TWISTY APP PRIVACY POLICY

Last updated April 9, 2024

This Privacy Policy (“Policy”) describes how TWISTY APP (“we,” or “us,” or “Developer”) collect, use and share personal information of users of the TWISTY mobile application (TWISTY or the “App”), website (the “Site”) and other services provided by the Developer (the App, the Site, and such services shall be collectively referred to as the “Service”). This Policy also applies to any of our other mobile applications or websites that post this Policy. This Policy does not apply to websites that post different statements.

WHAT WE COLLECT

We get information about you in a range of ways.

• Information You Give Us. We collect information you directly give us, such as your voice recording when you engage with our pronunciation validation through the App (“Voice Recordings”), and your‎ name,‎ email address,‎ phone number,‎ password, login credentials to your social network accounts, and your musical playlist data (for example, your favourites tracks from Spotify, Youtube Music, Deezer, etc.), that cloud be directly shared on your permission. Please note that we only record Voice Recordings when you engage with our pronunciation validation through the App – we do not access the microphone of your device at any other time.
• Information That Is Aggregated. “Aggregate data” are data we collect about a group or category of features, services or individuals, from which individual identities have been removed. For example, information about how you use a feature may be collected and combined with information about how others use the same feature, without any personal information included in the resulting data.
• Information Automatically Collected. We automatically log information about you and your computer. For example, when you visit TWISTY, we log‎ your computer operating system type,‎ browser type,‎ browser language,‎ pages you viewed,‎ how long you spent on a page,‎ access times,‎ Internet protocol (IP) address, and information about your use of and actions on TWISTY. We also collect (a) information stored in your phone, such as advertiser ID, phone brand and model, and default language, (b) your login information (either through email or Facebook), and (c) your approximate location (via IP address).
• Public Content. You can contribute to the Service in a number of different ways that are intended to be viewed by other users, including writing reviews, uploading videos and photos, participating in forums, tagging products, filling out your public profile, and voting on other users’ contributions. We may store these contributions (your “Public Content”), display them to other users, and use them for promotional purposes. Note that if you include personally identifiable information in your Public Content, it can be used and viewed by others. We are not responsible for the information you choose to include in your Public Content.

HOW WE USE PERSONAL INFORMATION

We use your personal information for the following purposes:

• To operate, maintain, and improve our sites, products, and services.
• To analyze your usage of the App for the purpose of improving our App, including analyzing Voice Recordings to improve our twister validation.
• To find and connect with your friends (when instructed by you).
• To provide custom, personalized advertisements, content, and information.
• To let your friends know about your activity on TWISTY.
• To monitor and analyze usage and trends, and to personalize and improve TWISTY and your experiences when you use TWISTY.
• To respond to comments and questions and provide customer service.
• To send information including confirmations, invoices, technical notices, updates, security alerts, and support and administrative messages.
• To protect, investigate, and deter against fraudulent, unauthorized, or illegal activity.
• To communicate about promotions, upcoming events, and other news about products and services offered by us and our selected partners. The legal bases for our processing of your personal information are (a) our obtaining your consent for the processing of your personal information for the foregoing purposes, and (b) the fact that such processing is necessary for us to render the Service. We retain your personal information to provide the Service to you and as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements; otherwise, we will delete your personal information immediately after you terminate your account.

SHARING OF PERSONAL INFORMATION

In certain circumstances we may share your personal information with third parties without further notice to you, unless required by the law, as set forth below:

• With your friends on TWISTY, according to the preferences set in your account.
• With certain social networking services, if you allow such sharing through our services.
• With your consent. For example, you may let us share personal information with third parties for their own marketing uses. Those uses will be subject to the privacy policies of such third parties.
• With those who provide services to TWISTY, such as sending TWISTY email communications, analyzing usage logs and Voice Recordings to improve our pronunciation validation, and managing TWISTY marketing campaigns.
• With educational institutions and other third parties for research purposes.
• We may sell or license to third parties Voice Recordings that have been stripped of information that could identify you directly (such as your name and contact information).
• For legal, protection, and safety purposes:
  • To comply with laws.
  • To respond to lawful requests and legal processes.
  • To protect the rights and property of TWITY, our agents, customers, and others. This includes enforcing our agreements, policies, and terms of use.
  • In an emergency. This includes protecting the safety of our employees and agents, our customers, or any person.
  • If and when we negotiate a transaction involving the sale or transfer of all or a part of our business or assets. These transactions can include any merger, financing, acquisition, or bankruptcy transaction or proceeding.
  • If you post Public Content on the Site or the App, we may distribute such Public Content to a wider audience by sharing it (or portions of it) with third parties so that they can publish it on their own websites and media platforms. We allow you to access third party services, such as Facebook and Twitter, to share your selected Public Content with those services.

We may share aggregate data with interested third parties to assist them in conducting research, developing new products, and understanding the interest and usage patterns for certain information, products, services, data, content, services, advertisements, promotions, and/or functionality on the Service.

RETENTION OF PERSONAL INFORMATION

We will retain your personal information for as long as your account is active, and as long as is reasonably necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

YOUR PRIVACY RIGHTS AND CHOICES

You have certain rights and may make certain choices regarding our processing of your personal information:

• You may request access to, correction of, or erasure of your personal information by contacting on email romanov.roman.65041@gmail.com, or using "Delete Account" button in your account settings page.
• You may request that we restrict processing of your personal information or object to our processing of your personal information by contacting our Data Protection Officer, in which case you will no longer be able to have an account with TWISTY.
• You may withdraw your consent at any time by deleting your account with us.
• If you reside in the EEA, you have the right to lodge a complaint with the supervisory authority of your member state. For a list of supervisory authorities, please see http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm
• You are not obligated to provide any personal information, but (a) if you do not provide your email address, we will not be able to communicate with you, and (b) if you do not provide us with voice recordings, we will not be able to provide you feedback regarding your pronunciation.
• Our marketing emails tell you how to “opt-out.” If you opt out, we may still send you non-marketing emails. Non-marketing emails include emails about your accounts and our business dealings with you.
• You may send requests about personal information to our Contact Information below. You can request to change contact choices, opt-out of our sharing with others, and update your personal information.

SECURITY OF YOUR PERSONAL INFORMATION

We take steps to help protect personal information. No company can fully prevent security risks, however. Mistakes may happen. Bad actors may defeat even the best safeguards.

TRANSFER OF PERSONAL INFORMATION TO THE UNITED STATES OR OTHER COUNTRIES

Your personal information will be transferred to, and stored and processed in, the United States, and may in the future be transferred to, and stored and processed in, other countries. All transfers will either (a) be under the European Commission’s model contracts for the transfer of personal information to third countries, or (b) rely on the EU-US Privacy Shield framework.

CONTACT INFORMATION / DATA PROTECTION OFFICER

If you have questions, comments or complaints about this Privacy Policy or our privacy practices, or would like to exercise any of your rights and choices under this Privacy Policy or applicable law, you may contact the following email address: romanov.roman.65041@gmail.com

CHANGES TO THIS PRIVACY POLICY

We may occasionally update this Privacy Policy. When we do, we will also revise the "updated date" on the Privacy Policy. For changes to this Privacy Policy that may be materially less restrictive on our use or disclosure of personal information that you have provided to us, the new policy will not apply to information collected prior to the change unless we obtain your consent. We encourage you to periodically review this Privacy Policy to stay informed about how we are protecting the personal information we collect. Your continued use of the Service constitutes your going forward agreement to this Privacy Policy and any updates.

This privacy policy was last updated on April 9, 2024.