AllFriends, Inc. (“AirSwap,” “we,” “our,” and/or “us”) values the privacy of individuals who use our application, and related services (collectively, our “Services”) to send photos, videos and messages. This privacy policy (the “Privacy Policy”) explains how we collect, use, and share information that we collect from users of our Services. By using our Services, you agree to the collection, use, disclosure, and procedures this Privacy Policy describes. Beyond the Privacy Policy, your use of our Services is also subject to our Terms of Service.

When you use our Services, we use artificial intelligence to identify the time and location of your photos and videos, and we use facial recognition data when you tag your AirSwap Friends (as defined in the Terms of Service) in order to allow AirSwap Friends to share photos with one another, as further described in the Terms of Service.
Information We Collect

A. Information You Provide to Us.

Registration Information. When you register to use our Services, we collect your username and phone number.

Photos, Videos and Messages. You can use AirSwap to request, share and receive photos, videos and messages with Friends. When you download and install the Service, you may choose to allow the Service to access your contacts (e.g., Friends) and the photos and videos stored on your device. When you send photos, videos, or messages to Friends, your photos, videos, or messages are encrypted on your device before being sent to your AirSwap Friends via AirSwap servers using end-to-end encryption. Your photos, videos and messages are not stored on our servers, with the exception of when you share photos or videos with Friends, or send messages, the photos, videos and messages are transmitted to your Friends using end-to-end encryption and are stored on our servers briefly to facilitate sharing between Friends. Once those photos, videos or messages are successfully delivered to a Friend, they are deleted from AirSwap’s servers. Time and location meta data of photos, videos, and messages are stored on our servers to enable us to suggest photos taken at the same time and place with friends that can be requested and shared.
Your Contacts. The Service uses phone numbers to identify individuals in your contact book (e.g., Friends). With your permission, we will access the phone numbers stored in the contact book on your device. If you choose to provide AirSwap with access to your contact book, we will securely store your contacts on our servers and will let you know when a contact joins AirSwap.
Communications. If you contact us, we may receive additional information about you. For example, when you contact us for customer support, we may receive your name, email address, phone number, the contents of a message or attachments that you may send to us, and other information you choose to provide.
B. Information We Collect When You Use Our Services.

Location and Time. When you give us access to your photos and videos, we will collect the time and the location the photo or video was taken or recorded.
Device Information. We receive information about the device and software you use to access our Services, including IP address, web browser type, operating system version, phone carrier and manufacturer, application installations, device identifiers, mobile advertising identifiers, and push notification tokens.

Usage Information. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the dates and times you use the Service.

Technical Information. We collect and store technical information, including randomly generated authentication tokens, keys, push tokens, and other material that is necessary to transmit photos and messages.
Data from Device Settings: We collect information when you grant us permission to access your camera, contacts, or photos, including meta data about your photos, camera, or contacts.
Information from Cookies and Similar Technologies. We and our third party partners collect information using cookies, pixel tags, or similar technologies. Our third party partners, such as analytics partners, may use these technologies to collect information about your online activities over time and across different services. Cookies are small text files containing a string of alphanumeric characters. We may use both session cookies and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Services.

Please review your web browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential.

C. Biometric Information.

When a user tags a Friend on AirSwap, our technology identifies face(s) that are tagged in the user’s photos based on that tag. AirSwap scans the photos on a user’s device, identifies faces that appear within them, generates a faceprint for each face, and allows users to match those faces with individuals that the user tags (e.g., Friends). Facial recognition data is hashed before it is stored on AirSwap servers. A user can tag photos of Friends or of individuals who are not AirSwap users. If a user tags an individual that is not an AirSwap user, we will invite that individual to use the Service.
How We Use the Information We Collect

We use the information we collect:

• To provide, maintain, improve, and enhance our Services;
• We use the biometric information that we collect from you to match your photos with other User’s photos so that you can request and receive photos of you taken by your AirSwap Friends and share photos of AirSwap Friends that you take.
• To personalize the Services, including making recommendations to you or other Users based on the information we collect (such as to recommend Users with whom to share photos or videos);
• To understand and analyze how you use our Services and develop new products, services, features, and functionality;
• To communicate with you, provide you with updates and other information relating to our Services, provide information that you request, respond to comments and questions, and otherwise provide customer support;
• To send you text messages and push notifications, including to verify your phone number;
• To allow you or other Users to share photos or videos with third party services (e.g., via iMessage or WhatsApp);
• To find and prevent fraud, and respond to trust and safety issues that may arise;
• For compliance purposes, including enforcing our Terms of Service or other legal rights, or as may be required by applicable laws and regulations or requested by any judicial process or governmental agency; and
• For other purposes for which we provide specific notice at the time the information is collected.

How We Share the Information We Collect

Because we do not have access to your photos or messages, we cannot and do not share them. Users can choose to request photos and videos or share photos and videos with Friends (as described in our Terms of Service). AirSwap does not collect any data for advertising purposes, does not share data with advertisers, and has no plans to serve ads.
Affiliates. We may share any information we receive with our affiliates for any of the purposes described in this Privacy Policy. However, we never share your photos, contacts, or messages with any affiliates.

Vendors and Service Providers. We may share any information we receive with vendors and service providers retained in connection with the provision of our Services. For example, our service providers send a verification code to your phone number when you register for our Services.

User Content. Our Services allow you to request, receive and share photos, videos and messages with Friends, and for other Friends to request, receive and share photos and videos of you. We are not responsible for any user’s use of information you send, so you should carefully consider whether and what to share. Users who receive photos and videos of you may share them with other users or may tag other users or individuals without permission. We are not responsible for how users share photos, videos or messages or how the Service shares photos, videos or messages between users.
Other AirSwap Users. If you are a user of AirSwap and a new user joins AirSwap and has your phone number in his or her contact book, or if you have their phone number in your contact book and you join AirSwap, AirSwap will inform both of you that the new user (you or your contact) joined AirSwap.
Tagging. If you choose to link or tag a face in your photos with a Friend, AirSwap will share that information (e.g., the tag) with your AirSwap friends automatically to help them link or tag the same face in their photos with the same Friend.
Analytics Partners. We use analytics services to collect and process certain analytics data. If you get a new computer, install a new browser, erase or otherwise alter your browser’s cookie file (including upgrading certain browsers) you may clear the cookies used to recognize your opt-out request. These services may also collect information about your use of other websites, apps, and online resources. To help us understand how you use our Services and to help us improve them, we automatically receive information about your interactions with our Services, like the dates and times of your visits.
As Required By Law and Similar Disclosures. We may access, preserve, and disclose your information if we believe doing so is required or appropriate to: (a) comply with law enforcement requests and legal process, such as a court order or subpoena; (b) respond to your requests; or (c) protect your, our, or others’ rights, property, or safety.

Merger, Sale, or Other Asset Transfers. We may transfer your information to service providers, advisors, potential transactional partners, or other third parties in connection with the consideration, negotiation, or completion of a corporate transaction in which we are acquired by or merged with another company or we sell, liquidate, or transfer all or a portion of our assets. The use of your information following any of these events will be governed by the provisions of this Privacy Policy in effect at the time the applicable information was collected.

Consent. We may also disclose your information with your permission.

Your Choices

Contacts. You may enable or disable AirSwap’s access to your contact book by using the settings provided by your device’s operating system.

Photos and Videos. You may enable or disable AirSwap’s access to your photos and videos, or to specific photos or videos, by using the settings provided by your device’s operating system.

Third Parties

Our Services may contain links to other websites, products, or services that we do not own or operate. Our Services may also provide you with the ability to invite your Friends to join AirSwap using the communication platform of your choosing. We are not responsible for the privacy practices of these third parties. Please be aware that this Privacy Policy does not apply to your activities on these third party services or any information you disclose to these third parties. We encourage you to read their privacy policies before providing any information to them.

Security

We make reasonable efforts to protect your information by using physical and electronic safeguards designed to improve the security of the information we maintain. However, as no electronic transmission or storage of information can be entirely secure, we can make no guarantees as to the security or privacy of your information.
With respect to biometric information, we maintain administrative, technical, and physical safeguards that are designed to protect biometric information against accidental, unlawful or unauthorized destruction, alteration, access, disclosure or use. We also hash biometric information and/or use encryption to transmit biometric information. We only store biometric information for three years (unless you delete your account, in which case such information is deleted upon deletion of your account). When you delete your account, all data associated with your account is deleted (including any biometric information).
Children’s Privacy

We do not knowingly collect, maintain, or use personal information from children under 13 years of age, and no part of our Services are directed to children. If you learn that a child has provided us with personal information in violation of this Privacy Policy, then you may alert us at privacy@allfriends.ai.

International Transfers of Data

Our Services are hosted in the United States and intended for visitors located within the United States. If you choose to use the Services from the European Union or other regions of the world with laws governing data collection and use that may differ from U.S. law, then please note that you are transferring your personal information outside of those regions to the United States for storage and processing. Also, we may transfer your data from the U.S. to other countries or regions in connection with storage and processing of data, fulfilling your requests, and operating the Services. By providing any information, including personal information, on or to the Services, you consent to such transfer, storage, and processing.

Update Your Information or Pose a Question

If you have questions about your privacy on the Services or this privacy policy, please contact us at privacy@allfriends.ai.

Changes to this Privacy Policy

We will post any adjustments to the Privacy Policy on this page, and the revised version will be effective when it is posted. If we materially change the ways in which we use or share personal information previously collected from you through the Services, we will notify you through the Services, by email, or other communication.

Contact Information

If you have any questions, comments, or concerns about our processing activities, please email us at privacy@allfriends.ai.