Unless otherwise specified, our Policy applies to all of “Twins”’ mobile software applications that have been made available for download (each, an “App” and together, the “Apps“) and any related websites or other online properties owned or controlled by “Twins” (together with the Apps, the “Services“).
When we say “Twins” (or “we“, “us” and “our“) we’re referring to “Twins”, Inc., including any of its subsidiaries. For the purposes of EU data protection law, “Twins” is a controller of personal data processed in the context of the Services.
1. INFORMATION WE COLLECT AND USE
When we provide the Services, we may collect or receive personal information in a few different ways. In many cases, you can select the information to provide, although certain information is needed in order to use “Twins” and for us to provide the Services to you. We use your information for the purposes described below:
From you and/or from other sources at your direction:
We may collect a variety of information from you when you provide it to us directly or when you tell us to get it from a third party source. The different kinds of information we gather typically depend on how you interact with us. For instance:
- We may collect basic account information such as your email address, phone number, username and password. This information is necessary to create your account and it helps secure and provide access to our Services. We may also obtain or infer demographic information. If you use Facebook or Google to register for or log in to the Services (or later connect your accounts), you authorize Facebook or Google to share your personal information with us, including your email address, age and publicly available information about you and your Facebook friends, if you use Facebook for signup.
- If you access the Services with another third party social network we will collect information you have agreed to make available. This could include for instance, your name, user ID/URL, profile picture, age, list of friends, email address and/or phone number, and/or your birthday, language, and/or geolocation.
- We may collect additional profile information about you when you upload a picture, or add your interests for example.
- We may gather information from the actions you take to recommend, create, communicate and share content. This includes messages you send, videos or content you create, information about the content you create yourself and the content you post. In addition, we track social interactions in our Apps which might include things you like, follow, etc.
- If you send us support requests or feedback, you may provide us with additional information to enable us to contact you and address your feedback and we may retain such information to enhance our Services and to respond to you.
- Message boards or forums or groups may be available to you through the Services. Please remember that any information you post (including in these areas) may become public information and may be removed or addressed if in violation of our Terms of Service. We use publicly available information to help provide our Services. Please be aware that if you post personal information online that is accessible to the public, you may receive unsolicited responses. You should exercise caution when deciding to disclose any of your personal information in a public forum, including within our applications, as it may be misused or abused by third parties.
- When you purchase a subscription, you provide our payment processor with your payment information.
- We don’t ask you to provide us with any sensitive personal information, which could include any information relating to your race or ethnic origin, political opinions, religious or philosophical beliefs, membership of a trade union, physical or mental health, genetic or biometric information, sexual life or sexual orientation. If you decide to share this type of information on “Twins” Services, you explicitly consent to us displaying it or sharing it in accordance with your selection.
From your device and browser:
In order to provide us with technical information, we may collect information from your browser, computer, or mobile device when you use the Services, including:
- If you choose to share content or find your friends on “Twins”, we will access your contacts on your device (including contact information your service provider(s) or app automatically added to your address book when you communicated with addresses or numbers not already in your list) and send your contacts to our servers to check if any of them are on the Services or the App you are using. If they are, we’ll suggest your follow them and you can choose if you would like to do so. Every time you open the contacts page in a “Twins” App, we may automatically resend the latest version of your contacts to our servers and provide you with an updated list of matches. After we check for matches we will We delete your contacts from our servers.
- When you use the Services, we may automatically collect log data, including your IP address, browser type, hardware type, unique device ID, the version of your operating system and your activity within the Services. We use the log data for security purposes and to improve our Services.
- We receive device identifiers like Apple’s IDFA, IDFV and Google’s AdID. These are mainly used for online advertising and marketing purposes.
- We may access Geolocation information from your mobile device which helps us share where you are in the world, provide locations to your posts and content, and display local activities and content based on your current location. It is also used to aid us in sending you relevant messages based on where you live. You are able to control the collection of geo-location information through your device.
As with any business, we may change or work with different partners from time to time. We may provide a list of partners in this Policy or in another document which we will make available to you.
2. HOW WE USE YOUR INFORMATION
We use the information we have to help us provide, operate, enhance, customize, support, and market our Services.
- In order to register for a “Twins” account, we need certain information. We may use your email address and/or phone number to send you information about the Services, provide customer support or to notify you of additional “Twins” products and services, where permitted by applicable law. In cases described above, you may use your account settings to unsubscribe from notifications from “Twins”.
- We may use information from one “Twins” App to improve your experience in other Apps as we may integrate our Services.
- We collect information to learn about your use of the Service and to enhance your experience when using the Services, such as interaction with other users and notifications, chat, or messaging functionality, public boards, competition and other similar features. We make an effort to show you social content that we think will be of interest to you.
- We try to continuously improve our Services and your experience. As part of this, we use the data we have to identify ways to make our Services better and more engaging for our users. We use your interactions on the Services, along with the other data described in this policy, to infer your interests. We do this to identify and suggest content that you may like and to tailor advertising, including off-site advertising.
- We use data to identify and respond to potential risks to our users and Services which might include spammers, phishing attempts, screen scraping, bullying and other violations of our Terms of Service).
- In limited situations, we may share de-identified content and information with researchers for educational research purposes.
- We promote our Services via customized advertising on third party sites. We may use your information to target advertising; including to design advertising campaigns. You use your information for customer relationship management (CRM) purposes, including for targeting email and other engagement campaigns.
- We may conduct or sponsor surveys and contests. Participation in surveys and contests is completely voluntary. If you elect to participate, we may ask you for contact, demographic, and other information and may ask you to agree to additional terms and conditions.
- We use log data, such as device identifiers, to recognize you and / or your devices across “Twins” applications. We do so to provide you with seamless access to another “Twins” application by identifying you and making your content available on both applications.
3. INFORMATION YOU AND WE SHARE
“Twins” is designed to help you create and share your videos or any posts. The information you provide us through your use of the Services is information you have consented to allow us to make public. You share your information as you use and communicate through our Services, and we share your information to help us operate, provide, improve, understand, customize, support, and market our Services.
- Account Information. Your phone number, profile name and photo, bio, status may be available to anyone who uses our Services, although you may be able to configure your settings to manage whether certain information is available to other users and businesses with whom you communicate.
- Your Content. Your content is published in accordance with your privacy settings. Content is public by default. If you comment on any content on the Services, your comments may be public and available to other users of the Services. In certain cases, you may choose to create recordings with other “Twins” users. In such cases, it is important to remember that you create the content together with another user or group of users as a collective. As an individual user within the collective, it is difficult if not impossible to undo the creation. So, if you create a collaboration with another “Twins” user, you won’t be able to change or delete that collaborative work. In addition, in such cases, other users will be able to record and share that content.
- Your Contacts and Others. Users and businesses with whom you communicate may store or re-share your information (including your messages) with others on and off our Services.
- We may share information about you or your use of the Services with our advertisers and third party advertising partners. This means we may give our advertisers information about the characteristics of our users, along with sharing certain identifiers and/or location information, but we do not specifically identify you by name or share your contact information. Third parties can use this data to deliver targeted advertisements that they believe will be of most interest to you or to assess the effectiveness and reach of advertising campaigns.
- We work with Google Analytics which collects information such as how often users visit our website, what pages they visit when they do so, and what other sites they used prior to coming to the website. You may opt-out of Google Analytics tracking with the Google Analytics opt-out browser add-on.
- Third-Party Service Providers. We work with third-party service providers to help us provide, enhance, understand, customize, support, and market our Services.
- Any information in your public profile which may include your username and any profile image, location or additional information that you provide as part of your Public Profile, including but not limited to your phone number, or email address) may will be accessible by other users of the Services. Content that you create through or upload to the Services will by default be public and available to users of the Services.
- We may publicly disclose aggregated statistics which may vary depending on the “Twins” you are using.
- We may use any recording, video and/or other content you create in the Services in order to promote “Twins” or our Services.
- We may share some or all of your information in connection with, or during negotiation of, any merger, financing, acquisition or dissolution, transaction or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets. In the event of an insolvency, bankruptcy, or receivership, information may also be transferred as a business asset.
4. OUR LEGAL BASES FOR COLLECTING, USING, SHARING AND OTHERWISE PROCESSING YOUR INFORMATION
For the purposes of EU law, “Twins” relies on a number of legal bases to collect, use, share, and otherwise process the information we have about you for the purposes described in this Policy. These legal bases include:
- Certain processing is needed to provide the Services in accordance with the Terms of Service. For example, we need to disseminate your content to provide our Service. We need basic contact information in order to register you for a “Twins” account and to share content on “Twins”, which is part of our Service;
- Where you have consented to certain processing. For example we may send you marketing messages if you have consented to receiving them, or we may ask you if you want to take part in voluntary surveys or contests. You may revoke that consent at any time;
- For “Twins” to comply with a legal obligation, a court order, or to exercise and defend legal claims, to protect your vital interests or those of others, or where the processing is necessary in the public interest. We may, for instance, share data where we are required by law to do so; and
- Some processing is necessary because it is in “Twins”’ or a third party’s legitimate interests.
- Our legitimate interests
We process your information in furtherance of the following legitimate interests:
- Keeping the Services safe and secure: We use your information in an effort to keep our Services safe and secure. We do so as it is necessary to pursue our legitimate interests, the interests of our community and yours, in ensuring “Twins” is secure, and to protect against fraud, spam, misuse and abuse.
- Providing our Services: We use your information to provide the Services, including any personalized services. We do so as it is necessary to pursue our legitimate interests in providing an innovative and tailored offering to our users on a sustained basis and to provide stable connectivity. For example, where there is poor connectivity, users can experience difficulty in downloading/uploading content. Therefore, “Twins” needs to process log data, including your IP address, to troubleshoot the issue. Without your IP address and location info, it can be hard to address connectivity issues.
5. HOW WE STORE YOUR INFORMATION
Storage and Processing
Your information collected through “Twins” app may be stored and processed in the United States by Microsoft bing visual search. We do not collect or store your data to app or other websites. You can find more about privacy of Microsoft bing visual search by:
We use commercially reasonable safeguards to help keep the information collected through the Service secure and take reasonable steps to verify your identity before granting you access to your account. However, “Twins” cannot ensure the security of any information you transmit to Microsoft bing visual search or guarantee that information on the Service may not be accessed, disclosed, altered, or destroyed.
6. MANAGING AND DELETING YOUR INFORMATION
We may offer the ability to correct or update the information collected during registration via your account settings on our website or the applicable App or by contacting support and we rely on the accuracy of the information you provide us (such as your age). You may request deletion of your account by contacting support via [email protected]
We retain your information in our server logs, our databases and our records only for as long as necessary in light of the purposes set out in this Policy, subject to any legal obligations to further retain such information. We may use third party service providers to store and maintain such data. We retain your verification-related information for a reasonable period of time, even if you do not complete all verification steps, to assist with future verifications and to prevent abuse of our verification processes. If you decide not to verify the account and would like us to delete the verification information you provided, contact support.
If you create content with other users such group content will remain after you delete your account.
7. YOUR RIGHTS
If you reside in certain territories, including the European Economic Area, you benefit from a number of rights in relation to your information. While some of these rights apply generally, certain rights apply only in certain limited cases. We describe these rights below in a summary format, but mandated applicable law shall govern.
- You can access much of your information by logging into your account. Where legally required, we can provide your information upon your request. Note that, in accordance with applicable law, information will not be provided where doing so would adversely affect the rights (including the intellectual property rights) of others.
- You can also change, restrict, limit or delete much of your information by logging into your account. If you cannot do this, or you do not have a “Twins” account, contact support via our online support form. We may retain certain information as required by applicable law.
- If we process your information based on our legitimate interests explained above, or in the public interest, you can object to this processing in certain circumstances. In such cases, we will cease processing your information unless we have compelling legitimate grounds to continue processing or where it is needed for legal reasons. If you live in the European Economic Area, you also have a general right to object to the use of your information for direct marketing purposes.
- Where you have previously provided your consent, you have the right to withdraw your consent to the processing of your information at any time. For example, you can withdraw your consent to email marketing by following the link provided in a marketing email. You can also revoke any consent you have provided to our use of your geo-location information by changing the setting on your mobile device. If you withdraw your consent to the use of your information for purposes set out in this Policy, you may not have access to all (or any) of our Services and we might not be able to provide you all (or any) of the Services. In certain cases, we may continue to process your information after you have withdrawn consent if we have a legal basis to do so or if your withdrawal of consent was limited to certain processing activities.
- If you reside in the European Economic Area, should you wish to raise a concern about our use of your information, you have the right to do so with your local data protection authority.
We maintain technical and organizational measures to protect against accidental or unlawful destruction, loss, alteration, unauthorised disclosure of, or access to your information.
We try to ensure a level of security appropriate to the risks that are presented by the processing and the nature, scope, context and purposes of the processing as well as the risk to users. No method of transmission over the Internet, or method of electronic storage, is 100% secure, however. While we use reasonable efforts to protect your personal information, we cannot guarantee its security.
9. DATA TRANSFERS
When you use our Services your personal information is transferred to the United States, where the laws protecting privacy may be less stringent than those in your home country. We’re a US company so this transfer is necessary for the performance of our Terms of Service. In certain cases, your data may be transferred to other countries or made available to users in other countries as part of the Services.
We may use a legal mechanism known as “standard contractual clauses” to protect information transferred outside the EU. Standard contractual clauses refer to contracts between companies transferring personal information that contain standard commitments approved by the EU Commission protecting the privacy and security of the information transferred. You can contact us to learn more and to request a copy of any clauses which may relate to your data.
10. CHILDREN’S PRIVACY
Our Services are intended for general audiences, and are not intended for anyone under 13, anyone under 16 in the European Economic Area or anyone under the minimum age to use the Services in the jurisdiction where they reside (“Minimum Age”). Persons under the Minimum age are prohibited from using our Services and we do not knowingly collect information from such individuals. If we become aware that a child under the Minimum Age has provided us with their information, we take steps to remove such information and terminate the account, unless proper parental consent is received by “Twins”.
11. SUBSCRIPTION POLICY
Сhoose from different subscription options. Our standard subscription options are:
- 1-month Subscription with a 3-day Trial (prices vary by region)
- Subscription with a free trial period will automatically renew to a paid subscription.
- You can cancel your subscription in the iTunes settings at least 24- hours before the end of the free trial period.
- Subscription payments will be charged to your iTunes account at confirmation of your purchase and upon commencement of each renewal term.
Please note: any unused portion of a free trial period (if offered) will be forfeited when you purchase a premium subscription during the free trial period.
You can cancel a free trial or subscription anytime by cancelling your subscription through your iTunes account settings. This must be done 24 hours before the end of a free trial or subscription period to avoid being charged. The cancellation will take effect the day after the last day of the current subscription period, and you will be downgraded to the free service.