SwingGPT - Privacy Policy

1. Introduction

SwingGPT (referred to as "we," "us," "our," or the "App") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our iOS mobile application, including all features, functionality, and services offered through the App.

SwingGPT is an AI-powered golf swing coach that uses your device's camera to analyze your golf swing and provide personalized coaching feedback through artificial intelligence.

Please read this Privacy Policy carefully. If you do not agree with our policies and practices, please do not use the App.

2. Information We Collect

2.1 Camera and Video Data

Video Capture: When you use SwingGPT, the App accesses your device's camera to capture video of your golf swing. The video itself is processed locally on your device and is not stored or transmitted to our servers.

Pose Landmark Data: Using Google MediaPipe (processed on-device), we extract only body pose landmarks from the video. Pose landmarks are mathematical representations of key body positions (joints, angles) and do not contain visual information. These pose landmarks are sent to our backend server for analysis.

Important: Raw video and images are never stored, transmitted, or saved. Only extracted pose landmark data is used for analysis.

2.2 Account Information

When you create an account, we collect:

Your authentication method: Apple Sign-In or Google Sign-In
Basic profile information provided by your sign-in provider (name, email address)
Unique identifier assigned by your sign-in provider

2.3 User Preferences

We store the following preferences you configure within the App:

Preferred coach persona
Skill level (beginner, intermediate, advanced)
Handedness (right-handed, left-handed)
Preferred language (English, Japanese, Traditional Chinese)

2.4 Session and Analysis Data

We collect and store:

Session history (date, time, duration of swing analyses)
Pose landmark data for each analyzed swing
AI coaching responses and analysis results

2.5 Subscription and Payment Information

Subscription purchases are processed through Apple In-App Purchase. We do not directly collect or store credit card information or payment details. Apple handles all payment processing securely. We receive only subscription status information from Apple (subscription active/inactive, tier, renewal date).

2.6 Device Information

We may collect:

Device type and iOS version
App version
Crash logs and diagnostic information

2.7 Usage Analytics

We use Google Analytics for Firebase (GA4), an analytics service provided by Google LLC, to understand how the App is used. Through this service we collect:

App usage events, such as account sign-up, completion of a swing analysis, viewing the subscription page, and starting a free trial
Features used and frequency
Number of swings analyzed per day/week/month
Session duration and timestamps
Device-level analytics identifiers (a Firebase-generated app instance ID and Apple's identifier for vendor, IDFV), device model, iOS version, app version, and approximate region

This data is pseudonymous: it is associated with a device-level identifier, not with your name or email address. We do not collect Apple's advertising identifier (IDFA), and the App does not request App Tracking Transparency permission. See Section 4.6 for how this data is shared with Google.

3. How We Use Your Information

3.1 Primary Uses

Provide Coaching Analysis: To analyze your golf swings using AI and provide personalized coaching feedback through text and audio
Account Management: To authenticate your account, manage your profile, and maintain your preferences
Subscription Management: To track your subscription status and enforce free tier limits (5 swings/day)
Service Improvement: To analyze aggregated usage patterns and improve the App's features and accuracy

3.2 Secondary Uses

To communicate with you about your account, subscription, or App updates
To troubleshoot technical issues and provide customer support
To comply with legal obligations and enforce our Terms of Service
To protect against fraud, abuse, and security threats

3.3 AI Training

Important Disclosure: Pose landmark data from your swing analyses may be used to improve our AI models and coaching algorithms. Your personal information (name, email) will not be used for AI training purposes. Pose landmark data used for training is aggregated, anonymized, and de-identified to prevent individual identification.

You may opt out of AI model training while maintaining full App functionality. Your opt-out preference will be respected going forward.

4. Data Sharing and Third-Party Services

4.1 Third Party AI

Pose landmark data is sent to third party AI providers for coaching analysis. These providers process this data to generate AI coaching responses. Their use of your data is subject to their respective Privacy Policies and API Terms of Service. We send only pose landmark data (not video or personal identifiable information) to these providers.

4.2 Google MediaPipe

Google MediaPipe runs locally on your device and does not transmit data to Google's servers. MediaPipe only processes video to extract pose landmarks, which are then sent to our backend.

4.3 Apple Sign-In and Google Sign-In

If you authenticate using Apple Sign-In or Google Sign-In, authentication is handled by Apple or Google respectively. We receive only your authenticated identity and basic profile information. Your password is never shared with us; authentication tokens are managed by Apple or Google.

4.4 Apple App Store

Subscription information is managed through Apple's App Store. Apple's Privacy Policy governs the collection and use of payment data for in-app purchases.

4.5 Service Providers

We may engage third-party service providers to assist with:

Cloud hosting and data storage
Analytics and usage monitoring
Customer support
Security and fraud detection

These service providers are contractually obligated to use your information only as necessary to provide services and to maintain the same level of confidentiality.

4.6 Google Analytics for Firebase and Google Ads

We use Google Analytics for Firebase (GA4) to measure how the App is used, and we share certain conversion events (account sign-up, first swing analysis, subscription page views, and free trial starts) with Google Ads to measure the effectiveness of our advertising. The information described in Section 2.7 (usage events and device-level identifiers) is transmitted to and processed by Google LLC on servers that may be located in the United States.

This data is used solely for analytics and advertising measurement. It is not used to build advertising profiles of you, and we do not collect Apple's advertising identifier (IDFA). On iOS, ad campaign performance is additionally measured through Apple's privacy-preserving SKAdNetwork framework, which reports aggregated, delayed results without identifying individual users.

For more information about how Google processes this data, see Google's Privacy Policy and How Google uses information from sites or apps that use our services.

Notice for users in Japan: In accordance with the external transmission rules under the Japanese Telecommunications Business Act (電気通信事業法の外部送信規律), we disclose that the App transmits the usage events and device identifiers described above to Google LLC for the purposes of usage analytics and advertising measurement.

4.7 No Data Selling

We do not sell, trade, or rent your personal information to third parties. We do not and will not monetize your data. Your information is used exclusively to provide SwingGPT services.

5. Camera Usage Disclosure

Camera Access: SwingGPT requires access to your device's camera to capture golf swings for analysis. You will be prompted to grant camera permission when you first attempt to use the swing analysis feature. Camera access is required for core App functionality.

Video Processing: Video captured by the camera is processed locally on your device using Google MediaPipe. The raw video is never stored on your device, our servers, or transmitted anywhere. Only extracted pose landmark data is transmitted for analysis.

Privacy Controls: You can revoke camera permissions at any time through iOS Settings. If camera permission is revoked, you will not be able to use the swing analysis feature.

6. Data Storage and Security

6.1 Data Storage Location

Your data is stored on secure cloud servers located in the United States. Some data may be cached locally on your iOS device for offline functionality.

6.2 Security Measures

We implement comprehensive security measures to protect your information:

Encryption in Transit: All data transmitted between your device and our servers is encrypted using industry-standard TLS/SSL protocols
Encryption at Rest: Sensitive data stored on our servers is encrypted using AES-256 encryption
Access Control: Access to personal information is restricted to authorized personnel and service providers who need it to perform their duties
Authentication: We use secure authentication mechanisms including OAuth 2.0 for sign-in
Network Security: Our infrastructure includes firewalls, intrusion detection, and monitoring systems
Regular Security Audits: We conduct regular security assessments and penetration testing

6.3 No Absolute Security

While we implement strong security measures, no method of transmission over the internet or electronic storage is 100% secure. We cannot guarantee absolute security of your information. You use SwingGPT at your own risk.

7. Data Retention

We retain your information for as long as necessary to provide SwingGPT services and fulfill the purposes outlined in this Policy:

Account Information: Retained while your account is active and for 30 days after account deletion to process refunds or resolve disputes
Swing Analysis Data: Retained for as long as your account is active. You may request deletion at any time
Session History: Retained for as long as your account is active. Older sessions may be archived after 12 months
Subscription Information: Retained for accounting and audit purposes as required by law
Usage Analytics: Aggregated and anonymized data is retained indefinitely for service improvement
Legal Holds: Information may be retained longer if required by law or for legal proceedings

7.1 Account Deletion

You may request deletion of your account and associated data at any time by contacting us at riotychang@gmail.com. We will delete your account and personal information within 30 days. Some information may be retained for legal or accounting purposes as permitted by law.

8. Apple App Store Privacy Categories

In compliance with Apple's App Privacy requirements, the following table describes the data we collect and how it is used:

Data Type	Collected	Purpose	Shared with Third Parties
User ID	Yes	Account authentication and management	Apple Sign-In / Google Sign-In providers
Email Address	Yes	Account recovery and communication	No
Name	Yes	Personalization	No
Body Pose Landmarks	Yes	Swing analysis and AI coaching	Third Party AI providers (for analysis)
Coarse Location	No	N/A	N/A
Precise Location	No	N/A	N/A
Contacts	No	N/A	N/A
User Photos	No	N/A (video is captured via camera, not photo library)	N/A
Search History	No	N/A	N/A
Browsing History	No	N/A	N/A
Health and Fitness Data	No	N/A	N/A
Financial Information	No	N/A (handled by Apple In-App Purchase)	N/A
Subscription Information	Yes	Subscription management and tier enforcement	Apple (via App Store)
Usage Data (app events)	Yes	Service improvement, analytics, and advertising measurement	Google (Google Analytics for Firebase / Google Ads)
Device ID (Firebase app instance ID, IDFV)	Yes	Analytics and advertising measurement	Google (Google Analytics for Firebase / Google Ads)

9. Your Privacy Rights

9.1 Access and Portability

You have the right to access your personal information. You may request a copy of all personal information we hold about you at any time by contacting us at riotychang@gmail.com.

9.2 Correction and Deletion

You may request correction of inaccurate personal information or deletion of your account and associated data. Please contact us at riotychang@gmail.com with your request. We will respond within 30 days.

9.3 California Consumer Privacy Act (CCPA)

If you are a California resident, you have additional rights under the CCPA, including the right to know, delete, and opt-out of the sale of personal information. SwingGPT does not sell personal information, but you may exercise your rights by contacting us at riotychang@gmail.com.

9.4 European General Data Protection Regulation (GDPR)

If you are located in the European Union, you have rights under the GDPR including access, correction, deletion, restriction, portability, and withdrawal of consent. You may exercise these rights by contacting us at riotychang@gmail.com. We will respond within 30 days of verifying your identity.

9.5 Children's Privacy (COPPA)

SwingGPT is not intended for children under 13 years old. We do not knowingly collect personal information from children under 13. If we become aware that a child under 13 has provided us with personal information, we will immediately delete such information and terminate the child's account. Parents who believe their child has provided information to SwingGPT should contact us immediately at riotychang@gmail.com.

10. International Data Transfers

Your information may be processed and stored in the United States or other countries where we or our service providers operate. These countries may have data protection laws that differ from your country of origin. By using SwingGPT, you consent to the transfer of your information to countries outside your country of residence, which may have different data protection rules than your home country. We will take appropriate safeguards to ensure your information remains protected.

11. Links to Third-Party Websites

SwingGPT may contain links to third-party websites and services not operated by us. This Privacy Policy applies only to information collected through the App. We are not responsible for the privacy practices of third-party websites. We encourage you to review the privacy policies of any third-party services before providing your information.

12. Do Not Track Signals

Some web browsers include a "Do Not Track" feature. Currently, there is no industry-wide standard for recognizing DNT signals. SwingGPT does not respond to Do Not Track browser signals. However, you may opt out of data collection through your device privacy settings.

13. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. We will notify you of any material changes by updating the "Effective Date" at the top of this policy and posting the revised policy within the App. Your continued use of SwingGPT after such modifications constitutes your acceptance of the updated Privacy Policy.

If we make material changes that reduce your privacy rights, we will obtain your explicit consent before implementing those changes.

14. Accessibility

This Privacy Policy is provided in English. The App supports English, Japanese, and Traditional Chinese languages. If you require this Privacy Policy in a different language, please contact us at riotychang@gmail.com.