Last updated: 1 October 2026
The short version
- Your menu photos are stored privately in your account and are only shown to you. To read a menu, we send the photo to Google's Gemini AI service.
- Order notes you type or dictate may also be sent to Gemini so they can be translated for the restaurant. Voice dictation is handled by your browser or device, not by us.
- Payments go through PayPal. We never see or store your card details.
- Waiter links show an order's dishes, notes and total to anyone who has the link, but never your name or contact details. You decide whether to share one.
- You can delete any menu, or your whole account, at any time from your Profile. We keep only the purchase records the law requires us to keep.
- We do not sell your personal information.
1. About this policy
This Privacy Policy explains how XTO Pty. Ltd. ("we", "us", "our") handles personal information when you use swap.menu at swap.menu (the "Service"). We are an Australian company and we handle personal information in accordance with the Privacy Act 1988 (Cth) and the Australian Privacy Principles (APPs).
"Personal information" means information or an opinion about an identified individual, or an individual who is reasonably identifiable. This policy should be read together with our Terms of Service.
If you have any questions about this policy or how we handle your information, contact us at support@swap.menu.
2. The information we collect
We only collect information that we need to run the Service, keep it secure and improve it. Most of it comes directly from you.
2.1 Account information
When you create an account, or later update your profile, we collect:
- your first name, and your last name if you choose to give it;
- your email address;
- your password. We never store your password itself. We store only a salted, one-way hash of it (using PBKDF2), which cannot practically be turned back into your password;
- optional details you choose to add, such as your phone number and country;
- your preferences, such as your preferred translation language, your home currency and whether you want to receive marketing emails;
- the times you sign in.
2.2 Security information
When you register or sign in, we record your IP address and your browser's user agent (a short string describing your browser and device). We use this for security, for example to detect and rate-limit repeated failed sign-in attempts and to investigate suspicious activity on an account.
2.3 Menu photos and what we read from them
When you photograph or upload a restaurant menu, the photo is uploaded to our servers and stored privately in your account. Menu photos are not publicly accessible and are only served to you when you are signed in to the account that uploaded them.
We then use AI to read the menu (see section 4). The result, including translated dish names, descriptions, prices, the detected currency and any dietary hints, is saved with the menu in your account.
Menu photos are not meant to contain personal information, so please try to keep people and other personal details out of the frame.
2.4 Orders and order notes
When you build an order, we store the dishes and quantities you choose, any notes you add, the table number if you enter one, and the order's status. If you type or dictate a note, it may be sent to our AI provider to be translated into the restaurant's language (see section 4).
2.5 Usage records
Each time you scan a menu, we record that a scan took place, when it happened and whether it succeeded or failed. We use these records to manage your free scan allowance and the fair-use limit that applies to travel passes, and to spot technical problems.
2.6 Payment information
Travel passes are paid for through PayPal. We never receive your card number or bank details. From PayPal we receive the payer's name and email address, transaction and capture identifiers, and the amount and currency paid (see section 6).
2.7 Website activity and analytics
We run our own first-party analytics to understand how people use the site. It records things like the pages you view, how long you spend on a page, how far you scroll, and key steps such as playing the demo or viewing the pricing page. It also records how you arrived at the site, such as the referring website, campaign (UTM) tags and any advertising click identifier in the link you followed. It does not record your keystrokes or the contents of any forms. See section 8 for more detail, including Google Analytics and Google Ads.
2.8 When you contact us
If you email us, we keep the correspondence and any details you choose to include so that we can respond and keep a record of the request.
3. How we use your information
We use personal information to:
- create and manage your account and sign you in securely;
- read, translate and save the menus you scan, and build and translate your orders;
- convert menu prices into your home currency;
- track your free scans, process travel pass purchases and apply the fair-use limit;
- send you service emails, such as your welcome email, purchase receipts and password reset links;
- send you a small number of tips and follow-up emails after you sign up, which you can opt out of at any time (see section 7);
- protect the Service and our users, including preventing abuse, automated scanning and unauthorised access;
- understand how the site is used so we can fix problems and improve it;
- respond to your questions, requests and complaints; and
- meet our legal obligations, including tax and accounting record-keeping.
We do not sell your personal information, and we do not use your menu photos or notes for any purpose other than providing the Service to you.
4. How menu reading and translation works
swap.menu uses Google's Gemini API, a service provided by Google LLC, to read menus and translate text.
- Menu photos. When you scan a menu, we send the photo to the Gemini API solely so it can read the menu and return the dish names, descriptions, prices, currency and dietary hints in your chosen language.
- Order notes. When you ask us to translate an order note, the text of the note may be sent to the Gemini API so it can be translated into the restaurant's language.
Google runs this service on its global infrastructure, which includes the United States, so this information may be processed outside Australia (see section 10). Google's handling of data submitted through its API is governed by Google's own terms and privacy policy.
Voice dictation. If you dictate a note instead of typing it, the speech recognition is performed by your web browser or operating system (for example, Google or Apple, depending on your device), not by us. Their privacy policies apply to that processing. We receive only the resulting text, not the audio.
5. Waiter links
Every order has its own waiter link (a web address in the form swap.menu/o/<code>) and matching QR code. The code is long and random so that it cannot practically be guessed.
Anyone who has the link or scans the QR code can view that order's dishes, notes and total. The waiter link does not show your name, email address or any other account details.
You choose whether to share a waiter link, and with whom. Because the link works for anyone who has it, please only share it with the people you want to see the order, and avoid putting personal or sensitive information in order notes.
6. Payments
Payments are processed by PayPal (including PayPal Australia and its parent, PayPal Holdings). When you buy a travel pass you complete the payment with PayPal, and PayPal's own privacy policy applies to the information you give them.
We never receive or store your card number or bank details, and passes do not automatically renew. From PayPal we receive the payer's name and email address, transaction and capture identifiers, and the amount and currency of the payment. We use this to activate your pass, send your receipt, handle refunds and keep the financial records we are required to keep.
7. Emails
We send emails through our email service provider (an SMTP relay). We send:
- Service emails: a welcome email when you sign up, receipts when you buy a pass, and password reset links when you ask for one. These are part of the Service and are sent regardless of your marketing preference.
- Tips and follow-up emails: up to three emails over about the first week after you sign up, with tips on getting the most out of swap.menu. These are marketing messages. Every one includes an unsubscribe link, and you can also turn them off at any time by unticking the marketing option in your Profile.
8. Cookies, local storage and analytics
Cookies and local storage are small pieces of information saved by your browser. We use a small number of them, as set out below.
| Name | Type | Purpose | How long it lasts |
|---|---|---|---|
| sm_auth | Cookie (HttpOnly, signed) | Keeps you signed in to your account. | About 180 days, or until you sign out |
| sm_guest | Cookie (HttpOnly) | A random, anonymous identifier that recognises your browser as a returning visitor. | About 1 year |
| sm-theme | Local storage | Remembers whether you prefer the light or dark theme. | Until you clear it |
| sm_sk | Local storage | First-party analytics session key, used to group the pages viewed in one visit. | For the current session |
| sm_vk | Local storage | First-party analytics visitor key, used to recognise repeat visits. | About 1 year |
"HttpOnly" means the cookie cannot be read by scripts running in the page, which helps protect it from being stolen.
First-party analytics. Our own analytics records the activity described in section 2.7. It is linked to the random identifiers above rather than to your name, although activity that takes place while you are signed in may be associated with your account. We use it to understand which parts of the site are useful and where people run into trouble.
Google Analytics and Google Ads. We may use Google Analytics and Google Ads tags to measure site traffic and the effectiveness of our advertising. Where these are enabled, Google sets its own cookies (for example, cookies beginning with _ga or _gcl) and collects information about your visit under Google's privacy policy. This information may be processed outside Australia. You can limit this by blocking third-party tracking in your browser or by using Google's opt-out tools.
Your choices. You can delete or block cookies and local storage in your browser settings. If you block the sm_auth cookie you will not be able to stay signed in.
9. Who we share information with
We share personal information only with the service providers who help us run swap.menu, and only as much as they need to do their job:
| Provider | What they do | What they receive |
|---|---|---|
| Google LLC (Gemini API) | Reads menu photos and translates text | Menu photos; the text of order notes you ask us to translate |
| PayPal | Processes travel pass payments and refunds | Payment details you give PayPal directly; the pass you are buying and its price |
| Our email service provider | Delivers our emails | Your name, email address and the content of the email |
| Google (Analytics and Ads), if enabled | Website traffic and advertising measurement | Information collected by Google's tags and cookies about your visit |
We get exchange rates from a third-party rate feed (open.er-api.com). This is a one-way request for published currency rates and no personal information is sent to it.
We may also disclose personal information if we are required or authorised to do so by law (for example, in response to a valid court order or a request from a law enforcement agency), or where it is reasonably necessary to protect the rights, property or safety of our users, the public or us.
If our business, or part of it, is sold or restructured, personal information may be transferred to the new owner, who must handle it consistently with this policy.
10. Overseas disclosure
Some of our service providers may store or process personal information outside Australia. In particular:
- Google (the Gemini API, and Google Analytics and Google Ads if enabled) operates global infrastructure and may process information in the United States and other countries;
- PayPal may process payment information in the United States and other countries where it operates.
We take reasonable steps, as required by APP 8, to ensure that these providers handle your information in a way that is consistent with the Australian Privacy Principles, including by using established providers that publish their own privacy and data-protection commitments.
11. How we keep your information secure
We take reasonable steps to protect personal information from misuse, interference, loss and unauthorised access, change or disclosure. These include:
- storing passwords only as salted PBKDF2 hashes;
- keeping menu photos in private storage that is served only to the account owner;
- using signed, HttpOnly sign-in cookies;
- making waiter links long and random so they cannot practically be guessed;
- rate-limiting failed sign-in attempts and monitoring for abuse; and
- limiting what we send to service providers to what they need.
No system is perfectly secure. Please use a strong password that you don't use anywhere else, and contact us straight away at support@swap.menu if you think your account has been compromised. If a data breach is likely to result in serious harm to you, we will notify you and the Office of the Australian Information Commissioner as required by the Notifiable Data Breaches scheme.
12. How long we keep your information
- Account information is kept while your account is open.
- Menus stay in your account until you delete them. When you delete a menu, its photos are deleted from our storage.
- Failed or abandoned scans. Photos from scans that fail or are not completed may be kept for a limited period so we can troubleshoot problems, and are then deleted.
- Deleting your account. You can delete your account at any time from Profile → Delete account. This deletes your menus, photos and orders, and removes your personal details from your account record.
- Purchase records. Records of purchases and payment transactions are kept for as long as Australian tax and accounting law requires (typically five to seven years). After your account is deleted, these records are kept in de-identified form, linked only to the closed account.
Once deleted information has been removed from our live systems, it may take a short time to be cleared from any routine backups.
13. Accessing, correcting and deleting your information
You can see and update most of your account information yourself in your Profile, including your name, contact details, language, home currency and marketing preference. You can delete individual menus in the app, and delete your whole account from Profile → Delete account.
You can also ask us to:
- give you access to the personal information we hold about you;
- correct information that is inaccurate, out of date, incomplete or misleading; or
- delete your information.
Email your request to support@swap.menu. We may need to confirm your identity before acting on it. We will respond within a reasonable time, usually within 30 days, and we won't charge you for making a request. If we can't do what you ask (for example, because the law requires us to keep certain records), we will tell you why in writing and explain how you can complain.
14. Visitors from the European Union and the United Kingdom
If you are in the European Union or the United Kingdom, you may have additional rights under the GDPR or the UK GDPR, including the right to access, correct or delete your personal information, to object to or restrict certain processing, and to receive a copy of your information in a portable format. Where we rely on your consent (for example, for marketing emails), you can withdraw it at any time.
We process your information to provide the Service you have asked for (performance of a contract), for our legitimate interests in keeping the Service secure and improving it, to comply with legal obligations, and, where relevant, with your consent.
To exercise any of these rights, email support@swap.menu. You also have the right to complain to your local data protection authority.
15. Children
swap.menu is not directed at children under 16, and you must be at least 16 to create an account. We do not knowingly collect personal information from children under 16. If you believe a child under 16 has given us personal information, please contact us and we will delete it.
16. Anonymity and pseudonyms
You can browse the public parts of the site without telling us who you are. To scan menus and save orders you need an account with a working email address, but you are welcome to use a nickname as your first name and to leave your last name blank.
17. Changes to this policy
We may update this policy from time to time, for example when we add features or change service providers. We will post the updated policy on this page and change the "Last updated" date at the top. If a change materially affects how we handle your personal information, we will let you know on the site and, where appropriate, by email.
18. Complaints
If you have a concern or complaint about how we have handled your personal information, please contact us first at support@swap.menu with details of the issue. We will acknowledge your complaint, look into it and respond, usually within 30 days.
If you are not satisfied with our response, you can complain to the Office of the Australian Information Commissioner (OAIC) at www.oaic.gov.au.
19. Contact us
XTO Pty. Ltd.
Email: support@swap.menu
Our postal address is available on request from support@swap.menu.
You can also find help on our Support page.