1. Who we are
Swipe to Clean ("we", "our", or "the app") is the data controller for the personal data we process in connection with the Swipe to Clean mobile application. For contact details and how to exercise your rights, see section 16.
2. Scope and applicability
This Privacy Policy applies to the Swipe to Clean app and our related services. It describes how we collect, use, disclose, and protect your information. We aim to comply with applicable privacy and data protection laws globally, including:
- European Union / European Economic Area and United Kingdom: General Data Protection Regulation (GDPR) and UK GDPR
- United States (California): California Consumer Privacy Act (CCPA) as amended by the CPRA, and California Online Privacy Protection Act (CalOPPA)
- United States (Nevada): Nevada Revised Statutes Chapter 603A
- Brazil: Lei Geral de Proteção de Dados (LGPD)
- Canada: Personal Information Protection and Electronic Documents Act (PIPEDA) and provincial laws
- Australia: Privacy Act 1988 (Cth) and Australian Privacy Principles (APPs)
- Japan: Act on the Protection of Personal Information (APPI)
- South Korea: Personal Information Protection Act (PIPA)
- India: Digital Personal Data Protection Act (DPDP Act)
- Other jurisdictions with similar data protection requirements
If you are in a jurisdiction with specific requirements (e.g., GDPR, CCPA), the relevant sections and your statutory rights are set out below.
3. Your photos and media — processed on your device
We do not upload, store, or process your photos or video on our servers. The app accesses your photo library only with your permission. All photo and media processing (including browsing, swiping to keep or delete, and managing Recently Deleted) happens locally on your device. We do not receive, transmit, or have access to the content of your photos or videos.
4. Information we collect
We may collect the following categories of information, depending on how you use the app and your choices:
4.1 Information you give us
- Communications: If you contact us (e.g. support or feedback), we collect what you send (e.g. email address, message content).
- Preferences: In-app settings and preferences (e.g. theme, language, notification preferences) stored on your device or, if we offer sync features in the future, on our systems.
4.2 Information we collect automatically
- Device and app information: Device type, operating system and version, app version, language, and similar technical data, to support and improve the app.
- Usage data: How you use the app (e.g. features used, session length, general interaction) where we use analytics, to improve the product and fix issues.
- Identifiers: Where necessary, we or our service providers may use identifiers such as advertising identifiers (e.g. IDFA) or similar, in line with your device and app choices. We do not sell your personal information (see section 6).
4.3 Information we do not collect
We do not collect the content of your photos, videos, or photo library metadata (e.g. locations in photos) on our servers. Photo library access is used only on your device.
4.4 CCPA categories (California)
For California residents, the categories of personal information we may collect (as defined in the CCPA/CPRA) include: identifiers (e.g. device identifiers, email if you contact us); internet or other electronic network activity (e.g. app usage); and inferences drawn from the above (e.g. to improve the app). We do not collect sensitive personal information as defined under the CCPA in a way that would trigger the right to limit use of sensitive personal information. We do not offer financial or other incentives in exchange for the collection or use of your personal information.
5. Legal basis for processing (EEA/UK and other jurisdictions that require a basis)
Where a legal basis is required (e.g. under the GDPR):
- Performance of a contract: Providing the app services you request.
- Legitimate interests: Improving the app, security, analytics (where not based on consent), and communicating with you about the service.
- Consent: Where we rely on consent (e.g. for optional analytics or marketing), you may withdraw it at any time without affecting the lawfulness of processing before withdrawal.
- Legal obligation: Compliance with applicable law (e.g. tax, legal process).
6. How we use your information
We use the information described above to:
- Provide, operate, and maintain the app
- Send you push notifications if you have enabled them (e.g. reminders)
- Respond to your requests and support inquiries
- Improve the app, fix bugs, and develop new features
- Analyse usage in an aggregated or pseudonymised way where we use analytics
- Comply with legal obligations and enforce our terms
- Protect our and our users’ security and rights
We do not sell your personal information (as "sale" is defined under the CCPA/CPRA and similar laws). We do not share your personal information for cross-context behavioural advertising in a way that constitutes a "sale" or "share" under those laws, unless we have obtained your consent where required.
7. Sharing and disclosure
We may share your information only in the following circumstances:
- Service providers: With vendors who assist us (e.g. hosting, analytics, and support tools), under contracts that require them to protect your data and use it only for the purposes we specify.
- Apple: App distribution and platform-related data may be processed by Apple in accordance with Apple’s privacy policy and App Store terms.
- Legal and safety: Where required by law, court order, or government request, or to protect the rights, property, or safety of us, our users, or others.
- Business transfers: In connection with a merger, sale, or other transfer of assets, subject to the same privacy commitments.
International transfers (EEA/UK and others): Your data may be processed in countries outside your country of residence, including countries that may not provide the same level of data protection. Where required by law (e.g. GDPR, UK GDPR), we use appropriate safeguards such as standard contractual clauses (SCCs), adequacy decisions, or other approved mechanisms to protect your data when transferred internationally.
7.1 Third parties that may collect information through our app (CalOPPA)
In addition to us, the following types of third parties may collect or receive information in connection with your use of our app: (1) Apple (for app distribution and platform operation—see Apple’s privacy policy); (2) analytics or crash-reporting providers, if we use them (they may collect device and usage data); (3) support or communication tools we use if you contact us. We do not control the data practices of these third parties; their privacy policies govern their use of information. We require our service providers to use data only for the purposes we specify and to protect it appropriately.
8. Data retention
We retain your information only as long as necessary for the purposes set out in this policy, including to provide the app, comply with legal obligations, resolve disputes, and enforce our agreements. For example:
- Support communications: as needed to resolve your request and for a limited period thereafter
- Usage and analytics data: in aggregated or anonymised form where possible; otherwise for a limited period consistent with our purposes
- Preference data: for as long as needed to provide app functionality and your chosen experience
You may request deletion of your personal data (see section 12); we will honour such requests where required by law.
9. Security
We implement appropriate technical and organisational measures to protect your personal data against unauthorised access, alteration, disclosure, or destruction, in line with the risks and the nature of the data. Because photo and media processing is done on your device, your photo content is not transmitted to or stored on our systems.
10. Children
The app is not directed at children under the age of 13 (or higher where local law sets a greater minimum age, e.g. 16 in some jurisdictions). We do not knowingly collect personal information from children. If you are a parent or guardian and believe your child has provided us with personal information, please contact us and we will delete it in accordance with applicable law (e.g. COPPA in the US, GDPR in the EEA/UK).
11. Do Not Track and similar signals
Some browsers or devices support a "Do Not Track" (DNT) or similar signal. Our app does not currently respond to DNT signals in a specific way because there is no common standard for how such signals should be interpreted. We do not track you across third-party sites or apps for targeted advertising. You can control certain data collection via your device settings (e.g. limiting ad tracking on iOS) and within our app where we offer choices.
12. Region-specific notices
12.1 European Economic Area (EEA) and United Kingdom
You have the right to: access your personal data; rectify inaccurate data; request erasure ("right to be forgotten"); restrict processing; data portability; object to processing based on legitimate interests; withdraw consent where processing is based on consent; and lodge a complaint with a supervisory authority (e.g. in your country of residence or where we are established). We will respond to your request within the timeframes required by the GDPR/UK GDPR (generally one month).
12.2 California, USA (CCPA/CPRA and CalOPPA)
Under the CCPA/CPRA, you have the right to: know what personal information we collect, use, and disclose; request deletion of your personal information; correct inaccurate personal information; opt out of the "sale" or "share" of your personal information (we do not sell or share your personal information as defined there); and non-discrimination for exercising these rights. We do not sell or share personal information for cross-context behavioural advertising. To submit a request, see section 16. We will verify your identity before fulfilling requests. You may designate an authorised agent to make requests on your behalf; we may require proof of authorisation.
Under the California Online Privacy Protection Act (CalOPPA), we disclose: what personally identifiable information we collect (section 4); with whom it is shared (sections 6 and 7); how you can review and request changes to your data (sections 13 and 16). Our response to Do Not Track and similar signals is described in section 11.
Under California Civil Code Section 1798.83 ("Shine the Light"), California residents may request once per calendar year a list of third parties with whom we shared their personal information for direct marketing purposes. We do not share your personal information with third parties for their direct marketing purposes. If you have questions, contact us (section 16).
12.3 Nevada, USA
Nevada residents may opt out of the "sale" of certain covered information under Nevada Revised Statutes Chapter 603A. We do not sell your personal information as defined there. If you are a Nevada resident and have questions or wish to submit an opt-out request, contact us (section 16).
12.4 Brazil (LGPD)
Under the LGPD, you have the right to access, correct, anonymise or delete, port, and request information about sharing and processing of your personal data, and to withdraw consent. You may also lodge a complaint with the Autoridade Nacional de Proteção de Dados (ANPD). We process your data in accordance with the legal bases set out in the LGPD.
12.5 Canada (PIPEDA and provincial laws)
We comply with PIPEDA and applicable provincial privacy laws. You have the right to access your personal information and to request correction. You may withdraw consent subject to legal or contractual restrictions. We will respond to your requests in accordance with applicable Canadian law.
12.6 Australia (Privacy Act and APPs)
We follow the Australian Privacy Principles (APPs). You may request access to and correction of your personal information and complain to us or to the Office of the Australian Information Commissioner (OAIC) if you believe we have breached the APPs.
12.7 Other regions
If you are in Japan, South Korea, India, or another jurisdiction with specific data protection laws, we will honour the rights granted to you under those laws. Contact us (section 16) to exercise them.
13. How to review your data and exercise your rights
You can review the personal information we hold about you and request access, correction, deletion, portability, objection, restriction, or withdrawal of consent, or make a complaint, as follows:
- Use the contact details in section 16.
- We will respond within the time required by your jurisdiction (e.g. one month under GDPR, 45 days under CCPA where applicable).
- We may need to verify your identity (e.g. by email or account verification) before processing your request.
- You may have the right to lodge a complaint with a data protection authority in your country.
We will not discriminate against you for exercising your privacy rights where prohibited by law (e.g. under the CCPA).
14. Cookies and similar technologies
The Swipe to Clean app is a mobile application and does not use cookies. If we operate a website that uses cookies or similar technologies, we will describe that in a separate cookie notice or in an update to this policy. Where we use analytics or similar tools in the app, we do so in accordance with this policy and your device and in-app choices.
15. Changes to this policy
We may update this Privacy Policy from time to time. We will post the updated version in the app and/or on our website and indicate the "Last updated" date. For material changes that affect how we use your personal data, we will provide additional notice where required by law (e.g. by email, in-app notice, or consent for material new uses). Your continued use of the app after the effective date of the updated policy constitutes acceptance of the updated policy, except where your consent is required by law.
16. Contact and data protection inquiries
For privacy-related requests, questions, or complaints (including to exercise your rights or to contact a data protection officer if we have designated one):
- See our Contact page for current contact details.
- If you are in the EEA/UK and we have an EU/UK representative, we will indicate that on our Contact page or in the app.
We will respond to your request in accordance with applicable law. This Privacy Policy is effective as of the "Last updated" date shown at the top of this page.