Terms of Service

At a Glance

Swipenter is a photo cleanup app that helps you organize your camera roll by swiping. These Terms of Service govern your use of the app. Key points: Swipenter processes your photos entirely on your device — nothing is uploaded to any server. The app is free to download with optional premium subscriptions managed through Apple. You retain full ownership of your photos at all times. Deletion only happens when you explicitly confirm it, and deleted photos go to Apple's “Recently Deleted” folder where they remain recoverable for 30 days. By using Swipenter, you agree to these Terms. If you do not agree, please do not use the app.

Table of Contents

1. Who We Are
2. Definitions
3. Acceptance of Terms
4. Eligibility
5. Description of the Service
6. On-Device Processing and Your Photos
7. Your Account and Responsibilities
8. License Grant
9. Acceptable Use
10. Subscriptions, Payments, and Free Tier
11. Right of Withdrawal (EU Consumers)
12. Intellectual Property
13. User Content and Ownership
14. Third-Party Services
15. Privacy and Data Protection
16. Conformity and Updates
17. Availability and Modifications to the Service
18. Disclaimers
19. Limitation of Liability
20. Indemnification
21. Termination
22. Dispute Resolution
23. Governing Law and Jurisdiction
24. Changes to These Terms
25. Severability
26. Entire Agreement
27. Contact Us

1. Who We Are

Swipenter is provided by:

InDevLab Ro S.R.L.
Email: [email protected]
Privacy inquiries: [email protected]

InDevLab Ro S.R.L. is a company registered in Romania and acts as the provider of the Swipenter application and related services.

In accordance with the European Union Digital Services Act (Regulation (EU) 2022/2065), InDevLab Ro S.R.L. operates as a trader. Our contact information, including business address, email, and phone number, is published on our App Store product page as required by Articles 30 and 31 of the DSA.

2. Definitions

Throughout these Terms, the following definitions apply:

• “App” or “Swipenter” — the Swipenter mobile application for iOS, including all updates, upgrades, and related services.
• “We,” “Us,” “Our” — InDevLab Ro S.R.L., the developer and provider of Swipenter.
• “You,” “Your,” “User” — any individual who downloads, installs, or uses Swipenter.
• “Content” — any photos, videos, Live Photos, screenshots, screen recordings, and associated metadata stored in your device's photo library.
• “Service” — the functionality provided by the App, including photo review, organization, statistics, widgets, notifications, and any premium features.
• “Subscription” or “Premium” — a paid plan that unlocks additional features beyond the free tier, available as monthly, yearly, or lifetime purchase options.
• “Free Tier” — the version of the Service available without a paid Subscription, which includes core functionality with certain limitations and advertisements.
• “Review Session” — a period during which you use the swipe interface to review and make keep, delete, or bookmark decisions about your photos.
• “Terms” — these Terms of Service, as amended from time to time.

3. Acceptance of Terms

3.1 Agreement to Terms

By downloading, installing, accessing, or using Swipenter, you acknowledge that you have read, understood, and agree to be bound by these Terms and our Privacy Policy. These Terms form a legally binding agreement between you and InDevLab Ro S.R.L.

3.2 Supplementary Terms

Your use of Swipenter is also subject to:

• Our Privacy Policy, which describes how we handle data and is incorporated by reference into these Terms.
• Apple's Terms and Conditions, including the Licensed Application End User License Agreement (the “Standard EULA”) available at apple.com/legal/internet-services/itunes/dev/stdeula. In the event of a conflict between Apple's Standard EULA and these Terms, these Terms shall prevail to the extent permitted by applicable law.
• Apple's Usage Rules set forth in the Apple Media Services Terms of Service.

3.3 Updates to Terms

We may update these Terms from time to time. Material changes will be communicated as described in Section 24. Your continued use of the App after changes become effective constitutes acceptance of the revised Terms.

4. Eligibility

4.1 Age Requirement

You must be at least 16 years of age to use Swipenter. This age requirement aligns with GDPR Article 8 and Romanian Law 190/2018 regarding the processing of personal data relating to children.

If you are between 16 and 18 years of age (or the age of legal majority in your jurisdiction), you represent that your parent or legal guardian has reviewed and agrees to these Terms on your behalf.

4.2 Compliance with Law

You represent and warrant that your use of Swipenter complies with all applicable laws and regulations in your jurisdiction. You are solely responsible for ensuring that the App is suitable for your use and that such use is permitted under local law.

4.3 Device Requirements

Swipenter requires an iPhone running iOS 17.0 or later. We do not guarantee compatibility with all devices or operating system versions. Certain features, such as widgets and haptic feedback, may require specific hardware capabilities.

5. Description of the Service

5.1 Core Functionality

Swipenter is a photo management utility that provides:

• Swipe-based photo review — a card-style interface where you swipe right to keep a photo, swipe left to mark it for deletion, or swipe up to bookmark it for later review.
• Month-by-month organization — your photo library is presented chronologically, allowing you to work through your camera roll systematically.
• “On This Day” memories — photos taken on the current date in previous years are surfaced for review.
• Progress tracking and statistics — visual dashboards showing your cleanup activity, storage freed, streaks, and achievements.
• Session management — your review progress is saved automatically so you can pause and resume at any time.
• Widgets — home screen and lock screen widgets displaying streak counts, statistics, and memory previews.
• Local notifications — optional reminders for daily memories and streak maintenance.

5.2 How Photo Deletion Works

Swipenter does not automatically delete any photos. The deletion process is as follows:

1. During a Review Session, you mark individual photos by swiping. No photos are deleted at this stage.
2. At the end of a Review Session, you are presented with a summary of your decisions. You may change any decision before proceeding.
3. You must explicitly tap a confirmation button to execute deletion.
4. iOS will display its own system confirmation dialog before any deletion occurs.
5. Deleted photos are moved to Apple's “Recently Deleted” album, where they remain recoverable for approximately 30 days before permanent removal by iOS.

We are not responsible for the permanent deletion of photos from the “Recently Deleted” album. The 30-day recovery window is managed entirely by Apple's iOS operating system, and this timeframe may vary.

5.3 No Automated Decision-Making

Swipenter does not use artificial intelligence, machine learning, or any form of automated processing to make decisions about your photos. Every keep, delete, or bookmark action is initiated exclusively by you through deliberate gestures. The App does not analyze the content of your photos for any purpose other than displaying them to you on your device.

6. On-Device Processing and Your Photos

6.1 Local Processing Only

Your photos and videos never leave your device. All photo display, review, and management operations are performed entirely on your iPhone using Apple's PhotoKit framework. Swipenter does not upload, transmit, copy, or store your photos on any external server, cloud service, or third-party platform.

6.2 Photo Library Access

Swipenter requires access to your photo library to function. This access is granted through Apple's standard iOS permission system, and you can choose between:

• Full Access — allows Swipenter to display and manage your entire photo library.
• Limited Access — allows you to select specific photos for the App to access.

You may change your photo library permissions at any time through iOS Settings > Privacy & Security > Photos.

6.3 Metadata Usage

Swipenter reads metadata associated with your photos (such as creation dates, file sizes, media types, dimensions, and location data when available) solely for the purpose of organizing and displaying your photo library within the App. This metadata is processed on your device and is never transmitted externally.

6.4 No Use for Training

Your photos, videos, metadata, and any data derived from your content are never used to train machine learning models, algorithms, or artificial intelligence systems — by us or by any third party through the App.

7. Your Account and Responsibilities

7.1 No Account Required

Swipenter does not require you to create an account, register, or provide any personal information to use the App. All app data is stored locally on your device.

7.2 Your Responsibilities

You are responsible for:

• Your decisions. All keep, delete, and bookmark decisions are made by you. We are not responsible for the consequences of your photo management choices.
• Your device. Maintaining the security of your device, including keeping your operating system updated and protecting access to your phone.
• Backups. We strongly recommend maintaining regular backups of your photo library (for example, through iCloud Photos or iTunes) before using any photo deletion features. While Swipenter includes an undo feature within active sessions and iOS provides a 30-day “Recently Deleted” recovery period, these safeguards have limitations.
• Accurate permissions. Granting appropriate photo library permissions for the App to function as intended.

7.3 Assumption of Risk

By choosing to delete photos through Swipenter, you accept the inherent risk that some deleted photos may not be recoverable after the “Recently Deleted” recovery period expires. We encourage you to carefully review the session summary before confirming any deletion.

8. License Grant

8.1 License to Use the App

Subject to your compliance with these Terms, we grant you a limited, non-exclusive, non-transferable, revocable license to download, install, and use Swipenter on any Apple-branded device that you own or control, as permitted by Apple's Usage Rules set forth in the Apple Media Services Terms of Service.

8.2 Scope of License

This license does not grant you the right to:

• Distribute, sublicense, lease, lend, rent, or otherwise transfer the App or your license to any third party.
• Copy, modify, adapt, translate, reverse engineer, decompile, disassemble, or create derivative works based on the App, except to the extent that such activity is expressly permitted by applicable law notwithstanding this limitation.
• Remove, alter, or obscure any copyright, trademark, or other proprietary notices contained in the App.
• Use the App for any commercial purpose other than its intended use as a personal photo management tool.
• Access or attempt to access any part of the App's source code, servers, or infrastructure.

8.3 Open-Source Components

Swipenter may include open-source software components, each of which is subject to its own applicable license terms. A list of open-source components and their respective licenses is available in the App under Settings > About > Acknowledgements.

9. Acceptable Use

9.1 Permitted Use

You may use Swipenter solely for its intended purpose: managing and organizing photos and videos stored in your personal photo library on your iOS device.

9.2 Prohibited Conduct

You agree not to:

• Use the App in any way that violates applicable local, national, or international law or regulation.
• Attempt to gain unauthorized access to any part of the App, other users' data, or any systems or networks connected to the App.
• Introduce viruses, trojans, worms, malware, or other harmful material through or in connection with the App.
• Use automated tools, bots, scrapers, or similar means to interact with the App.
• Interfere with, disrupt, or create an undue burden on the App or the networks or services connected to the App.
• Use the App in any manner that could damage, disable, overburden, or impair the functioning of the App.
• Attempt to circumvent any access restrictions, usage limitations, or premium feature gates built into the App.

10. Subscriptions, Payments, and Free Tier

10.1 Free Tier

Swipenter offers a free tier that provides access to the core photo review functionality with the following limitations:

• A daily limit of photo reviews (currently 50 photos per day), which resets at midnight local time.
• Advertisements displayed within the App (served by Google AdMob).
• Restricted access to certain features designated as Premium.

We reserve the right to modify free tier limitations, including the daily review limit, at any time. We will notify you of significant changes to the free tier through in-app communication.

10.2 Premium Subscriptions

Swipenter offers the following premium options (prices may vary by region):

• Monthly Subscription — auto-renewing monthly plan.
• Yearly Subscription — auto-renewing yearly plan.
• Lifetime Purchase — a one-time, non-recurring purchase granting permanent premium access.

Premium features include, but are not limited to: unlimited daily reviews, ad-free experience, advanced statistics, all visual themes, all app icons, streak freeze, and priority support. The specific features included in Premium may change over time. We will not remove core Premium features without providing reasonable notice.

10.3 Payment Processing

All payments are processed by Apple through the App Store. We do not collect, store, or have access to your payment information (such as credit card numbers or banking details). Pricing is displayed in your local currency as determined by Apple.

Applicable taxes may be added to the listed prices, depending on your location and Apple's policies.

10.4 Auto-Renewal

Subscriptions automatically renew at the end of each billing period (monthly or yearly) unless you cancel at least 24 hours before the end of the current period. Renewal is charged at the same rate as the original subscription unless we have provided advance notice of a price change.

10.5 Managing and Canceling Subscriptions

You can manage or cancel your subscription at any time through:

• iPhone: Settings > [Your Name] > Subscriptions > Swipenter
• App Store: Open App Store > tap your profile icon > Subscriptions > Swipenter

Cancellation takes effect at the end of the current billing period. You will retain access to Premium features until the end of the period you have already paid for. Canceling a subscription does not entitle you to a refund for the current billing period.

10.6 Price Changes

We may change subscription prices from time to time. Apple will notify you of any price changes in advance, and you will have the opportunity to accept the new price or cancel your subscription before the change takes effect. Continued use of a subscription after a price change constitutes acceptance of the new price.

10.7 Refunds

Refund requests are handled by Apple in accordance with Apple's refund policies. To request a refund, visit reportaproblem.apple.com. We do not process refunds directly.

10.8 Restore Purchases

If you reinstall the App or switch devices, you can restore your previous purchases through the App's settings. This is facilitated by Apple's StoreKit framework and requires you to be signed in with the same Apple ID used for the original purchase.

10.9 Promotional Offers and Free Trials

We may offer promotional pricing, introductory offers, or free trial periods from time to time. The specific terms of any promotional offer will be presented to you at the time of offer. Free trials automatically convert to paid subscriptions at the end of the trial period unless you cancel at least 24 hours before the trial expires.

11. Right of Withdrawal (EU Consumers)

11.1 Your Right Under EU Law

If you are a consumer located in the European Economic Area (EEA), you have the right to withdraw from a distance contract within 14 days of the conclusion of the contract, without giving any reason, in accordance with Directive 2011/83/EU (the Consumer Rights Directive) as transposed into Romanian law by Government Emergency Ordinance 34/2014.

11.2 When the Right of Withdrawal Does Not Apply

For digital content (such as the Swipenter app and in-app purchases), the right of withdrawal expires once performance has begun with your prior express consent and your acknowledgment that you lose the right of withdrawal. When you initiate a purchase through the App Store and Apple begins delivering the digital content to you, you acknowledge and consent that the performance of the contract has begun, and that you therefore lose the right of withdrawal for that specific transaction.

For auto-renewing subscriptions, each renewal constitutes a new contract. You may cancel future renewals at any time as described in Section 10.5, but the right of withdrawal for a period that has already been charged does not apply once performance has begun for that period.

11.3 Free Tier

Since the free tier of Swipenter does not require any payment, the right of withdrawal under consumer protection law does not apply. You may stop using the App and uninstall it at any time.

11.4 How to Exercise the Right of Withdrawal

If the right of withdrawal applies to your situation, you may exercise it by sending a clear statement of your decision to withdraw to [email protected] before the 14-day period expires. Alternatively, you may request a refund directly through Apple at reportaproblem.apple.com.

12. Intellectual Property

12.1 Our Intellectual Property

The App, including its design, code, graphics, user interface, LiquidGlass design system, logos, icons, animations, text, and overall look and feel, is the intellectual property of InDevLab Ro S.R.L. and is protected by copyright, trademark, and other intellectual property laws.

The Swipenter name, logo, and associated branding are trademarks of InDevLab Ro S.R.L. You may not use these trademarks without our prior written consent.

12.2 Feedback

If you voluntarily provide suggestions, ideas, feedback, or other input regarding the App (“Feedback”), you grant us a non-exclusive, worldwide, royalty-free, perpetual, irrevocable license to use, modify, and incorporate such Feedback into the App and our other products and services without any obligation to you. Feedback does not include your photos, personal data, or Content as defined in Section 2.

12.3 Third-Party Intellectual Property

The App uses Apple's SF Symbols and system frameworks, which remain the intellectual property of Apple Inc. Google AdMob and Firebase are the intellectual property of Google LLC. All other third-party trademarks and intellectual property referenced in the App belong to their respective owners.

13. User Content and Ownership

13.1 Your Ownership

You retain full ownership of all photos, videos, and other media in your photo library at all times. Swipenter does not claim any ownership, license, or rights over your Content. The App merely provides a tool to view, organize, and manage Content that already exists on your device.

13.2 No Upload or Sharing

Since Swipenter operates entirely on your device and does not transmit your Content to any external server, there is no “upload” of user content. We never access, view, collect, or store your photos or videos.

13.3 User-Generated Data

Review decisions, statistics, streaks, achievements, and preferences generated through your use of the App are stored locally on your device. You may export this data at any time using the export function in the App's Settings. Upon deletion of the App or use of the “Clear All App Data” option, this data is permanently erased from your device.

14. Third-Party Services

14.1 Integrated Third-Party Services

Swipenter integrates the following third-party services:

• Google AdMob — for displaying advertisements in the free tier. Governed by Google's Privacy Policy.
• Firebase Analytics — for collecting anonymous usage analytics to improve the App. Governed by Firebase's privacy information.
• Apple StoreKit — for processing in-app purchases. Governed by Apple's Privacy Policy.

14.2 Third-Party Terms

Your use of third-party services integrated into Swipenter is subject to those services' own terms and privacy policies. We are not responsible for the practices, content, or availability of third-party services.

14.3 Links to External Resources

The App may contain links to external websites (such as our privacy policy, terms of service, or support pages). These links are provided for your convenience. We do not control and are not responsible for the content or availability of external websites.

14.4 No Endorsement

The inclusion of any third-party service or link does not imply endorsement by us of that service, its content, or its providers.

15. Privacy and Data Protection

15.1 Privacy Policy

Our collection and processing of personal data is governed by our Privacy Policy, which is incorporated into these Terms by reference. We encourage you to read the Privacy Policy carefully.

15.2 Key Privacy Principles

• Your photos and videos never leave your device.
• The App does not require an account or personal registration.
• Advertising and analytics data collection requires your consent (in the EEA, UK, and Switzerland).
• Premium subscribers are not shown ads, and AdMob is not initialized for Premium users.
• You can delete all locally stored app data at any time.

15.3 GDPR Rights

If you are located in the European Economic Area, you have rights under the General Data Protection Regulation (EU) 2016/679, including the rights to access, rectification, erasure, restriction, portability, objection, and withdrawal of consent. For full details and instructions on how to exercise these rights, please refer to Section 9 of our Privacy Policy or contact us at [email protected].

15.4 Consent for Advertising and Analytics

If you are located in the EEA, UK, or Switzerland, Swipenter will request your consent before activating personalized advertising or analytics tracking, in compliance with the GDPR and the IAB Transparency and Consent Framework (TCF) v2.2. You may manage your consent preferences at any time through the App's Settings under “Privacy & Data Settings.”

16. Conformity and Updates

16.1 Conformity of Digital Content (EU Consumers)

In accordance with Directive (EU) 2019/770 (the Digital Content Directive), as transposed into Romanian law, we warrant to consumers in the EEA that Swipenter:

• Conforms to the description, quantity, quality, and functionality as described in these Terms and on the App Store product page.
• Is fit for the purposes for which digital content of the same type would normally be used.
• Is delivered with all accessories, instructions, and customer assistance as the consumer may reasonably expect.
• Is updated as necessary to maintain conformity, including security updates.

16.2 Your Remedies for Lack of Conformity

If Swipenter does not conform to the above requirements, you have the right to have the digital content brought into conformity free of charge. If bringing the content into conformity is impossible or would impose disproportionate costs on us, or if we fail to do so within a reasonable time, you are entitled to a proportionate reduction in price or termination of the contract and a refund, to the extent applicable under EU consumer law.

16.3 Updates

We may release updates to the App from time to time to fix bugs, improve performance, add new features, or ensure compatibility with new iOS versions. Certain updates may be necessary to maintain the conformity of the App. We will inform you of such updates, and you are responsible for installing them. Failure to install necessary updates may affect the conformity of the App and our obligations under Section 16.1.

Updates that go beyond what is necessary to maintain conformity will only be made with your consent where they negatively affect your access to or use of the App. We will inform you of such changes in advance.

16.4 Compatibility and Interoperability

Swipenter is designed for use on iPhones running iOS 17.0 or later. The App interacts with your device's photo library through Apple's PhotoKit framework, with your device's storage through Apple's SwiftData framework, and with Apple's StoreKit for payment processing. Specific features such as widgets require WidgetKit support, and haptic feedback requires devices with a Taptic Engine.

17. Availability and Modifications to the Service

17.1 Availability

We strive to make Swipenter available at all times; however, since the App operates primarily on your device, its availability is generally dependent on your device's functionality rather than server uptime. Certain features (such as in-app purchases, ad delivery, and widget updates) may require an active internet connection and may be temporarily unavailable due to factors beyond our control, including but not limited to Apple service disruptions.

17.2 Modifications

We reserve the right to modify, update, or discontinue any feature of the App at any time. For changes that materially reduce the functionality you have paid for (Premium features), we will provide reasonable advance notice and, where applicable, offer a proportionate refund.

17.3 Force Majeure

We shall not be liable for any failure or delay in providing the Service caused by circumstances beyond our reasonable control, including but not limited to natural disasters, government actions, pandemics, internet disruptions, Apple platform changes, or other events of force majeure.

18. Disclaimers

18.1 “As Is” Provision

To the maximum extent permitted by applicable law, and without prejudice to your statutory rights as a consumer in the European Economic Area (including the conformity guarantees set out in Section 16), Swipenter is provided on an “AS IS” and “AS AVAILABLE” basis.

18.2 No Warranties on Outcomes

We do not warrant that:

• The App will meet all of your specific requirements or expectations.
• The App will be uninterrupted, timely, secure, or entirely error-free.
• The results of using the App (such as storage freed, photo organization) will be accurate or reliable.
• Any defects will be corrected within a specific timeframe (except as required by EU consumer law).

18.3 Photo Library Accuracy

While Swipenter reads photo metadata as provided by Apple's PhotoKit framework, we do not guarantee the accuracy of photo counts, file sizes, storage calculations, or other metrics derived from your photo library. Discrepancies may arise due to iOS system behavior, iCloud Photo Library syncing, or other factors outside our control.

18.4 Consumer Rights Preserved

Nothing in these Terms shall limit or exclude any rights you have as a consumer under mandatory provisions of EU law, Romanian law, or the laws of your country of residence. In particular, the conformity guarantees, liability provisions, and remedies available to you under the Digital Content Directive (Directive (EU) 2019/770), the Consumer Rights Directive (Directive 2011/83/EU), and their national implementing legislation apply in full and take precedence over any conflicting provision of these Terms.

19. Limitation of Liability

19.1 Scope of Limitation

To the maximum extent permitted by applicable law and subject to Section 19.3:

• We shall not be liable for any indirect, incidental, special, consequential, or punitive damages, including but not limited to loss of data, loss of photos, loss of profits, loss of goodwill, or other intangible losses arising from or related to your use of Swipenter.
• Our total aggregate liability to you for any claims arising from or related to these Terms or your use of the App shall not exceed the greater of: (a) the amounts you have paid to us (through Apple) for the App in the twelve (12) months immediately preceding the event giving rise to the claim, or (b) fifty euros (€50).

19.2 Photo Deletion

While Swipenter includes multiple safeguards (session summaries, confirmation dialogs, iOS system confirmation, undo functionality, and the “Recently Deleted” 30-day recovery period), you acknowledge that photo deletion carries inherent risk. We strongly recommend maintaining independent backups of your photo library. To the extent permitted by law, we shall not be liable for any loss of photos resulting from your use of the deletion features, provided such features functioned as described in Section 5.2.

19.3 Exclusions from Limitation

Nothing in these Terms shall limit or exclude our liability for:

• Death or personal injury caused by our negligence.
• Fraud or fraudulent misrepresentation.
• Any liability that cannot be limited or excluded under applicable mandatory law, including EU consumer protection law.
• Our obligations under the conformity guarantees set out in Section 16 (for consumers in the EEA).
• Intentional misconduct or gross negligence.

20. Indemnification

To the extent permitted by applicable law (and subject to any mandatory consumer protection provisions that may limit this obligation), you agree to indemnify, defend, and hold harmless InDevLab Ro S.R.L. and its officers, directors, employees, and agents from and against any claims, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising from or related to:

• Your violation of these Terms.
• Your misuse of the App.
• Your violation of any applicable law or regulation.

This Section does not apply to consumers in the EEA to the extent that it conflicts with mandatory consumer protection law.

21. Termination

21.1 Termination by You

You may terminate your use of Swipenter at any time by:

• Deleting the App from your device.
• Canceling any active subscription through your Apple ID settings.

Uninstalling the App will permanently delete all locally stored app data (settings, progress, statistics, and achievements). Your photos remain unaffected in your device's photo library.

21.2 Termination by Us

We may terminate or suspend your access to the App if:

• You materially breach these Terms.
• We are required to do so by law or regulatory order.
• We discontinue the App or the Service entirely.

In the event of termination due to our discontinuation of the Service, we will provide reasonable notice (not less than 30 days where practicable) and, for active paid subscribers, offer a proportionate refund for the unused portion of their subscription.

21.3 Effects of Termination

Upon termination:

• Your license to use the App is revoked.
• Your locally stored app data (settings, progress, statistics) will be deleted upon uninstalling the App.
• Your photos and videos are not affected and remain in your device's photo library.
• Any photos previously moved to “Recently Deleted” remain subject to Apple's 30-day retention policy.
• Provisions that by their nature should survive termination (including Sections 12, 13, 18, 19, 20, 22, and 23) shall continue to apply.

22. Dispute Resolution

22.1 Informal Resolution

We encourage you to contact us first at [email protected] to resolve any dispute informally. We will make reasonable efforts to address your concerns within 30 days.

22.2 EU Online Dispute Resolution

If you are a consumer in the European Union and we are unable to resolve your complaint informally, you may use the European Commission's Online Dispute Resolution (ODR) platform at ec.europa.eu/consumers/odr. This platform allows EU consumers to submit disputes related to online purchases for resolution by an approved dispute resolution body.

Our email for the purpose of the ODR platform is: [email protected].

22.3 Consumer Protection Authorities

Nothing in these Terms limits your right to bring claims before the competent courts of your place of habitual residence or to seek assistance from consumer protection authorities, including:

• Romania: Autoritatea Națională pentru Protecția Consumatorilor (ANPC), www.anpc.ro
• Your country of residence: the competent consumer protection authority applicable to you.

22.4 Supervisory Authority (Data Protection)

For disputes related to the processing of your personal data, you may lodge a complaint with a supervisory authority as described in Section 9 of our Privacy Policy. The Romanian supervisory authority is ANSPDCP (www.dataprotection.ro).

23. Governing Law and Jurisdiction

23.1 Governing Law

These Terms are governed by and construed in accordance with the laws of Romania, without regard to its conflict of law provisions.

23.2 Consumer Protection Preserved

If you are a consumer habitually resident in the European Economic Area, you also benefit from the mandatory provisions of the consumer protection law of your country of residence. Nothing in these Terms deprives you of this protection. In the event of a conflict between Romanian law and the mandatory consumer protection provisions of your country of residence, the provisions that are more favorable to you as a consumer shall apply.

23.3 Jurisdiction

Any disputes arising from or in connection with these Terms that cannot be resolved through the mechanisms described in Section 22 shall be submitted to the exclusive jurisdiction of the competent courts of Bucharest, Romania. However, if you are a consumer in the EEA, you may also bring proceedings in the courts of your place of habitual residence, and we may only bring proceedings against you in the courts of your place of habitual residence.

24. Changes to These Terms

24.1 Notification of Changes

We may modify these Terms from time to time. When we make material changes:

• We will update the “Last updated” date at the top of this document.
• We will notify you through the App (via an in-app notice or push notification) at least 15 days before the changes take effect.
• For paid subscribers, material changes to subscription terms will be communicated at least 30 days in advance.
• The updated Terms will be made available within the App and at the same public URL.

24.2 Acceptance of Changes

Your continued use of Swipenter after the updated Terms take effect constitutes your acceptance of the changes. If you do not agree with the revised Terms, you should stop using the App and, if applicable, cancel your subscription before the changes become effective.

24.3 Archive

Previous versions of these Terms will be made available upon request by contacting [email protected].

25. Severability

If any provision of these Terms is found to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such invalidity, illegality, or unenforceability shall not affect the remaining provisions, which shall continue in full force and effect. The invalid provision shall be modified to the minimum extent necessary to make it valid and enforceable while preserving its original intent.

26. Entire Agreement

These Terms, together with the Privacy Policy and any terms applicable to your purchase through the App Store, constitute the entire agreement between you and InDevLab Ro S.R.L. regarding your use of Swipenter. These Terms supersede all prior and contemporaneous agreements, proposals, and representations, whether written or oral, relating to the App.

No failure or delay by us in exercising any right under these Terms shall operate as a waiver of that right. A waiver of any provision shall not constitute a waiver of any other provision.

27. Contact Us

If you have any questions, concerns, or requests regarding these Terms of Service, please contact us:

InDevLab Ro S.R.L.
General inquiries and support: [email protected]
Privacy and data protection: [email protected]

We aim to respond to all inquiries within 30 days.