Privacy Policy

Introduction

Welcome to TwinOver, a social App that connects people through shared passions on a video-first platform that sparks meaningful conversations and builds vibrant communities—without clutter, distractions and noise. TwinOver (“we”, “us” or “our”) focuses on depth, not distraction, empowering users (“you” “your” or “Member(s)”) to thrive in a space where they can truly engage and grow.

This Privacy Policy (the “Privacy Policy” or “Policy”) explains what personal information we collect, how we store it, how we use and share it, how long we retain it, and the choices you have regarding your information. This Policy applies to all interactions with our products and services. If you do not agree with this Policy, you should refrain from using our products and services.

This Privacy Policy complies with all data protection and consumer protection laws, applicable in the regions where we operate, including the General Data Protection Regulation (“GDPR”), the California Consumer Privacy Act (“CCPA”), amongst other applicable laws.

Information We Collect

We prioritize transparency in how we collect and use your data to enhance your experience and create a safe user environment for you and other Members using our products and services.

The information we collect is categorized as follows:

Legal Basis for Data Processing

We process your personal data based on the following legal grounds:

How We Use Your Information

We use the information we collect to enhance your experience, improve the functionality of our platforms, and ensure a safe and engaging environment for all Members. Your data helps us personalize content, recommend T-Spaces to you, and tailor interactions to align with your preferences and interests. This includes suggesting posts, T-Spaces, or Members to follow based on your activity and settings. We leverage your information to provide features such as messaging, content sharing, and community interactions, ensuring a seamless and intuitive experience across our platforms.

We use your data to provide and enhance our features, products and services, including processing transactions and delivering content through our subscription features. Information is shared securely with merchants, payment processors, and other service providers to facilitate these actions. Additionally, your activity data helps us measure the effectiveness of our advertising and promotional campaigns, providing targeted and relevant advertisements while enhancing the platform's social features, such as connecting you with friends, recommending popular T-Spaces, and promoting interactive features like collaborative content creation.

Safety and security are integral to our operations. We use your information to detect and combat fraud, abuse, harmful content, spam, and illegal activities. User Content and metadata are analyzed to ensure compliance with our Terms of Service and Community Rules and Guidelines. To protect the platform's integrity, we monitor behavioral patterns and employ machine learning models to identify and prevent suspicious activities.

Your information also supports our ongoing development efforts. We use it for troubleshooting, testing, research, and product development to continuously improve our features, products and services. Location-based data helps us deliver personalized content and advertisements, ensuring relevance to your geographic area. Moreover, insights from user activity enable us to analyze engagement trends, assess campaign effectiveness, and verify age or identity where required.

To foster transparency and compliance, we respond to legal requests, handle user rights inquiries, and enforce platform policies. Communication with you is vital; we use your data to notify you about changes to our products and services, respond to support requests, share updates, and announce contest results when applicable.

Finally, your data enables us to power innovative technologies, such as our machine learning models, and train algorithms to deliver smarter, more intuitive products and services. Whether promoting safety, facilitating purchases, or creating engaging community interactions, we use your information responsibly to make our platforms vibrant and secure for everyone.

Information Sharing

We are committed to safeguarding your personal information. While we do not sell your data, we may share or disclose it under the following circumstances:

Storage of Information

Safeguarding your personal information is a top priority. We implement industry-standard security measures to ensure the confidentiality, integrity, and availability of your data.

• Encryption: Your information is encrypted during transmission and at rest, ensuring that it remains protected from unauthorized access or tampering.
• Secure Storage: Data is securely stored on servers located across the globe. These global data centers ensure reliable and uninterrupted services, optimizing performance, scalability, and accessibility, regardless of where you live.
• Secure Storage:We employ advanced firewalls and intrusion detection systems to prevent unauthorized access to our servers and protect your data from cyber threats.
• Access Control Mechanisms: Strict access controls are in place to ensure that only authorized personnel can access sensitive data, and even then, access is limited to what is necessary for their role.
• Regular Security Audits: Our systems undergo regular security audits and vulnerability assessments to identify and mitigate potential risks proactively.
• Data Minimization: We process only the data necessary for providing our products and services, further reducing the risk of exposure.

Your Rights & Choices

You have several rights regarding your personal data (we respond within 30 days):

If you wish to exercise any of these rights, you can submit a request by sending an email to info@twinover.com. If you disagree with a decision regarding your request, you may follow the appeal instructions provided in our response.

Managing Your TwinOver Profile

You can access and edit most of your profile information by logging into our platforms. Content you have uploaded, such as posts or videos, can also be deleted directly within the platforms. In addition, you can control:

• Who can view your posts.
• Who can send you messages.
• Who can comment on your content.

Should you wish, you also have the option to delete your entire account via the settings menu.

Protecting Your Information

We are committed to safeguarding your information and take steps to ensure its secure handling in accordance with our Privacy Policy. However, while we employ reasonable measures, such as encryption, to protect your personal data, it is important to note that the transmission of information over the internet is not entirely secure. As such, any information you transmit through our platforms is done at your own risk.

Security Measures

We implement and maintain appropriate technical and organizational measures to protect your information. These measures are designed to address varying levels of risk, ensuring a security standard that takes into account the likelihood and potential severity of threats to your rights and freedoms, as well as those of other Members. Our practices are periodically reviewed and updated to enhance the security of our systems.

Third-Party Websites

From time to time, we may include links to websites operated by partner networks, advertisers, or affiliates. Please note that these external sites operate under their own privacy policies, and we are not responsible for their practices. Before submitting any information to these websites, we recommend reviewing their privacy policies to understand how your data will be handled.

Your trust is our priority, and we continuously strive to provide secure platforms for our Members.

Retaining Your Information

We retain your information only for as long as necessary to provide our products and services and fulfill the purposes outlined in this Privacy Policy. This includes compliance with legal obligations, legitimate business interests, such as improving and developing our platforms, ensuring its safety and stability, and addressing potential legal claims.

Retention periods vary depending on the type of information and the purposes for its use. For example:

• Account Information: We keep your profile and related information for as long as your account is active on our platforms.
• Messages: Messages may be retained until you delete them or as per the retention settings.
• Policy Violations: If you violate our Terms of Service, Community Rules and Guidelines, or our other policies, your profile and User Content may be removed from public view immediately. However, we may retain certain information for record-keeping and to process the violation.
• Temporary Data: Some data, such as cached or temporary content, may be kept for shorter periods unless required for legal or business purposes.

When we no longer need to use your information and have no legal or regulatory obligations to retain it, we will delete or anonymize the data to prevent identification. For example:

• If you instruct us to delete your data, such as contacts or other personal information, we will comply promptly and remove it from backups within a reasonable timeframe.
• If content is deleted by its creator, we may retain a copy temporarily for operational needs but will remove it from our systems, including backups, once it is no longer required.

For features like recorded conversations or other shared content:

• Live Sessions: Content created in live sessions may be retained temporarily for investigation of complaints or violations of our Community Rules and Guidelines or Terms of Service. Once resolved, these recordings will be deleted
• Customizable Retention: Members have the ability to determine retention settings for content they create, such as chat conversations or shared media. For example, content may remain available to others based on the creator’s preferences unless they delete it.

We prioritize your control over your information while maintaining transparency about how long your data is retained.

International Data Transfers

If your personal data is transferred outside of your country of residence, including to countries or regions that may not offer the same level of data protection as your home country, we take appropriate measures to ensure the security and protection of your data. This includes, where applicable, using legal mechanisms such as Standard Contractual Clauses (SCC), Binding Corporate Rules (BCR), or other safeguards required by applicable data protection laws.

We ensure that any third parties involved in the processing of your personal data are contractually obligated to protect your information in accordance with the applicable privacy and data protection regulations.

Information Relating to Children and Teens

Our platforms are not intended for use by children under the age of 13, or the minimum age required by local regulations in your jurisdiction. If you believe that a user is under the required age for using our platforms, please contact us immediately through our support channels.

Privacy Policy Updates

We may update this Privacy Policy periodically to reflect changes in our practices or for other operational, legal, or regulatory reasons. When we make updates, we will notify you by revising the “Last Updated” date at the top of this Policy and posting the new version of the Privacy Policy. In some cases, we may provide additional notice as required by applicable law. Your continued use of our platforms after the date of the updated Privacy Policy constitutes your acceptance of the changes. If you do not agree with the updated Policy, you should discontinue using our products and services.