Privacy Policy

INTRODUCTION AND CRITICAL DISCLAIMERS

Agreement Formation and Jurisdiction

This Privacy Policy (“Policy”) governs all data collection, processing, storage, and disclosure activities by Swiv (“Company,” “Swiv.ai,” “we,” “us,” or “our”) through our artificial intelligence platform, mobile applications, websites, companion AI services, health monitoring integrations, gaming platforms, and all related services (collectively, the “Services”).

INFORMATION COLLECTION

Information You Provide

• Account information (name, email, phone, address, date of birth)
• Profile information and preferences
• Payment and billing information
• Communications and support requests
• Any content you upload, share, or create
• Survey responses and feedback

Automatically Collected Information

Device and Technical Information:

• IP address, device identifiers (UDID, IMEI, MAC address)
• Device type, model, operating system, browser type and version
• Screen resolution, time zone, language settings
• Mobile carrier, network connection type
• Hardware capabilities and specifications
• Installed applications and software versions

Website and App Usage Data:

• Pages visited, features used, buttons clicked
• Time spent on pages/features, session duration
• Referral sources and exit pages
• Search queries and navigation patterns
• Error messages and crash reports
• Performance metrics and load times

Location Information:

• Precise GPS coordinates (if location services enabled)
• Approximate location based on IP address
• Wi-Fi network names and Bluetooth beacons
• Cell tower information and signal strength
• Location history and frequently visited places

Cookies and Tracking Technologies:

• Session cookies and persistent cookies
• Web beacons, pixels, and clear GIFs
• Local storage and browser cache data
• Analytics and advertising tracking codes
• Social media plugins and widgets
• Cross-device and cross-platform identifiers

Voice and Audio Data:

• Voice recordings and speech patterns
• Audio quality and background noise
• Microphone permissions and usage
• Voice commands and responses
• Speech recognition data and transcripts

AI Interactions and Behavioral Data:

• All conversations and interactions with AI systems
• User prompts, queries, and commands
• AI-generated responses and outputs
• Conversation metadata (timestamps, duration, frequency)
• Emotional state indicators and sentiment analysis
• User preferences and personalization data
• Engagement patterns and usage analytics

Third-Party and Integrated Information

Connected Accounts and Services:

• Social media profiles and connections
• Cloud storage and email accounts
• Calendar and contact information
• Photos and media from connected accounts

Wearable Devices and Health Apps:

• Heart rate, blood pressure, sleep patterns
• Steps, calories, exercise activities
• Health metrics and wellness data
• Device synchronization logs

Business Partners and Data Providers:

• Marketing and advertising partners
• Analytics and measurement services
• Data brokers and enrichment services
• Publicly available databases
• Credit reporting agencies (where permitted)

Sensitive and Biometric Information

• Facial recognition data and voice prints
• Fingerprints or other biometric identifiers
• Health conditions and medical discussions
• Mental health status and emotional expressions
• Financial information and payment history
• Government identification numbers
• Precise geolocation and movement patterns

HOW WE USE INFORMATION

Service Operations

• Providing, maintaining, and improving Services
• Creating and managing your account
• Processing payments and transactions
• Customer support and communications
• Security and fraud prevention

AI Development and Training

• Training AI models using your conversations and prompts
• Analyzing user interactions to enhance AI responses
• Developing new AI features and capabilities
• Creating datasets for machine learning research
• Improving AI safety and bias reduction

By using our Services, you consent to this AI training use of your data.

Automated Decision-Making

Our AI systems may make automated decisions about:

• Content recommendations and personalization
• Service features and functionality
• Account security and fraud detection
• Customer support routing and responses

Personalization and Analytics

• Personalizing your experience and recommendations
• Understanding usage patterns and preferences
• Conducting research and analytics
• Marketing and advertising (where permitted)

Legal and Business Purposes

• Complying with legal obligations
• Protecting our rights and property
• Business transfers and corporate transactions
• Any other legitimate business purpose

INFORMATION SHARING

Service Providers and Technology Partners

We share information with third parties who help us operate our business:

Infrastructure and Hosting:

• Cloud hosting providers (AWS, Google Cloud, Microsoft Azure)
• Content delivery networks and data centers
• Database and storage services
• Backup and disaster recovery providers

Analytics and Advertising:

• Google Analytics, Facebook Pixel, and similar analytics services
• Advertising networks and marketing platforms
• Social media platforms for advertising and integration
• A/B testing and optimization services

Payment and Financial:

• Payment processors (Stripe, PayPal, etc.)
• Banking and financial institutions
• Fraud detection and prevention services
• Tax and accounting service providers

AI and Machine Learning:

• AI model training and development companies
• Natural language processing services
• Speech recognition and synthesis providers
• Computer vision and image processing services

Customer Support and Communications:

• Customer service platforms and helpdesk software
• Email marketing and communication services
• Live chat and messaging platforms
• Call center and phone support providers

Legal Requirements and Safety

We may disclose information when required by law or to:

• Respond to legal process (subpoenas, warrants, court orders)
• Comply with government requests and regulatory investigations
• Protect our rights, property, or safety and that of our users
• Investigate fraud, security breaches, or violations of our Terms
• Enforce our agreements and policies
• Respond to emergency situations involving threats to safety

Business Transfers and Corporate Transactions

We may share information in connection with:

• Mergers, acquisitions, or asset sales
• Bankruptcy or insolvency proceedings
• Corporate reorganizations and restructuring
• Investment, financing, or funding transactions
• Joint ventures and strategic partnerships

Marketing and Advertising Partners

We may share information with:

• Advertising networks and demand-side platforms
• Social media advertising platforms
• Email marketing service providers
• Affiliate marketing networks
• Customer relationship management (CRM) systems

Research and Development

We may share aggregated or anonymized information with:

• Academic institutions and researchers
• Industry partners for collaborative research
• Third-party developers and integrators
• Market research and analytics companies

With Your Consent or Direction

We may share information:

• When you explicitly consent to sharing
• At your direction (e.g., sharing with apps you connect)
• For purposes you authorize at the time of collection

AI AND CRISIS LIMITATIONS

YOUR RESPONSIBILITIES

By using our Services, you agree that you are solely responsible for:

• All consequences of your use of Services
• Seeking appropriate professional help when needed
• Protecting your own safety and well-being
• Complying with all applicable laws
• Any harm that may result from your use

DATA SECURITY, RETENTION, AND TRANSFERS

Security Measures

We implement reasonable technical and organizational measures to protect your information, including:

• Encryption of data in transit and at rest
• Access controls and authentication
• Regular security assessments
• Employee training and confidentiality agreements

However, no security system is perfect. We cannot guarantee complete security.

Data Retention Periods

We retain different types of information for different periods:

• Account Information: Until account deletion plus 30 days
• Conversation and AI Data: Up to 7 years for AI training and improvement
• Usage and Analytics Data: Up to 2 years
• Financial Records: 7 years for tax and legal compliance
• Health Data: Up to 10 years or as required by law
• Marketing Data: Until you opt-out plus 60 days
• Legal/Safety Data: As required by law or ongoing legal matters

You can request deletion of your information, subject to legal and operational limitations.

International Data Transfers and Storage

Your information may be transferred to, stored, and processed in:

• United States, European Union, United Arab Emirates
• Other countries where our service providers operate
• Cloud servers and data centers worldwide

We implement appropriate safeguards for international transfers including:

• Standard Contractual Clauses approved by data protection authorities
• Adequacy decisions where available
• Your explicit consent for specific transfers
• Other legal mechanisms as required

Data Breach Notification

If we experience a data security incident affecting your personal information, we will:

• Notify affected users within 72 hours where required by law
• Notify relevant data protection authorities as required
• Provide information about the incident and steps being taken
• Offer assistance and resources to affected users

YOUR RIGHTS

General Rights

Depending on your location, you may have rights to:

• Access your personal information
• Correct inaccurate information
• Delete your information
• Restrict processing of your information
• Object to certain processing
• Data portability

Marketing Communications

You can opt out of marketing emails by following unsubscribe instructions or contacting us.

Cookies and Tracking Technologies

Cookie Categories:

• Essential Cookies: Required for basic site functionality, security, and user authentication
• Analytics Cookies: Help us understand how visitors use our website and apps
• Marketing Cookies: Used for advertising and remarketing campaigns
• Functional Cookies: Remember your preferences and personalization settings

Cookie Management:

• You can control cookies through your browser settings
• You can opt-out of targeted advertising through industry opt-out tools
• Disabling cookies may affect website functionality
• Mobile apps may use similar tracking technologies

Third-Party Tracking:

• Google Analytics, Google Ads, and Google Tag Manager
• Facebook Pixel and Meta advertising tools
• Social media widgets and sharing buttons
• Advertising networks and measurement services

Mobile App Permissions

Device Permissions We May Request:

• Camera: For photo/video capture and scanning features
• Microphone: For voice interactions and audio recording
• Location: For location-based features and services
• Contacts: For social features and contact synchronization
• Storage: For saving files and offline functionality
• Phone: For customer support calling features
• Calendar: For scheduling and reminder features
• Notifications: For push notifications and alerts

You can control these permissions through your device settings.

Exercising Your Rights

How to Contact Us:

• Email: privacy@swiv.ai
• Subject Line: Include “Privacy Rights Request”
• Required Information: Your name, email, and specific request

Response Timeline:

• We will respond within 30-45 days (or as required by local law)
• Complex requests may take up to 90 days with notification
• We may request additional verification for security

Verification Process:

• We may ask for government-issued ID for deletion requests
• Account authentication may be required
• Additional verification for sensitive requests
• Protection against fraudulent requests

Request Limitations:

• Some rights may be limited by law or service functionality
• We may charge fees for excessive or repetitive requests
• Legal exceptions may apply (e.g., ongoing legal matters)
• Technical limitations may affect some requests

Appeals Process:

• You can appeal our decision on your rights request
• Contact privacy@swiv.ai with “Appeal” in subject line
• Include original request details and reason for appeal
• We will review appeals within 30 days

JURISDICTION-SPECIFIC INFORMATION

California Residents (CCPA/CPRA)

California residents have specific rights including:

• Right to know what personal information is collected
• Right to delete personal information
• Right to opt-out of “sale” of personal information
• Right to non-discrimination

We do not “sell” personal information as defined by CCPA.

EU/UK Residents (GDPR)

EU and UK residents have rights including data access, rectification, erasure, and portability under GDPR.

UAE Residents

UAE residents have rights under UAE Personal Data Protection Law including access, correction, and deletion rights.

Children’s Privacy and Parental Rights

Age Requirements:

• Services are intended for users 13+ (US) or 18+ (UAE)
• Users under 18 need parental consent in most jurisdictions
• We do not knowingly collect data from children without proper consent

Parental Consent Process:

• Parents can provide consent via email verification
• Additional verification may be required for sensitive features
• Parents can review and delete their child’s information
• Parents can restrict their child’s data sharing

Special Protections for Minors:

• Limited data collection from users under 18
• No targeted advertising to minors
• Enhanced safety monitoring and content filtering
• Restricted AI interaction features for young users
• Immediate data deletion upon parental request

If We Learn a Child Under 13 Has Provided Information:

• We will delete the information promptly
• We will terminate the account if applicable
• We will notify parents if we have contact information
• We will implement additional safeguards to prevent recurrence

CHANGES

We may modify this Policy at any time. Continued use constitutes acceptance of changes.

CONTACT INFORMATION

Privacy Questions

Email: privacy@swiv.ai

Data Protection Officer

Email: dpo@swiv.ai

Regulatory Authorities

You may also contact relevant data protection authorities:

• California: California Attorney General
• EU: Your local supervisory authority
• UAE: UAE Data Office

SENSITIVE DATA AND SPECIAL CATEGORIES

Health Data Processing

Health Information We May Collect:

• Wearable device data and health metrics
• Mental health discussions and emotional expressions
• Medical conditions mentioned in conversations
• Wellness goals and fitness activities

Special Protections:

• Health data is encrypted and access-controlled
• Used only for agreed purposes (AI training, personalization)
• Not shared with third parties without consent (except as legally required)
• You can request deletion of health data specifically

Biometric Data

Types of Biometric Information:

• Voice patterns and speech characteristics
• Facial recognition data (if camera features used)
• Typing patterns and behavioral biometrics

Biometric Data Protections:

• Obtained only with clear notice and consent
• Stored in encrypted format with limited access
• Retention limited to operational necessity
• Deleted upon account termination or request

Financial Information

Financial Data Security:

• Payment information processed by certified payment processors
• We do not store full credit card numbers
• Financial discussions in AI conversations are encrypted
• PCI DSS compliance for payment card data

Location Data Precision

Types of Location Information:

• Approximate location (city/region level) from IP address
• Precise GPS coordinates (only with your permission)
• Location history and frequently visited places

Location Controls:

• You can disable precise location tracking anytime
• Location data can be deleted upon request
• Used for service functionality and personalization only