Slowly Terms of Service have major revisions

October 4, 2024

Recently, the Terms of Service have been revised

And as previously, they remain a one sided document intended to solely protect the company and award it any rights they seem fit to claim.

I think it is interesting to read them. It is a long, legalese, mind boggling read, but a careful analysis can give you insights on important points. You can see the current, latest version (revised as of Sept 13, 2024) HERE.

And I did read it briefly, and noticed some worthy points.

Company HQ moved to United Kingdom?

Kevin Wong, Slowly's creator and CEO, has moved to London UK about a year ago. I had not looked at the ToS but now it shows the company no longer being Hong Kong based, but located in the address shown above.

This has good points, there were some concerns from users over Slowly's ability to deny user data access requests in Hong Kong, as Chinese mainland laws clearly state all companies operating in the PRC must comply promptly with any official requests.

So, this is a good thing?

Well, they apparently are no longer under PRC's jurisdiction. BUT their data is stored in Amazon Web Services machines, physically located in the USA, which brings them under a jurisdiction where intelligence agencies DO act to get access to data they feel is needed. Not ideal, clearly, but convenient for Slowly as AWS is a major Cloud provider.

Make the ToS easier to digest, try our AI friends?

I used Microsoft's Copilot, and would encourage you to read the document and even experiment with it. My request:

I use a software called Slowly. Could you review the Terms of Service for it, and give me some notes regarding noticeable impositions it places on its users? The Terms of Service page is at https://slowly.app/terms/

Here is Copilot's response:

Sure, I reviewed the Terms of Service for Slowly. Here are some key points and noticeable impositions:

Eligibility: Users must be at least 12 years old. If you’re a minor, your parent or guardian must agree to the terms on your behalf. ^(1).
Account Restrictions: You can only have one account. If you’ve been previously removed from the service, you cannot create a new account without explicit permission. ^(1).
Content and Conduct: Users must not engage in illegal activities, harassment, or any behavior that could harm others. Violations can lead to account termination without prior notice. ^(1).
Modifications to Terms: Slowly reserves the right to change the terms at any time. Users are responsible for reviewing the terms periodically to stay informed of updates. ^(1).
Termination of Service: Slowly can terminate or suspend your account at their discretion, without liability or prior notice. ^(1).
User Content: By posting content, you grant Slowly a non-exclusive, royalty-free license to use, reproduce, and distribute your content. ^(1).

These points highlight some of the more restrictive aspects of the Terms of Service. If you have any specific concerns or need further clarification, feel free to ask!

Source: Conversation with Copilot, 03/10/2024

(1) Terms of Service – Slowly. https://slowly.app/terms/. (2) Privacy Policy – Slowly. https://slowly.app/privacy/. (3) Slowly's home page. https://slowly.app/.

Any follow-up questions?

is there any mention of their obligation under GDPR user data protection act ?

Yes, the Slowly Terms of Service do mention their obligations under the GDPR (General Data Protection Regulation). Here are some key points related to GDPR compliance:

Data Collection and Use: Slowly outlines the types of personal data they collect and how they use it. This includes information provided by users during registration and data collected through the use of their services. [ 4 ].
User Rights: Users have rights under GDPR, such as the right to access their data, the right to rectify incorrect data, the right to erasure (right to be forgotten), and the right to restrict or object to processing. [ 4 ].
Data Security: Slowly commits to implementing appropriate technical and organizational measures to ensure a level of security appropriate to the risk of processing personal data. [ 4 ].
Data Transfers: If personal data is transferred outside the European Economic Area (EEA), Slowly ensures that appropriate safeguards are in place to protect the data. [ 4 ].
Data Retention: Personal data is retained only for as long as necessary to fulfill the purposes for which it was collected, or as required by law. [ 4 ].

[ 4 ] : The Data Protection Act, at gov.uk

These points highlight Slowly’s commitment to complying with GDPR and protecting user data. If you have specific concerns or need more detailed information, you might want to review their full Terms of Service or contact their support team directly.

Can I request a copy of my user data (letters and responses) for backup under GDPR ?

Yes, under GDPR, you have the right to request a copy of your personal data, which includes your letters and responses on Slowly. This is known as a data subject access request (DSAR). You can contact Slowly’s support team to make this request. They are obligated to provide you with a copy of your data within one month of your request. [ 4 ].

If you need help with how to phrase your request or any other details, feel free to ask!

How to request your user data?

How do I initiate a DSAR on Slowly?

To initiate a Data Subject Access Request (DSAR) on Slowly, follow these steps:

Contact Support: Reach out to Slowly’s support team via their official contact methods. This is usually done through their website or app. Look for a “Contact Us” or “Support” section.
Specify Your Request: Clearly state that you are making a DSAR under GDPR. Mention that you are requesting a copy of your personal data, including your letters and responses.
Provide Necessary Details: Include any relevant information that might help them locate your data, such as your username, email address, and any specific data you are requesting.
Verification: Be prepared to verify your identity. Slowly may ask for additional information to confirm that the request is coming from the account owner.
Wait for Response: Slowly is required to respond to your request within one month. They may extend this period by an additional two months if the request is complex or if they have received numerous requests. [ 5 ].

Here’s a sample template for your request:

Subject: Data Subject Access Request (DSAR)

Dear Slowly Support Team,

I am writing to formally request access to my personal data under the General Data Protection Regulation (GDPR). Specifically, I am requesting a copy of all my letters and responses stored on your platform.

For verification purposes, my account details are as follows:

Username: [Your Username]
Email: [Your Email Address]

Please let me know if you require any further information to process this request. I look forward to your response within the statutory timeframe.

Thank you, [Your Name]

If you need further assistance, feel free to ask!

And there is a LOT more to explore

...in this latest revision of the Terms of Service. I enjoyed using Copilot and getting focused, simple answers to some of my questions. I think there is a lot more to read and investigate so we can better understand the document's meanings and implications.

I will stop here – getting backup copies of our user data was always a concern for me, and it seems there are ways we can act to request that, which Slowly is legally obligated to respond and fulfil.

Any other notable items in the page as you see it? (hint – there are notes regarding AI usage in the app, along with other meaningful paragraphs.

Famous Last Words

Special Thank You to the folks behind this wonderful app — all the hard working people at Slowly Communications.

Letters we share, with pen pals all over the World, via the magic of the Slowly App. A modern day take in the traditional penpal experience.

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