PRIVACY POLICY NOTICE 

Effective Date: August 29, 2018 

This privacy notice discloses the privacy practices for Sawaya LLC (the "Company"), regarding the PhotoPGP mobile application ("PhotoPGP") and associated website photopgp.com (the "Website").  

This privacy notice applies solely to information collected by the Company, except where stated otherwise.  

The policy will notify you of the following:   

  • What information is collected  
  • With whom it is shared  
  • How it can be corrected  
  • How it is secured  
  • How policy changes will be communicated  
  • How to address concerns 

 INFORMATION COLLECTION, USE, AND SHARING  

No personally identifiable information ("Personal Information") is collected by PhotoPGP or the Website unless you provide such information as described below. 

PhotoPGP has no network interface permission or capability (except to help users select web links which open with the Android default web browser), and it is designed so that no data is shared with other apps (except for the Openkeychain service, which performs the cryptography).  

The Website only provides public domain information and does not allow any user data entry.  

The only information the Company has is what users voluntarily send via encrypted email, or other information received by the Company from Google (which is covered by the Google Privacy Policy).  See Google’s privacy policy for apps,  https://policies.google.com/privacy

The Company does not sell or rent any Personal Information and will not share user information with any third party, other than as may be necessary to provide and maintain PhotoPGP and the Website, fulfill user requests, and as may be required by applicable law.  

The Company may use this information to respond to the user request, regarding the reason the Company was contacted. The Company may contact you via email in the future to tell you about new products or features. You may opt-out of such communications by emailing us at photopgp@gmail.com or by unsubscribing from any email you receive. 

Except as otherwise described in this Privacy Policy, we do not knowingly permit third-parties to collect Personal Information or share Personal Information with any third-parties. We have no control, however, over the access or collection of Personal Information by third-parties such as your internet service provider, your device manufacturer, the Google Play app store, other persons from or through which you may obtain access to PhotoPGP or the Website. 

YOUR ACCESS TO AND CONTROL OVER INFORMATION  

You may review and request changes to any Personal Information that the Company has concerning you by emailing us at photopgp@gmail.com.  

REGISTRATION  

You are not required to register with the Company in order to use PhotoPGP, or to access the Website. You only need a Google Play Store account to install and update PhotoPGP.  

ORDERS  

The Company does not obtain or collect any financial information about you.  

The Google Play Store handles all financial transaction information, fulfills orders, and provides periodic software updates (which may also update this privacy policy). Google Play may collect certain information in connection with your use of the App, such as Personal Information, payment information, geolocational information, and other usage-based data. We have no control over the collection of such information by a third-party app store, and any such collection or use will be subject to that third party’s applicable privacy policies. 

SHARING  

We don't share Personal Information with any third-parties.  

SECURITY 

We take commercially reasonable precautions to protect your information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. While we use OpenPGP to protect sensitive information transmitted online, we also use this same protection for your information offline. Only persons who need the information to perform a specific job (e.g. customer service request) are granted access to user information. Please understand, however, that no security system is impenetrable. We cannot guarantee the security of our databases, nor can we guarantee that the Information you supply will not be intercepted while being transmitted over the Internet. You therefore should take special care in deciding what information you send to us via e-mail. If you send us any Personal Information via email, it is your responsibility to protect that information by encrypting your message/request with the PhotoPGP public key (so only we can read it) and by providing your valid OpenPGP public key (only if you want a response from us). 

WEBSITE LOGS AND COOKIES  

A third-party commercial web-host provides the implementation support for the Website. The Company does not use, access, or retain any logs which may exist for this Website and does not track visitors to the Website. The Website does not allow any personal data entry, and only uses a "session cookie" to handle tab navigation.  

LINKS 

PhotoPGP and the Website contain links to other sites. Please be aware that we are not responsible for the content or privacy practices of such other sites. We encourage our users to be aware when they leave our site and to read the privacy statements of any other site that may collects personally identifiable information.  

GEOLOCATION / GEOTAGGING  

PhotoPGP will never support geolocation or GPS tracking. PhotoPGP does not allow Android location permission, nor does it capture geographic coordinates (geotagging). This means that geolocation metadata is never embedded within the JPEG files that PhotoPGP creates for you (either encrypted or un-encrypted). Note: Your default Android "Camera" app may actually share your location and allow microphone permissions - but PhotoPGP does not. 

IMPORTANT NOTICES TO NON-U.S. RESIDENTS 

PhotoPGP, the Website, and its servers are operated in the United States and intended only by those in the United States. If you are located outside of the United States, please be aware that your Information, including your Personal Information, may be transferred to, processed, maintained, and used on computers, servers, and systems located outside of your state, province, country, or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you are located outside the United States and choose to use the App, you hereby irrevocably and unconditionally consent to such transfer, processing, and use in the United States and elsewhere. 

CHILDREN 

PhotoPGP is not directed to children under the age of 13. We adhere to the Children’s Online Privacy Protection Act (COPPA) and will not knowingly collect Personal Information from any child under the age of 13. We ask that minors (under the age of 13) not use the App. If a child under the age of 13 has provided us with Personal Information, a parent or guardian of that child may contact us and request that such information be deleted from our records. 

NOTIFICATION OF CHANGES  

This Privacy Policy is effective as of the date stated at the top of this Privacy Policy. We may change this Privacy Policy from time to time. Whenever material changes are made to this Privacy Policy, you will be notified by PhotoPGP as the version changes, through the Google Play Store software update process and any such changes will be posted on the App. By accessing the App after we make any such changes to this Privacy Policy, you are deemed to have accepted such changes. Please be aware that, to the extent permitted by applicable law, our use of the Information is governed by the Privacy Policy in effect at the time we collect the Information. Please refer back to this Privacy Policy on a regular basis. 

HOW TO CONTACT US 

If you have questions about this Privacy Policy, or if you feel that we are not abiding by this Privacy Policy, you should contact us immediately via email at photopgp@gmail.com with “Privacy Policy” in the subject line.