Privacy Policies

Privacy Policy of INVAI LTD

SWIPEY (the "APP") is owned and operated by INVAI LTD, duly incorporated in the Republic of Cyprus under incorporation number HE458964, having its address at Agiou Alexiou street 1, 1st Floor, 2054, Nicosia, Republic of Cyprus.

SWIPEY is an online chat application that uses artificial intelligence algorithms to generate virtual and fictional characters (the “AI Companions”). The APP also generates images and messages, so that you can chat with the AI Companions. Parts of the Services offered by the APP may require you to create a user account. For purposes of this Privacy Policy, “you” and “your” mean you as the user of the APP.

GDPR

If you are a resident of the European Union, you are protected by and enjoy additional rights under the European Union’s General Data Protection Regulation 2016/679, also known as GDPR.

1. Definitions

As we are committed to respecting your privacy, such Services will always be provided with your consent.

In this document, we provide clear information on how your data is processed when you visit the Website and when you use our Services.

At any time, please refer to the following definitions:

“Content” means the information that you will provide us with so that we can register you as a User and the information you will upload on our Platform, such information shall include your Personal Data and the discussions with the AI Companions;

“Consent” means any freely given, specific, informed, and unambiguous indication of your wishes by which you, by a statement or by a clear affirmative action, signify agreement to the Processing of Personal Data relating to you;

“Performance of our Services” means the actions necessary for us to provide our Services;

“Personal Data” means any information relating to you, as an identified person, directly or indirectly, such as your name, address, marital status, date of birth, gender, office location, position, company name, spoken languages, photos, your identification number, your location data, or factors specific to your physical, physiological, genetic, mental, economic, cultural, or social identity, your networks and connections made available to us, or obtained on your behalf and any personal information you would provide us with;

“Platform” means the APP.

“Processing” means any operation or set of operations which is performed on Personal Data or on sets of Personal Data, whether or not by automated means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure or destruction;

“Services” means all the steps for enabling you to chat with the AI Companions;

“Subscription” means an arrangement between INVAI LTD and you to enable you to benefit from and/or use the Services;

“User”, “you” and “your” collectively mean a person or company that has visited or is using the APP and/or the Services;

“Visitor” means anyone who is browsing the Website without a valid Subscription;

“Website” means https://swipey.ai/.

2. Purpose of Personal Data Processing

When visiting the Website

When you visit the Website, we will collect information for the following purposes:

• Analyzing and understanding your behavior on the Website;
• Performing our Services;
• Making improvements to the Website and Services;
• Enabling us to enhance, customize, or modify our communications;
• Improving data security;
• Determining whether marketing campaigns are effective.

When registering and using our Services

After a free test of a few messages, you will be asked to register, so we can identify you. At this stage, we receive and store any information you enter on the Website or that you provide us with in any other way. The types of Personal Data collected may include (but are not limited to) your name, date of birth, usage information regarding your use of our Services, and browser information.

The Personal Data you provide is used for purposes such as allowing you to set up a User account and profile that can be used to interact with the AI Companions. We may also draw upon this Personal Data to adapt the Services to your needs and to develop new tools.

When you use the Platform, we automatically receive and record information on our server logs from your browser or mobile, including your location, IP address, cookie information, and the page you requested. We treat this data as non-Personal Data, except where we are required to do otherwise under applicable law. We only use this data in aggregate form. We may provide this information to our partners about how our customers, collectively, use our site, so that our partners may also understand how often people use the Website and the Platform.

If you fail to provide your Personal Data, we may not be able to perform the Services pursuant to the Subscription. In this case, we may have to cancel the Service, provided that we will notify you if this is the case at the time.

You give your Consent to the Processing of your Personal Data for the following specific purposes: Processing is necessary for the performance of the Services pursuant to a Subscription.

We Process your Personal Data because it is necessary:

• For the Performance of our Services;
• To provide you with a confirmation regarding the Subscription;
• To deal with any complaint or request you may have;
• For any other purpose for which you provide us with your Personal Data;
• For the administration and management of our business; and
• To perform marketing analysis and to conduct market research.

3. Personal Data collection

3.1 Personal Data collection for Visitors

The Website can be visited anonymously. The Website may process anonymous metadata through cookies such as the URL of the requested file, the amount of data transferred, the date and time of the request from the User, Internet browser information, operating system type, the IP address of the used device, the Internet service provider, reference links such as user clicks on certain links. This metadata cannot be used by the Website to obtain personally identifiable information. This information is only used for general purposes, such as technical improvements, and statistical and marketing analysis.

When you visit the Website, we may automatically receive some information that identifies, for each page accessed:

• The type of browser and operating system you have used;
• The IP (Internet Protocol) address of the device which has accessed it (example PC, tablet);
• The date and time of your visit to the Website;
• The address of your server;
• The previous website visited;
• The average duration of page view;
• The navigation behavior and preferences of the user.

3.2 Personal Data collection for Users

We use different methods to collect Personal Data from and about you, including through:

• From the information you provide to us when you register for Subscription;
• From the Content you provide to us via your personal account on the Website;
• When you communicate with us in writing, by telephone, fax, website registration, email or other forms of electronic communication. In this respect, we may monitor, record and store any such communication;
• Automated technologies or interactions. As you interact with the AI Companions, we may automatically collect technical data about your equipment, browsing actions, and patterns. Our moderation team checks that you are in compliance with the law and we collect this Personal Data by using cookies, server logs, and other similar technologies. We may also receive technical data about you if you visit other websites employing our cookies; and
• Third parties or publicly available sources. We may receive Personal Data about you from various third parties and public sources as set out below:
  • Analytics providers such as Google Analytics;
  • Advertising networks/agencies; and
  • Search information providers.

4. Marketing

We may send you marketing about services we provide which may be of interest to you, as well as other information in the form of alerts, newsletters, and invitations to events or functions which we believe might be of interest to you or to update you with information (such as legal or commercial news) which we believe may be relevant to you. We may communicate this to you in a number of ways including by post, telephone, email, or other digital channels.

5. Third Party Marketing

We will get your express opt-in consent before we share your Personal Data with any company outside SWIPEY for marketing purposes.

You can ask us or third parties to stop sending you marketing messages at any time by logging into the Website, or third-party websites and checking or unchecking relevant boxes to adjust your marketing preferences or by following the opt-out links on any marketing message sent to you.

6. Cookies

You can set your browser to refuse all or some browser cookies or to alert you when websites set or access cookies. If you disable or refuse cookies, please note that some parts of the Website may become inaccessible or not function properly.

7. Change of purpose

We will only use your Personal Data for the purposes for which we collected it unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us. If we need to use your Personal Data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so. Please note that we may process your Personal Data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.

8. Sharing your personal information

SWIPEY may share your information with:

• Service providers we work with to deliver the Services;
• Our professional advisers where it is necessary for us to obtain their advice or assistance including lawyers, accountants, IT or public relations advisers;
• Legal and regulatory authorities, as required by applicable laws and regulations; and
• Our employees.

We will not disclose, sell, trade, or otherwise transfer your personal information to any third parties without your consent or unless otherwise stated in this Privacy Policy.

This Privacy Policy does not apply to the practices of service providers and other third parties that we do not own or control, or individuals that we do not employ or manage.

9. Sensitive Information

We will never ask you to provide us with Personal Data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs, or trade union membership, and genetic data, biometric data for the purpose of uniquely identifying a natural person, or data concerning health. If you decide to provide us with such sensitive information, you understand that you willingly disclose such sensitive information.

10. Controller

This Privacy Policy is issued on behalf of INVAI LTD so when we mention “we” or “us”, in this Privacy Policy, we are referring to INVAI LTD.

We have appointed a Controller, within our team, who is responsible for overseeing questions in relation to this Privacy Policy. If you have any questions about this Privacy Policy, including any requests to exercise your legal rights, please contact the Controller using the details set out below.

Contact details:

Email: Admin@invai.tech

Post: Agiou Alexiou street 1, 1st Floor, 2054, Nicosia, Republic of Cyprus

11. Request to access your Personal Data

At any time, you have the right to access your Personal Data. This enables you to receive a copy of the Personal Data we hold about you and to check that we are lawfully Processing it.

12. Period

We retain your personal information for as long as your account is in existence or necessary to fulfill the purposes for which we collect it or as needed to provide you with the Services, except if required otherwise by law. However, when you terminate your account, we will still retain your personal information for a period of time. Usually, we will store your personal information for a period of 6 (six) years after you cease being a User of our Services, beginning at the date your account is closed.

Retention periods may be changed from time to time based on business or regulatory requirements.

13. Personal information of minors

INVAI LTD does not provide Services and collects personal information from anyone under 18 years of age or equivalent minimum age depending on jurisdiction. Our Services are intended for use only by adults who are 18 years of age and over. If we learn that we have been misled by an individual under 18, or equivalent minimum age depending on jurisdiction, we will take steps to delete the information as soon as possible and block this user.

14. Third-party links

The Website may include links to third-party websites, plug-ins, and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. We encourage you to read the Privacy Policy of every website that can be accessed through the Website.

15. Merge of Company

If INVAI Ltd merges with, or is acquired by, another company or organization, or sells all or a portion of its assets, your personal information may be disclosed to our advisers and any prospective purchaser or any prospective purchaser’s adviser, and may be among the assets transferred. However, personal information will always remain subject to this Privacy Policy.

16. Right to rectification

You have the right to obtain from the Controller without undue delay the rectification of inaccurate Personal Data concerning you.

This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

17. Right to request restriction of processing of your Personal Data

This enables you to ask our Controller to suspend the processing of your Personal Data in the following scenarios: (a) if you want us to establish the Personal Data’s accuracy; (b) where our Processing of the Personal Data is unlawful and you do not want us to erase it and request us to suspend the Processing instead; (c) where you need us to hold the Data to establish, exercise or defend legal claims; or (d) you have objected to our Processing of your Personal Data and we need to verify whether we have overriding legitimate grounds to use it.

18. Withdrawal of Consent

We are committed to making it as easy to withdraw as to give consent.

You have the right to withdraw your Consent at any time. The withdrawal of Consent shall not affect the lawfulness of Processing of your Personal Data based on consent before its withdrawal.

If you withdraw your Consent, we will not be able to provide any more of our Services to you and we will take reasonable steps, taking into account available technology and means to delete your user account in a timely manner. We will also delete the Personal Data we have collected on you for internal use.

In the eventuality you withdraw your Consent, we are not responsible for Content that would still be hosted on third-party websites.

19. Right to be forgotten

You have the right to obtain from the Controller the erasure of Personal Data concerning you without undue delay and the Controller undertakes to erase Personal Data without undue delay.

This enables you to ask us to delete or remove Personal Data where there is no good reason for us continuing to Process it. You also have the right to ask us to delete or remove your Personal Data where you have successfully exercised your right to object to processing, where we may have processed your information unlawfully, or where we are required to erase your Personal Data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

Please object to the Processing of your Personal Data immediately if you feel that such Processing impacts your fundamental rights and freedoms. You also have the right to object where we are processing your Personal Data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which overrides your rights and freedoms.

20. Time limit to respond

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made several requests. In this case, we will notify you and keep you updated.

21. Data Security

We have put in place appropriate security measures to prevent your Personal Data from being accidentally lost, used, or accessed in an unauthorized way, altered, or disclosed.

We have put in place procedures to deal with any suspected Personal Data breach and will notify you and any applicable regulator of a breach where we are legally required to do so.

22. Changes to the Privacy Policy and your duty to inform us of changes

We may revise this Privacy Policy from time to time. Therefore, we may undertake a few changes to it. This version of the Privacy Policy will govern our use of your information. If we make any material changes in the way we use your Personal Data, we shall notify you by posting and sending you an email in order to obtain your approval. By continuing to access or use the Services after those changes become effective, you agree to be bound by the revised Privacy Policy.

Please keep a copy of this document at all times and feel free to ask us any questions or address any concerns you may have regarding our Privacy Policy.

Cookies Policy

This Cookies Policy is designed to help visitors and users understand how and why we use cookies on our website https://swipey.ai (the “APP“). “We” and “Us” in this document refer to INVAI LTD, duly incorporated in the Republic of Cyprus under incorporation number HE458964, having its address at Agiou Alexiou street 1, 1st Floor, 2054, Nicosia, Republic of Cyprus.

By using our APP, you agree to the use of cookies as described in this policy.

1. What are Cookies?

Cookies are small text files that are stored on your computer or mobile device when you visit a website. They help websites recognize your device and remember information about your visit, preferences, and actions.

2. Types of Cookies We Use

Essential Cookies

These cookies are necessary for the proper functioning of our website. They enable you to navigate our site and use its features, such as accessing secure areas. Without these cookies, certain services you have requested cannot be provided.

Analytical/Performance Cookies

We use these cookies to analyze how visitors use our website and to monitor its performance. For example, we may use Google Analytics to collect information about your online activity and interactions with our site.

Functionality Cookies

These cookies allow us to remember choices you make on our website (such as your username, language, or region) and provide enhanced, more personalized features.

Targeting Cookies

We may use these cookies to deliver content that is more relevant to your interests. They may be used by third-party companies to build a profile of your interests and show you relevant advertisements on other sites.

3. Your Consent

By using our APP, you consent to the placement of cookies on your device. You can manage your cookie preferences through your browser settings. However, please note that disabling certain cookies may affect the functionality of our APP.

4. How to Manage Cookies

Most web browsers allow you to control cookies through their settings. To find out more about cookies, including how to see what cookies have been set, visit www.allaboutcookies.org.

5. Changes to the Policy

We may update our Cookies Policy to reflect changes in our practices or for other operational, legal, or regulatory reasons. Any changes will be effective immediately upon posting the updated policy on our website.

6. Contact Information

If you have any questions or require further clarification regarding our Cookies Policy, please contact us at: Admin@invai.tech or directly report in the APP in the “Contact” section.

Underage Policy

At INVAI Ltd we are committed to ensuring that our platform SWIPEY (“APP”) is used in a responsible and safe way by users who meet the legal age requirements.

The APP includes AI-generated adult content for registered users only. Therefore, users must be at least 18 years old or of legal age in their country of residence to access and engage with such content. By using the APP, users affirm that they meet the minimum age requirement and are legally permitted to access adult content.

We have implemented several measures to oversee and prevent the registration of users not of legal age.

We are committed to ensuring that AI-generated content on our APP does not bear any resemblance to minors or exploit their likeness. For this purpose, we have implemented our proprietary content moderation filter to ensure full compliance with our Terms and Policies.

1. Registering

When registering for the APP, an initial landing page or age gate, strategically designed to restrict entry to individuals who are not of legal age, is presented to the user. Prior to gaining access to the main content, users are obligated to confirm their age.

Users are prompted to affirm that they are above 18, and this information is used to verify their eligibility to access the website.

A transparent disclaimer emphasizes that users must be 18 years or older to access our services. Users are also notified that providing inaccurate information about their age constitutes a violation of our Terms of Service.

INVAI Ltd cannot be held responsible for any inaccuracies or misrepresentations regarding user age. It is the user's responsibility to ensure compliance with their local laws and regulations regarding the access and consumption of adult content.

2. Content Responsibility

You, as a user of the APP, are solely responsible for the Output generated by the AI Companions through text messages, voice messages, images, and videos. The AI Companions learn and respond based on the conversations you lead and the parameters you select. You understand and agree that INVAI Ltd does not control or endorse the content generated by the AI Companions. Therefore, you acknowledge that you are fully responsible for the Output generated by the AI and for your own actions while using the APP.

You must ensure that your interactions with the AI Companions comply with applicable laws, regulations, our Terms and Policies, in particular the Blocked Content Policy, and you shall not engage in any illegal, unethical, or harmful activities through the APP.

We explicitly point to the paragraphs 1d) and 1e) of the Blocked Content Policy prohibiting any content that exploits or poses a danger to minors, including but not limited to child pornography, sexual exploitation, or any form of harm or harassment towards minors as well as any attempt to generate AI content which would bear any resemblance to minors or exploit their likeness.

3. Content Moderation

We at INVAI LTD value the safety, respect, and integrity of all our users. While conversations between users and AI Companions are generally confidential, we have implemented a content moderation filter, based on our proprietary LLM technology, to ensure compliance with our Terms and Policies, in particular with our Blocked Content Policy. In the event that the moderation filter detects any content that violates our terms, we reserve the right to manually review the flagged content and take appropriate action, which may include terminating the user's account. This measure is implemented to maintain a respectful and secure environment for all users. We strive to strike a balance between privacy and community standards, and we appreciate your understanding and cooperation in adhering to our guidelines.

4. Content Removal

Any user content that we believe, in our sole discretion, violates these provisions will be promptly removed.

5. Contact Information

If you have noticed any violation of these Terms from your perspective, content of any nature whatsoever or you have any questions or require further clarification regarding our Underage Policy, please contact us at: Admin@invai.tech or directly report in the APP in the “Contact” section.

6. Termination

We have the right to suspend or terminate the use of the APP by anyone engaged in suspected infringement described above.

Complaint Policy

At INVAI LTD we value our users and strive to provide a positive experience with SWIPEY (the “APP”). We understand that concerns or complaints may arise from time to time, and we are committed to addressing them promptly and effectively. This Complaint Policy outlines the process for users to file complaints regarding any issues encountered while using our platform.

1. Customer Support

We have a dedicated support team to assist our users with any concerns or complaints.

Our support team is committed to providing prompt and effective assistance. Users can contact our support team if they come across any issues or have inquiries regarding our APP or services.

All inquiries are managed by our support team with professionalism, confidentiality, and impartiality. We are committed to addressing our users’ concerns promptly and to the best of our abilities.

2. Submitting a Complaint

Users who wish to file a complaint can do so by contacting our customer support team through Admin@invai.tech or directly reporting in the APP in the “Contact” section.

3. Information to Include in the Complaint

When submitting a complaint, users are encouraged to provide the following details to help us investigate and address the issue promptly:

• User's full name and email;
• Description of the complaint, including relevant details such as the date and time of the incident;
• Any supporting documentation or screenshots, if applicable.

4. Acknowledgment of Complaint

Upon receiving a complaint, our customer support team will acknowledge receipt within 24 hours via email.

5. Investigation and Resolution

We will conduct a thorough investigation into each complaint to understand the nature of the issue. Our goal is to provide a resolution within a reasonable timeframe. Depending on the complexity of the complaint, some cases may require additional time to conduct a comprehensive investigation. Users will be kept informed of the progress and expected resolution timeline.

6. Feedback and Follow-Up

Once the complaint has been addressed, users will receive feedback regarding the outcome of the investigation and any actions taken. We may also seek user feedback on the resolution process to continuously improve our services.

7. Escalation

If a user is dissatisfied with the resolution provided, he/she may request further escalation. In this case, users can notify our support team within a reasonable timeframe, providing clear reasons for their dissatisfaction with the initial resolution.

The case will be reviewed by individuals or teams not initially involved in the complaint resolution process. They will reassess the complaint and reconsider the previous decision. The user will be notified of the outcome of the escalation within a reasonable timeframe.

DMCA Policy

At INVAI LTD, we respect the intellectual property rights of others and expect our users to do the same. This Digital Millennium Copyright Act (DMCA) Policy outlines our process for handling copyright infringement claims.

1. Notification of Infringement

If you believe that your copyrighted work has been copied in a way that constitutes copyright infringement and is accessible on our APP, please notify our designated Copyright Agent. Your notification must be in writing and contain the following information:

• A physical or electronic signature of a person authorized to act on behalf of the owner of the copyright interest;
• A description of the copyrighted work that you claim has been infringed;
• A description of where the material that you claim is infringing is located on the APP;
• Your address, telephone number, and email address;
• A statement by you that you have a good faith belief that the disputed use is not authorized by the copyright owner, its agent, or the law;
• A statement by you, made under penalty of perjury, that the information in your notification is accurate and that you are the copyright owner or authorized to act on the copyright owner’s behalf.

Contact Information for Copyright Agent:

Email: Admin@invai.tech

Post: Agiou Alexiou street 1, 1st Floor, 2054, Nicosia, Republic of Cyprus

2. Counter-Notification

If you believe that your content was removed or disabled by mistake or misidentification, you may file a counter-notification with our Copyright Agent. Your counter-notification must be in writing and contain the following information:

• Your physical or electronic signature;
• Identification of the material that has been removed or to which access has been disabled and the location at which the material appeared before it was removed or disabled;
• A statement by you, under penalty of perjury, that you have a good faith belief that the material was removed or disabled as a result of mistake or misidentification of the material to be removed or disabled;
• Your name, address, telephone number, and email address, and a statement that you consent to the jurisdiction of the federal court in your district, or if you are outside of the United States, that you consent to the jurisdiction of any judicial district in which the service provider may be found, and that you will accept service of process from the person who provided notification of the alleged infringement.

3. Repeat Infringers

We reserve the right to terminate the accounts of users who are repeat infringers of intellectual property rights.

Content Removal Policy

At INVAI LTD, we are committed to maintaining a respectful and secure environment for all users. This Content Removal Policy outlines our process for handling content that violates our Terms of Service or other policies.

1. Grounds for Content Removal

We reserve the right to remove content that:

• Violates our Terms of Service;
• Is illegal, harmful, or offensive;
• Infringes on the intellectual property rights of others;
• Contains personal or sensitive information;
• Is identified as spam or misleading.

2. Reporting Violations

Users can report content that they believe violates our policies by contacting us at Admin@invai.tech or by using the reporting feature in the APP.

3. Investigation and Action

Upon receiving a report, we will conduct a thorough investigation to determine whether the content violates our policies. If we determine that the content should be removed, we will take appropriate action, which may include:

• Removing the content;
• Issuing a warning to the user who posted the content;
• Suspending or terminating the user's account.

4. Notification

Users whose content has been removed will be notified of the removal and the reason for the action. Users will also be informed of their right to appeal the decision.

5. Appeals

Users who believe that their content was removed in error can file an appeal by contacting us at Admin@invai.tech Appeals will be reviewed by a team not involved in the initial decision, and users will be notified of the outcome.

Blocked Content Policy

At INVAI LTD, we strive to maintain a safe and respectful environment for all users. This Blocked Content Policy outlines the types of content that are prohibited on our platform.

1. Prohibited Content

The following types of content are prohibited on our platform:

• Content that exploits or poses a danger to minors, including but not limited to child pornography, sexual exploitation, or any form of harm or harassment towards minors;
• Content that is illegal, harmful, or offensive;
• Content that infringes on the intellectual property rights of others;
• Content that contains personal or sensitive information;
• Content that is identified as spam or misleading;
• Content that incites violence, hatred, or discrimination;
• Content that promotes illegal activities.

2. Reporting Violations

Users can report content that they believe violates our policies by contacting us at Admin@invai.tech or by using the reporting feature in the APP.

3. Investigation and Action

Upon receiving a report, we will conduct a thorough investigation to determine whether the content violates our policies. If we determine that the content should be removed, we will take appropriate action, which may include:

• Removing the content;
• Issuing a warning to the user who posted the content;
• Suspending or terminating the user's account.

4. Notification

Users whose content has been removed will be notified of the removal and the reason for the action. Users will also be informed of their right to appeal the decision.

5. Appeals

Users who believe that their content was removed in error can file an appeal by contacting us at Admin@invai.tech. Appeals will be reviewed by a team not involved in the initial decision, and users will be notified of the outcome.