PRIVACY POLICY
PhotoSwipe Privacy Policy
Summary of Key Points
- PhotoSwipe (the “App”) helps you review and tidy the Photos library on your iPhone. It processes your photos, videos and their metadata only on your device.
- The Developer does not collect any Personal Data through the App. The App has no developer-operated server, no user accounts, and no analytics, advertising, tracking or third-party software development kits (SDKs). No data is sold or shared. The App’s privacy label on the App Store is therefore “Data Not Collected”.
- The App requests a single iOS permission: access to your Photos library. You may grant Limited Access, and you may change or revoke access at any time in iOS Settings.
- The App changes your library only on your instruction. Every deletion must also be confirmed in a prompt displayed by iOS, and deleted items normally remain recoverable in “Recently Deleted” for about 30 days.
- Some features use Apple services directly from your device. iCloud Photos may download originals. Place names are looked up by sending capture coordinates rounded to about 110 metres to Apple. Maps are provided by Apple, and purchases are processed by the App Store. Apple handles that information under its own privacy policy.
- Information the App stores, such as settings, the deletion queue and statistics, remains on your device until you delete the App. “Withdrawing Consent and Deleting Your Data” explains how to withdraw consent and delete data at any time.
- This summary is provided for convenience only. Please read the full Policy below.
1. Introduction
That Developer Steven (the “Developer”, “we”, “us” or “our”), an independent software developer based in the Hong Kong Special Administrative Region, develops and publishes PhotoSwipe, an application for iPhone (the “App”). This privacy policy (the “Policy”) explains how the App accesses, uses, stores and discloses information, which services are involved, and the rights and choices available to you.
The App helps you review the photos and videos in your Apple Photos library by swiping. You can place items you no longer need in a deletion queue and delete them together after review. The App also lets you browse your library by album and collection, view the details of an item, share items and organize albums.
We are committed to handling information lawfully, fairly and transparently, and to limiting it to what the App needs in order to function. This Policy is prepared with reference to Apple’s App Store Review Guidelines, the Personal Data (Privacy) Ordinance (Cap. 486) of Hong Kong and, where applicable, the EU and UK General Data Protection Regulations. By downloading, installing or using the App, you acknowledge that you have read and understood this Policy. If you do not agree with it, please do not use the App.
2. Definitions and Interpretation
In this Policy, unless the context otherwise requires, the following terms have the meanings set out below:
- Apple
- Apple Inc. and its affiliates, which provide iOS, the App Store, iCloud and the other services on which the App relies.
- Collect
- To transmit information off your Device in a way that allows the Developer, or a third party acting for the Developer, to access it for longer than is necessary to service the request in real time. This follows the meaning Apple uses for App Store privacy disclosures.
- Device
- The iPhone or other Apple device on which you install and use the App.
- GDPR
- Regulation (EU) 2016/679 (the General Data Protection Regulation) and, where applicable, the UK General Data Protection Regulation together with the UK Data Protection Act 2018.
- Personal Data
- Any information relating to an identified or identifiable natural person, including “personal data” as defined in the Personal Data (Privacy) Ordinance and the GDPR, and “personal information” as defined in applicable United States state laws.
- Photo Library
- The photos, videos, Live Photos and albums stored in the Photos app on your Device, together with their metadata, including any library synchronized through iCloud Photos.
- Processing
- Any operation performed on information, such as reading, displaying, organizing, storing, modifying or deleting it, whether or not by automated means. “Process” has a corresponding meaning.
- You
- The individual who downloads, installs or uses the App. “Your” has a corresponding meaning.
Headings are for convenience only and do not affect the interpretation of this Policy. Words such as “including” and “for example” are illustrative and do not limit the words that precede them. References to iOS settings and screen names describe the App and iOS at the date of this Policy and may differ slightly between versions.
3. Scope of This Policy
This Policy applies to the App, version 1.0 and later versions, as distributed through Apple’s App Store, and to any correspondence you send to the Developer about the App. It remains in effect until it is replaced by an updated version published at the address given in “Contact Us”.
This Policy does not apply to iOS, the Photos app, iCloud, the App Store, Apple Maps or any other service provided by Apple. Nor does it apply to any app, website or service to which you choose to send content through the iOS share sheet or by email. Those services are governed by their own terms and privacy policies, including the Apple Privacy Policy.
The App is an independent product and is not affiliated with, endorsed by or sponsored by Apple. Apple, iPhone, iCloud, iOS and App Store are trademarks of Apple Inc.
4. Overview of Our Data Practices
The App is designed so that your Photo Library, and all information derived from it, remains on your Device. Counting, filtering, sorting, random selection, grouping into collections, statistics and the preparation of deletion queues are all performed locally on your Device.
The Developer does not operate any server, database, user-account system or cloud storage for the App, and the App contains no code that sends information to the Developer. The App does not include any analytics, crash-reporting, advertising, attribution or other third-party SDK. Accordingly, the Developer does not Collect any Personal Data through the App, and the App’s privacy details on the App Store are declared as “Data Not Collected”.
Information Processed only on your Device is not “collected” in the sense used by Apple. However, some Apple services that the App uses receive certain information directly from your Device, as described in “Apple Services and Other Third Parties”. Apple is responsible for its own handling of that information.
5. Information the App Processes
This section describes the categories of information the App Processes, the source of each category and where it is kept.
5.1 Photo Library Content and Metadata
Subject to the access you grant (see “Device Permissions”), the App reads the following information from your Photo Library so that it can display and organize it: photos, videos and Live Photos; creation and modification dates; filenames; media type, dimensions and file sizes; favorite and hidden status; album and collection membership; captions stored with an item; subtitles provided by iOS for videos; camera and exposure details; and the location at which an item was captured, where one is stored with it.
The App does not upload your photos or videos and does not copy them to any server. It does not analyze the content of your images to identify people, faces or objects, and it performs no facial recognition, biometric processing or machine-learning analysis.
5.2 Information Stored on Your Device
To remember your progress and preferences, the App stores the following information within its own sandboxed storage on your Device:
| Category | What it includes | Purpose | Where it is kept | Retention |
|---|---|---|---|---|
| Settings and preferences | Your choices in the App, such as language, appearance, review filters, gesture and deletion-protection options, whether capture locations are shown, the selected app icon, and whether you have completed the tutorial. | To apply your preferences each time you open the App. | The App’s preferences storage (UserDefaults) on your Device. | Until you change the setting or delete the App. |
| Review progress, deletion queue and bookmarks | Identifiers that iOS assigns to items in your Photo Library, recording which items you have reviewed, marked for deletion, selected or bookmarked, and your position in a review. | To let you resume a review, and to confirm and carry out the deletions you request. | The App’s preferences storage on your Device. | Until you remove the marks (for example, with “Cancel all queued”), the deletion is completed, or you delete the App. Marks for items that are temporarily unavailable are kept so that your choices return when access is restored. |
| Statistics | The number of items reviewed and deleted, in total and for the current day, the identifiers needed to avoid counting an item twice, and the estimated storage space freed. | To show your progress and the space you have freed. | The App’s preferences storage on your Device. | Until you delete the App. |
| Library index | A cache of item identifiers, filenames, dates, dimensions, file sizes, status flags, album membership and stored capture coordinates. | To open your library and sort it by size quickly, without re-reading every item each time. | A file in the App’s Application Support folder, protected by iOS Data Protection and excluded from Device backups. | Updated as your library changes; deleted when you delete the App. |
| Onboarding survey answers | If you answer the optional survey on first launch, the ranges you select for the approximate number of photos in your library and the storage space they use. | To estimate, on the closing screen of the survey, how much space the App may help you free. | The App’s preferences storage on your Device. | Until you delete the App. You may skip the survey. |
| Temporary files and caches | Temporary copies of items you share, Live Photo effect files, and image, caption and place-name caches held in memory. | To prepare items for sharing or playback and to keep the App responsive. | Temporary storage or memory on your Device. | Temporary files are deleted when sharing is completed, cancelled or dismissed, or as soon as they are no longer needed; memory caches are cleared when the App is closed. If the App is force-quit, iOS removes any remaining temporary files in due course. |
Information in the App’s preferences storage may be included in backups of your Device made through iCloud Backup or a computer, in accordance with your backup settings. Such backups are created and controlled by you and by Apple, not by the Developer.
5.3 Information You Choose to Provide
The App does not require registration, sign-in or any personal details in order to function. You may, at your option, provide information in the following ways:
- Support correspondence. If you use the support option in the App, your email app opens a new message addressed to us that contains only a subject line. The App does not add device information, diagnostic data or photos. We receive only what you choose to send, together with your email address and any information your email provider includes.
- Ratings and reviews. Ratings and reviews you submit through Apple’s rating prompt or the App Store are handled by Apple and may be published by Apple. The Developer receives them only in the form Apple makes available to developers.
5.4 Information We Do Not Collect
Through the App, the Developer does not Collect, receive, store or have access to:
- your photos or videos, or any copies, thumbnails or derivatives of them;
- the metadata of your Photo Library, including dates, filenames, captions and capture locations;
- your name, email address, telephone number or other contact details, except where you email us;
- your precise or approximate Device location, because the App does not request access to Location Services;
- device identifiers, the advertising identifier (IDFA) or the identifier for vendor (IDFV);
- usage data, analytics, crash logs or performance diagnostics generated by the App itself (for diagnostics that Apple may provide with your consent, see “Diagnostics Provided by Apple”);
- payment card or other financial information, which is handled exclusively by Apple;
- contacts, camera, microphone, health, biometric or browsing data; or
- information from other apps on your Device.
6. Purposes and Legal Bases of Processing
The App Processes information solely for the following purposes:
- to display your Photo Library and enable you to review, sort, filter, bookmark and organize its items;
- to record the items you mark for deletion and to submit your confirmed deletion requests to iOS;
- to calculate and display statistics and the estimated storage space freed;
- to show the date, details and place of capture of an item, and a map of that place;
- to prepare items that you choose to share;
- to provide and restore the optional Pro purchase;
- to respond to your support requests; and
- to comply with applicable legal obligations.
The App does not use information for advertising, marketing, profiling, data brokerage or the training of artificial-intelligence or machine-learning models. It does not use information from your Photo Library to build any database for the Developer’s own use or for sale or distribution to third parties.
Where the GDPR or a similar law applies, and to the extent that the Processing described in this Policy is attributable to the Developer, the Developer relies on the following legal bases:
| Processing activity | Legal basis |
|---|---|
| Processing your Photo Library on your Device to provide the App’s features, within the access you grant through iOS | Performance of a contract with you, namely providing the App you have chosen to use (GDPR Article 6(1)(b)) |
| Displaying place names and maps for items that have a stored capture location | Performance of a contract (Article 6(1)(b)) and our legitimate interest in providing a complete photo-details feature (Article 6(1)(f)) |
| Providing and restoring the Pro purchase | Performance of a contract (Article 6(1)(b)) |
| Responding to support correspondence | Our legitimate interest in responding to your enquiry (Article 6(1)(f)) and, where relevant, performance of a contract (Article 6(1)(b)) |
| Retaining correspondence where the law requires it | Compliance with a legal obligation (Article 6(1)(c)) |
In accordance with Data Protection Principles 1 and 3 of the Personal Data (Privacy) Ordinance, any Personal Data that the Developer receives, such as support correspondence, is collected for a lawful purpose directly related to providing and supporting the App, and will not be used for a new purpose without your prescribed consent.
7. Device Permissions
The App requests only the permission that is necessary for its core functionality:
| Permission | Why it is needed | Your choices |
|---|---|---|
| Photos (read and write access) | To display the items in your Photo Library and, on your instruction, to delete items, mark favorites, create, rename or delete albums, and add items to or remove items from albums. The App’s permission request states: “PhotoSwipe uses the photos and videos you allow to display, sort and group them on your device. You choose when to share, favorite, add to albums or confirm deletion.” | You may grant full access, grant Limited Access to selected items only, or refuse access. You may change your choice at any time in iOS Settings under Privacy & Security > Photos > PhotoSwipe. |
The App does not request access to Location Services, the camera, the microphone, contacts, calendars, Bluetooth, the local network, notifications or health data, and it does not request permission to track you under App Tracking Transparency. Before iOS asks for Photos access for the first time, the App explains on its own screen why access is needed.
If you refuse or revoke Photos access, the App cannot display your Photo Library, but nothing in your Photo Library is affected. The optional Pro purchase does not require you to grant any additional permission.
8. Changes the App Makes to Your Photo Library
Because the App is a library-management tool, it can modify your Photo Library, but it does so only in response to an action that you take:
- Deletion. Swiping an item into the deletion queue does not delete it. Items are deleted only after you choose to delete them from the queue and then confirm the deletion in a prompt displayed by iOS, which no app can bypass. If “Confirm before deleting” is turned on, the App first shows you the selected items for review.
- Recently Deleted. Under Apple’s current practice, deleted items normally remain in the Recently Deleted album of the Photos app for about 30 days, during which you can recover them in the Photos app.
- Albums and favorites. The App creates, renames or deletes albums, adds items to or removes items from albums, and marks or unmarks favorites only when you choose those actions. Deleting an album does not delete the photos in it.
- iCloud Photos. If iCloud Photos is turned on, Apple synchronizes the changes you make through the App, including deletions, to your other devices that use the same library.
The Developer has no access to your Photo Library and cannot recover items that have been permanently deleted.
9. Apple Services and Other Third Parties
The Developer does not share Personal Data with any third party. Certain features of the App, however, use services provided by Apple through iOS. When you use these features, information is transmitted from your Device directly to Apple and not to the Developer. Apple Processes that information under the Apple Privacy Policy, and the Developer cannot access it.
9.1 iCloud Photos
If your Photo Library is stored in iCloud Photos, displaying, playing, sharing or showing the details of an item whose original is stored only in iCloud may cause iOS to download that original from Apple’s servers. The download is performed by Apple’s Photos framework. It does not upload your data, and the Developer does not receive it.
9.2 Place Names and Maps
Where an item has a stored capture location, the App displays the name of the place. To obtain that name, the App rounds the coordinates to three decimal places (approximately 110 metres) and sends them, together with the App’s display language, to Apple’s geocoding service. These look-ups take place automatically when the App shows the place of an item during a review, in the information panel, or for event collections in the Library. The results are kept in memory, and look-ups are rate-limited.
When you open the information panel for an item, a map of the capture area is displayed using Apple’s MapKit service, which requests map data for the area around the stored coordinates. If you choose “Open in Maps”, the stored coordinates are passed to the Apple Maps app.
The App never requests or uses your Device’s current location. Turning off “Show capture location” in the App hides the place label during review and stops the look-ups for that label. Place names may still be looked up when you open the information panel or browse event collections. Items without a stored location are never looked up. You can stop recording locations with new photos under Privacy & Security > Location Services > Camera in iOS Settings, and you can remove the location from items in the Photos app.
9.3 In-App Purchase
The App offers an optional one-time purchase (“Pro”) that unlocks appearance customization. All features for reviewing, deleting, sharing and organizing remain free. Purchases and restorations are processed entirely by Apple through the App Store and StoreKit. The App receives from Apple only signed transaction information showing whether Pro has been purchased, which it verifies on your Device. The Developer does not receive your name, Apple Account details or payment card information. Apple provides developers with sales reports that do not identify individual purchasers.
9.4 Ratings Prompt
After a large deletion, the App may ask iOS to display Apple’s standard rating prompt, at most once for each version of the App. iOS decides whether the prompt appears, and any rating or review you submit is handled by Apple.
9.5 Diagnostics Provided by Apple
If you have turned on “Share with App Developers” in iOS Settings under Privacy & Security > Analytics & Improvements, Apple may provide the Developer with crash reports and aggregated usage and performance statistics relating to the App. Through App Store Connect, Apple also provides aggregated download and sales information. These reports are generated and controlled by Apple, do not contain the content of your Photo Library, and are used by the Developer only to maintain and improve the App. You can turn this sharing off at any time in the same setting.
9.6 Sharing and Email
When you share items, the App passes them to the iOS share sheet, and they are sent only to the destination you select. Shared files may contain metadata, including the capture location, and the receiving app or service handles your copy under its own terms and privacy practices. If you email us, your message is processed by your email provider and by Google, which provides the Developer’s Gmail service, under the Google Privacy Policy.
9.7 Third-Party SDKs and Equivalent Protection
The App does not contain any third-party analytics tools, advertising networks or other third-party SDKs, and no parent, subsidiary or other related entity has access to user data. If the Developer ever shares user data with a third party in future, it will do so only after updating this Policy and obtaining any consent required by law, and only with a third party that provides the same or equal protection of user data as stated in this Policy and as required by Apple’s App Store Review Guidelines.
10. Disclosure of Information
The Developer does not sell, rent, trade or otherwise disclose Personal Data, and does not “sell” or “share” Personal Data as those terms are defined in the California Consumer Privacy Act, as amended. Because the App does not transmit information to the Developer, the Developer holds no information from the App that it could disclose to advertisers, data brokers or other third parties.
The Developer may disclose support correspondence only where required to do so by applicable law, regulation, court order or other legal process, or where reasonably necessary to protect the rights, property or safety of the Developer, users or others, and in each case only to the extent so required.
If the App is transferred to another developer, for example as part of a sale or reorganization, any support correspondence relating to the App may be transferred to the new developer. The new developer will be bound by this Policy, or by a policy that provides at least equivalent protection, and you will be notified as described in “Changes to This Policy”.
11. Data Security
The App keeps information within its own sandboxed storage on your Device, which iOS isolates from other apps. The library index is stored with iOS Data Protection, so that it cannot be read after the Device restarts until you first unlock it, and it is excluded from backups. Because no information is transmitted to the Developer, there is no Developer-held copy of App data that could be exposed through a breach of the Developer’s systems.
Communications between your Device and Apple services are carried out by iOS and secured by Apple in accordance with Apple’s own practices.
The security of information on your Device also depends on you. We recommend that you protect your Device with a passcode, Face ID or Touch ID, keep iOS up to date, and encrypt any backups you make on a computer. No method of electronic storage or transmission is completely secure, and the Developer cannot guarantee absolute security.
12. Data Retention
Information is retained only for as long as it is needed for the purposes for which it was obtained, consistent with Data Protection Principle 2 and section 26 of the Personal Data (Privacy) Ordinance and Article 5(1)(e) of the GDPR:
- Information stored by the App on your Device: kept on your Device for the periods set out in “Information Stored on Your Device”, and deleted when you delete the App. The Developer never holds a copy.
- Device backups: copies included in iCloud or computer backups remain until those backups are deleted or replaced, under your control and Apple’s.
- Place names, captions and media held in memory: kept only while the App is running.
- Support correspondence: kept only for as long as reasonably necessary to deal with your request and any follow-up, unless a longer period is required by law. You may ask us to delete it at any time.
13. Withdrawing Consent and Deleting Your Data
You can withdraw your consent and delete information at any time, without contacting us:
- Revoke or limit Photos access. Open iOS Settings, go to Privacy & Security > Photos > PhotoSwipe, and choose Limited Access or None. The App will then stop reading your Photo Library, or will read only the items you select. Deletion marks for items that become unavailable are kept, so that your choices return if you restore access.
- Clear the deletion queue. In the App’s deletion queue, choose “Cancel all queued” to remove every deletion mark. No photo is deleted.
- Reduce place-name look-ups. Turn off “Show capture location” in the App’s settings.
- Delete all App data. Delete the App from your Device: touch and hold the App icon, then choose Remove App > Delete App. iOS then deletes the App’s settings, deletion queue, statistics, survey answers, library index and temporary files. Deleting the App does not delete your Photo Library or your purchase history with Apple, and Pro can be restored if you reinstall the App.
- Delete backed-up copies. Delete or replace any iCloud or computer backups that contain App data, following Apple’s instructions.
- Request deletion of correspondence. Email ThatDeveloperSteven138@gmail.com to ask us to delete your support correspondence. We will do so within 30 days, unless the law requires us to keep it.
Because the Developer does not hold any data from the App, the steps above give you direct and complete control over the information the App Processes.
14. Your Rights
Depending on where you live, you may have the following rights in relation to your Personal Data:
- Hong Kong: under the Personal Data (Privacy) Ordinance, the right to request access to, and correction of, Personal Data held about you. We will comply with a data access request or data correction request within 40 days of receiving it, as the Ordinance requires.
- European Economic Area and United Kingdom: under the GDPR, the rights of access, rectification, erasure, restriction of Processing, data portability and objection; the right to withdraw consent at any time, without affecting the lawfulness of Processing before its withdrawal; and the right not to be subject to a decision based solely on automated Processing.
- California and other US states: under the California Consumer Privacy Act, as amended by the California Privacy Rights Act, and similar state laws, the rights to know, delete and correct personal information, to opt out of its sale or sharing, to limit the use of sensitive personal information, and not to be discriminated against for exercising these rights.
Because the Developer does not Collect Personal Data through the App, most of these rights are exercised by managing data on your Device, as described in “Withdrawing Consent and Deleting Your Data”. For any correspondence we hold, you may exercise your rights by emailing ThatDeveloperSteven138@gmail.com. We may need to verify your identity before responding, and we will not charge a fee except where the law permits.
You also have the right to lodge a complaint with a data protection authority, such as the Office of the Privacy Commissioner for Personal Data, Hong Kong, the supervisory authority in your EU Member State, or the UK Information Commissioner’s Office. We would, however, appreciate the opportunity to address your concerns first.
15. Children’s Privacy
The App is a general-audience utility and is not directed to children under the age of 13, or under the minimum age of digital consent in your jurisdiction. It is not offered in the Kids category of the App Store. The Developer does not knowingly collect Personal Data from children, and because the App does not transmit information to the Developer, no such data is received through it. If you are a parent or guardian and believe that a child has sent us Personal Data by email, please contact us and we will delete it.
16. International Data Transfers
The Developer is located in the Hong Kong Special Administrative Region. The App does not transfer information to the Developer, in Hong Kong or elsewhere. Information sent from your Device to Apple services may be Processed by Apple in countries other than your own, in accordance with Apple’s privacy policy and the transfer safeguards Apple applies. If you email us, your message is delivered through your email provider and Google’s Gmail service, which may process it in other countries, and is received by the Developer in Hong Kong.
17. Tracking, Advertising and Automated Decision-Making
The App does not track you across apps or websites owned by other companies and does not use the advertising identifier, so it does not ask for permission under App Tracking Transparency. The App displays no advertising.
The App does not carry out profiling or automated decision-making that produces legal or similarly significant effects concerning you. Features such as random selection and sorting by size run only on your Device and serve only to present items to you.
18. Changes to This Policy
We may update this Policy from time to time to reflect changes to the App, to our practices or to applicable law. The updated Policy will be published at the address given in “Contact Us” with a revised “Last updated” date. If we make a material change, in particular one that would involve collecting or sharing Personal Data, we will give prominent notice before the change takes effect, for example in the App or in its App Store release notes, and we will obtain your consent where the law requires it. Earlier versions of this Policy are available on request.
19. Language
This Policy is written in English and may be translated into other languages for convenience. If there is any inconsistency between the English version and a translation, the English version prevails to the extent permitted by law.
20. Contact Us
If you have any questions, requests or complaints about this Policy or the App’s privacy practices, please contact the Developer:
- Developer: That Developer Steven
- Email: ThatDeveloperSteven138@gmail.com
- Website: https://www.thatdevelopersteven.com
We aim to reply within 30 days, or within any shorter period required by law. If you contact us by email, we receive your email address and the content of your message and use them only to respond to you.
This Policy is published at https://www.thatdevelopersteven.com/ios-application/photoswipe/Privacy-Policy