Privacy · The Swink Group

Your information shouldn't be a mystery.

This Policy explains what information The Swink Group may collect, why we use it, when it may need to move through another system or business, and what choices you may have. The short version: collect what we reasonably need, use it for legitimate business purposes, and don't turn your information into an advertising product.

Information Flow · High-Level View

No Advertising Tracking Active

  1. Source

    You

    • Contact

      Name, email, phone, business information

    • Business Context

      Problems, goals, systems, team and service information

    • Candidate Data

      Résumés, experience, skills, interviews and placement information

    • Technical

      Device, browser, IP and basic website diagnostic information

  2. Processing Point

    The Swink Group uses what the work requires.

    Information may support inquiries, service delivery, systems work, recruiting, placement, communications, billing, security, recordkeeping, and legal obligations.

    • Service Providers

      Business technology used to operate and deliver Services.

    • Placement Clients

      Relevant candidate information when evaluating a placement.

    • Legal / Required

      Disclosure where law, security, or legitimate legal process requires it.

  • No Ad Pixels

    No Meta/Facebook Pixel, Google Ads conversion tracking, or retargeting pixels currently used.

  • No Data Brokerage

    We do not sell personal information to data brokers or advertisers for money.

  • No Behavioral Advertising

    TSG does not currently use website information for cross-context behavioral advertising.

Privacy Policy · Last Updated August 30, 2026

This Privacy Policy explains how Jeremy Allen Swink, LLC, doing business as The Swink Group (“The Swink Group,” “TSG,” “Company,” “we,” “us,” or “our”) collects, uses, discloses, stores, and protects personal information in connection with our websites, communications, professional Services, recruiting and placement activities, forms, scheduling systems, and other interactions with you.

01 Collection

What information enters the system?

Article 01: Information We Collect#

A. Contact and Identity Information

We may collect information such as:

  • name;
  • email address;
  • telephone number;
  • business name;
  • job title or role;
  • mailing or business address;
  • location; and
  • other contact information you choose to provide.

B. Business and Service Inquiry Information

When you contact us about consulting, advisory, systems, marketing, Remote Assistant placement, or other Services, we may collect information concerning:

  • your business;
  • industry;
  • business model;
  • operational challenges;
  • customer or client processes;
  • team structure;
  • technology and systems;
  • business goals;
  • current problems or priorities;
  • requested Services;
  • information submitted through Strategy Call or other intake forms; and
  • other context you voluntarily provide.

C. Client and Engagement Information

If you become a client, we may collect and maintain information necessary to perform and administer the engagement, including agreements, proposals, Statements of Work, invoices, communications, meeting notes, documents, CRM or system information, implementation requirements, account information, client-provided data, and records of Services performed.

D. Remote Assistant, Virtual Assistant, and Candidate Information

If you apply for, inquire about, or are considered for a Remote Assistant, Virtual Assistant, contractor, staffing, or placement opportunity, we may collect information such as:

  • name and contact information;
  • location and time zone;
  • résumé or curriculum vitae;
  • employment and work history;
  • education;
  • skills and experience;
  • portfolio materials or work samples;
  • availability;
  • compensation expectations;
  • interview information and notes;
  • assessment results;
  • professional references;
  • communications with us;
  • information supplied through recruiting platforms; and
  • other information reasonably relevant to recruiting or placement.

Where appropriate and disclosed, additional verification, background, reference, or identity-related information may be collected directly or through third-party providers.

We do not require candidates to provide sensitive personal information that is unnecessary for the recruiting or placement process.

E. Information We Process on Behalf of Clients

Certain Services may require us to access or process personal information contained within a client's CRM, database, customer records, communication systems, marketing platforms, operational systems, or other business tools.

In those circumstances, we generally process that information for the purpose of providing Services to the client and according to the client's instructions and our applicable agreement.

The client remains responsible for determining the lawful basis for collecting its own customers', employees', contractors', or other individuals' information and for providing any notices or obtaining any consents required by law.

F. Communications

We may retain emails, SMS or text messages, form submissions, meeting communications, support requests, telephone or voicemail records where applicable, scheduling information, and other correspondence with us.

G. Payment and Transaction Information

Payments may be processed through third-party payment processors. We do not generally store full payment-card numbers ourselves.

We may receive billing names, billing addresses, transaction amounts, payment status, invoice information, payment method type, limited payment identifiers, and transaction history.

H. Technical and Website Information

When you use our website or online Services, certain information may be collected automatically, including:

  • IP address;
  • browser type;
  • operating system;
  • device type;
  • referring pages;
  • pages viewed;
  • date and time of access;
  • website interactions;
  • approximate location derived from IP address;
  • cookies or similar identifiers; and
  • diagnostic, security, or performance information.

Article 02: Where We Obtain Information#

We may obtain personal information:

  • directly from you;
  • through our website;
  • through intake and contact forms;
  • through scheduling systems;
  • through email, telephone, SMS, or video meetings;
  • through client engagements;
  • through recruiting or applicant systems;
  • through referrals;
  • through professional networking or recruiting platforms;
  • from candidates or professional references;
  • from clients seeking staffing or placement Services;
  • from service providers;
  • from publicly available professional or business sources; and
  • automatically through website or technology interactions.

Collection Principle

We do not intentionally collect more personal information than we reasonably need for legitimate business purposes.

02 Purpose

Why do we use it?

Article 03: How We Use Personal Information#

We may use personal information to:

  • respond to inquiries;
  • evaluate whether our Services may be appropriate;
  • schedule consultations or Strategy Calls;
  • provide consulting and advisory Services;
  • perform operational or client-success work;
  • design, configure, or support systems and technology;
  • provide marketing, website, or digital Services;
  • source, evaluate, recruit, match, and place Remote Assistants or other candidates;
  • communicate with candidates and clients;
  • facilitate candidate interviews or placement decisions;
  • onboard and support engagements;
  • provide customer or client support;
  • administer agreements and projects;
  • process transactions and payments;
  • maintain business and accounting records;
  • send appointment reminders and service communications;
  • improve our Services and internal operations;
  • maintain and protect our systems;
  • detect or prevent fraud, abuse, or security incidents;
  • enforce agreements;
  • comply with legal obligations;
  • establish, exercise, or defend legal claims; and
  • perform other purposes disclosed when information is collected.

We may also use information for marketing communications where permitted by law and consistent with your communication preferences.

Article 04: Remote Assistant and Candidate Placement#

Because Remote Assistant and talent placement is part of our business, candidate information may need to be shared with prospective or existing client organizations considering an individual for an opportunity.

Depending on the placement process, we may share relevant information such as:

  • résumé or professional profile;
  • work history;
  • skills;
  • portfolio or work samples;
  • assessment information;
  • availability;
  • compensation expectations;
  • interview information; and
  • other information reasonably relevant to evaluating the candidate.

We seek to limit candidate information shared with clients to information reasonably relevant to recruitment, evaluation, placement, or engagement.

Submitting information for consideration does not guarantee placement, employment, engagement, interview, or selection.

Article 09: Artificial Intelligence and Automated Tools#

We may use artificial intelligence, automation, or software-assisted tools to support legitimate business functions such as:

  • drafting;
  • summarization;
  • research;
  • analysis;
  • documentation;
  • coding;
  • workflow development;
  • administrative work;
  • recruiting support; and
  • service delivery.

These systems may be operated by third-party service providers.

We use such tools as aids to our work rather than assuming their outputs are always accurate.

Where personal or confidential information is involved, we seek to use reasonable judgment concerning what information is appropriate to process through third-party tools.

Material consulting, placement, or business decisions remain subject to human judgment where appropriate.

03 Disclosure

Where may information go?

Article 05: How We Share Personal Information#

Core Disclosure

We do not sell personal information for money.

A. Service Providers

We use third-party providers to operate parts of our business. These may include providers of CRM systems, website hosting, scheduling, communications, email, SMS, cloud storage, payment processing, accounting, video conferencing, recruiting, automation, analytics, artificial intelligence, cybersecurity, document management, and other business technology.

B. Clients and Prospective Clients

Where we provide Remote Assistant, recruiting, staffing, or placement Services, relevant candidate information may be disclosed to organizations considering the candidate for an engagement.

C. Contractors and Personnel

Personal information may be accessible to employees, contractors, Remote Assistants, consultants, or other personnel who reasonably need access to perform work for the Company.

D. Professional Advisors

We may disclose information to attorneys, accountants, insurers, auditors, consultants, or other professional advisors where reasonably necessary.

E. Legal and Safety Requirements

We may disclose information where we reasonably believe disclosure is necessary to comply with applicable law, respond to lawful process, protect legal rights, investigate fraud, enforce an agreement, protect safety or security, or establish or defend legal claims.

F. Business Transactions

If Jeremy Allen Swink, LLC or relevant business assets are involved in a merger, acquisition, financing, restructuring, reorganization, sale, or similar transaction, personal information may be disclosed or transferred as part of that transaction, subject to applicable law.

G. With Your Direction or Consent

We may disclose information when you direct us to do so or otherwise consent to the disclosure.

Article 06: SMS and Telephone Communications#

If you provide a telephone number and consent to receive text messages, we may send communications related to:

  • appointments;
  • inquiries;
  • requested Services;
  • client support;
  • engagement updates;
  • follow-ups; and
  • marketing communications where separately permitted.

Consent to receive marketing text messages is not required merely to browse our website.

Message frequency may vary. Message and data rates may apply.

You may opt out of SMS communications by replying STOP or otherwise clearly telling us that you no longer wish to receive text messages.

SMS Privacy

Mobile information and SMS consent information will not be sold or shared with third parties or affiliates for their own marketing or promotional purposes.

Article 07: Cookies and Similar Technologies#

Our website and technology providers may use cookies and similar technologies for purposes such as:

  • website functionality;
  • security;
  • session management;
  • remembering preferences;
  • diagnostics;
  • performance measurement; and
  • basic analytics.

You may be able to control cookies through your browser settings. Disabling certain cookies may affect website functionality.

Advertising and Behavioral Tracking

As of the Last Updated date of this Policy, The Swink Group does not use third-party advertising pixels, retargeting tools, or behavioral advertising technologies such as Meta/Facebook Pixel or Google Ads conversion tracking.

Article 08: Sale, Sharing, and Targeted Advertising#

We do not sell personal information for monetary consideration.

As of the Effective Date, we do not intentionally use personal information collected through the TSG website for cross-context behavioral advertising.

Some privacy laws use terms such as “sale” or “sharing” more broadly than ordinary language.

If our practices change in a manner that creates additional rights under applicable law, we will update this Policy and provide required opt-out mechanisms.

04 Stewardship

How is information maintained and protected?

Article 10: Data Retention#

We retain personal information for as long as reasonably necessary for the purposes described in this Policy, including to:

  • provide Services;
  • maintain client and candidate records;
  • administer engagements;
  • maintain accounting and transaction records;
  • comply with legal obligations;
  • resolve disputes;
  • enforce agreements;
  • maintain legitimate business records;
  • prevent fraud or abuse; and
  • protect our legal interests.

Retention periods vary depending on the type of information, why it was collected, contractual requirements, applicable law, and legitimate business needs.

When information is no longer reasonably required, we may delete, anonymize, aggregate, or securely dispose of it.

Article 11: Information Security#

We use reasonable administrative, technical, and organizational safeguards appropriate to the nature of the information we maintain.

Safeguards may include access controls, authentication measures, restricted permissions, secure third-party platforms, account-security practices, and other measures appropriate to our operations.

No internet transmission, cloud platform, database, or electronic storage system can be guaranteed to be completely secure.

Accordingly, we cannot guarantee absolute security.

Article 12: International Processing and Transfers#

The Swink Group operates remotely and may work with personnel, contractors, candidates, clients, and technology providers located in different countries.

As a result, personal information may be accessed, stored, or processed in the United States or other jurisdictions where we or our service providers operate.

Privacy and data-protection laws may differ between jurisdictions.

Where applicable law requires specific safeguards for international transfers, we will use reasonable measures intended to comply with those requirements.

05 Control

What choices may you have?

Article 13: Your Privacy Rights#

Depending on where you live and the laws applicable to us, you may have rights concerning your personal information.

Access
Request personal information we maintain about you.
Correction
Ask us to correct inaccurate personal information.
Deletion
Request deletion where applicable law permits it.
Portability
Request a portable copy of certain information where applicable.
Consent
Withdraw consent where processing is based on consent.
Marketing
Opt out of marketing communications.
Certain Advertising Uses
Exercise applicable opt-out rights if our practices ever trigger them.
Appeal
Appeal certain privacy-request decisions where required by law.

Not every right applies in every circumstance or to every business.

Nothing in this Policy is intended to limit rights that cannot lawfully be waived.

Article 14: Exercising Your Privacy Rights#

To submit a privacy request, contact: [email protected]

Please include enough information for us to understand and reasonably verify the request.

We may ask for additional information where reasonably necessary to verify your identity or authority to make the request.

We will not discriminate against you for exercising a privacy right provided by applicable law.

Certain requests may be denied or limited where permitted by law, including where information must be retained for contractual, security, tax, legal, fraud-prevention, dispute, or recordkeeping purposes.

Where applicable law provides a right to appeal a privacy decision, you may submit an appeal using the same email address and identify the request as a Privacy Appeal.

Article 15: Marketing Communications#

You may opt out of marketing email communications by using the unsubscribe mechanism provided in the message where available or by contacting us.

Opting out of marketing does not prevent us from sending legitimate transactional or service-related communications, such as:

  • appointment confirmations;
  • invoices;
  • contractual communications;
  • security notices;
  • project updates; or
  • responses to inquiries.

06 Governance

The rest of the privacy framework.

Article 16: Children's Privacy#

Our website and Services are intended for businesses and adults.

We do not knowingly solicit personal information from children under the age of 18 through our general Services.

If you believe that a minor has provided personal information to us inappropriately, contact us so we can review the matter and take appropriate action.

Article 17: Third-Party Websites and Services#

Our website or communications may contain links to third-party websites, applications, tools, products, or services.

Once you leave a TSG-controlled environment, the third party's own terms and privacy practices apply.

We are not responsible for the privacy practices, security, content, or operation of independent third-party services.

Article 18: Legal and Regulatory Requirements#

Jeremy Allen Swink, LLC is organized in Wyoming, United States.

Our privacy practices are subject to applicable federal, state, local, and, where relevant, international laws.

Nothing in this Policy is intended to eliminate or restrict privacy rights that applicable law does not permit us to waive.

Article 19: Changes to This Privacy Policy#

We may update this Privacy Policy periodically to reflect changes in:

  • our Services;
  • technology;
  • vendors;
  • recruiting practices;
  • data-processing activities;
  • business operations; or
  • applicable legal requirements.

When we update the Policy, we will change the Last Updated date shown on this page.

Material changes may also be communicated through other reasonable means where required by applicable law.

Article 20 · Privacy Contact

Questions, concerns, or privacy requests?

Legal Entity
Jeremy Allen Swink, LLC
d/b/a The Swink Group
Location
Sheridan, Wyoming
United States
Privacy Email
[email protected]
Policy Date
Effective
Last Updated