ALMA SOCIAL PRIVACY POLICY
1. INTRODUCTION
This Privacy Policy describes how Alma Social, an association registered in Lugano, Switzerland ("Association", "we", "us", or "our") collects, uses, processes, and protects your personal data when you use the Alma Social mobile application ("App") and associated services. We are committed to protecting your privacy in accordance with the Swiss Federal Act on Data Protection ("FADP"), the General Data Protection Regulation ("GDPR"), and applicable international regulations.
2. DATA CONTROLLER INFORMATION
Legal Entity: Alma Social
Address: c/o Studio Legale Velo SA, Via della Posta 2, 6900 Lugano, Switzerland
Email: app@almasocial.ch
3. INFORMATION WE COLLECT
We collect the minimum amount of data necessary to provide our invite-only social networking service.
3.1. Information You Provide to Us
• Account Data: Full name, username, email address, password (encrypted), profile biography, professional title, and profile photograph.
• Authentication Data: Phone number used for Multi-Factor Authentication (MFA) or OTP login.
• User Generated Content (UGC): Photos, videos, text posts, comments, and messages you engage with on the platform.
• Invite Data: Information about the people you invite to the platform (email or phone number), stored only for the purpose of sending the invitation.
3.2. Information We Collect Automatically
• Social Graph: We analyze your interactions (likes, follows, replies) and your invite chain (who invited you / who you invited) to build a relevance model for your feed.
• Device & Usage Data: IP address, device model (e.g., iPhone 15), operating system version, carrier, unique device identifiers (IDFA/AAID), and crash logs.
• Location Data: General location based on IP address. Precise GPS location is only collected if you explicitly grant permission for specific features (e.g., "Find Users Near Me").
4. HOW WE USE YOUR INFORMATION
• Service Delivery: To create your account, verify your identity via SMS, and display the personalized feed.
• AI & Orchestration: To power our AI agents that detect spam, moderate content, and recommend relevant communities.
• Safety & Security: To detect bot activity, fraud, and enforce our Community Guidelines.
• Communications: To send you service updates, security alerts, and invitations.
5. SMS & MESSAGING COMPLIANCE (10DLC & CARRIER REGULATIONS)
This section is legally binding for US/Global SMS delivery.
• Consent: By providing your phone number, you consent to receive SMS messages from Alma Social strictly for authentication (OTP) and security notifications.
• No Marketing Sharing: No mobile information will be shared with third parties or affiliates for marketing or promotional purposes. All other categories exclude text messaging originator opt-in data and consent; this information will not be shared with any third parties.
• Opt-Out: You may opt-out of receiving SMS messages at any time by replying "STOP". Note that opting out may restrict your access to the platform if 2FA is required.
6. DATA SHARING AND AI PROCESSORS
We do not sell your personal data. We share data only in the following limited circumstances:
• AI Model Providers: We utilize third-party Large Language Models (LLMs) (e.g., OpenAI, Anthropic) for content moderation and feed ranking. Zero Training Policy: We have strict agreements ensuring that your personal social data is NOT used to train their foundation models.
• Cloud Infrastructure: Your data is securely hosted on AWS/Google Cloud servers which comply with ISO 27001 standards.
• Legal Compliance: We may disclose data if required by law, subpoena, or valid court order from Swiss or international courts.
7. YOUR RIGHTS
Under GDPR and FADP, you have the right to:
• Access: Request a copy of the data we hold about you.
• Rectification: Correct inaccurate data.
• Deletion (Right to be Forgotten): Request permanent deletion of your account and data. You can initiate this directly within the App Settings > Account > Delete Account.
• Portability: Receive your data in a structured, machine-readable format.
TERMS OF SERVICE AND END USER LICENSE AGREEMENT
1. ACCEPTANCE OF TERMS
These Terms of Service ("Terms") constitute a legally binding agreement between you ("User") and Alma Social, an association registered in Lugano, Switzerland ("Association"). By creating an account or accessing Alma Social, you agree to these Terms.
2. THE "INVITE-ONLY" ACCESS LICENSE
• Revocable Privilege: Access to Alma Social is a privilege, not a right. It is granted via invitation only.
• Right to Terminate: The Association reserves the right to revoke your access, disable your invite code, or ban your account at its sole discretion, with or without cause, and without notice, subject to applicable Swiss consumer protection laws.
• Reputation System: You acknowledge that you bear responsibility for the users you invite. If your invitees violate these Terms (e.g., spamming, harassment), the Association may revoke your ability to invite others or suspend your account ("Chain Responsibility").
3. USER-GENERATED CONTENT AND COMMUNITY STANDARDS
3.1 Community Standards
Users agree not to post, upload, transmit, or otherwise make available any content that is objectionable, abusive, harassing, unlawful, or otherwise inconsistent with these Terms. Alma Social reserves the right to determine violations in its sole discretion. Violations may result in content removal, account suspension, or termination.
3.2 Prohibited Content
Users shall not post content that is:
• Hateful or discriminatory based on protected characteristics
• Violent, threatening, or promoting self-harm
• Sexual, pornographic, or exploitative
• Harassing, stalking, or involving doxxing or impersonation
• Illegal or infringing upon intellectual property rights
• Spam, deceptive, fraudulent, or misleading
3.3 Prohibited Conduct
Users shall not:
• Harass, threaten, or abuse other users
• Create fake accounts or impersonate others
• Use bots or automated systems to manipulate the platform
• Share private information without consent
• Interfere with the security or functionality of the App
• Scrape or use automated bots, spiders, or scrapers to access or extract data from the App
• Attempt to artificially inflate engagement (likes, follows) or game the recommendation algorithms
3.4 Reporting, Blocking, and Enforcement
Users may report content or accounts using in-app reporting tools or by contacting app@almasocial.ch. Users may block other users through in-app functionality.
Alma Social may use automated systems and human moderation to detect and remove violations. We aim to review reports within 24 hours, though response times may vary. Users posting objectionable content (hate speech, nudity, harassment) will be removed from the service.
Enforcement actions may include content removal, suspension, or termination. Unlawful activity may be reported to appropriate authorities where required. Users may request review of enforcement decisions at Alma Social's discretion.
3.5 Moderation Rights
Alma Social reserves the right to:
• Monitor, review, and moderate user-generated content
• Remove content without prior notice if it violates these Terms
• Suspend or terminate accounts for violations
• Preserve content or account information for legal compliance purposes
3.6 User Representations and License Grant
By posting content, users represent that they own or have the necessary rights to such content and that it complies with applicable laws. Users grant Alma Social a non-exclusive, worldwide, royalty-free license to use, reproduce, display, distribute, and otherwise make available such content for purposes of operating, maintaining, and improving the App.
3.7 Age Requirements and Disclaimer
The App is intended for users eighteen (18) years of age or older unless verifiable parental consent is provided where legally required. The App provides peer mentorship and community engagement only and does not constitute legal, medical, financial, psychological, or professional advice.
3.8 Contact Information
For questions regarding these content policies or to report violations, please contact app@almasocial.ch.
4. INTELLECTUAL PROPERTY RIGHTS
• Your Content: You retain ownership of the content you post. However, you grant the Association a worldwide, royalty-free, perpetual, non-exclusive license to use, display, reproduce, and distribute your content within the Service.
• Association Rights: The "Alma Social" name, logo, and the App's interface, code, and design are the exclusive property of Alma Social.
5. DATA PROTECTION AND PRIVACY
Alma Social is committed to protecting your personal data in accordance with the Swiss Federal Act on Data Protection (FADP) and the EU General Data Protection Regulation (GDPR) where applicable. Please refer to our Privacy Policy for detailed information on how we collect, use, and protect your personal data.
You have the right to access, rectify, delete, and port your personal data, as well as the right to object to processing and lodge a complaint with the Federal Data Protection and Information Commissioner (FDPIC).
6. AI DISCLAIMER
Alma Social uses Artificial Intelligence for content recommendation and moderation. While we strive for accuracy, AI systems may occasionally make errors. The Association is not liable for any content removal or feed ranking decisions made by automated systems, subject to applicable consumer protection laws.
7. DISCLAIMER OF WARRANTIES
THE SERVICE IS PROVIDED "AS IS" AND "AS AVAILABLE". TO THE MAXIMUM EXTENT PERMITTED BY SWISS LAW, THE ASSOCIATION DISCLAIMS ALL WARRANTIES, WHETHER EXPRESS OR IMPLIED, INCLUDING WARRANTIES OF MERCHANTABILITY OR FITNESS FOR A PARTICULAR PURPOSE.
However, nothing in these Terms excludes or limits liability for fraud, fraudulent misrepresentation, or any liability that cannot be excluded or limited under Swiss law.
8. LIMITATION OF LIABILITY
TO THE MAXIMUM EXTENT PERMITTED BY SWISS LAW, IN NO EVENT SHALL ALMA SOCIAL BE LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL OR PUNITIVE DAMAGES, ARISING OUT OF YOUR USE OF THE SERVICE.
This limitation of liability does not apply to liability for intentional acts, gross negligence, or personal injury. The Association's total aggregate liability shall not exceed CHF 100 or the amount you paid to use the Service in the twelve (12) months preceding the claim, whichever is greater.
9. GOVERNING LAW & JURISDICTION
These Terms are governed by and construed in accordance with Swiss law, without regard to conflict of law principles. Any disputes arising from or relating to these Terms or the Service shall be subject to the exclusive jurisdiction of the courts of Lugano, Canton Ticino, Switzerland.
If you are a consumer domiciled in the European Union, you may also bring proceedings in the courts of your place of residence, and you benefit from mandatory provisions of consumer protection laws in your country of residence.
10. END USER LICENSE AGREEMENT (EULA)
10.1 Parties
This Agreement is between you and Alma Social only, and not with Apple, Inc. or Google LLC. Alma Social is solely responsible for the App and its content.
10.2 Scope of License
Alma Social grants you a non-transferable, non-exclusive license to use the App on any Apple/Android-branded products that you own or control, as permitted by the Usage Rules set forth in the App Store Terms of Service.
10.3 Third-Party Terms
You must comply with applicable third-party terms when using the App. Apple and Google have no obligation to furnish any maintenance and support services with respect to the App.
10.4 Third-Party Beneficiary
Apple and its subsidiaries are third-party beneficiaries of this EULA. Upon your acceptance of these Terms, Apple will have the right (and will be deemed to have accepted the right) to enforce this EULA against you as a third-party beneficiary thereof.
11. CHANGES TO TERMS
Alma Social reserves the right to modify these Terms at any time. We will notify users of material changes via email or in-app notification at least 30 days before the changes take effect. Your continued use of the Service after the effective date constitutes acceptance of the modified Terms.
12. SEVERABILITY
If any provision of these Terms is found to be invalid or unenforceable under applicable law, such provision shall be modified to the minimum extent necessary to make it valid and enforceable. If such modification is not possible, the provision shall be severed, and the remaining provisions shall continue in full force and effect.
13. CONTACT INFORMATION
Any questions, complaints, or claims with respect to the App should be directed to:
Alma Social
c/o Studio Legale Velo SA
Via della Posta 2
6900 Lugano
Switzerland
Email: app@almasocial.ch
Last Updated: March 2026