Twylo - Privacy Policy

Last Updated: 13th January 2025

Welcome to Twylo!
Your privacy is important to us. This Privacy Policy explains how we collect, use, and protect your personal data when you use Twylo, a social network focused on meaningful connections.

1. Who We Are
Twylo is operated by:
Company Name: schantastic (Julian Schanta)
Contact Email: twylo-app@schantastic.com
Address:
Mattersburger Straße 26
7000 Eisenstadt
AT Austria

As a company based in Austria, we comply with the General Data Protection Regulation (GDPR) and other applicable privacy laws.

2. Information We Collect

We collect information you provide directly to us, automatically through the app, and from third-party services.

2.1 Information You Provide

• Account Data: Name, email, gender, date of birth, profile photo, hobbies, and city.

• User-Generated Content: Messages, photos, and profile details.

• Social Media Data: If linked, your public profile and shared data from platforms like Facebook or Google.

2.2 Information We Collect Automatically

• Location Data: Real-time GPS location to suggest nearby users (requires your consent).

• Device Data: IP address, device type, operating system, and app usage data.

• Usage Data: Interaction with the app (e.g., chats, likes, matches).

2.3 Information From Third Parties

• Firebase Services: Authentication, analytics, and crash reporting.

• Payment Providers: If you subscribe to Twylo Gold, we collect transaction IDs but do not store payment details.

3. How We Use Your Information

We use your information to provide, improve, and personalize the Twylo experience. This includes:

• Matching users based on preferences and location.

• Providing communication features (e.g., chats).

• Ensuring safety by monitoring suspicious activity.

• Sending notifications about matches, messages, or updates.

• Conducting analytics to optimize app performance.

• Complying with legal obligations.

4. Legal Bases for Processing

Under the GDPR, we process your data based on:

1. Consent: For location services and optional features.

2. Contract: To provide the services you signed up for.

3. Legitimate Interests: Fraud prevention, safety, and app improvement.

4. Legal Obligations: To comply with laws or respond to legal requests.

5. Sharing Your Information

We do not sell your personal data. We may share your information under the following circumstances:

5.1 With Service Providers

•Hosting & Cloud Providers: Firebase (Google LLC) for secure data storage and app functionality.

•Analytics: To understand app usage patterns.

•Crash Reporting: To resolve issues and improve reliability.

5.2 For Legal Compliance

We may disclose your data if required by law, regulation, or court order.

5.3 With Your Consent

You can control sharing settings in your profile.

5.4 During Business Transfers

In case of a merger, acquisition, or sale of assets, your information may be transferred, but you will be notified.

6. How We Protect Your Information

We implement robust security measures to protect your data, including:

•Encryption: Data in transit is secured using SSL/TLS.

•Access Control: Restricted access to sensitive data.

•Regular Security Audits: To identify and address vulnerabilities.

While we strive to protect your data, no system is 100% secure. Use strong passwords and avoid sharing sensitive information in chats.

7. Your Privacy Rights
Under the GDPR and other applicable laws, you have the following rights:

7.1 Access Your Data
Request a copy of the data we hold about you.

7.2 Correct Your Data
Update or correct inaccurate information.

7.3 Delete Your Data
Request the deletion of your account and associated data.

7.4 Restrict Processing
Limit how we use your data in certain circumstances.

7.5 Data Portability
Request a copy of your data in a machine-readable format.

7.6 Withdraw Consent
Disable location sharing or other features that require consent.

To exercise these rights, contact us at twylo-app@schantastic.com.

8. Data Retention

We retain your data only as long as necessary:

• Location Data: Deleted after 30 days.

• Account Data: Retained until you delete your account.

• Backup Data: Stored for up to 90 days for recovery purposes.

After retention periods, data is securely deleted.

9. Data Transfers
Your data may be processed on servers located outside your home country. For users in the EU, we ensure GDPR-compliant safeguards, such as Standard Contractual Clauses (SCCs) with service providers like Google.

10. Cookies and Tracking

We may use cookies or similar technologies for:

• Authentication and login persistence.

• Analytics to track user behavior.

• Push notifications and user preferences.

You can control cookies through your device settings.

11. Children’s Privacy
Twylo is not intended for users under 18. If we discover data from a minor, we will delete it immediately.

12. Updates to This Policy
We may revise this Privacy Policy from time to time. Significant changes will be notified through the app or email. Check this page regularly for updates.

13. Contact Us
If you have any questions about this Privacy Policy, reach out to us:
Email: twylo-app@schantastic.com
Address:
Mattersburger Straße 26
7000 Eisenstadt
AT Austria