Privacy Policy

This Privacy Policy explains how Swixie ("we", "us", or "our") collects, uses, shares, and protects your personal information when you use the Swixie mobile application and related services (the "Service"). Please read this together with our Terms of Service. If you do not agree with this policy, please do not use the Service.

1. Who we are

The Service is operated by Swixie, P.O. Box 633-00100, Nairobi, Kenya. For any privacy questions or requests, contact us at support@swixie.com. For the purposes of applicable data-protection law (including the GDPR where it applies), Swixie is the data controller of your personal information.

2. What Swixie does

Swixie is a photo-album service. An event organiser uploads photos from an event, and Swixie uses face matching to help each person find and collect the photos they appear in. You can then view, save, and share the photos that feature you. Swixie can also help you discover public events near you and invite people you know.

Swixie does not run a real-time location-tracking map, and does not currently process any payments (see Section 11). Location is used only as described in Section 5.

3. Information we collect

Information you provide directly

• Account details: your name, email address, and (where provided) your phone number. If you sign in with a third-party provider such as Google or Apple, we receive the basic profile information that provider shares with us.
• Profile / selfie photo: a photo you provide so we can match you to the photos you appear in.
• Event content: if you are an organiser, the photos you take or upload, and the event details you provide.
• Communications: information you send us when you contact support.

Biometric / face data — see Section 4. Location data — see Section 5. Contacts — see Section 6.

Camera and photos access

With your permission, Swixie accesses your device camera (to take photos for events you organise) and your photo library (to select photos to upload or to choose a selfie). We only access these when you use the relevant feature.

Information collected automatically

• Device and technical data: device type, operating system, app version, and similar identifiers.
• Usage and diagnostic data: app activity, crash logs, and error diagnostics used to operate and improve the Service.
• Push notification tokens: if you enable notifications.

We do not track your location continuously or run a live-tracking map. Location is only used as described in Section 5.

4. Face data (biometric information)

Finding your photos relies on face recognition, which in some jurisdictions is treated as sensitive or "special category" biometric data:

• What we create: from the selfie you provide, we generate a face signature — a numerical representation of facial features. It is not a photograph and cannot be used to reconstruct your image.
• What we do with it: we compare your face signature against faces detected in event photos to identify the photos you appear in.
• The selfie image: it is not retained after your face signature has been created.
• Control: searching for your photos is initiated by you. We do not use your face signature for advertising, and we do not sell it.
• Retention & deletion: your face signature is retained while your account is active and is deleted when you delete your account, or earlier on request (see Section 12).

Your consent: by providing a selfie and using the face-matching feature, you consent to the creation and use of your face signature as described here. You may withdraw consent at any time by deleting your account or contacting support@swixie.com.

5. Location data

Swixie can show you public events happening near you. When you open the "Nearby" view, or enable location from your settings, we ask permission to access your device location and use it as follows:

• We read your device location only at that time — we do not track your location in the background or continuously, and we do not build a location history.
• Your coordinates are sent to our servers to find and rank nearby events, and are used for that purpose only.
• You can decline location access, or revoke it at any time in your device settings; the rest of the Service continues to work without it.

6. Contacts

To help you invite people you know and connect with friends already on Swixie, the app offers a "find friends / invite" feature. When you open an invite screen and grant contacts permission:

• We read the names, email addresses, and phone numbers stored in your device contacts.
• We send the email addresses and phone numbers to our servers to check which of them match existing Swixie accounts, so we can show you who you can connect with or invite.
• We use this information only to power the invite/find-friends feature. We do not sell contact data, and we do not message your contacts without your action.
• You should only share contacts you have a basis to share. You can decline contacts access, or revoke it at any time in your device settings.

7. How we use your information

We use your information to create and authenticate your account; match you to your photos and deliver your album; let organisers manage the events and photos they create; help you discover nearby events and invite people you know; send you Service-related notifications; operate, secure, and improve the Service; and comply with legal obligations.

Legal bases (where GDPR applies): your consent (face data, location, contacts, notifications), performance of a contract, our legitimate interests, and legal obligation.

8. How we share information

We do not sell your personal information. We share it only: within an event/album (photos matched to you, and photos you organise, are visible to the people entitled to view them; a shared album link is viewable by anyone with the link); with service providers who host, store, and deliver the Service under contract; where required by law or to protect safety; and in a business transfer, subject to this policy.

9. International data transfers

We use Cloudflare (including Cloudflare R2 object storage and its content-delivery network) to store and serve your photos and related data, which may be processed in data centres outside Kenya, under Cloudflare's data processing addendum incorporating the Standard Contractual Clauses. We also use Expo to deliver push notifications, relayed via Apple's APNs and Google's Firebase Cloud Messaging. We transfer personal data across borders only where such safeguards, or another lawful basis under the Kenya Data Protection Act, 2019, are in place.

10. Photos and event content

• Event photos are stored securely and are accessible within the event they belong to and to the people entitled to view it.
• Organisers are responsible for the photos they upload and for having a proper basis to upload photos of others.
• You may request removal of photos that feature you by contacting support@swixie.com.

11. Payments

Paid albums and in-app purchases are not currently available, and Swixie does not currently collect or process any payment information. If we introduce paid features, we will update this Policy before they go live.

12. Your rights and choices

Depending on where you live, you may have rights to access, correct, delete, object to or restrict processing of, and port your personal data, and to withdraw consent (including for face-data processing) at any time.

Account deletion: you can delete your account from within the app (Settings → Delete account). This removes your identity, your face signature, and the photos matched to you. Albums you organised remain available to the people you shared them with, so they do not lose their photos. You can also contact support@swixie.com for help. You have the right to lodge a complaint with your local data-protection authority.

13. Data retention

We retain your personal data while your account is active. When you delete your account, we delete your personal data, your face signature, and the photos matched to you. Albums you organised are kept so their recipients do not lose access. We may retain limited information where required for legal obligations, disputes, fraud prevention, or enforcing our agreements.

14. Security

We use technical and organisational measures — including encryption in transit, access controls, and secure storage — to protect your information. No method of transmission or storage is completely secure, and we cannot guarantee absolute security.

15. Children

Swixie is intended for people aged 13 and over. We do not knowingly collect personal data from children under 13. If you believe a child under 13 has provided us with personal data, contact support@swixie.com and we will delete it.

16. Changes to this policy

We may update this Privacy Policy from time to time. We will revise the "Last updated" date above and, where appropriate, provide additional notice. Continued use of the Service after an update means you accept the revised policy.

17. Contact us

Swixie, P.O. Box 633-00100, Nairobi, Kenya.
support@swixie.com