Privacy Policy

Operator: Folkone Pty Ltd (ABN 40 696 661 560; ACN 696 661 560)
Contact: hello@swem.ai
Postal address: Level 1, 63–73 Ann Street, Surry Hills NSW 2010, Australia

1. About this policy

The Swem app is an 18+ social connection service designed to help people find friends who suit them. In the app, Swem is also a character: a manta ray, powered by AI, that chats with you, learns from what you choose to share and helps identify people you are likely to get along with.

This Privacy Policy explains how Folkone Pty Ltd (“Folkone”, “we”, “us” or “our”) collects, holds, uses and discloses personal information.

In this policy, the “Platform” means the Swem mobile app, our websites, support channels and related services. “Swem” on its own means the character in the app.

When a feature needs a more specific explanation, such as Swem, location, age assurance or reporting, we may also give you a collection notice at the time the information is collected.

2. The personal information we collect

We collect personal information that is reasonably necessary for our functions and activities. The information we collect depends on how you use the Platform and may include:

• Account and eligibility information, such as your name, contact details, date of birth or age status, sign-in method, account identifiers and information needed to keep your account secure or confirm that you are eligible to use the Platform.
• Profile and preference information, such as your photos, biography, city or general location, interests, languages, the gender or genders of the people you want to meet, relationship or connection preferences and the people or opportunities you would like to find.
• Location information, such as the city on your profile; if you allow location access, a rounded location from your device (the center of a grid square about 1.5 km wide) used for searching by distance; and a place you choose to send in a chat or add to a post, which can be your current location or any other place you pick and is not rounded. Section 10 explains when we read your device’s location and how long we keep it.
• Swem conversations and AI-derived information, including what you tell Swem, your answers to Swem’s quiz, conversation summaries, facts and preferences identified from the conversation and inferences about compatibility, personality, values, interests or relationship preferences.
• Interactions and content, such as connection choices, messages (including messages in group chats), posts, comments, likes, media and other content you create, send or share.
• Purchase information, such as the product you bought, its price and currency, purchase and renewal dates, subscription status and transaction identifiers provided by the app store and our purchase verification provider. We do not receive your full card or payment account details.
• Safety and support information, such as reports, blocks, complaints, appeals, support requests, relevant communications and evidence needed to investigate misuse or protect people.
• Technical and usage information, such as IP address, device and app information, log and diagnostic data, feature activity, approximate network location, notification tokens and security signals.
• Website information, such as the email address and related details kept when you ask for an invite on our website. Section 10 explains what our website collects and how it counts visits.
• Information from other sources, such as information another user provides in a report, information supplied by a sign-in or age assurance provider, purchase records from an app store and information from public sources where collection is lawful and reasonably necessary.

Some of this information may be sensitive information. Section 4 explains how we handle it.

The Platform will identify the profile details and content that are displayed to other users. Information shown in private settings, internal safety tools or Swem is not automatically public.

3. How we collect information

We collect personal information:

• from you, when you register, complete a profile, talk to Swem, choose or contact connections, post content, make a purchase, attend or check in to a Swem activity, use a QR code, contact support, ask for an invite on our website, make a report or otherwise use the Platform;
• automatically, when you use the Platform, through logs, device permissions, cookies or similar technologies, website visit counting and security or diagnostic tools;
• from other people, for example when another user interacts with you, shares content with you or reports a concern involving you;
• from service providers, such as authentication, age assurance, communications, cloud, AI, purchase verification and support providers; and
• from public sources, where the collection is lawful, fair and reasonably necessary for the relevant function.

If you provide personal information about another person, you must be authorized by that person or otherwise permitted to provide it, such as when making a genuine safety report. You should not share more than is needed.

4. Sensitive information and Swem

What you choose to share may reveal information that Australian privacy law treats as sensitive. Swem may obtain or derive sensitive information from your conversations, other profile information or information you disclose while using Swem. Examples may include sexual orientation, health or disability information, racial or ethnic origin, religious or philosophical beliefs, political opinions, trade union membership or criminal history.

The gender or genders of the people you want to meet may indicate your sexual orientation. We treat that preference as sensitive information. We use it to suggest connections whose preferences are compatible with yours, and we do not show it on your profile unless the Platform clearly says so. We ask for it when you sign up and explain why it is needed.

We collect sensitive information only where you have consented and the collection is reasonably necessary for one or more of our functions or activities, or where collection is otherwise permitted or required by law. Sensitive information may be provided when you set up an account, complete your profile, use a particular feature, talk to Swem or post certain information.

Where required by law, we ask for your express consent through a separate consent control before collecting or using sensitive information for Swem-based profiling and matching. The consent request will explain the relevant purpose, the information involved, the service providers that may process it and the effect of declining. Merely accepting these Terms or reading this Privacy Policy is not treated as that separate consent.

You may choose not to provide sensitive information. You may also withdraw such consent through the available in-app control or by contacting us. If the information is needed for Swem or personalized matching, declining or withdrawing consent may mean that those features cannot operate, do not work in the same way or provide a less personalized experience.

Withdrawing consent applies to future handling. It does not invalidate handling that was lawful before withdrawal, and we may keep limited information where reasonably necessary for safety, dispute resolution or legal obligations.

We do not use or disclose sensitive information for another purpose unless that purpose is directly related to the purpose for which it was collected and you would reasonably expect the use or disclosure, you have consented or the use or disclosure is otherwise permitted or required by law. We do not use sensitive information for marketing unless you have specifically consented.

If you tell Swem that you are thinking about suicide or self-harm, Swem shows you crisis support information, and we keep a record that this happened, linked to your account and to the message, for up to 90 days. Authorized staff may review these records from time to time to help keep people safe and to improve how Swem responds. These records are not monitored in real time, and Swem is not an emergency or crisis service. If you are in immediate danger, call 000. In Australia you can call Lifeline on 13 11 14 at any time.

Swem uses automated processing and may produce incomplete, inaccurate, biased or inconsistent inferences. You can correct relevant profile information, decline a suggested connection and contact us about information that appears wrong.

5. Automated decision-making

We use automated tools, including AI, to operate parts of the Platform. These tools may use:

• profile information, preferences, Swem conversations and AI-derived information to rank, suggest or explain potential connections;
• content submitted to profiles or other shared Platform areas to determine whether it can be published or should be restricted; and
• account activity, technical signals, reports and safety information to detect misuse or flag an item for review.

Automated processing may therefore affect the connection suggestions you see or whether particular shared content can be published. For example, photos you upload to your profile or to Space are automatically checked for sexually explicit and graphically violent content, and a photo that is very likely to contain either is not published. At present, automated content screening applies to profiles and other shared content, not routine review of private direct messages. A private message may still be handled when a user reports it, when limited evidence must be preserved for a safety matter or where handling is otherwise permitted or required by law.

User reports and appeals are sent to authorized reviewers. At present, an automated tool does not make the final decision to suspend or ban an account. An authorized reviewer makes that decision using the relevant report, evidence, account history and safety context.

If an automated decision or automated step materially affects you, you may email hello@swem.ai to ask what happened, request an explanation, correct relevant information or ask for review by a person. Automated tools can make mistakes, and we will consider a request within a reasonable time.

6. How we use personal information

We use personal information to:

• provide, operate, personalize, maintain and improve the Platform;
• create and manage accounts and confirm eligibility;
• operate Swem, understand user preferences and produce or explain potential connections;
• use the rounded device location you last shared only to search by distance, both when you search and when other members search for people within a distance of them, and not to change your profile city or for advertising;
• enable profiles, messaging, shared content and other user interactions;
• process and verify purchases, provide paid features and handle renewals, cancellations, refunds and related questions;
• communicate about the account, support, security, reports and important service changes;
• invite people who ask for an invite on our website and understand interest in Swem in aggregate, as section 10 explains;
• investigate reports, prevent fraud and misuse, enforce our Terms and protect users and the Platform;
• analyze performance, reliability, matching quality, accessibility and user experience;
• develop, test, upgrade and enhance our services, subject to applicable notice and consent requirements;
• comply with law, respond to lawful requests and establish, exercise or defend legal claims; and
• manage our business, advisers, insurance, corporate transactions and records.

We may use aggregated or de-identified information for analytics, evaluation, research and service improvement where it is no longer reasonably capable of identifying an individual.

7. Marketing communications

We do not currently send optional marketing communications. If you ask for an invite on our website, we email you only about that invite (section 10). If we introduce marketing, advertising or promotional communications, we may use personal information for those purposes only where permitted by law and after providing a separate opt-in control where required. Agreeing to these Terms, accepting this Privacy Policy or consenting to Swem processing will not by itself opt you in to marketing.

Each marketing message will explain how to unsubscribe or use the relevant preference control. We will process an opt-out within the period required by law. You may still receive transactional, operational, safety, support and legal messages that are necessary for your account or use of the Platform.

8. Who we disclose information to

We may disclose personal information to:

• other users, when you choose to make profile details or content visible, contact someone, participate in a shared feature or receive a match explanation;
• service providers, including providers of hosting, storage, databases, authentication, age assurance, AI processing, purchase verification, analytics, security, communications, support and content delivery;
• professional advisers and insurers, where reasonably necessary for advice, claims, audit or risk management;
• regulators, courts, law enforcement or emergency services, where required or authorized by law or reasonably necessary to address a serious threat, suspected offense or significant safety concern;
• a buyer, investor, successor or transaction adviser, in connection with a genuine financing, restructure, merger or sale, subject to appropriate confidentiality and legal requirements; and
• another person, when you direct us to disclose the information or otherwise consent.

Our main service providers currently are:

• Railway, for application servers and databases;
• Cloudflare, for file and media storage, our domain and our website, including its invite list, visit counting (Cloudflare Web Analytics) and the bot check on its invite forms (Cloudflare Turnstile);
• Google, for the AI services that power Swem and related features;
• Google (Cloud Vision), for automatically checking photos uploaded to profiles and Space for sexually explicit or graphically violent content;
• Resend, for account and service emails;
• Apple and Expo, for app distribution, push notifications and, on iOS, payments; Apple also provides the maps, place search, addresses, nearby places and street-level images in location features;
• RevenueCat, for verifying purchases and subscription status;
• KLIPY, for searching GIFs you choose to send in chat; and
• Grafana Labs (Grafana Cloud), for service monitoring and alerts.

We require contracted processors to handle personal information for the agreed service purposes and subject to applicable privacy, security and confidentiality requirements. We will update this list when our main providers change.

We do not currently disclose personal information to business partners for their own marketing or independent commercial use. If that practice changes, we will update this policy and obtain any consent required by law.

We do not give another user your raw Swem conversation or the internal evidence behind Swem’s inferences merely because the Platform recommends a connection. Other users may copy or share information that you disclose to them, so consider carefully what you choose to share.

9. Overseas processing and disclosure

Some service providers, personnel or systems may be located outside Australia. Overseas processing may occur for cloud hosting, storage, authentication, AI, communications, purchase verification, support, security or other Platform operations.

The countries likely to receive or access personal information are Singapore, the United States and Japan. Photos and other files are stored with Cloudflare in its Asia-Pacific region; Cloudflare does not disclose the specific country within that region. We chose Cloudflare’s Oceania location for the database that holds our website’s invite list. Cloudflare’s network is global, so a visit to our website or an invite request may be handled at a Cloudflare data center in another country. Cloudflare may also process the invite list, its backups, the website’s visit counts and its logs outside Australia.

Where Australian Privacy Principle 8 applies, we take reasonable steps to ensure that an overseas recipient handles personal information consistently with the Australian Privacy Principles, subject to exceptions permitted by law.

10. External services, device permissions and our website

The Platform may connect to third-party sign-in, map, GIF, link preview, media or other services. A third party may collect information independently when you choose to use its service. Its own privacy policy then applies to that handling. We recommend that you read the third party’s privacy policy and understand how it collects, uses and discloses personal information before using the service.

Some features may request device permissions, such as photos, camera, notifications or location. You can manage permissions in your device settings. Refusing a permission may prevent the related feature from working as intended or may affect your experience.

Location for searching by distance. For introductions, we use your device’s location only for the option to meet people within a chosen distance. The app asks for location permission the first time you search by distance or open the location picker described below. If you allow it, the app reads your device’s location each time you ask Swem to look for people, whichever search area you choose. Before the location leaves your phone, the app rounds it to the center of a grid square about 1.5 km wide. Your exact coordinates are not sent to us or stored by us. We do not read your location in the background or when you open the app. Apart from these searches, the app reads it only when you open the location picker described below.

We keep the rounded location you last shared until you share a new one. We use it as the center of your own distance searches and to work out whether you are within the distance other members choose. Turning off location permission stops the app from reading your location, but it does not delete the last rounded location, and we continue to use it for other members’ distance searches. To have it deleted, email hello@swem.ai or delete your account. If you have never shared your location, we use the center of the city on your profile. A distance search needs your location at the time of that search; if the app cannot get it, you can search by city, state, country, continent or worldwide instead, which use the city on your profile. We do not show your distance or location to other members.

Locations you share in chats and posts. Separately, you can choose a place to send in a chat or add to a Space post. It is the place you pick, which can be your current location, a pin you drop, a search result or a nearby place, together with any place name or address included with it, and it is not rounded. We store it as part of the message or post and show it to the people who can see that message or post. When someone opens the location on a post, the app uses that post’s location, not the viewer’s location, to show a street-level image and nearby places from Apple’s map service. We do not use these locations for matching. When you open the location picker, the app reads your device’s current location to center the map and suggest nearby places. To show the map, places and addresses, that location and anything you type in the search box are sent to Apple’s map service. They are not sent to us unless you share a location.

Neither the app nor our website currently uses advertising tools from other companies, and we do not track you across other companies’ apps or websites. The app does not currently use analytics tools from other companies. Our website counts visits only with Cloudflare Web Analytics, which sets no cookies (described below). Apart from the note our website keeps in your browser’s session storage about how you arrived (described below), we use cookies or similar technologies only where needed for sign-in, security, preferences and the reliable operation of the Platform. Our website provider may set cookies that are strictly necessary for security, such as protection against automated traffic. If we start using other analytics or advertising tools, we will update this policy and provide any choices required by law.

Our website and its invite list

Cloudflare hosts our website at swem.ai, stores its invite list and counts its visits for us as our service provider. Section 9 explains where Cloudflare may handle this information. Like the rest of the Platform, the invite list is for people 18 or older.

Counting visits. Our website uses Cloudflare Web Analytics to count visits and see how well pages load. When you open a page, a script from Cloudflare sends it the page’s address, the page that linked you there and measurements of how the page loaded and responded (such as load times), with an identifier for that page view only. Cloudflare records the address without anything after a question mark and works out your country and the kind of browser, operating system and device you use from your connection and the description your browser sends of itself. The script sets no cookies and stores nothing in your browser. Cloudflare receives your IP address with each report and says it discards it without storing it. We see only totals, such as visits by country or by referring site, not who made them. Cloudflare’s dashboard shows us the last six months. Cloudflare also receives your IP address and the details your browser sends with every request, as it must to deliver and protect our website, and its dashboard shows us overall totals of that traffic, such as requests by country. Apart from these totals and Web Analytics, our website does not count visits.

How you arrived. When you first open a page of our website in a browser tab, the page notes in that tab’s session storage how you arrived: the name of the site that linked to it (never the address of the linking page), any campaign tags (utm_source, utm_medium and utm_campaign) and any ?ref= name in the link, which kind of click code the link carried, if any (the code that an ad network or app such as Google, Facebook, TikTok or X adds to its links, for example gclid, fbclid or ttclid), but never the code itself, the first page you opened and, on an iPad, that it is an iPad. This note is not a cookie. It stays in that tab until you close it, and it leaves your browser only if you ask for an invite.

Asking for an invite. If you leave your email address in one of the invite forms on our home page, we keep:

• your email address, which form you used and when you first asked;
• your country and region (such as AU and NSW), as Cloudflare works them out from your IP address;
• the kind of device you use (such as iPhone, Android or Mac) and, if you opened our website inside an app such as TikTok, Instagram or Facebook, which app, both worked out from the description your browser sends of itself (its user agent), which we do not keep;
• your browser’s first choice of language (such as en-AU);
• how you arrived at our website, from the note described above;
• your answer to the optional question “Who would you like to meet?”, if you give one;
• whether the address was already on the invite list of our earlier website, 1in8b.com (see below);
• how many times the address has asked for an invite and when it last did; and
• a random code made with your latest request from a page whose scripts ran, which lets the page save your answer to that question within 24 hours of your latest request. The page holds the code only while it is open. The code stays with your entry but identifies nothing outside the list.

If you asked at 1in8b.com. The Swem app was called 1in8B until November 2026. We moved the invite list from 1in8b.com into the same database, keeping only each email address and when it first asked, so we can check new requests against it and invite nobody twice. The forms answer every request the same way, so they never show whether an address was on that list.

You do not have to give us your email address, but without it we cannot invite you. Answering the question about who you would like to meet is optional. The forms need your browser to run the page’s scripts, for the check described below. We do not store your IP address, the description your browser sends of itself, the click code from a link, a cookie or any identifier that follows you from visit to visit. If you ask again with the same address, we keep one entry, count the request and keep what we first recorded, except that a new code replaces the old one. A new answer to the question replaces your earlier answer.

Checking for bots. To keep automated sign-ups out of the list, the invite forms use Cloudflare Turnstile. When you start using a form, a frame from Cloudflare runs a short check in your browser and asks you to tick a box only if it is unsure. To do this, Cloudflare processes your IP address, the description your browser sends of itself, technical details of your connection and the page you are on, and says it uses them only to detect and block bots and to improve that detection. Anything Turnstile stores in your browser stays in Cloudflare’s frame, under Cloudflare’s cookie policy. Our website receives only whether the check passed (never your address) and keeps nothing from it. If you never use a form, the check does not run.

Why we keep it. We use your email address only to invite you when there is a place for you. We use the other details to understand interest in Swem as a whole, such as how many people ask, how they found our website (for example through a post on X or TikTok, or a search), where they are, what devices they use and who they hope to meet. Reports we share about that interest, for example with investors, hold only totals, never the list itself or anything that identifies you.

How long we keep it. We keep your entry until you ask us to remove it or until we no longer need it to invite you, and then delete it.

Leaving the list. To be removed, email hello@swem.ai with the address you used. We may ask you to confirm the request from that address. Removal deletes your entry from the list and from any copy of the list we have saved on our own computers, for example to send invites. Cloudflare keeps point-in-time backups of the list for up to 30 days, so a copy that includes your entry stays in those backups until it ages out. If we ever restore the list from one of them, we will remove your entry again. Our visit counts never hold your email address.

Signup records. Each time we keep an invite request, our website also writes a short record to Cloudflare’s logging service saying whether the address was new or had asked before and which form was used. We put no email address in it. Cloudflare may add details of its own about the request to each record, such as the time, the country and city it came from and the IP address. Cloudflare keeps these records for up to 7 days, as it does records of any errors in our website’s code.

Limits on requests. To stop the forms from being flooded, Cloudflare counts the requests that come from each IP address (or, for an IPv6 address, its network) each minute and turns away any over the limit. Our website reads your IP address only for this and never stores it. Cloudflare may also keep its own records of requests to our website to protect it from attacks.

11. Retention and deletion

We keep personal information only for as long as it is reasonably needed for the purposes described in this policy, including providing the Platform, maintaining security, investigating reports, resolving disputes, meeting legal and accounting obligations and establishing or defending claims.

Retention depends on the type of information, why it was collected, the sensitivity of the information, the risk of harm from unauthorized use or disclosure, technical requirements and applicable law.

When information is no longer needed, we take reasonable steps to destroy or de-identify it. After you request account deletion, the request enters our deletion process. Deletion from active systems and later rotation from backups may occur at different times, so deletion is not necessarily completed at the moment you submit the request.

If a deleted account is involved in an unresolved safety report, we may first preserve a limited evidence snapshot that is reasonably necessary to investigate or resolve that report. The snapshot may include relevant messages or media contributed by either participant. It is held separately from the live conversation and is subject to a defined retention period and access controls.

We may retain limited records after account closure or deletion where reasonably necessary for safety, fraud prevention, legal compliance, complaints, appeals or dispute handling. Information held under a legal requirement or litigation hold may be kept for the applicable period. Purchase records may be kept for the period required for tax and accounting purposes.

Closing or deleting an account is different from changing a profile field or withdrawing consent. The in-app flow will explain the available action and its effect.

Our main retention periods are:

• Account, profile, messages, shared posts and Swem conversations: kept while your account exists and deleted when you delete your account. We keep a minimal record without identifying details so that a ban can continue to apply.
• Rounded device location: the location you last shared is kept until you share a new one, and is deleted when you delete your account or ask us to delete it. Turning off location permission does not delete it.
• Search records: the rounded location used as the center of a distance search is kept with the record of that search while your account exists, and is deleted when you delete your account.
• Notification content: removed from our servers once delivered. Delivered but unread notification records are deleted after 30 days.
• Safety evidence: a limited evidence snapshot linked to a safety report is kept until 90 days after the report is closed, and for no more than 365 days if it remains open.
• Records that someone expressed thoughts of suicide or self-harm to Swem: 90 days.
• Security and audit logs: 90 days.
• Service and usage records linked to your account: 30 to 90 days. After that we keep only summary statistics that do not identify anyone.
• Purchase records: for the period required by tax and accounting laws.
• Website invite list: kept until you ask us to remove you or until we no longer need it to invite you, then deleted. A removed entry can remain in database backups for up to 30 days. Cloudflare keeps the short signup records in its logs for up to 7 days.
• Website visit counts: Cloudflare keeps each page view’s report in full for 7 days, then reduces them to about a tenth of their original volume and does not say how long it keeps that. Its dashboard shows us the last six months.
• Backups: deleted information may remain in backups until they are overwritten in the normal backup cycle.

12. Security and data breaches

We take reasonable technical and organizational steps to protect personal information from misuse, interference, loss and unauthorized access, modification or disclosure. Measures may include access controls, encrypted transmission, monitoring, testing and supplier safeguards.

No system is completely secure or error-free. You are responsible for protecting your device, account information and sign-in credentials. Contact us promptly if you suspect unauthorized access or misuse of your account.

We will take reasonable action to investigate suspected data breaches and notify affected people and regulators where required by law.

13. Your choices and privacy rights

Depending on the feature and applicable law, you may be able to:

• edit profile information and visibility settings;
• manage device permissions and optional notifications;
• see what Swem remembers about you and clear all of it;
• ask us to delete the rounded device location we hold for distance search;
• ask us to remove you from our website’s invite list;
• withdraw consent;
• delete your account using the account deletion option in the app; and
• request access to, or correction of, personal information we hold about you.

To make a formal access or correction request, email hello@swem.ai with sufficient detail for us to understand the request. We may need to verify your identity. We will respond within a reasonable period and explain any lawful refusal or charge before it applies.

We have not appointed a data protection officer. Privacy questions and requests are handled by our team at hello@swem.ai.

14. Privacy complaints

If you have a privacy question or complaint, email hello@swem.ai and include:

• your name and contact details;
• what happened and when;
• the information or feature involved; and
• the outcome you are seeking.

We will acknowledge, investigate and respond to the matter within a reasonable time. If you are not satisfied with our response, you may lodge a complaint with the Office of the Australian Information Commissioner (OAIC) through oaic.gov.au, call 1300 363 992 or write to GPO Box 5288, Sydney NSW 2001, Australia.

15. People under 18

The Platform is only for people aged 18 or older.

If you believe a person under 18 is using the Platform, use the available reporting tool or contact hello@swem.ai. We may restrict the account while we investigate and take appropriate steps to protect the person and other users.

16. Changes to this policy

We may update this policy from time to time when our practices, technology, features or legal obligations change. We will post the updated version and effective date.

If a change is material, we will also give reasonable notice by email, an in-app notification or another prominent notice. We will seek fresh consent before the change takes effect where required by law.

17. Additional information for people in the European Union, United Kingdom and similar regions

If the EU or UK General Data Protection Regulation or a similar law applies to you, Folkone Pty Ltd is the controller of your personal data, and the following also applies.

Legal bases. We process personal data:

• to provide the Platform and paid features you ask for (performance of a contract);
• with your consent, for Swem-based profiling and matching, for the genders you want to meet and for any other special category data and where we ask for consent for a specific purpose;
• for our legitimate interests in keeping the Platform safe, preventing fraud and misuse, securing our systems, improving the Platform and understanding interest in Swem, where those interests are not overridden by your rights; and
• to comply with legal obligations, such as tax records and responses to lawful requests.

Device location. We read your device’s location only with your permission, which you give when your device asks for it and through your device’s location setting, and, when you search by distance, because that reading is needed for the search you asked for. We use the rounded location to provide distance search (performance of a contract). You can stop the app reading your location at any time by turning off location permission in your device settings. To have the rounded location we hold deleted, email hello@swem.ai or delete your account.

Your rights. You may ask to access, correct or delete your personal data, to restrict or object to certain processing, to receive a copy of data you provided in a portable format and to withdraw consent at any time without affecting earlier lawful processing. Final decisions to suspend or ban an account are made by a person, not solely by automated means. To make a request, email hello@swem.ai.

International transfers. Your data may be transferred to Australia and to the other countries listed in section 9. Where the destination does not have an adequacy decision, we rely on appropriate safeguards such as standard contractual clauses offered by our service providers.

Complaints. You may also complain to the data protection authority in your country of residence.

18. Additional information for residents of the United States

No sale or sharing. We do not sell personal information, and we do not share it for cross-context behavioral advertising. We have not done so in the past 12 months, and we have no actual knowledge of selling or sharing information of people under 16. Because of this, a browser opt-out preference signal does not change how we handle your information.

Categories. In the past 12 months we have collected the categories described in section 2: identifiers and contact details; profile information and photos; characteristics such as gender and the genders you want to meet; purchase information; app and website activity and device information; approximate location, such as your city, the rounded device location used for searching by distance and the country and region of a website invite request; places you choose to send in a chat or add to a post, which are not rounded; inferences drawn by Swem; and sensitive information that you choose to share. We use and disclose these categories for the business purposes in sections 6 and 8. We use sensitive information only to provide the Platform you request and for safety and security.

Your rights. Depending on where you live, you may ask to know, access, correct or delete your personal information. You may use an authorized agent, and we may need to verify your identity and the agent’s authority before acting on a request. We will not discriminate against you for exercising your rights. To make a request, email hello@swem.ai.