GoSwipe
Privacy
Privacy Policy
Effective from the release of GoSwipe 1.2. Updated 25 October 2026. Version 3.2.
This Privacy Policy explains how MB Elzee group (“we”, “us”, “Elzee”) processes personal data when you use the iOS application GoSwipe: Photo Storage Cleaner (the “App”) and the website goswipe.app (the “Site”). It is written to meet Articles 13 and 14 of the EU General Data Protection Regulation (“GDPR”) and Apple’s App Store requirements.
In short
- Your photos and videos are processed only on your iPhone. They are never uploaded.
- We store a user id, your sign-in email (if shared), subscription status, swipe counts, and a short list of in-app activity events (such as app opens, reminder taps and Tidy Shelf levels played) that we use only ourselves to improve the App.
- Reminders are scheduled on your iPhone and only with your permission. You can turn each kind off in Settings → Reminders.
- We do not sell personal data or show ads in the App.
- Only if you choose Allow in the iOS tracking prompt, we share installs, sign-ups and subscription events with Meta to measure our ads. You can change this at any time (Section 5).
- You can delete your account, and all server-side data, from Settings in the App.
1. Who is responsible (data controller)
MB Elzee group, a small partnership (mažoji bendrija) registered in the Republic of Lithuania.
- Company code: 306274598
- VAT number: LT100017807418
- Registered address: Pievų g. 7, LT-19152 Širvintų r., Lithuania
- Privacy contact: privacy@elzeego.com
- General support: support@elzeego.com
- Telephone: +370 657 79026
We have not appointed a Data Protection Officer because the scale and nature of our processing do not require one under Article 37 GDPR. Privacy requests are handled by the partnership’s management at the address above.
2. Your photos never leave your iPhone
The App asks for access to your photo library through the iOS permission system. It reads your library locally on your device to display photos and videos so you can decide what to keep. The following never leave your device and are never received by us:
- photo and video files, thumbnails, or any pixel data;
- photo library asset identifiers, album names, or file names;
- EXIF and other media metadata, including capture location, dates, and camera details;
- face, object, or scene recognition data of any kind.
Duplicates and Tidy Shelf. To find exact copies and look-alikes, the App analyses small versions of your photos on your device, using Apple’s Vision framework. For each photo it keeps a numeric fingerprint, a short hash, and one quality score from 0 to 1, which is used only to suggest which photo in a group to keep. The score blends sharpness, resolution, Apple’s aesthetics score and, where a face is in the frame, Apple’s face capture quality (blur, closed eyes, bad angle). This does not identify or recognise anyone and builds no face template. These numbers are stored in the App’s local database next to the photo’s identifier on your iPhone. They are never sent to us, and they are deleted when you delete the App or choose Put photos back in the deck.
Your keep and let-go decisions, and the Bin queue, are stored in a local database on your iPhone only. Deletions you confirm are carried out by iOS itself through the system confirmation sheet; iOS moves those items to its Recently Deleted album, where Apple retains them for approximately 30 days. We have no access to that album.
You can grant full or limited library access. With limited access, the App only sees the items you selected. You can change this at any time in iOS Settings → Privacy & Security → Photos.
3. What personal data we process, and why
We process the minimum data needed to run an account, enforce the free allowance, and honour your subscription. Legal bases refer to Article 6(1) GDPR.
| Data | Source | Purpose | Legal basis |
|---|---|---|---|
| User id (created by us), sign-in provider name, provider account id | Created at sign-in with Apple or Google | Create and operate your account; authenticate you | Contract, Art. 6(1)(b) |
| Email address (or Apple “Hide My Email” relay address) | Shared by Apple or Google when you sign in, if you allow it | Identify your account; respond to support and legal requests | Contract, Art. 6(1)(b) |
| Session data: session token, expiry, IP address, device user-agent string | Generated when you sign in and use the App | Keep you signed in; detect abuse and unauthorised access | Contract, Art. 6(1)(b); legitimate interest in security, Art. 6(1)(f) |
| Aggregate usage counters per calendar day: number of swipes, items kept, items queued, bytes freed; your device time zone | Sent by the App | Enforce the free allowance; show your statistics; prevent quota circumvention | Contract, Art. 6(1)(b) |
| In-app activity events, each with a timestamp: app opened; your answer to the notification permission prompt; a reminder shown or opened, with its kind (for example “bin waiting” or “weekly recap”); the upgrade screen viewed, with where it was opened from; the free limit reached; the Bin emptied, with the number of items; a Tidy Shelf level finished, with its level number, how many sets were matched, the star rating and whether time ran out; the daily Tidy Shelf limit reached; photos moved to the Bin from Duplicates, with the number of items. Also the time your App last contacted our servers | Sent by the App; last contact recorded by our servers | Understand which features help people free up storage, measure whether reminders are useful or annoying, and improve the App. Used only by us, in aggregate | Legitimate interest in improving the App, Art. 6(1)(f). You can object at any time (Section 10) |
| Subscription status: whether GoSwipe Pro is active, product identifier, expiry and renewal state, RevenueCat event ids | Received from RevenueCat, which receives it from Apple | Unlock paid features; restore purchases; handle billing disputes | Contract, Art. 6(1)(b); legal obligation for accounting records, Art. 6(1)(c) |
| Server request logs: IP address, request path, status, timestamp, user-agent | Generated automatically by our servers | Operate, secure, and debug the service; rate limiting | Legitimate interest in security and reliability, Art. 6(1)(f) |
| Correspondence you send us | You | Answer your request; keep a record of complaints | Legitimate interest, Art. 6(1)(f); legal obligation where a request is made under data-protection or consumer law, Art. 6(1)(c) |
| Ad-measurement data, only if you agree: Meta’s app-scoped anonymous id, your device’s advertising identifier (IDFA), app install and open events, a sign-up event with the sign-in method (Apple or Google), subscription events (purchase, renewal, product, price, currency), and the device and network details Meta’s SDK sends with them (device model, iOS and app version, language, time zone, IP address) | The Meta SDK in the App; subscription events via RevenueCat | Measure which of our ads on Facebook and Instagram lead to installs and subscriptions (see Section 5) | Consent, Art. 6(1)(a), and for access to your device, Art. 5(3) of the ePrivacy Directive |
Usage counters are totals only. They are not linked to any specific photo or video, and they cannot be used to reconstruct what you kept or removed. Activity events follow a fixed list: the App cannot attach photo data, album names, or free text to them, and our servers reject anything outside that list.
Reminders. If you allow notifications in the iOS prompt, the App schedules reminders on your iPhone, for example when items are waiting in your Bin or for a weekly recap of the space you freed. Their text is put together on your device from data already there; we do not send them and do not receive their content. At most one reminder is shown per day, between 10:00 and 20:30 local time. You can turn each kind off in Settings → Reminders in the App, or turn notifications off completely in iOS Settings → Notifications → GoSwipe.
We do not collect: photos or videos, precise or coarse location, contacts, health data, payment card details, or browsing history. We do not use third-party analytics SDKs. The only advertising SDK in the App is Meta’s, and it stays switched off unless you agree as described in Section 5.
4. Payments and purchases
GoSwipe Pro subscriptions are sold and billed exclusively by Apple through the App Store. Apple is an independent controller of your payment and billing data under its own privacy policy. We never receive your card number, bank details, or billing address.
We use RevenueCat, Inc. (United States) as our processor to validate App Store receipts and tell us whether your subscription is active. RevenueCat receives your user id, an anonymised app-user id, Apple transaction identifiers, product identifiers, and purchase and expiry timestamps. RevenueCat does not receive your email address or photos. If you agree to ad measurement (Section 5), RevenueCat also receives Meta’s anonymous id and your advertising identifier, and forwards your subscription events to Meta on our behalf.
5. Ad measurement with Meta (only if you agree)
We advertise GoSwipe on Facebook and Instagram. To learn which ads work, the App contains the Meta SDK. It is switched off by default and sends nothing until you choose Allow in the iOS prompt “Allow ‘GoSwipe’ to track your activity across other companies’ apps and websites?”. The App shows that prompt once, after your first swipe. Its text explains that GoSwipe shares installs and sign-ups with Meta to measure our ads on Facebook and Instagram, and that your photos are never shared.
If you choose Ask App not to Track, or tracking is turned off on your iPhone, the SDK stays off and nothing is sent to Meta. Nothing else in the App changes either way.
When you allow tracking, Meta receives the ad-measurement data listed in Section 3: installs and app opens, account sign-ups, and subscription events. Meta never receives your photos or videos, anything about them, your email address, your name, or our user id for you. We do not use Meta’s “advanced matching”.
For collecting this data in the App and passing it to Meta, we and Meta Platforms Ireland Limited (Merrion Road, Dublin 4, Ireland) are joint controllers under Article 26 GDPR. Meta then processes it as an independent controller under its own privacy policy, which also explains how to exercise your rights with Meta.
You can withdraw consent at any time, as easily as you gave it: turn off Allow Tracking in iOS Settings → GoSwipe, or in iOS Settings → Privacy & Security → Tracking. Turning it off stops all further data going to Meta, and the App removes the Meta id from your RevenueCat record the next time it opens. Withdrawal does not affect data already sent.
6. Who we share data with
We share personal data only with the following categories of recipients:
- Hosting — Hetzner Online GmbH (Germany). Our API and database run on servers located in the European Union. Database backups are stored with the same provider in the EU.
- Subscription infrastructure — RevenueCat, Inc. (United States), acting as our processor under a data-processing agreement (see Section 4).
- Advertising measurement, only if you agree — Meta Platforms Ireland Limited (Ireland), as joint and then independent controller (see Section 5).
- Identity providers — Apple Inc. (Sign in with Apple) and Google LLC (Google Sign-In), each acting as an independent controller when you choose to sign in with them. They tell us who you are; we tell them nothing about how you use the App.
- Apple, for diagnostics — if you have enabled Share with App Developers in iOS Analytics settings, Apple may share aggregated, de-identified crash and performance data with us. This is controlled entirely by you in iOS settings.
- Public authorities and legal advisers — only where required by law, a binding order, or to establish, exercise, or defend legal claims.
We do not sell personal data and do not share it with data brokers or analytics networks. The only advertising platform that receives data is Meta, and only with your consent as described in Section 5. Where we use processors, we have written contracts that meet Article 28 GDPR and require them to protect your data at least as well as we do.
7. International transfers
Your account data is stored in the European Union. Where a processor or identity provider is located outside the European Economic Area — in particular RevenueCat, Apple, and Google in the United States, and Meta Platforms, Inc., to which Meta Platforms Ireland transfers ad-measurement data — we rely on the safeguards permitted by Chapter V GDPR: the European Commission’s Standard Contractual Clauses and, where the recipient is certified, the EU–US Data Privacy Framework. You may request a copy of the relevant safeguards by writing to privacy@elzeego.com.
8. How long we keep data
| Data | Retention |
|---|---|
| Account, email, usage counters, activity events, subscription status | Until you delete your account in the App or ask us to delete it. If we decide to remove long-inactive accounts in future, we will give prior notice to the email on file |
| Sessions | Expire 30 days after last use; deleted at sign-out or account deletion |
| Database backups | Rolling 14 days, then automatically destroyed. Deleted accounts disappear from backups within that window |
| Server request logs | No longer than 30 days |
| Subscription event records | For the period required by Lithuanian accounting and tax law (up to 10 years) where they form part of a financial record; otherwise deleted with the account |
| Meta anonymous id and advertising identifier stored with RevenueCat | Until you withdraw consent or delete your account. We keep no ad-measurement data on our own servers. Meta keeps what it received under its own policy |
| Support correspondence | Up to 3 years after the matter is closed, to handle follow-up questions or claims |
9. Deleting your account
Open the App, go to Settings → Delete account, and confirm. This immediately and permanently deletes your user record, sessions, usage counters, activity events, and subscription status from our production database and instructs RevenueCat to delete the matching customer record, including any Meta id stored with it. Backups purge within 14 days. You do not need to contact us or explain why. Ad-measurement data Meta already received is held by Meta; you can ask Meta to delete it through the tools in its privacy policy.
Deleting your account does not cancel an active Apple subscription; cancel it in your Apple ID subscription settings so you are not charged again. It also does not affect items already in your iPhone’s Recently Deleted album, which is managed by iOS.
You may also request deletion by email at privacy@elzeego.com. We will verify that you control the account, then delete within 30 days.
10. Your rights
Under the GDPR you have the right to:
- access the personal data we hold about you (Art. 15);
- rectify inaccurate or incomplete data (Art. 16);
- erase your data (Art. 17) — available directly in the App;
- restrict processing in certain circumstances (Art. 18);
- receive a copy of the data you provided in a machine-readable format and have it transmitted to another controller (Art. 20);
- object to processing based on legitimate interests (Art. 21);
- withdraw consent to ad measurement at any time in iOS Settings, without affecting earlier processing (Art. 7(3));
- not be subject to automated decisions with legal or similarly significant effects — we make none (Art. 22).
To exercise a right, email privacy@elzeego.com from the address linked to your account, or include your user id from Settings → Account. We respond within one month; this may be extended by two further months for complex requests, in which case we will tell you. Requests are free unless manifestly unfounded or excessive.
You also have the right to lodge a complaint with a supervisory authority. Our lead authority is the Lithuanian State Data Protection Inspectorate (Valstybinė duomenų apsaugos inspekcija), L. Sapiegos g. 17, LT-10312 Vilnius, Lithuania, ada@ada.lt, vdai.lrv.lt. You may instead contact the authority in the EU/EEA country where you live or work.
11. Security
Data in transit is protected with TLS. Session tokens are stored in the iOS Keychain on your device, not in shared app storage. Our servers are hardened Linux hosts with firewalling, rate limiting, and regular security updates; administrative access is limited to named personnel using key-based authentication. Authorisation and cookie headers are redacted from application logs. No system is perfectly secure; if we become aware of a personal data breach that is likely to result in a high risk to you, we will notify you and the supervisory authority as required by Articles 33 and 34 GDPR.
12. Children
The App is not directed to children under 13, and we do not knowingly collect personal data from them. If you are under the age of digital consent in your country (16 in some EU member states; 14 in Lithuania), you may use the App only with the consent of a parent or guardian. If you believe a child has created an account, contact us and we will delete it.
13. The website
The Site is static. It sets no cookies, uses no analytics, and loads no third-party scripts or fonts. Our web server records standard access logs (IP address, requested page, timestamp, user-agent) for security and capacity purposes, retained for no longer than 30 days, on the basis of our legitimate interest in operating a secure service.
14. Changes to this policy
We may update this policy to reflect changes in the App, in law, or in our processors. The effective date and version at the top will change. For material changes that affect how we use your personal data, we will notify you in the App or by email before they take effect. Previous versions are available on request.
15. Contact
MB Elzee group
Pievų g. 7, LT-19152 Širvintų r., Lithuania
privacy@elzeego.com ·
support@elzeego.com