Privacy Policy

SwipePic ("we", "our", or "the Service") explains in this Privacy Policy how information is processed when you use our photo organizer application ("Service"). SwipePic is an iOS-only app that lets you swipe to keep or delete photos, and group similar or duplicate photos together to clean up your albums.

This Privacy Policy is provided in accordance with the General Data Protection Regulation (EU) 2016/679 ("GDPR"), the Korean Personal Information Protection Act ("PIPA"), and other applicable data protection laws.

SwipePic has no account and no login. All core features work without signing in, and we do not collect a name, email address, or password to use the app.

MoonshotWorks Team · Address: 101-1103, 87 Jukjeon-ro, Suji-gu, Yongin-si, Gyeonggi-do, Republic of Korea · Email: support@moonshotworks.net

For inquiries related to data protection or privacy, please contact us at the email address above.

※ As the Republic of Korea has received an adequacy decision from the European Commission (as of December 2021), a separate EU representative under Article 27 GDPR is not required at this time. Should this status change, we will update this section accordingly.

We process personal data based on the following legal grounds under Article 6(1) GDPR:

1. Photo Library Access (On-Device Only)

SwipePic accesses your photo library through Apple PhotoKit, with your permission.

How It's Processed

• All photo analysis — similar-photo grouping, duplicate detection, and "best shot" quality scoring — runs entirely on your device using Apple's on-device Vision framework (Neural Engine)
• Photos and their contents are never uploaded to MoonshotWorks servers or any other third party
• We do not view or separately store the content of your photos

Retention Period

Photos exist only on your device and follow the retention behavior of the iOS Photos library itself. We do not separately retain photos.

2. Local Derived Index (On-Device Cache)

To speed up organizing, the app builds a local cache (an on-device SQLite database) containing only technical metadata about your photos.

• This cache contains only technical metadata needed for organizing — not the content of your photos
• It is excluded from device backups
• It can be rebuilt from your photo library if needed
• It is never transmitted off your device

Retention Period

Stored locally on the device until the app is uninstalled or the user clears the cache.

3. Photo Deletion

When you delete photos in the app, the app moves them, via Apple PhotoKit, to the iOS system "Recently Deleted" album.

• We do not keep copies of deleted photos
• Once a photo is permanently removed from "Recently Deleted," it cannot be recovered
• You are encouraged to keep your own backups of your photos; MoonshotWorks is not responsible for photos you delete

4. Purchase and Subscription Information (RevenueCat)

We use RevenueCat, a third-party subscription management service, to validate and manage SwipePic Pro purchases:

• Processed data include an app-generated anonymous user identifier, purchase receipts/tokens issued by the App Store, and subscription status
• Because SwipePic has no account, RevenueCat never receives your name or email address
• Payment itself is processed by Apple (App Store); we never receive your payment card details

Retention Period

Purchase records are retained as long as necessary to provide Pro entitlements and to comply with legal obligations regarding transaction records.

5. Advertising (Free Users)

For users who are not Pro subscribers, advertisements are displayed via Google AdMob:

• The device advertising identifier (IDFA) is used for personalized advertising only if you provide consent through App Tracking Transparency (ATT) and the Google UMP consent dialog
• If consent is not provided, only non-personalized ads are shown
• Ads are completely removed for SwipePic Pro subscribers

You may withdraw advertising consent at any time:

• Settings > Privacy & Security > Tracking, or by resetting the advertising identifier

Retention Period

Advertising data is managed by Google AdMob in accordance with Google's privacy policy and retention schedules.

6. App Analytics and Crash Reports

We use the following services to improve app quality and stability:

Firebase Crashlytics

• Collects technical information such as device model, OS version, app version, and crash stack traces
• Does not include your photo content and does not include information that directly identifies you

Firebase Analytics

• Collects aggregate usage statistics such as sessions and screen views
• Does not include your photo content

Retention Period

Firebase Crashlytics and Firebase Analytics data are retained in accordance with Google Firebase's default data retention policies.

7. App Tracking Transparency (ATT)

The app requests tracking permission via Apple's App Tracking Transparency (ATT) prompt. If you do not allow tracking, cross-app/website tracking for personalized advertising is not performed.

8. Device Permissions

We request the following permissions only when necessary:

• Photos: Photo library access via Apple PhotoKit — used only within the scope of the permission you grant
• Notifications (optional): if you use reminder features, the app may request permission to send notifications; used only to deliver the reminders you set, and you can change or revoke it in iOS Settings at any time

We do not collect:

• Your name, email address, or phone number — SwipePic has no account, so these are never collected
• Location data
• The content of your photos or identifying information contained in them, such as faces — all analysis happens on-device only and is never transmitted to a server
• Device fingerprinting data
• Advertising identifiers without your consent

Processed information is used solely for the following purposes:

• Providing swipe-to-keep and swipe-to-delete photo organizing
• Providing similar-photo grouping, duplicate detection, and album cleanup features
• Validating and managing Pro purchases and subscriptions
• Displaying advertisements to free-tier users
• Improving service stability and functionality

We do not engage in automated decision-making or profiling that produces legal or similarly significant effects on users.

SwipePic is operated from the Republic of Korea. When you use our Service, a minimal amount of data related to advertising, analytics, and subscription management may be transferred to and processed in the following jurisdictions. Your photos themselves never leave your device and are therefore never transferred internationally.

The Republic of Korea has received an adequacy decision from the European Commission, meaning transfers from the EU/EEA to Korea are permitted without additional safeguards.

For transfers to the United States and other jurisdictions, we rely on Standard Contractual Clauses (SCCs) adopted by the European Commission, as incorporated in our agreements with each data processor.

On-Device Storage (Photos and Local Cache)

• Photos are stored in the iOS Photos library and follow Apple's device security model (e.g., device encryption)
• The local derived index is stored within the app's sandbox and is never transmitted to our servers
• We have no remote access to your photos or local cache

These third-party services act as data processors on our behalf and are bound by contractual obligations to process data only as instructed by us and in compliance with applicable data protection laws.

SwipePic is not directed to children under the applicable age (e.g., 13, or 16 where required under local law) and does not knowingly collect personal information from children.

※ Because SwipePic has no account, we hold little to no personal information that directly identifies you. Most data processing — including organizing and deleting your photos — happens entirely on your device and is under your direct control within the app. The rights below primarily apply to the purchase and subscription information we do hold.

Under the GDPR and other applicable data protection laws, you have the following rights regarding your personal data:

• Right of Access — Request a copy of the personal data we hold about you
• Right to Rectification — Request correction of inaccurate or incomplete data
• Right to Erasure (“Right to be Forgotten”) — Request deletion of your personal data, subject to legal retention obligations
• Right to Restriction of Processing — Request that we limit how we use your data in certain circumstances
• Right to Data Portability — Receive your data in a structured, commonly used, machine-readable format, or request transfer to another controller
• Right to Object — Object to processing based on legitimate interests
• Right to Withdraw Consent — Where processing is based on consent, you may withdraw consent at any time without affecting the lawfulness of prior processing
• Right to Lodge a Complaint — You have the right to lodge a complaint with a supervisory authority. If you are in the EU/EEA, you may contact your local Data Protection Authority. In the Republic of Korea, you may contact the Personal Information Protection Commission (PIPC).

To exercise any of these rights, please contact us at support@moonshotworks.net. We will respond to your request within 30 days.

If this Privacy Policy is updated:

• The “Last updated” date will be revised
• Significant changes will be communicated through in-app notices
• Where required by law, we will obtain your consent before applying material changes that affect how your data is processed

MoonshotWorks Team · Email: support@moonshotworks.net · Country: Republic of Korea

For data protection inquiries or to exercise your rights, please contact us at the email address above.