Last Updated: November 5, 2022
Effective date: November 5, 2022
It is important to note that this Policy does not apply to services provided to you by other third parties. You may receive links, content, products or services provided by third parties, please prudently determine whether to access them. We encourage you to carefully review the privacy policies of any Third Parties you access before submitting any personal information.
We have chosen to use plain language in order to make sure that you fully understand this Policy and make your own choices. We have also marked or highlighted key terms in bold or capital letters for your attention. We will also notify you by a pop-up window when you first use our service to help you understand the core terms of this Policy.
If you have any questions, please feel free to contact us by the following means:
- I. How We Collect and Use Your Personal Information
- III. How We Store and Protect Your Personal Information
- IV. How We Share, Transfer and Disclose Your Personal Information
- V. How Your Personal Information is Transferred Across Borders
- VI. Your Rights to Your Personal Information
- VII. How We Handle the Personal Information of Children
- VIII. Third-Party Service Providers and Services
- IX. Supplement and Update of the Policy
- X. How to Contact Us
I. How We Collect and Use Your Personal Information
Twibida firmly believes that the fundamental privacy rights should not differ depending on where you live in the world. Any information relating to an identified or identifiable individual, in particular by reference to the individual's name, identification number, location data, and online identifier or to one or more factors specific to the physical, physiological, genetic, mental of that natural person will be treated as “Personal Information” by us, regardless of where such natural person lives.
We only collect the information that is necessary for specified, concrete, explicit and legitimate purposes and will ensure that the information is not further processed in a manner that is incompatible with those purposes. If we intent to use your personal information for other purposes not specified in this Policy, we will obtain your consent at that time.
We may collect your personal information by the following means: 1) information you provide directly to us (such as your nickname, profile picture, name and phone number you provide to us when you login to your account or take part in the promotion activity we held); 2) information we obtain automatically during your use of this Application (such as device information, service log information); 3) information we obtain from other sources.
You have the right to choose whether or not to provide the personal information when you use Twibida and its Service or when we have requested. You are not required to provide your personal information to Twibida , but in some cases, if you choose not to do so, we will not be able to provide you with related products or services, nor will we be able to respond or resolve the problems you've encountered. We will collect and use your personal information only for the purposes described in this Policy. The following describes your personal information that we collect:
2.Key business functions of Twibida and scenes of collecting and using information in Twibida
This application mainly provides you with services such as notification push and personalized content push.
2.1 To provide you with notifications services
We may also send you service-related notifications, events, prize winning and other messages based on your device identifier (GAID), VAID, country/region, operating system language setting, phone brand and model, third-party application information (version of the application with access to the Service). To unsubscribe from pushing such notifications, you can withdraw your consent via Settings > Notification Centre > Notification Management, permission management may vary for different versions.
2.2 To provide you with personalized content push services
During your use of Twibida and its services, we may use your personal information that you have provided to us or our affiliated companies to create your user portrait and show you promotions you might be interested in (It may also include more relevant personalized advertising content). In this process, we will protect your privacy strictly. Your following information may be used to create a user group so as to create your personal profile (put your information in one or more fields):
- (1) Device location information: country/region/city;
- (2) Device information: device identifier (IMEI/GAID), phone information (model, brand, resolution), system information (OS version number, Android version number, Rom version number), device language;
- (3) Network information: network type, IP address, traffic consumption information, operator information;
- (4) Application usage behavior record: application opening times, application list, number of applications used, usage market, list of applications running in the background, application installation information;
Directional push will only be delivered to you with your consent and to the extent required by applicable law.
We may combine the above information with other information (including cross-service or computer, mobile phone and other connected device information) to provide and improve our products, services, content and advertisements. You can reserve the rights to cancel the receiving of personalized advertisements and to object to user portrait analysis at any time, including identity analysis for the purpose of direct marketing and automatic decision making. To exercise these rights, you can enable or disable such permissions in Settings at any time and you can also contact us via firstname.lastname@example.org . Permission management may vary for different versions.
2.3 To improve our products or services
We may also collect other information about you that we reasonably need to improve our products or services, including event information (message arrival, display and click and application notification turning off events) and application activity state in the background. We will process such information and generate statistical data to help us improve our push service in order to provide you with better service, content and recommendations.
3. Other situations in which your information may be collected
Where permitted by law, we may obtain your personal information from other individuals, business entities, public channels or other third parties acting at your direction, our partners who work with us to provide our products and services and assist us in information security and fraud prevention, and from other lawful sources. We will explain it to you at the time of such collection and obtain your consent.
We may also use other methods to collect other information about you, your device or your use of services, which will be explained to you at the time of collection and we will obtain your consent.
In order to better improve our product layout and provide you with great services, we may conduct research, statistical analysis and prediction on the collected information in an anonymized manner (including machine learning or model algorithm training by using anonymous data). We will take technical measures and other necessary measures to process such data, so that the data cannot be re-identified to specific individuals, nor can it be recovered. In accordance with the applicable laws and regulations, such processed data can be used without separately notifying you or obtaining your consent.
1. What are Cookies and Similar Technologies
III. How We Store and Protect Your Personal Information
1. How we store your personal information
The personal information collected with your consent will be stored in accordance with the laws and regulations on the personal privacy data protection of the countries concerned. To the extent not prohibited by local laws and regulations, we may also store the collected personal information in countries or regions outside the country where the business is located.
Currently, Twibida may store your personal information in: India, Ireland. In particular:
The personal information collected and generated during our operations in India will be stored on servers located in India.
The personal information collected and generated in our business outside India will be stored on servers in Ireland.
According to business conditions, we may use servers in other regions or countries in the future, and we will update this Policy at that time.
Whether we store personal information in the country where the business is located, or in other countries or regions to the extent that doing so does not violate laws and regulations, we will retain it in accordance with the relevant laws and regulations on data storage. At the same time, we will consider the characteristics, scope and purpose of personal information processing, the risks that may be encountered in the processing, and the serious consequences caused by the damage, etc., and implement the necessary security measures. For example, we will use encryption and de-identification methods to store the personal information collected. We will also keep the information for the shortest storage period specified by law. For those not specified by law, we will retain the information according to the shortest storage period required for business. For data that exceeds the storage period, or data that you request us to delete, we will delete said data accordingly or take other appropriate measures without violating the relevant laws and regulations.
2. How we protect your personal information
We will take other necessary measures to protect the security of your personal information and prevent data from being misused, unauthorized access, and unauthorized modification, disclosure or destruction, etc.
We implement security safeguards designed to protect your personal information and regularly monitor our systems for possible vulnerabilities and attacks, and we use administrative, technical, and physical safeguards to protect your personal information by taking the types of the personal information, the processing, and the threats posed themselves into account. We are constantly working to improve on these safeguards to keep your personal data secure.
Nevertheless, we need to remind you that no matter how perfect the measures are, there is no absolute guarantee of avoiding the occurrence of data storage security incidents. If a data breach event occurs, we will report it to the corresponding regulatory authorities as required by the relevant laws and regulations, and provide the type of personal data involved in the breach, the number of data subjects, the possible consequences of the breach, and the remedial measures we intend to take according to the requirements of the regulatory authorities. We will take the best possible measures to remedy or mitigate the damage and consequences of data breach. When permitted or required by laws and regulations, we will inform you of the possible consequences or significant damage to you in a timely manner, so that you can take appropriate measures promptly to protect your rights as much as possible.
There is no absolutely safe website, Internet transmission, computer system and wireless connections. In addition to the necessary protective measures we have taken, users have to strengthen the awareness of privacy security risks. For example, when you access third-party websites, links, products or services from our services, for the security of any data collected by those websites, links, products or services, please read through the terms and conditions of those third-parties carefully. We do not take any legal responsibility for data security issues caused by such third parties. If you find that certain contents, advertisements or features in our websites, products or services may be provided by a third party and may possibly endanger your privacy and security, please contact us promptly, as we will handle it with priority in accordance with laws and regulations.
IV. How We Share, Transfer and Disclose Your Personal Information
When sharing, transferring, and disclosing your personal information, we uphold the principles and requirements of minimization, necessity, and legality. Under normal circumstances, we do not share, transfer or disclose your personal information externally. However, to the extent permitted by applicable laws and regulations, we may share, transfer and disclose your personal information in the following situations:
1.How we share your personal information
We may share the necessary personal information with authorized third-party partners (including technical service providers, data storage service providers, etc.) for the performance of certain features or to provide you with better service and a better user experience. Specifically, we will use the cloud service of the cloud storage service provider to ensure that the push service can be offered normally. We uphold the principles of minimization, necessity, and legality to carry out such sharing. Before sharing information, we will sign strict confidentiality agreements with authorized partners and require them to take relevant confidentiality and security measures to process personal information in accordance with this Policy and applicable laws in your jurisdiction. In addition, we will also require them to provide data security capabilities and information security qualifications (e.g., grade protection assessment, information security management system). When we embed the third party SDK or other similar applications of authorized partners in this Application, we will notify you promptly and request the SDK service provider that obtains the information to protect your data security.
In order to provide evaluation, analysis or other business services, we may also share your non-personal information with third parties. For example, we may use aggregated data to help partners (e.g., application operator using Twibida , advertising service providers) understand the effectiveness, feedback and usage trends of their services.
In the event of a merger, acquisition or bankruptcy liquidation, asset transfer and other related transaction, if a personal information transfer is involved, we will require the new entity or organization holding your personal information to continue to be bound by this Policy through an agreement or other appropriate measures, and we will require such subject to take confidentiality and security measures of a degree no less than the requirements of this Policy to process personal information.
2. How we transfer your personal information
Twibida will not transfer your information to any other parties, except in the following circumstances:
- (1) Obtain your explicit consent.
- (2) If Twibida is involved in a merger, acquisition or sale of all or part of its assets, which may affect your personal information, we will issue a prominent notice via email and/or on our website or other appropriate methods to inform you of any changes in the ownership and your rights of your personal information, and any choices you may have about your personal information.
3. How we disclose your personal information
According to the legal requirements, legal procedures, litigation and/or requests from government departments and authorities, Twibida may need to disclose your personal information. If the disclosure is necessary or appropriate for national security, law enforcement, or other matters of public importance, we may also disclose information about you.
Additionally, we may share your personal information with:
- (1) Our attorneys, lawyers, accountants, auditors, or similar consultants, when we request them to provide professional advice.
- (2) Investors and other relevant third parties, if actual or potential sales or other company transactions occur and are related to entities within our group.
- (3) Other third parties, for example, the disclosure of specific information with your authorization.
V. How Your Personal Information is Transferred Across Borders
In the circumstance that we transfer personal information outside of your jurisdiction, whether it transferred to our affiliates or third-party service providers, we will comply with relevant applicable laws. We will take appropriate security measures and safeguards to make sure that all such transfers meet the requirements of applicable local data protection laws.
VI. Your Rights to Your Personal Information
As a data subject, you have a series of rights to your personal information, including the right to confirm, access, correct, delete, withdraw consent, and lodge complaints (hereinafter referred to as “request”). We fully understand and respect your rights, and such rights will be subject to specific exclusions and exceptions under applicable laws. We will also take active steps to ensure that your rights are effectively protected. However, please understand and note that for security reasons, we may need to verify your identity before processing your request. In principle, we do not charge a fee for your lawful and reasonable request, but we will charge a certain reasonable fee for repeated requests that exceed the reasonable limit where applicable, and based on actual administrative costs permitted by the applicable laws. We may reject requests that are unreasonably repetitive, require excessive technical means (for example, to develop new systems or fundamentally change existing practices), pose risks to the legal rights of others or are extremely impractical, or violate the mandatory provisions by law.
1. Right to confirm and access
2. Right to correct and delete
However, we may not grant your deleting request in some situations, for example, if you ask us to delete your transaction data when we are legally obligated to keep a record of that transaction to comply with the applicable local law. Please also kindly note that if you request to delete your information from our products and services, we may not remove the corresponding information from the backup system immediately due to some applicable local laws and technological limitations, however, we will securely store your personal information and isolate it from any further processing until the backup is updating or can be deleted or be made anonymous.
3. Right to withdraw consent
To achieve the respective features of our various products or services, we will require necessary personal information in accordance with the applicable local laws. This is described in the "How We Collect and Use Your Personal Information" part of this Policy. You can withdraw your consent previously granted to us for a specific purpose by deleting information, turning off device features, and requesting to withdraw consent, including the collection, use and/or disclosure of your personal information that we manage or control. You can email us at email@example.com for above operations. We will process your request within a reasonable time after you send the request, and thereafter will not collect, use and/or disclose your personal information in accordance with your request.
If you withdraw your consent, you may not be able to continue receiving the part and/or full benefit of Twibida and its Service. The withdrawal of your consent or authorization will not affect the validity of our previous processing activities based on your consent.
4. Right to complain
You have the right to lodge a complaint by sending us an email at firstname.lastname@example.org . We will respond promptly after receiving your complaint. If you are unsatisfied with our response, especially if our processing of personal information violates your legitimate rights and interests, you may refer your complaint or report to your local statutory personal data protection department, or file a lawsuit with a competent court.
5. Right to control your privacy settings
You have the right to control your privacy settings and restrict our collection, use, disclosure, or processing of your personal information via such privacy settings. For example, you can prefer turn on or turn off the permissions of “Location Access”, “Camera”, “Text Message”; you can also obtain detailed information regarding the device security status in “Settings”. If you have agreed to such permission or have agreed to our use of your information previously for the above-mentioned scenarios. You can turn it off via Settings > App management > Permission management or contact us via email@example.com to change your decision.
6. Right to cancel services or account
You can request to cancel your account through the cancellation path provided in this Service or by contacting us via firstname.lastname@example.org . Please exercise utmost prudence when you cancel your account. You acknowledge and understand that, upon cancellation of your account, we will cease to provide products and services on the basis of the account. Unless otherwise required by the applicable laws in your region, we will delete corresponding personal data under your account. If you log in this Service via an account authorized by a third party, please apply to the third party for account cancellation.
7. Rights in some jurisdictions
Particularly, according to the applicable laws of some jurisdictions, you may have the following data subjects rights:
- (1) Right to restriction processing. You have the right to request our restriction on the processing of your personal information. We shall consider the grounds regarding your restriction request. If the grounds are in the compliance with applicable data protection laws, we will process your personal information under applicable circumstances in such laws and notify you before the restriction of processing is lifted.
- (2) Right to automated decision-making. You have the right to refuse the processing based on automated decision-making, including profiling and other automated processing which may have legal or similar effects on you.
- (3) Right to data portability. You have the right to apply for your personal information to be transmitted to another data controller in a structured and commonly used format.
We have the right to refuse to process your requests or only respond to some of your requests where an exemption applies or when we are otherwise entitled to do so under applicable laws, for example, some requests are manifestly unfounded or obviously excessive or it requires the disclosure of information of third parties.
VII. How We Handle the Personal Information of Children
Twibida does not provide our products or services to children under the age of 14 or the equivalent age as specified by law in your jurisdiction (we will define children mainly based on the laws and regulations of the country or region where our business is located because laws of different countries may differ when defining the age of children). We do not knowingly collect children’s personal data or use children’s personal information for the purposes of marketing. If you find that a child’s information has been collected to us, please send an email to email@example.com to contact us. We will remove the relevant information as soon as possible. If we become aware that a child has provided us with personal information, we will take steps to delete their personal information from Twibida as soon as possible.
VIII. Third-Party Service Providers and Services
IX. Supplement and Update of the Policy
The content of Twibida and its services described herein may vary according to the type of product you use, your system version, or requirements of local laws and regulations.
X. How to Contact Us
We will review your privacy or personal information requests as soon as possible and respond to you in 15-30 days after verifying your user identity. If your request itself involves any complicated or significant issue, we may ask you for more information.
If you are not satisfied with our response, especially when you believe that your legitimate rights and interests have been violated by us, you can seek remedy from relevant data protection regulatory authority in your jurisdiction. If you consult us, we will provide information on the relevant complaint channels that may be applicable based on your circumstance.