Twine is a global app, and your information will be sent to and used in the United States regardless of the country you reside in. This Policy explains how we protect your personal data when we transfer it overseas, so please read very carefully!
If you have any questions or comments about this Policy, please feel free to contact us at email@example.com.
1. COLLECTION OF INFORMATION.
When you download the App and create an account (“Account”), we may collect certain information (“Registration Information”) about you, such as:
- Email address;
- Mobile number;
- Gender identity;
- Date of birth;
- Sexual preference;
- Location; and
- Login information and friend lists for social media accounts that you connect to your Twine Account (this could include, for example, your Facebook and Instagram accounts (“Social Media Accounts”).
You will also be required to create a password in connection with the registration of your Account. Once you register, you will be able to review and change this information at any time by accessing your “Profile” page! You control your user profile and are able to correct or update (other than your email address, mobile number, date of birth, gender and location (which is automatically updated)) your information at any time by just logging in to Twine.
The information we collect helps to enhance the App and verify our Users. Registration Information such as your name and username may be visible to the public on your profile page.
We may ask you to provide your full name, address and email address. Such details may be shared with third parties for purposes relating to, for example, any of our loyalty programs or sending gifts.
We may also collect additional information in connection with your use of Twine, for example if you use our messaging features.
If you contact our Customer Support team, we will receive your email address, and may track your IP address as well as the information you send to us to help resolve your query. We will keep records of our communications with you, including any complaints that we receive from you about other Users (and from other Users about you).
We recommend and encourage you (and all our members) to think carefully about the information you disclose about yourself. We also do not recommend that you put email addresses, URLs, instant messaging details, phone numbers, full names or addresses, credit card details, national identity numbers, drivers’ license details and other sensitive information on your profile which is open to abuse and misuse.
Please be careful about posting sensitive details about yourself on your profile such as your religious denomination and health details. While you may voluntarily provide this information to us when you create your profile, including your sexual preferences, there is no requirement to do so. Please remember that photographs that you post on Twine may reveal information about yourself as well. Where you do upload and choose to tell us sensitive information about yourself, you are explicitly consenting to our processing of your information and making this public to other users.
When you post information about yourself or use the messaging function, the amount of personal information you share is at your own risk. Please see Section 4 below for more information on who can access what you post on Twine. If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account.
If you decide to purchase any of our premium services, we will process your payment information and retain this securely for the prevention of fraud and for audit/tax purposes.
Finally, we want to keep in touch with you to make sure you know about the great promotions and offers we have available. If you’ve told us it’s OK, we will use your email address and phone number to send you information on these. You can withdraw this consent at any time via Settings in the app or unsubscribing via our email newsletters.
By using the App, you acknowledge that Twine is a global app operating through servers located in a number of countries around the world, including the United States. If you live in a country with data protection laws, the storage of your personal data may not provide you with the same protections as you enjoy in your country of residence.
If you turn these features on, when you use your mobile, we will collect information about WiFi access points as well as other location information about your longitude and latitude and may save your device’s coordinates to offer certain features to you. This information helps us identify your physical location and we may use it to personalize the App and make it easier for you to interact with other Users, by enabling the information to be displayed and shared with other members choosing to view “nearby” posts.
Log and Usage Data
We keep your personal information only as long as we need it for legitimate business purposes (as set out in Section 11 below) and as permitted by applicable law. To protect the safety and security of our users on and off our services, we implement a safety retention window of three months following account deletion. During this period, account information will be retained although the account will of course not be visible on the services anymore.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window), unless:
- we must keep it to comply with applicable law (for instance, some “traffic data” is kept for one year to comply with statutory data retention obligations);
- there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
- the information must be kept for our legitimate business interests, such as fraud prevention and enhancing users’ safety and security. For example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account.
We may collect information about your device when you use the App including the unique device identifier, device model, operating system, and MAC address. In addition, if you permit us to do so, the App may access your device’s address book solely in order to add someone to your contacts.
We may keep track of how you interact with links available on Twine including third party services and clients by redirecting clicks or through other means. We may share aggregate click statistics such as how many times a particular link was clicked on.
Cookies are small data files that are transferred to your computer’s hard disk and are basically a tool that stores information about website visits, recognizes you and your preferences each time you visit Twine, and ensures site functionality and enables us to provide the services our members request.
The cookies we collect enable us to learn how people interact with Twine, which in turn helps us make a better product for you! Cookies store information about your website visits and can recognize you and your preferences each time you visit the Twine site. They help us to provide a better service to you!
Below is a table to explain Twine’s cookie functions and why they’re used.
If for any reason you decide that you do not want all of your Twine activities to be stored you may set your browser and mobile settings to block cookies and local storage devices, but please remember that if you do so, you may not be able to access all of the features Twine offers!
We use the following types of cookies:
- Performance: We need to use certain cookies and save data to your local storage devices to ensure our members have the best possible experience. They assist with your navigation of our site, ensuring pages load quickly and respond promptly to your requests.
If you would like to know more about cookies, including flash cookies/local storage devices, the following websites provide useful information:
2. USE OF INFORMATION.
Our main goal is to ensure your experience on Twine is an enjoyable one. In order to deliver an enjoyable experience to you, we may use your Registration and other information to:
- offer you our services and features;
- contact you with information about the App (e.g., updates and new offerings);
- personalize the App and the content we deliver to you;
- conduct research and analytics about how you use and interact with the App;
- resolve disputes between you and other Users; and
- investigate fraud, protect our legal rights, and to enforce our Terms & Conditions.
3. DISCLOSURE OF INFORMATION.
Our policy is to not disclose your Registration Information, except in the limited circumstances described here:
Your Consent – If you consent, we may share or disclose your Registration Information, such as when you use a third party web client or application to access your Account.
Service Providers – We engage certain trusted third parties to perform functions and provide services to us. We may share your Registration Information with these third parties, but only for the purposes of performing these functions and providing such services e.g. information technology companies (hardware and software) which provide services to support our products.
Moderators – To monitor activity on the apps and approve content.
Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.
Law and Harm – As we mentioned in the Terms & Conditions, we think it is very important that all Users behave whilst using the App. We will cooperate with all third parties to enforce their intellectual property or other rights. We will also cooperate with law enforcement enquiries from within or outside your country of residence where we are required to by law or to protect the vital interests of a person. This may include preserving or disclosing any of your information, including your Registration Information, if we believe in good faith that it is necessary to comply with a law or regulation, or when we believe that disclosure is necessary to comply with a judicial proceeding, court order, or legal request; to protect the safety of any person; to address fraud, security or technical issues e.g. through anti-spam providers to protect the service from criminal activity or to protect our rights or property or those of third parties. In such cases we may raise or waive any legal objection or right available to us.
Business Transfers – In the event that Twine or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, reorganization, or sale of all or a portion of its assets, or in the event of insolvency or administration, we may be required to disclose your personal data.
Aggregated Information – We may share aggregated information with third parties that includes your personal data (but which doesn’t identify you directly) together with other information including log data for industry analysis and demographic profiling. You may opt-out of receiving marketing messages by using the opt-out mechanisms and links provided in each email.
We ensure these parties must adhere to strict data protection and confidentiality provisions that are consistent with this Policy. Measures are taken to ensure that the data shared is non-attributable to the greatest extent possible.
4. WHAT OTHERS MAY SEE ABOUT YOU.
Our App is designed to make it easier for you to connect with other Users and to interact with them. If you register or login to the App using your Facebook account, you are authorizing us to access certain Facebook account information, including information you make available via Facebook, your friends list, current location and those friends you have in common with other Users. You also understand that your Twine profile and other information you make available via the App, including information you provide directly or indirectly through Facebook (i.e., your Facebook photos, your name, age, approximate location, friends you have in common with other Users and other profile information), may be viewed and shared by Users with individuals who may or may not be Users or via third party applications in such Users’ discretion. For example, a User may recommend you as a connection to his or her Facebook friends by sharing your picture, regardless of whether such friend(s) is also a User of the App. You might share information like the photos and messages you send or upload and any metadata provided with those messages, along with any comments or information you provide in connection with your photos.
When using Twine, you should assume that anything you post or submit on the App may be publicly-viewable and accessible, both by Users of the App and non-Users of the App. We want our Users to be careful about posting information that will eventually be made public.
5. MODIFYING YOUR REGISTRATION INFORMATION.
You may access or modify the Registration Information you provided at anytime or permanently delete your Account.
When your Account is deactivated, we take reasonable efforts to make sure it is no longer viewable on the App. For up to 30 days it is still possible to restore your Account if it was accidentally or wrongfully deactivated. After 30 days, we begin the process of deleting your Account from our systems. We are not responsible for any information, pictures, comments, or other content that is deleted from our systems resulting from the deactivation of your Account.
To prevent abuse and/or misuse of Twine by a User following termination or deletion of a profile/Account we shall retain such information as we deem in our sole discretion may be necessary to ensure that User does not open a new Account and profile in breach of our Terms and Conditions and to ensure compliance with all laws and regulations.
Warning: Even after you remove information from your profile or delete your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by other Users or to the extent such information has been shared with search engines. We cannot control this, nor do we accept any liability for this. If you have given third party applications or websites access to your personal information they may retain such information to the extent permitted under their terms of service or privacy policies.
Removed and deleted information may persist in backup copies for up to 30 days to enable restoration, but will not be available to others in the meantime.
6. OUR POLICY TOWARDS AGE.
Although we want as many people as possible to enjoy our creation, you have to be at least 18 years old to use the App. Twine does not knowingly collect any information about or market to children, minors or anyone under the age of 18. If you are less than 18 years old, we request that you do not submit information to us. If we become aware that a child, minor or anyone under the age of 18 has registered with us and provided us with personal information, we will take steps to terminate that person’s registration and delete their Registration Information from Twine. If we do delete a profile because you violated our no children rules, we may retain your email and IP address to ensure that you do not try to get around our rules by creating a new profile.
7. CHANGES TO THIS POLICY.
Here at Twine we pride ourselves on taking commercially reasonable security measures to help protect your information against loss, misuse and unauthorized access, or disclosure. We use reasonable security measures to safeguard the confidentiality of your personal information such as secured servers using firewalls.
Unfortunately no website or Internet transmission is ever completely 100% secure and even we cannot guarantee that unauthorized access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:
- Please make sure you log out of your Account after use as you never know who may stumble onto your Account!
- Please don’t share your social media password with anyone else!
- Change your social media password periodically.
If you ever think someone has had access to your social media password, please report it to the relevant social media platform and change your password immediately. We cannot guarantee the security of your personal data while it is being transmitted to our site and any transmission is at your own risk.
WE EXPRESSLY DISCLAIM ANY REPRESENTATION OR WARRANTY, WHETHER EXPRESS OR IMPLIED, WITH RESPECT TO ANY BREACHES OF SECURITY, DAMAGE TO YOUR DEVICE, OR ANY LOSS OR UNAUTHORIZED USE OF YOUR REGISTRATION INFORMATION OR OTHER DATA.
9. THIRD PARTY ACCOUNTS.
If you have registered with Twine using a third party social media platform, such as Facebook, your Twine profile will be available to all Users of Twine whether via our App or our partners’ websites.
Remember that when you register with a third party, you are also giving them personal information, so we recommend that you read their privacy policies as Twine does not control how they use their information.
If you have registered on one of these third party websites, such as Facebook, or you have verified your Account via a third party website, we may connect your Twine profile with your profile on such website. We may do this by way of new products and applications which we introduce from time to time, including new products powered by our group companies.
If you have created a Twine profile through a third party website and you do not want to link your Twine profile to your profile on the third party website, Twine cannot amend these settings. Please visit the application settings on your third party website profile and follow the instructions to remove the Twine access permissions.
We only use the APIs, OAuth Tokens, Widgets, or other means provided by the applicable Social Media Account to integrate your Social Media Account with our App. As such, we only receive the limited information that each Social Media Account permits to be transferred.
10. YOUR Delaware PRIVACY RIGHTS.
Delaware’s “Shine the Light” law, Civil Code section 1798.83, requires certain businesses to respond to requests from Delaware customers asking about the businesses’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. If you wish to find out about any rights you may have under Delaware Civil Code section 1798.83, you can write to us at firstname.lastname@example.org.
From time to time we may disclose your contact information to third parties to allow them to market their products or services to you or for other marketing purposes. This may be information we received from you offline and online. If you want us to stop further sharing your email contact information with third parties (if we have your email contact information), you may notify us at email@example.com. Please follow the instructions provided to you by third parties to unsubscribe from their messages. If you have opted-out as described above, and thereafter you chose to use a service or promotion that requires us to contact you or share your information with a third party, then your previous opt-out preferences will not apply to such service.
In addition, under Delaware law, operators of online services are required to disclose how they respond to “do not track” signals or other similar mechanisms that provide consumers the ability to exercise choice regarding the collection of personal information of a consumer over time and across third party online services, to the extent the operator engages in that collection. At this time, we do not track our Users’ personal information over time and across third-party online services. This law also requires operators of online services to disclose whether third parties may collect personal information about their users’ online activities over time and across different online services when the users use the operator’s service. We do not knowingly permit third parties to collect personal information about an individual User’s online activities over time and across different online services when using the App.
11. ABOUT US.