Privacy Policy

1. Who this policy applies to

This Privacy Policy ("Policy") describes how the MemorySwipe iPhone application ("MemorySwipe", the "App", "we", "us", "our") handles information in connection with your use of the App. By installing, accessing, or using MemorySwipe, you acknowledge that you have read and understood this Policy.

Data controller

The data controller responsible for the personal data processed under this Policy is:

Pavlo Kish, sole proprietor (jednoosobowa działalność gospodarcza) registered in the Polish Central Register of Business Activity (CEIDG)
Okrag 4/42, 00-423 Warszawa, Poland
NIP: 7011201444
Email: hello@memoryswipe.com

If you have any questions about this Policy or wish to exercise your privacy rights, you can reach us at the email above.

2. What data we collect

We do not collect your name, email address, phone number, contacts, precise location, or any content from your Photos library. MemorySwipe does not operate a user-facing backend, does not create user accounts, and does not use sign-in (including Sign in with Apple). Your photos, the selections you make, your streak, your Trash list, and your preferences are processed and stored on your device only.

The only categories of data transmitted off your device are described below. All of it is pseudonymous: it is keyed to random identifiers generated by the App, not to your name, email, Apple ID, or phone number.

Subscription and paywall events (processed by Adapty)

• Purchase and subscription events. Paywall impressions, trial starts, purchase receipts, subscription status, renewal and cancellation events, refunds.
• Technical identifiers. A vendor-scoped device identifier (Apple's IDFV), an Adapty customer profile ID, and a randomly generated install ID. We do not collect the IDFA (advertising identifier).
• Device and app context. Device model, iOS version, App version, locale and country code, and timestamps of the events above.

We use this data solely to operate the subscription system, evaluate which paywall variants and pricing options perform better in aggregate, and resolve issues with purchases, renewals, and refunds. It is not used for advertising, not sold, and not shared with data brokers. See Section 5 for details on the provider.

Legal bases for processing (GDPR / UK GDPR)

If you are in the European Economic Area, the United Kingdom, or Switzerland, we rely on the following legal bases under Article 6 of the General Data Protection Regulation:

• Performance of a contract (Art. 6(1)(b)) — to provide and operate the Subscription you purchase, including receipt validation, granting access to premium features, and handling renewals or refunds.
• Legitimate interests (Art. 6(1)(f)) — to keep the App secure, prevent fraud and abuse, debug technical issues, and evaluate paywall variants in aggregate so that we can improve the product. We have assessed that these interests do not override your privacy rights given the minimal, pseudonymous nature of the data. You may object to this processing at any time by contacting us.
• Compliance with a legal obligation (Art. 6(1)(c)) — to keep purchase and tax records required by Polish and EU accounting and tax law.

3. Data stored on your device

The App stores the following information locally on your iPhone. None of it leaves your device:

• Photos and photo metadata. Accessed through iOS Photos permission so the App can show you photos taken on this date in past years and move photos you mark for deletion to iOS "Recently Deleted".
• App state. Your streak count, protective "Shields", date of your last session, onboarding progress, cleanup-mode progress, and similar local state.
• In-app Trash list. Identifiers of photos you have swiped to delete, held only until you confirm deletion.
• Preferences. Settings such as your reminder time, notifications choice, and UI preferences.
• Profile (optional). A display name and avatar you choose, used only to personalize the in-app interface. Never transmitted.

Uninstalling MemorySwipe removes all of this data from your device.

4. Permissions the App requests

Photos (required for core functionality)

The App requires read and write access to your Photos library to show you daily stacks of photos taken on this date in past years and to move photos you confirm for deletion to iOS "Recently Deleted". Photo data is processed entirely on your device and never transmitted. You can change this permission at any time in iOS Settings → Privacy & Security → Photos → MemorySwipe.

Notifications (optional)

If you grant notification permission, we use it only for:

• The daily reminder at the time you configure.
• An occasional alert when your in-app Trash grows large or your streak is at risk.

We do not send marketing notifications. You can revoke this permission at any time in iOS Settings → Notifications → MemorySwipe.

5. Third parties

MemorySwipe does not integrate advertising networks, marketing attribution SDKs, or social-media SDKs. The only third parties involved in processing data on our behalf are listed below.

Adapty (subscription management and paywall analytics)

We use Adapty, provided by Adapty Tech Inc., to manage subscriptions, validate purchase receipts, and run A/B tests on our paywalls. When you open the App or interact with a paywall or a purchase flow, Adapty receives the purchase and subscription events, technical identifiers, and device/app context described in Section 2.

Adapty acts as our data processor. The data is used to:

• Verify the authenticity and status of your subscription and unlock premium features on your device.
• Debug and resolve issues with purchases, renewals, and refunds.
• Measure which paywall variants and pricing options perform better in aggregate.

Adapty does not receive your photos, your Photos library contents, your streak, your Trash list, any content you create in the App, your name, or your email address. Adapty may process and store this information on servers located in the United States and the European Union. For further detail, see Adapty's Privacy Policy and Data Processing Addendum.

Payments and the App Store

In-app purchases are processed by Apple through the App Store and are subject to Apple's Privacy Policy. We never see your payment method, full name, or billing address. From Apple we receive only a signed purchase receipt that confirms an active subscription is associated with your Apple ID; that receipt is validated via Adapty as described above.

iOS platform services

When you use the App, iOS itself may collect diagnostic information if you have opted in under iOS Settings → Privacy & Security → Analytics & Improvements → Share With App Developers. This data is controlled by Apple and shared with us only in aggregated and de-identified form for crash reporting and stability. We do not pair this data with any other identifier.

6. Tracking

MemorySwipe does not track you across apps or websites owned by other companies, as "tracking" is defined under Apple's App Tracking Transparency framework. We do not collect the advertising identifier (IDFA), do not share identifiers with data brokers, and do not combine the data described above with third-party advertising data. The pseudonymous identifiers used by Adapty stay within that service and are used only to operate and analyze our own App. Because there is no cross-app tracking to authorize, the App does not present the App Tracking Transparency prompt.

7. Children's privacy

MemorySwipe is not directed to children under 13, and we do not knowingly collect personal information from children under 13 in compliance with the U.S. Children's Online Privacy Protection Act (COPPA). In jurisdictions that require a higher age of digital consent under the GDPR (typically 16, or as set by national law), we likewise do not knowingly collect personal information from children below that age.

If you are a parent or guardian and believe a child under the applicable age has used the App and that personal information has reached us, please contact hello@memoryswipe.com and we will take steps to delete that information and forward any deletion request to our processor.

8. Your rights and choices

You remain in full control of everything the App does on your device, and you can exercise the practical controls below at any time:

• Delete all local App data. Uninstall MemorySwipe. All locally stored App data is removed.
• Revoke Photos access. iOS Settings → Privacy & Security → Photos → MemorySwipe.
• Revoke Notifications. iOS Settings → Notifications → MemorySwipe.
• Access or delete subscription data held by our processor. Write to hello@memoryswipe.com including the Adapty customer profile ID shown in the App's Settings → About screen, and we will forward the request to Adapty. We will respond within thirty (30) days.
• Contact us. For any privacy-related question, write to hello@memoryswipe.com.

Rights under the GDPR and UK GDPR

If you are in the European Economic Area, the United Kingdom, or Switzerland, you have the following rights with respect to personal data we process about you:

• Right of access (Art. 15) — confirmation of whether we process your data and a copy of it.
• Right to rectification (Art. 16) — correction of inaccurate or incomplete data.
• Right to erasure (Art. 17) — deletion of your data where one of the listed grounds applies.
• Right to restriction (Art. 18) — to limit how we use your data in defined situations.
• Right to data portability (Art. 20) — to receive your data in a structured, machine-readable format.
• Right to object (Art. 21) — to processing based on legitimate interests, including any profiling.
• Right not to be subject to automated decision-making (Art. 22) — we do not carry out any solely automated decision-making that produces legal or similarly significant effects on you.
• Right to withdraw consent where processing is based on consent (which is not currently the case for any data we process).

To exercise any of these rights, contact hello@memoryswipe.com. We will respond within thirty (30) days as required by the GDPR. We will not charge a fee unless your request is manifestly unfounded or excessive.

Right to lodge a complaint. You also have the right to lodge a complaint with a supervisory authority. Our lead authority is the Polish data-protection authority:

Urząd Ochrony Danych Osobowych (UODO)
ul. Stawki 2, 00-193 Warszawa, Poland
uodo.gov.pl

You may also lodge a complaint with the supervisory authority in your country of residence or workplace.

Rights under U.S. state privacy laws

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, or another U.S. state that grants you statutory privacy rights (collectively, "U.S. State Privacy Laws"), you have rights to (i) know and access the categories and specific pieces of personal information we have collected about you, (ii) request deletion of your personal information, (iii) request correction of inaccurate personal information, (iv) opt out of the sale or sharing of personal information for cross-context behavioral advertising, and (v) be free from unlawful discrimination for exercising these rights.

We do not sell or share your personal information for cross-context behavioral advertising, and we do not use sensitive personal information for any purpose that would require a right to limit. Because we do not process advertising identifiers or build user profiles, the practical effect of these rights is limited to the pseudonymous subscription data described in Section 2, which you can request through hello@memoryswipe.com. We do not discriminate against you for exercising any privacy right.

California "Shine the Light" (Civil Code § 1798.83). We do not share personal information with third parties for their own direct-marketing purposes.

9. Data retention

Local App data lives on your device and persists only as long as the App is installed. Subscription and paywall event data processed through Adapty is retained by Adapty for as long as is necessary to operate the subscription service and to meet legal, tax, and accounting obligations (typically up to seven years for financial records).

10. International users and cross-border transfers

MemorySwipe is operated from Poland (European Union) and is offered globally, with a primary user base in the United States. Your on-device data does not leave your iPhone. The subscription events described in Section 2 are processed by Adapty on servers located in the United States and the European Union.

Transfers outside the EEA. Where personal data of EEA, UK, or Swiss users is transferred to the United States (or to any other country that has not been the subject of an adequacy decision by the European Commission), the transfer is protected by the European Commission's Standard Contractual Clauses (SCCs), the UK International Data Transfer Addendum where applicable, and supplementary technical and organisational measures, as set out in Adapty's Data Processing Addendum. You may request a copy of the relevant safeguards by contacting us.

11. Security

On-device App data is protected by iOS platform security, including Data Protection, Secure Enclave, and App Sandbox. Data transmitted to Adapty is encrypted in transit using TLS and is protected at rest in accordance with Adapty's security program. We do not weaken, bypass, or replicate those protections.

12. Changes to this Policy

We may update this Policy from time to time. The "Last updated" date at the top reflects the most recent revision. If we make material changes, we will, where appropriate, surface the change inside the App. Your continued use of the App after a revision becomes effective constitutes acceptance of the revised Policy.

13. Contact

For privacy questions, requests, or concerns, contact the data controller:

Pavlo Kish, sole proprietor (jednoosobowa działalność gospodarcza)
Okrag 4/42, 00-423 Warszawa, Poland
NIP: 7011201444
Email: hello@memoryswipe.com