Sway — Privacy Policy

Effective: on the first public release of the Sway iOS app · Version 1.5 Last Updated: August 22, 2026 Operator: Sway is operated by Keveen Delgado, an individual sole proprietor, in Massachusetts. A mailing address is available on request at support@swayos.us. Contact: support@swayos.us

1. The Short Version

2. Who This Applies To

This policy covers personal information Sway collects through the Sway app, our websites, and related communications. Sway is intended for people 18 and older in the United States. We do not knowingly collect information from anyone under 18; if we learn we have, we delete it (see §12).

3. Information We Collect

3.1 You give us

About the Gull Card number. It is six digits you type in yourself. A card number is not an education record under FERPA — FERPA covers records held by an educational institution, and Sway is not one and holds none (see §5.4). Sway does not check the number against any Endicott system, because we have no roster and no connection to one, and we never send it to the college. It is stored for one purpose: to confirm campus affiliation. Your date of birth, gender, phone number, and Gull Card number are readable only by you and by Sway — no other user, no venue, and no school can read them, and that is enforced by row-level database rules, not just by this promise.

3.2 Generated by your use

• Participation history — the record of the posts you made, over time.
• Device and app data — device model, OS version, app version, language, time zone, and a Sway-generated device/install identifier.
• Log and diagnostic data — IP address, timestamps, error records, and coarse performance data in our server logs. Crash reports reach us only through Apple's own opt-in crash sharing; Sway embeds no third-party analytics, attribution, or crash-reporting SDK.
• Push token — if you enable notifications.

3.3 Location — read this carefully

Sway does not collect continuous movement history. Every presence record in Sway comes from a tap you made. Nothing in this app writes a visit, a check-in, or a presence row on its own — not from a geofence, not from a dwell timer, not from a beacon or a Wi-Fi network, and never in the background.

• Self-reported place is the primary signal: you tap a venue. That is a statement, not a measurement.
• Foreground location, with your permission, is used to: show directions to a venue; confirm you are at a venue when you tap "I'm Here"; find the places near you when you are picking one; share a coarse live location with the friends your visibility setting allows; and — after you tap I'm Here — refresh a when-in-use fix while Sway is open so we can drop you from the live headcount if a decent reading shows you have clearly left. That refresh never writes a new check-in.
• Directions stay on your device. That location fix is handed to Apple Maps and is never sent to us.
• Checking in does send us your coordinates — latitude, longitude, and accuracy — at the moment you tap, so we can confirm the check-in is real. Those coordinates and the distance we computed are stored on that one check-in record and kept with it; they are used for nothing else, and we do not stitch them into a movement track. Late check-ins within 24 hours may omit coordinates when you log from elsewhere. Heartbeats while you keep Sway open after I'm Here may send another fix for the same purpose: confirming you are still there, or dropping the live count if you are not.
• Live location is off until you turn it on, and it shares the one visibility setting. Every account starts in Ghost, which publishes nothing. Opening it up is a deliberate trip to Settings → Privacy, and the mode you pick there — All friends, Selected friends, Only when I'm out — governs both who sees your Going/Here posts and who receives a live location; there is no second switch that could quietly be on. Going back to Ghost clears what was published. Live location is written only while Sway is open in the foreground, is coarsened before storage, and expires within minutes. Declining the location permission still lets you use Going/Here presence sharing without a live GPS layer.
• Place search leaves your device. When you search for a place or tap a pin, the text you typed and an approximate area around you go to Apple's Maps service, and the app may ask a places provider for that place's photo and hours. See §6.
• Opt-in arrival reminders (Always). These take two separate steps, and both are required. First, under Settings → Check-in reminders you may choose Always location. Second, you switch arrival reminders on for a specific place, from that place's page in the app. Sway monitors a place only when you have done both — granting Always by itself monitors nothing, and a place you have not switched on is never geofenced, whether or not you are going there tonight and whether or not you visit it often. Those regions are venue pins, they are processed on your device, and your per-place choices are stored on that device rather than on our servers (so a reinstall forgets them). A nudge is only a nudge: it never auto-checks you in. If you have already tapped I'm Here, leaving that region can take you off the live headcount — it still never checks you in. If you decline Always, time-based reminders still work while the app can use When In Use. You can turn any place off, or all reminders off, anytime.
• Closing the app. If you leave Sway after I'm Here, the live count drops you after about 25 minutes without a heartbeat (or sooner if you tap Leave). Your visit for the night stays on your own record.
• Map views show clustered aggregate activity for venues. Individual pins appear only for friends who have left Ghost and chosen to share with you — never for strangers, and never as a continuous track.
• Precise geolocation is treated as sensitive personal information under several state laws. We do not use or disclose it for any purpose other than the ones listed here.

3.4 Contacts — we don't touch them

Sway does not access your contacts. The app requests no contacts permission and uploads no address book. We do not build profiles of people who are not on Sway, and we will never message or invite anyone on your behalf. You add friends by searching for them or sharing an invite code.

3.5 Friend-visible contact details

You may optionally add Instagram, Snapchat, or Venmo usernames and a contact phone number on your profile. These are text handles you type, not OAuth connections — Sway does not sign into those platforms or post on your behalf.

• Visible only to accepted friends. Non-friends cannot load these fields.
• The phone number you gave at signup is separate and is not shown to friends unless you explicitly copy it into the friend-visible contact-phone field.
• Clear or change any of these anytime in Profile. Deleting a field removes it from friend views.

3.6 What we do NOT collect

No continuous or ambient audio. No microphone or camera access except when you deliberately use a feature that needs it. No browsing history outside Sway. No purchase, payment, bank, or card data. No biometric identifiers. No health data. No academic records, grades, enrollment, discipline, or financial-aid data. No advertising identifiers (IDFA) and no third-party advertising or data-broker SDKs. No continuous GPS track — even with Always granted, Sway only monitors the individual places you switched arrival reminders on for, and never auto-logs presence.

4. How We Use Information

1. Operate the core product — show your posts to the audience you chose, render feeds, headcounts, Crews, and your own history.
2. Authenticate you and keep accounts secure.
3. Notify you — sparse, utility-only push notifications you can turn off. We do not send engagement-bait or promotional pushes.
4. Safety and integrity — detect fake presence, spam, abuse, and violations; investigate reports; enforce our Community Guidelines and Terms.
5. Support — answer your questions.
6. Improve the Service — understand which features are used, fix bugs, measure reliability. Where a de-identified or aggregate dataset will answer the question, we use that instead of identified data.
7. Aggregate venue and program insights — see §5.
8. Legal — comply with law, enforce agreements, protect rights and safety.

We do not use your information for advertising, for training third-party AI models, or to build profiles for sale. If that ever changes, we will update this policy and tell you before it happens, not after.

5. What Venues and Institutions Receive

5.1 Venues receive aggregate, de-identified insights only — for example: how many people indicated they were going or present in a time window, return-rate patterns, and whether an event correlated with later returns.

5.2 Minimums. Any figure that slices activity into a smaller cell — an hour of the night, a peak hour, a return-rate cohort — is withheld when fewer than 5 distinct people fall inside it, and a withheld rate is withheld together with its numerator and denominator so it cannot be divided back out. A venue's own whole-period totals — presence taps, distinct people, and regulars across all of its activity — are exact counts and carry no floor; a count with no time slice and no segment names nobody. In every case a venue receives numbers, never a named list of who was present, never an individual's history, never Crew rosters, and never the ability to look up a person.

5.3 Institutions receive nothing about individuals. No college or university receives individual participation data. Sway does not integrate with any SIS or LMS, receives no student roster, and issues no individual reports.

5.4 FERPA. FERPA governs education records held by an educational institution. Sway holds none. Your voluntary use of a private app is not an education record and does not flow into one. A campus card number you type into Sway is not an education record either — it is a number you gave us, held by us, disclosed to no one, and never sent to the college. We maintain this separation architecturally, not just as policy.

5.5 If this ever changes. If Sway ever proposes to disclose identified individual presence to a venue, we will rewrite this section, disclose it clearly at signup, and ask each affected person for specific, revocable opt-in consent before any such disclosure happens. We will not reinterpret the aggregate-only commitment above to permit it.

6. When We Share Information

We share personal information only as follows:

We do not sell personal information. We do not share personal information for cross-context behavioral advertising. We do not disclose personal information to data brokers. We have not done so in the preceding 12 months.

We maintain a current list of subprocessors on request at support@swayos.us, and will update it before adding a new category.

7. How Long We Keep Information

8. Your Choices and Controls

• Visibility — Ghost by default; you choose an audience in Settings → Privacy, and can adjust it per post and globally.
• Ghost mode — one toggle to become invisible again. Applies going forward.
• Notifications — turn off in-app or in iOS Settings.
• Permissions — location, notifications, and camera are each optional and revocable in iOS Settings; Sway still works without them. Sway never asks for contacts, and its photo picker runs outside the app, so it never asks for your photo library either.
• Delete a post — anytime.
• Delete your account — Settings → Delete Account, at the bottom of the screen. Permanent, in-app, no email required, no dark patterns. Your rows and your uploaded photos are destroyed at the moment you confirm; the retention table below is the outside bound for backups, not a waiting period.
• Export your data — request a machine-readable copy at support@swayos.us.

9. Your Privacy Rights

9.1 Everyone. Regardless of where you live, Sway extends these rights to all users: access, correction, deletion, portability, and the right to object to a use. Email support@swayos.us or use the in-app controls. We respond within 45 days (extendable once by 45 days with notice).

9.2 State privacy laws. Residents of California, Colorado, Connecticut, Virginia, Texas, Oregon, and other states with comprehensive privacy laws have rights including access, correction, deletion, portability, opting out of sale/targeted advertising/profiling, and limiting use of sensitive personal information. Because Sway does not sell data, does not run targeted advertising, and does not conduct profiling with legal or similarly significant effects, there is nothing to opt out of — but you may still exercise the other rights above.

9.3 Sensitive personal information. To the extent precise geolocation qualifies as sensitive personal information, we use it only for the purposes in §3.3 and §4 — never to infer characteristics about you. We do not use your date of birth or gender to infer anything about you either, or to target, rank, or profile you.

9.4 Non-discrimination. We will not deny service, charge a different price, or degrade quality because you exercised a privacy right.

9.5 Authorized agents. An agent may submit a request with proof of authorization; we may ask you to verify directly.

9.6 Appeals. If we deny a request, you may appeal to support@swayos.us with "Privacy Appeal" in the subject. We respond within 45 days. If we deny the appeal, you may contact your state attorney general.

9.7 Massachusetts. Massachusetts residents are protected by Mass. Gen. Laws ch. 93A and ch. 93H. Nothing in this policy waives those rights.

10. Security

We maintain administrative, technical, and physical safeguards appropriate to the sensitivity of the data, including encryption in transit (TLS) and at rest, row-level access controls in our database, least-privilege access for the small number of people who can reach production, authentication logging, and vendor review before adding a subprocessor.

No system is perfectly secure. If a breach affects your personal information, we will notify you and the appropriate regulators as required by law — for Massachusetts residents, under Mass. Gen. Laws ch. 93H, including notice to the Attorney General and the Office of Consumer Affairs and Business Regulation, without unreasonable delay.

Report a vulnerability: support@swayos.us. We will not pursue legal action against good-faith security research that respects user privacy and does not degrade the Service.

11. Where Data Is Processed

Sway is operated in the United States and data is processed and stored in the United States. If you access Sway from outside the U.S., you understand your information will be transferred to and processed in the U.S., which may have different data-protection laws than your country.

12. Children

Sway is for adults 18 and older. We do not knowingly collect personal information from anyone under 18. If we learn that we have, we delete the account and its data promptly. Parents or guardians who believe a minor has registered should contact support@swayos.us.

13. Changes to This Policy

We will post updates here with a new "Last Updated" date. For material changes — especially any change to what we collect, who receives it, or the aggregate-only venue commitment — we will give at least 14 days' advance notice in-app or by email, and where the change expands how we use data you already gave us, we will ask for your consent rather than assume it.

14. Contact

Privacy: support@swayos.us · Safety: support@swayos.us · Security: support@swayos.us Sway is operated by Keveen Delgado, sole proprietor, Massachusetts. Mailing address available on request.

Sway · Only the people you chose can see where you're going.