At Twone, we value clarity and openness about how we collect, store, and share your information.

This Privacy Policy applies to the Twone app, websites, events, and any other services, collectively referred to as “Services.” If a service requires its own privacy policy, that policy applies rather than this one.

1. Information We Collect

By using our services, you agree to give us certain information, such as:

• when creating an account, you provide us your name, date of birth, phone number, and email address;
• when completing your profile, you may share your gender identity, pronouns, and photos;
• when you participate in our events, promotions, contests, surveys, or focus groups, we collect the information you provide as well as your responses;
• if you contact our customer support, we receive and collect the information you give us; and
• when you publish content and chat with other members, we process the information as necessary.

You can review this information by logging into your Twone account. It is your responsibility to make sure this information is accurate.

We may collect information about you as provided by other members, as they interact with you or submit a report involving you.

With your consent, we collect your geolocation, such as longitude and latitude. If you wish to turn this off, you can do so by going to your phone’s settings. We also collect your photos with your consent, to be used for your profile.

We strongly encourage you to be mindful of the information you disclose about yourself on your profile and while communicating with other users. We do not recommend sharing personal information such as your address, financial details, IDs, or other sensitive information.

Cookies and similar technology

When you use our app we may collect personal data by using cookies or similar technologies. If you’d like to know more about how we use cookies, please refer to our Cookie Policy.

2. How We Use Information

Your information is mainly used to improve our services and your experience.

In order to do so, we may use your information to:

• offer our services to you;
• provide and contact you about the app, such as updates and new features;
• deliver personalized content and operate advertising and marketing campaigns;
• gather and research analytics about how you interact with the app;
• resolve disputes or problems, and enforce our Terms and Conditions; and
• detect fraud, protect our rights, and ensure legal compliance.

Moderating content

In order to keep our community safe, we may monitor and review profiles such as photos and other uploaded information, published posts, and messages. This is to ensure that content on Twone adheres to our Terms and Conditions. If it is determined that a profile, content, or message has been deemed inappropriate as per our criteria and/or as outlined in our Terms and Conditions, the relevant user (or users) may be given a warning and placed under restrictions and/or blocked from the app. Nevertheless, it is possible that we are not aware of all instances in which content has breached our Terms and Conditions, and for that reason, we ask all users to promptly report such instances so that we can take swift and appropriate measures.

3. How We Share Information

Our main priority is bridging the brief spontaneous connections you make in real life to a more meaningful and momentous connection, and therefore the main way we share your information is with other users. We also share some users’ information with service providers that help us operate and optimize our services, and if needed, with legal authorities.

With other users

Your information is shared with other users when you explicitly choose to publish content or connect with another user. Even though we only facilitate exchanging of information as authorized by you, you should assume that anything you post or publish on the app may be viewed and accessed by other users and non-users, so we want our users to make sure that you only share what you feel comfortable being visible.

With service providers

We use third parties to assist us in operating and optimizing our services, such as hosting data, analytics, customer care, and marketing. In this process, we may share strictly necessary information. We also carry out due diligence to make sure that our service providers have data protection and information security measures, and agree to strict confidentiality obligations.

Corporate transactions

We may transfer your information if we are involved, whether in whole or in part, in a merger, sale, acquisition, divestiture, restructuring, reorganization, dissolution, bankruptcy, or other change of ownership or control.

With law enforcement

We may share your information if necessary to comply with a legal process, assist law enforcement regarding a crime (as applicable by law), or protect the safety of any person.

To enforce legal rights

We may share any information relevant to the purposes of defending legal claims, protecting legal rights, and investigating real or suspected illegal activity.

4. Your Rights

Your information is and should always be in your control, so we would like to remind you of the privacy rights that may be applicable to you depending on your location.

• Access to your information:

You have the right to know what personal data we are collecting and why, as well as the right to access the information that we keep. Further, you can request a copy of your data. All inquiries and requests can be sent to support@twone.app.

• Changes to your information:
  

If the information we have is inaccurate or you would like to request changes regarding its rectification, erasure, object to or restrict its processing, please contact us at support@twone.app.

• You have the right to equal services without discrimination.

For safety and security reasons, we may ask you to verify your proof of identity before we can resolve the above requests. We may also be unable to answer certain requests, of which you will be notified upon request.

California Consumer Privacy Rights

Residents of California have the following rights, in addition to those listed above, under the California Consumer Privacy Act.

1. You have the right to be free from unlawful discrimination for exercising your rights under the Act.
2. You have the right to request the disclosure of certain information that we have collected, as well as how we have collected, used, and shared your personal information over the past 12 months.You have the right to request that we delete the personal information we have collected.

To submit an access or deletion request, contact us at support@twone.app.

5. Policy Regarding Age

We do not permit users under the age of 18 on the Twone app or services. Our services are strictly restricted to individuals above the age of 18.

If you suspect that a user is a minor, or under the age of 18, please report it to us using the report function on the app. Once we become aware of the situation, we will take the necessary steps to terminate that person’s account.

6. How Long We Retain Your Information

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law. When you decide to delete your account, or it is deactivated by us, your account and profile will no longer be visible to other users of the app. Upon deletion, there will be a safety retention window of three months, or one year following an account ban, in the event that it might be necessary to investigate unlawful conduct. The deletion of your personal information will be processed with exceptions as laid out below:

1. Data retention to comply with applicable legal obligations, such as tax and accounting purposes;
2. The information must be kept for legitimate business interests, such as enhancing security (for example, keeping data necessary to prevent members who were banned,) improving quality of service (for example, customer care records,) and enforcing our rights to defend ourselves in the event of a claim; and
3. In the case of an outstanding issue, claim, or dispute, relevant information must be kept until the resolution of the issue, claim, or dispute.

7. Privacy Policy Changes

As we expand and improve the way we foster connections between users, to best provide transparency in explaining our data practices, we may update this Privacy Policy from time to time. We will notify you, via email or by posting a notice within the Twone app, if we make a change to this policy so that you can review the changes.

8. How to Contact Us

If you have any questions about this Privacy Policy, you can contact us at support@twone.app.

Effective Date

Last revised on March 3, 2023