Last updated: 21 October 2024

EMQM Limited (“we,” “us,” or “our”) is committed to protecting your personal data and respecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile application Swace: Your AI Tennis Coach (“the App”). Please read this Privacy Policy carefully. By using the App, you agree to the terms of this Privacy Policy.

1. Data Controller

EMQM Limited is the data controller responsible for your personal data.

2. Information We Collect

Usage Data

We collect information about how you access and use the App (“Usage Data”), which may include:

• IP address

• Device type and operating system

• Actions performed within the App

• Time and date of your activities

Location Data

We may collect geolocation data to provide location-based features within the App.

Multimedia Data

• Uploaded Videos: The primary function of the App is to allow users to upload videos of themselves playing tennis for analysis.

3. How We Use Your Information

We use the collected data for various purposes:

• To Provide and Maintain Our Service: Including processing your uploaded videos to deliver AI-powered coaching feedback.

• To Improve User Experience: By analyzing usage data to enhance App functionality.

• To Communicate with You: Regarding updates, changes, or customer support inquiries.

• To Ensure Compliance: With legal obligations and to enforce our terms and policies.

4. Legal Basis for Processing

We process your personal data based on the following legal grounds:

• Consent: For collecting and processing geolocation data and multimedia content.

• Performance of a Contract: To provide the services you have requested.

• Legitimate Interests: To improve our services and user experience.

5. Disclosure of Your Information

We may share your information with third parties in the following circumstances:

• Service Providers: We engage third-party companies to facilitate our App and provide services on our behalf, such as subscription management, backend hosting, analytics, and AI processing of uploaded videos. These third parties have access to your personal data only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

• Legal Obligations: If required by law or in response to valid requests by public authorities.

6. International Data Transfers

Your information may be transferred to—and maintained on—servers located outside of your country, including countries that may not have data protection laws equivalent to those in your jurisdiction. We take appropriate measures to ensure that your data is treated securely and in accordance with this Privacy Policy and applicable data protection laws.

7. Data Security

We implement reasonable security measures, including the use of secure servers, to protect your personal data. However, please be aware that no method of transmission over the internet or electronic storage is completely secure.

8. Data Retention

We retain your personal data until you delete your account. Upon account deletion, your data, including uploaded videos, will be permanently removed from our systems.

9. Your Rights

You have the following data protection rights:

• Access: Request access to the personal data we hold about you.

• Correction: Request correction of inaccurate or incomplete data.

• Deletion: Request deletion of your personal data.

• Restriction: Request restriction of processing your personal data.

• Objection: Object to processing your personal data.

To exercise these rights, please contact us at [email protected].

Please note: We currently do not offer data portability options.

10. Children’s Privacy

Our App is intended for users aged 17 and above. We do not knowingly collect personal data from individuals under 17. If you believe we have collected data from a minor, please contact us immediately.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. Changes will be posted within the App, and the “Last updated” date will be revised. We encourage you to review this Privacy Policy periodically.

12. Third-Party Analytics

We use third-party analytics services to monitor and analyze the use of our App. These services may collect information such as frequency of use, events within the App, aggregated usage, performance data, and where the App was downloaded from.

13. Contact Us

If you have any questions or concerns about this Privacy Policy or our data practices, please contact us:

Email: [email protected]

By using Swace: Your AI Tennis Coach, you acknowledge that you have read and understood this Privacy Policy.