DAA): optout.aboutads.info
• Network Advertising Initiative (NAI): optout.networkadvertising.org
• European Interactive Digital Advertising Alliance (EDAA): youronlinechoices.eu

6.6 Do Not Track

Some browsers have a "Do Not Track" (DNT) feature that lets you tell websites that you do not want to have your online activities tracked. Currently, our Site does not respond to DNT signals from browsers. We do not currently respond to browser-initiated DNT signals because there is no consistent industry standard for what "tracking" means in this context or how to honor these signals. We will continue to monitor developments in the DNT field and revisit this policy if a clear standard emerges.

7. Consent Requirements Under GDPR and UK GDPR

For users located in the European Economic Area (EEA) or the United Kingdom, we are required under the GDPR and UK GDPR to obtain your prior informed consent before placing non-essential cookies on your device. Essential cookies that are strictly necessary for the Site to function are placed without consent on the basis of legitimate interests (Article 6(1)(f) GDPR).

When you first visit our Site from the EEA or UK, you will see a cookie consent banner asking for your consent to place analytics, functional, and marketing cookies. You can accept all non-essential cookies, reject all non-essential cookies, or customize your preferences by category. You may change your consent at any time by clicking "Cookie Preferences" in the footer.

We maintain records of your cookie consent choices, including the date and time of consent, the categories of cookies consented to, and the version of our cookie policy in effect at the time of consent, in compliance with GDPR accountability requirements (Article 5(2)).

8. California Privacy Rights and CCPA

Under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA), California residents have the right to opt out of the "sharing" of personal information for cross-context behavioral advertising purposes. Our use of certain advertising cookies may constitute "sharing" under the CPRA. California residents may opt out by clicking "Cookie Preferences" in the footer of the Site and disabling marketing cookies, or by visiting our Privacy Policy for full CCPA rights information.

9. Cross-Border Cookie Data Transfers

Cookie data collected on the Site may be processed outside of your country of residence, including in the United States. For transfers from the EEA or UK, we rely on appropriate safeguards for such transfers as described in our Privacy Policy, including Standard Contractual Clauses with service providers such as Google LLC and LinkedIn Corporation.

10. Updates to This Cookie Policy

We may update this Cookie Policy from time to time to reflect changes in the cookies we use, our data practices, or applicable legal requirements. When we make material changes, we will update the "Last Updated" date at the top of this policy and, where required by law, obtain fresh consent from users in the EEA and UK through our cookie consent mechanism.

11. Contact Us

If you have questions about our use of cookies or other tracking technologies, or if you would like to exercise any rights related to the use of cookies, please contact us:

• Email: privacy@swarm-us.com
• Data Protection Officer: dpo@swarm-us.com
• Postal Address: Swarm Capital LLC, Privacy Team, 340 Pine Street, Suite 1800, San Francisco, CA 94104, United States
• Phone: +1 (415) 555-0182

For EU residents, you may also contact our EU representative at eu-rep@swarm-us.com. For UK residents, please contact our UK representative at uk-rep@swarm-us.com.

If you are located in the EEA and are not satisfied with our response to your cookie-related inquiry, you have the right to lodge a complaint with your local data protection supervisory authority. UK residents may contact the Information Commissioner's Office (ICO) at ico.org.uk.