Privacy Policy

Welcome to the TwineIn Privacy Policy ("Policy")! This explains how we collect, store, protect, and share your information, and with whom we share it. We suggest you read this in conjunction with our brilliant Terms and Conditions of Use. Whilst you're enjoying the TwineIn mobile application ("App"), we collect some information about you. In addition, you may choose to use the App to share information with other people on the TwineIn app, including your friends and contacts ("Users"). We may also need to share your information sometimes. TwineIn is a global app, and your information will be sent to and used in India 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 nishant@twinein.com.

1. COLLECTION OF INFORMATION.

Registration Information

When you download the App and create an account ("Account"), we may collect certain information ("Registration Information") about you, such as:

  • Name;
  • Username;
  • Email address;
  • Mobile number;
  • Gender identity;
  • Date of birth;
  • Photographs;
  • Location; and
  • Login information and friend lists for social media accounts that you connect to your TwineIn Account (this could include, for example, your Facebook and Instagram accounts ("Social Media Accounts").

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 your information at any time by just logging in to TwineIn.

The information we collect helps to enhance the App and verify our Users (robots are not welcome!!). Registration Information such as your name and username may be visible to the public on your profile page.

Additional Information

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, sending gifts or delivery of merchandise.

We may also collect additional information in connection with your use of TwineIn, for example, if you use our super cool electronic messaging function.

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' licence 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. You may also choose to add sensitive information about yourself, such as your religion and political leanings. While you may voluntarily provide this information to us when you create your profile, there is no requirement to do so. Please remember that photographs that you post on TwineIn 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 TwineIn. If you post anything that is inconsistent with our Terms and Conditions of Use, we reserve the right to terminate your Account - we really don't want to have to do this so please play by the rules!

For safety and security and to ensure you have the best possible user experience, we require users to verify their accounts and might ask for your phone number. We want to make sure you are not a robot! And we also want to avoid fake TwineIn accounts being created which can be used for malicious activities and cybercrime – they threaten the TwineIn network and spoil things for everyone. We use a third-party provider for account verification who will keep your phone number for up to 90 days for fraud identification purposes.

It is your responsibility to ensure that your account details are kept up to date. If your phone number changes, please ensure that you update this in your account.

To prevent abuse of the app/site, TwineIn uses automated decisions and moderators to block accounts as part of its moderation procedures. In order to do this, we check accounts and messages for content that indicates breaches of our Terms and Conditions of Use. This is done through a combination of automated systems and our team of moderators. If an account or message meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached, the relevant account will automatically be blocked. All users of accounts that have been blocked will be notified that their account has been blocked and affected users can contact TwineIn to contest the decision.

TwineIn also uses automated decisions to prevent fraudulent payment transactions being processed as part of its anti-fraud procedures. In order to do this, our systems check payment transactions for behaviour that indicates breaches of our Terms and Conditions of Use. If a transaction meets certain criteria that demonstrate that the Terms and Conditions of Use are likely to have been breached and the transaction is likely to be fraudulent, the relevant transaction may automatically be blocked. Where a transaction is blocked, the user will be notified that their transaction cannot be processed and affected users can contact TwineIn to contest the decision.
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.

We may process some limited data to drive targeted advertising in our legitimate interest, via promo cards and ads on our App. We also may process limited data (device identifiers) and share this with third-party advertising networks which host our ads. If you opt-out of targeted advertising you will still see adverts though they will be less relevant to you. Through your device’s security settings you also have the option to prevent or limit device identifiers being shared with third party advertisers and what use is made of the device identifiers.

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.

Data Storage

By using the App, you acknowledge that TwineIn is a global app operating through servers located in a number of countries around the world, including India. 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.

Geolocation Information

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. However, we don't disclose your location to any user or business as per our policies.

If you have enabled location services, but wish to turn it off, you can do so by the following methods:

  1. iPhone app — settings, privacy, location services, TwineIn
  2. Android — settings, location, TwineIn, permissions, location

Log and Usage Data

We keep your personal information only as long as we need it for legitimate business purposes and as permitted by applicable law.
In practice, we delete or anonymize your information upon deletion of your account (following the safety retention window), unless:

  1. 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);
  2. we must keep it to evidence our compliance with applicable law (for instance, records of consents to our Terms, Privacy Policy and other similar consents are kept for five years);
  3. there is an outstanding issue, claim or dispute requiring us to keep the relevant information until it is resolved; or
  4. 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 behaviour or security incidents from opening a new account.

Where TwineIn uses machine learning, for example, to help us detect and prevent fraudulent card transactions, and to detect and prevent spam communications on the App (as explained above), we may need to keep personal information for a longer period than the retention periods explained above, to enable the machine learning to work properly. Where this is the case, we always seek to minimise the amount of personal information that is used and we ensure that it is ring-fenced and kept securely from other users' personal information. We regularly review the period for which personal information is required for machine learning purposes and delete any identifiable information when it is no longer required.

Device Information

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 TwineIn 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

The cookies we collect enable us to learn how people interact with TwineIn, which in turn helps us make a better product for you!

Cookies store information about your website visits and can recognise you and your preferences each time you visit the TwineIn site. They help us to provide a better service to you!
TwineIn use of cookies and local storage devices is basically related to the performance of TwineIn’s site, such as analytics that helps us determine how our site is performing and ensure a smooth and trouble-free experience for our members and visitors.

Below is a table to explain TwineIn’s cookie functions and why they’re used.

If for any reason you decide that you do not want all of your TwineIn 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 TwineIn offers!

We use the following types of cookies:

  1. Cookie Functions - Cookie Purposes
  2. Analytics and research - We use Google Analytics to collect information about how visitors use the site. The cookies collect information in an anonymous form, including the number of visitors to the App, where visitors have come from and the pages they visited.
  3. 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 – no one likes snail pace technology!
    Our use of cookies and local storage devices, including the specific cookie names, may change over time, but will generally fall into the above categories. We will notify you of any important changes to our use of cookies and local storage devices. Please visit this page regularly so that you are aware of any changes.

2. USE OF INFORMATION.

Our main goal is to ensure your experience on TwineIn is an enjoyable one and you don't end up getting stung! 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:

  • Circumstances where data may be disclosed
    Disclosed data
    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 and help us with information security matters.

  • Moderators – To monitor activity on the apps and approve content, we may disclose Name and user registration details, profile information, the content of messages and photographs.

  • Payment Processing and Telecommunications Companies – To facilitate payments for our premium services.
    Cardholder name, cardholder address, card number, payment amount, transaction date/time

  • 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, where there is an investigation into alleged criminal behaviour 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. This could include any personal data that TwineIn holds about you, depending on the nature of the request or the issue that we are dealing with.

  • Business Transfers -In the event that TwineIn or any of our affiliates undergoes a business transition or change of ownership, such as a merger, acquisition by another company, re-organisation, 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. This could include all personal data that TwineIn holds about you.

  • Advertising Partners – To serve targeted advertisements to users. This could include data around Device ID, geolocation data, demographic data

  • Anti-Spam and Anti-Fraud -Your data may be shared with other Pnjaa Technologies companies, for example, to block accounts and suspected fraudulent payment transactions as part of our anti-spam and anti-fraud procedures. This could include data around Email address, phone number, IP address and IP session information, social network ID, username, user agent string, and transaction and payment 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.
    TwineIn does not sell your data and has not sold your personal data in the previous 12 months.

4. WHAT OTHERS MAY SEE ABOUT YOU.

We think our users are awesome, and we want you to share how awesome you are with the world, so we have built certain features to enable this. Our App is designed to make it easier for you to connect with other Users and to interact with them. If you register or log in 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 TwineIn 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 at such users’ discretion. For example, a User may recommend you as a match to his or her Facebook friends by sharing your picture, regardless of whether such a 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 TwineIn, 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.

If you log into or access TwineIn through your Facebook profile, remember to log off Facebook when you leave a device in order to prevent other users from accessing your account.

5. MODIFYING YOUR REGISTRATION INFORMATION.

You may access or modify the Registration Information you provided at any time or permanently delete your Account (although we really hope you don't!)

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 TwineIn 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 of Use 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 - sorry kids, we know TwineIn is cool, but you'll have to come back when you're old enough!

TwineIn 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 TwineIn. 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.

As TwineIn evolves, we may revise this Privacy Policy from time to time. The most current version of the policy will govern our use of your information and will always be at bumble.com/privacy/. If we make a change to this policy that, in our sole discretion, is material, we will notify you, for example, via an email to the email associated with your Account or by posting a notice within TwineIn. By continuing to access or use the App after those changes become effective, you agree to be bound by the revised Privacy Policy.

8. SECURITY.

Here at TwineIn, 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 unauthorised access, hacking, data loss or other breaches will never occur, but here are some handy tips to help keep your data secure:

  1. 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!
  2. Change your social media password periodically.
  3. 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 TwineIn using a third party social media platform, such as Facebook, your TwineIn profile will be available to all Users of TwineIn 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 TwineIn 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 TwineIn 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 TwineIn profile through a third party website and you do not want to link your TwineIn profile to your profile on the third party website, TwineIn cannot amend these settings. Please visit the application settings on your third party website profile and follow the instructions to remove the TwineIn 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. ABOUT US.

Your access to the App, as well as this Privacy Policy, are governed and interpreted by the laws of the State of Maharashtra, India, other than such laws, rules, regulations and case law that would result in the application of the laws of a jurisdiction other than the State of Maharashtra, India. By using the App, you are consenting to the exclusive jurisdiction of the courts of the state of Maharashtra, India. You agree that such courts shall have in personam jurisdiction and venue and waive any objection based on inconvenient forum.

You agree that you will not file or participate in a class action against us. In the event there is a discrepancy between this English language version and any translated copies of the Policy, the English version shall prevail.
Thanks for reading, we hope we didn't drone on for too long!

Effective date

This Privacy Policy was last updated on 10th March 2021.