Privacy policy

Last updated: 13 October 2026

This policy explains in plain words which data arises with the Android app Sortwell, who receives it and what you can do. It follows the Swiss Federal Act on Data Protection (FADP) and, where they apply, the GDPR and the UK GDPR.

1. Who is responsible

Mirza Tahirovic
Hagenholzstrasse 81, 8050 Zurich, Switzerland
kontakt@tahirolabs.com

2. What happens on your phone

Your photos and videos are processed on the phone only: comparing, computing similarity, detecting faces to pick the best photo, shrinking videos. They are never uploaded. Sortwell has no server of its own and no user accounts.
The app stores a local database on the phone (scan results, file references, clean-up runs) and settings (for example the start of your trial). This stays on the device until you delete the app or clear its data.
Android Auto Backup includes only the settings file with the trial start date. That keeps the date after a reinstall if you use Google's backup. The database is not backed up.

3. Subscription and payment through Google Play

The subscription runs through Google Play. Google processes the payment and is responsible for it. The app only checks, on the phone, whether a subscription exists. Sortwell receives no payment details and runs no server for this.

4. Ads during the trial (Google AdMob)

During the 7-day trial the app shows one ad banner on two screens. With a subscription there are no ads. The ads come from Google AdMob.

In the European Economic Area, the United Kingdom and Switzerland, Google's consent form (UMP) asks you on first start. It separates two questions:

Access to your device: whether Google may read or store identifiers on the phone, for example the advertising ID. Google needs this also for non-personalised ads, for example to limit how often you see the same ad, for ad reporting and against fraud.
Personalisation: whether Google may tailor the ads to your interests.

Depending on your choice:

Both allowed: personalised ads.
Only access allowed: non-personalised ads. Google then uses the advertising ID for the purposes above, but not for ads based on your interests.
Access declined: Google shows limited ads at most. They are not personalised. According to Google, they use cookies or local storage on the device only to detect fraud and invalid traffic. Google also receives technically necessary data such as IP address, device type and app.

Declining is as easy as accepting. You can change your choice at any time in Settings under "Privacy and ads". Outside these countries the app shows no form; there you control whether Google uses the advertising ID for personalised ads in the Android settings under "Google", "Ads".

USA: If you live in a US state with its own privacy law (for example California), you can ask in Settings under "Privacy and ads" that your data is not "sold" or "shared" for personalised ads. Google then only processes it in a restricted way and shows no personalised ads. We do not sell data for money. Passing the advertising ID to Google for personalised ads may, however, count as "selling" or "sharing" under some US laws.

Do Not Track: Android apps have no Do Not Track signal like a browser; Sortwell therefore does not respond to such signals. As far as your choice allows, Google can collect data about your use of different apps and websites over time through AdMob. We ourselves collect no such data.

Google is an independent controller for the ads. As far as your choice allows, Google receives the advertising ID, the IP address and an approximate location derived from it, device and app details, and data about interactions with the ads.

5. Crash reports (Firebase Crashlytics)

Crash reports are off until you agree: with a checkbox on first start or later in Settings. Then, if the app crashes, it sends a report to Firebase Crashlytics, a Google service. The report contains an installation ID and device and crash data (for example device model, Android version, where the error happened). Google processes this data on our behalf (as a processor) and keeps it for 90 days. You can withdraw your consent at any time in Settings under "Send crash reports".

More: firebase.google.com/support/privacy.

6. Finding faces in photos (Google ML Kit)

To suggest the best photo, the app can use Google's ML Kit library to check whether and where there are faces in a photo and whether the eyes are open. This face check is off until you switch it on: with a separate checkbox at first start (next to crash reports, off by default) or later in Settings with "Face check for the best photo". Without your consent Sortwell does not start ML Kit at all and picks the best photo by sharpness and exposure only.

The check runs entirely on the device with a model built into the app. It does not identify anyone. Photos and face data never leave the device. Sortwell stores the results (eyes open, smiling) on your phone only.

When the face check is on, ML Kit sends diagnostic and usage data to Google. According to Google, this is:

device details: manufacturer, model, Android version and build, available machine-learning hardware;
app details: package name and app version;
a per-installation identifier (not a device ID) that Google uses to count usage;
technical metrics: latency, image format and resolution, input and output size, feature version, event type and error codes.

Google uses this data for diagnostics and usage statistics of ML Kit, transmits it encrypted and, by its own account, does not pass it to third parties. Google processes it for its own purposes and is an independent controller for it; we do not receive this data. While the face check is on, the app cannot switch this transfer off. You can withdraw your consent at any time with the switch in Settings. Sortwell then stops using ML Kit and deletes the stored face values (eyes open, smiling) on your phone. More: developers.google.com/ml-kit/android-data-disclosure.

7. Transfers to the USA

Google LLC is based in the USA. Data that goes to Google (ads, crash reports, diagnostic data) can be processed there. Google LLC is certified under the EU-US Data Privacy Framework and the Swiss-US Data Privacy Framework, and also under the UK Extension, on which transfers from the United Kingdom are based.

If you live outside Switzerland, the EU and the USA, for example in Japan, Singapore or Brazil, this data also goes to Google in the USA. Google bases such transfers on the safeguards it describes at policies.google.com/privacy/frameworks, for example standard contractual clauses.

For transfers from Singapore, we make sure under the PDPA that recipients are bound by legally enforceable obligations, in particular the contracts and standard contractual clauses named above, to give a standard of protection comparable to the PDPA.

8. Website and email

The website www.tahirolabs.com and emails to us are covered by the general TahiroLabs privacy policy.

9. Legal bases

Ads with access to your device (advertising ID) and personalised ads: your consent (Art. 6(1)(a) GDPR; for device access together with the national rules on terminal equipment, such as Section 25 TDDDG in Germany).
Limited ads without your consent to device access: legitimate interest in funding the free trial (Art. 6(1)(f) GDPR). Where Google uses cookies or local storage for them, it does so, according to Google, only to detect fraud and invalid traffic.
Subscription: contract with you (Art. 6(1)(b) GDPR).
Crash reports: consent (Art. 6(1)(a) GDPR).
ML Kit diagnostic data: your consent (Art. 6(1)(a) GDPR; for the access to the device together with Art. 5(3) ePrivacy Directive, for example Section 25 TDDDG in Germany and Section 165(3) TKG 2021 in Austria).

In the United Kingdom the corresponding provisions of the UK GDPR apply and, for access to the device, Regulation 6 of the Privacy and Electronic Communications Regulations (PECR).

10. How long data is kept

On the phone: until you delete the app or clear its data. Android removes moved files from the trash after 30 days.
Crash reports at Google: Firebase Crashlytics keeps crash reports and the related identifiers for 90 days. After that, Google starts removing them from live and backup systems; this can take some further time.
Ad data at Google: Google anonymises advertising data in its server logs by removing part of the IP address after 9 months and certain cookie information after 18 months. For other ad data and identifiers, the periods in Google's policy apply: policies.google.com/technologies/retention.
ML Kit diagnostic data at Google: Google states no fixed period. Google keeps it as long as it needs it for diagnostics and usage statistics, under the rules at policies.google.com/technologies/retention.

11. Your rights

Where the applicable law provides for it, you have the right to:

access your data;
have incorrect data corrected;
erasure;
restriction of processing;
data portability, that is, receive your data in a common format where we process it automatically based on your consent or a contract;
object to processing based on legitimate interest;
withdraw consent, effective for the future.

Write to us at the email address below. You can delete the data on your phone yourself by clearing the app's data or deleting the app. For crash reports at Firebase we arrange deletion. For data Google is itself responsible for (ads, ML Kit) you can also exercise your rights directly with Google: policies.google.com/privacy.

If you live in another country, you also have the rights under that country's data protection law, for example under Brazil's data protection law (LGPD).

You can complain to a supervisory authority: in Switzerland to the Federal Data Protection and Information Commissioner (FDPIC), in the EU to the supervisory authority of your place of residence, in other countries to the data protection authority there, in Brazil to the ANPD.

If you live in the United Kingdom, the UK GDPR also applies. You can complain to us first (kontakt@tahirolabs.com). We acknowledge your complaint within 30 days, look into it and tell you the outcome without undue delay. You can also complain to the Information Commissioner's Office (ICO): ico.org.uk.

If you live in Singapore, the Personal Data Protection Act 2012 (PDPA) also applies. You can ask for access to the personal data we hold about you and to information about how we used or disclosed it in the past year, and you can ask us to correct it. You can withdraw your consent at any time; we will tell you what that means for your use of the app. We reply within 30 days, or tell you within that time when we will be able to reply. You can complain to the Personal Data Protection Commission (PDPC, pdpc.gov.sg).

12. Contact

For all privacy questions, also as the contact point under Brazil's LGPD (Encarregado): kontakt@tahirolabs.com

Data Protection Officer under Singapore's PDPA: Mirza Tahirovic, kontakt@tahirolabs.com

13. Changes to this policy

If we change this policy, we publish the new version on this page and update the "Last updated" date. We also point out material changes at the top of this page for at least 30 days. If a change needs your consent, we ask you again in the app.