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Privacy Policy

Last updated: 9/8/2025

Privacy Policy for Moments

This Privacy Policy describes the privacy practices of 1v9 Holding AB ("Company," "we," "us," or "our"), a company located in Sweden, governing how we collect, use, and protect the personal information of individuals who use our Moments mobile application and related services ("Services").

By using any of the Services, you agree to the collection, use, storage, processing, disclosure and cross-border transfer of your information as described in this Privacy Policy. If you do not agree to this Privacy Policy, please do not use or access the Services.

1. How We Process Your Personal Information

We collect information about you from a variety of sources, and the type of information we collect depends on how you interact with our Services. This section provides information on the types of information we collect from you and why.

Personal Information You Provide to Us

Personal InformationPurposeLegal Basis
Email AddressAccount creation, authentication, and service communicationsNecessary to perform our contract with you to provide the Services
Photos and ImagesGenerate personalized soundtracks and music based on your contentNecessary to perform our contract with you to provide the Services
User-Generated ContentCreated soundtracks, saved moments, and any content you create through our ServicesNecessary to perform our contract with you to provide the Services
Feedback and CorrespondenceCustomer support, product improvements, and responding to your requestsNecessary to perform our contract with you. Legitimate interest to improve the Services

Personal Information We Automatically Collect

Information TypePurposeLegal Basis
Usage InformationHow you use and interact with our Services, troubleshooting, testing, security, and personalizationNecessary to perform our contract. Legitimate interest to improve our Services
Device DataOperating system, device type, browser information, screen resolution, language settings, network informationNecessary to perform our contract. Legitimate interest to improve and secure our Services
Location DataIP address and approximate location (city, state, geographic area)Necessary to perform our contract. Consent where required
Online Activity DataPages viewed, time spent, navigation patterns, access timesLegitimate interest to improve Services. Consent where required

2. How We Use Tracking Technologies

We use cookies, local storage technologies, and similar tracking technologies to:

  • Remember your preferences and settings
  • Understand how you interact with our Services
  • Improve performance and functionality
  • Provide analytics and insights

3. How We Disclose Your Personal Information

We may disclose your information to the following categories of third parties:

  • Service Providers: Third-party companies that provide services on our behalf, including cloud storage, analytics, content moderation, fraud detection, payment processing, and customer support
  • Business Transfers: In connection with business transactions such as mergers, acquisitions, or asset sales
  • Legal Compliance: To comply with applicable laws, court orders, law enforcement requests, or to protect our rights and safety

Where we allow third parties to collect and use personal information, we use reasonable measures to ensure such third parties provide the same or equal protection of user data as stated in this policy.

4. Third-Party AI Services

Our Services utilize third-party artificial intelligence providers for image analysis and music generation. These providers process your photos solely to generate personalized soundtracks and do not retain your content beyond what is necessary to provide the service.

5. Privacy of Individuals Under 18

Our Services are not intended for individuals under 18 years of age. We do not knowingly collect personal information from individuals under 18. If we learn that we have collected such information without proper consent, we will delete it. Where the age of legal consent is higher than 18 in your jurisdiction, you must obtain parent or guardian consent.

6. International Data Transfers

As we use international service providers, your data may be processed outside of Sweden. We ensure that all third-party providers maintain adequate data protection standards and comply with applicable data protection laws.

7. Data Retention

We retain your personal information only as long as reasonably necessary to fulfill the purposes for which it was collected, in accordance with our retention policies and applicable laws, or until you withdraw consent where applicable.

To determine appropriate retention periods, we consider:

  • The amount, nature, and sensitivity of personal information
  • Potential risks from unauthorized use or disclosure
  • Purposes for which we use the information
  • Applicable legal requirements

8. Security Practices

We implement reasonable organizational, technical, and administrative measures to protect against unauthorized access, misuse, loss, disclosure, alteration, and destruction of personal information. However, no data transmission over the Internet can be guaranteed as completely secure.

9. Your Rights and Choices

Depending on your location, you may have rights including:

  • Right to be informed about how we collect and use your personal information
  • Right to access a copy of personal information we have collected about you
  • Right to correction of inaccurate or outdated personal information
  • Right to deletion of personal information we maintain about you
  • Right to restrict processing in certain circumstances
  • Right to data portability where applicable
  • Right to object to our processing of your personal information
  • Right to withdraw consent where processing is based on consent
  • Right to lodge a complaint with relevant supervisory authorities

Data Control and Deletion

You have complete control over your data:

  • Complete Data Deletion: Delete all data through the app's settings menu
  • Individual Content Management: Delete specific songs and moments
  • Data Export: Download your created content
  • Account Deletion: Remove your entire account and all associated data

When you delete data, it is permanently removed from our systems and cannot be recovered.

10. Contact Us

If you have questions about this Privacy Policy or would like to exercise your rights regarding your personal information, please contact us:

Company: 1v9 Holding AB

Location: Sweden

Email: edwin@turbolabs.so

11. Changes to This Policy

We may update this Privacy Policy periodically. Material changes will be communicated through the app or via email. Continued use after changes constitutes acceptance of the updated policy.