Privacy Policy


Effective Date: January 15th, 2019


Twiddle Inc. is committed to respect and protect your privacy. This Privacy Policy is incorporated into the Terms of Use which may be found at www.twiddle.me. The terms “Company,” “we,” and “us” refer to Twiddle Inc. Please read this Privacy Policy, as it explains how we may COLLECT, USE, and DISCLOSE information -including personal data- through the Service. If you do not agree with the way we process personal data in accordance to this Privacy Policy (in whole or any part) then you should not use the Service.

Information we COLLECT concern:

(1) Information and personal data you choose to give us. This includes information you provide when you register or log in to use the Service with your credentials, such as your name and surname, unique username, password, email address, date of birth, ip address (in relation to our website), credentials to other social network in case you register to our Service through them, additional information that you choose to share and make publicly visible, such as profile pictures or profile videos, and in case of transactions a debit or credit card number. It also includes any audio that you upload to our service, information in your posted videos including any text in them, and comments exchanged with friends -including any Personal Information- in the context of composing, sending, or receiving messages through our Service. These are available to other users to see, save, copy, or use outside the Service, so always use common sense and don’t send or share content that you wouldn’t want someone to see, save, or share, neither post information that may affect your privacy or even put you -or others- in danger.

(2) Information we get while you use our service. This concerns information about your usage of the service, about your published content, your location (not using GPS data), time zone, videos and photos, your device, app version, and information collected by cookies and Related Technologies. For example, we collect information about your activity such as which audio files, filters, or gifs you prefer, your activity on third-party links or services or integrations like links to providers of audio to or through our App, the time, date, extend of your communication, how you interact in messages and with which people and information about how many and which people viewed the content, your user-generated content and video content that you upload on our App, hashtag to mark keywords to the video or comments, as well as behavioral information, for example, collecting engagement scores (likes, comments, repeated views) and marketing information such as opt-ins and communication preferences. We also may collect information about the devices you use including the hardware model, operating system version, device memory, advertising identifiers, apps installed, language and time zone, information from device sensors, such as accelerometers, microphones and whether you have headphones connected, and information about your mobile network connections and service provider, information from your phonebook (if you choose to enable such feature), images from your videos, your precise location (upon your consent), information collected by cookies (like advertising identifiers) which collect information about your activity and interaction. Additionally, we collect information regarding your interaction with our partners, as well as usage statistics -including your preferences- through the use of logs, cookies, and other similar technology, which is generated automatically as you use the Service. We may also use third party cookies on our Service as well, to collect and process certain analytics data. Our third party analytics tool is Microsoft Azure Application Insights provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-7329, USA.

(3) Information we get from third parties. This concerns information originating from other users interacting with you when they use our service, for instance when they make a “follow” request to you. For example, if another user allows us to collect information from their device’s phonebook -and you’re one of that user’s contacts- we may combine the information we collect from that user’s phonebook with other information we have collected about you. We may also obtain information from our affiliates or any other third-party sources, and combine that with the information we collect through our services. We may also receive information from third party SDKs (such as Facebook). For further information as to how and for what purpose that social network provider processes your Personal Data, please see their privacy policies.

Finding users & inviting friends: You may find other users either through (i) your phone contacts or (ii) Facebook contacts. If you chose to find other users through your phone contacts, we will access your phone contacts, including the names, phone numbers, addresses and any other information that you have stored on your phone about your contacts in order to determine if they are using the App by matching them with existing users of the App. If you want to find other users through your Facebook contacts, we may process your public Facebook information as well as names and profiles of your Facebook contacts in accordance with the provisions of the privacy policy of Facebook. You may also invite selected recipients to join our App by sending them an e-mail with your profile information.

(4) Information we get when you voluntarily communicate with us. This concern information you’re providing on your communication with us through our site, our provided emails, or any other way.


The Information we collect may be USED to:

  • Provide you with, and continuously improve, our product
  • Facilitate the development, operation, maintenance, and protection of our products and services
  • To communicate with you, for example we may use your email to respond to support inquiries, to share information that we think may interest you about our products, services, and promotional offers, to provide you with updates relating to our product, to notify you about changes to our Services, or to enforce the Terms of Use or this Privacy Policy
  • To analyze usage and trends in the use of our product
  • To store information as local cache on your device, so that you can open the app and view content faster
  • To use information, including personal information, for service-related purposes, which may include to provide it to third parties for the purpose of improving our services. For example, we may scan any sound recordings in the local library on your mobile device to identify such content
  • Personalize the services like, but not limited to, customizing the content provided, suggest friends or include ads
  • Verify your identity and prevent unauthorized or illegal activity
  • To verify your age and ensure that you are old enough to use our Services
  • To allow other users to identify you via the "Find other friends" function as a user of the Service as well as your phone contacts to find other users and to connect you
  • To show you content that is similar to content you liked or interacted with
  • We may use the content you upload in an aggregated anonymous way, to train AI services.
  • Improve your user experience, as well as improve ad targeting and measurement by using -upon your permission - your precise location data
  • To provide you with services based on the country settings you have chosen
  • Use information we’ve collected from cookies and other related technology to enhance your experience in using our service
  • Enhance the safety and security of our products and services


We may SHARE the information in the following ways:

  • With other users, including information about you such as your username, full name, the users you follow, the users following you, the users you have in common. Your profile information is also searchable and accessible by other Users, and we do not hold responsible for the privacy practices of the other users. Thus, you should always be careful about the content and personal information that you upload, post, or make available in any way through the service, and avoid disclosing information about your home address, locations of frequent visit, school, or place of business
  • With our third party providers, business partners, our affiliates, and the general public, we may share your public information, like your full name, username, profile pictures, content you submit to our platform or any other service. If your content is broadcasted in other media or on the web, it may be viewed by the public or be rebroadcasted by others. In any such case the use of your personal information by other media will be governed by their own privacy policies, and you may be able to modify those via the settings on their own services
  • With service providers, sellers, vendors, and partners that provide services and functionality or perform services on our behalf or provide goods through our services in connection with the provision of our service
  • We may share with other users information that you wish to provide about what you will do or about your approximate location by time based on content or text that you may upload and/or tag in your posts
  • With third parties such as advertisers, we may share non-personally identifiable or de-identified information in an aggregated manner.
  • Wherever required in order to comply with legal obligations, if we reasonably believe that disclosing such information is needed to comply with applicable law, regulation, legal process, governmental request, or protect and defend the safety, rights, and property of users, us, or others, as well as to investigate violations of the Terms of Use and Privacy or detect and resolve fraud
  • With third parties involved in any mergers, acquisitions (full or partial), financing, asset sale, transition of the service to another provider, liquidation, reorganization, bankruptcy, both before and after the transaction closes
  • We do not share, sell, or rent personal information with non-affiliated or other third parties for their direct marketing purposes, without your permission. We may however disclose your personal information with your permission.
  • If you receive communications from third parties in any way relating to our service, you are solely responsible for your engagement with such third parties


Information Security

We take the security of your personal information seriously and we take appropriate technical and organizational steps to ensure that your personal information will be secure against unauthorized or unlawful processing and accidental loss, destruction or damage. However, since the internet is not 100% secure, we cannot warrant the security of the information you provide, neither we accept any liability for unintentional access and use of it.

Data Retention: If your account is terminated, we delete your Personal Data immediately, and they will not be possible to retrieve. After you have terminated your use of our services, we may store your information in an aggregated and anonymized format. We may also retain any personal information in cases it is reasonably necessary to comply with our legal obligations, enforce our agreements, and allow us to resolve and litigate disputes.


Children

We do not knowingly collect, maintain, or use Personal Information from children under the age of 13 years. Our services are not intended for children under 13. If we learn that we have collected any personal information from children under 13, then we will promptly take steps to delete such information and terminate the corresponding account.

Specifically concerning users in the European Union, the corresponding minimum age is 16 years old (or the lower age that your country has provided for you to consent to the processing of your personal data), so our services are not intended, and we do not collect, maintain, or use Personal information from children under the age of 16.

If you believe that we may have Personal Data about or collected from a child under the specified age in the relevant jurisdiction without the consent of their parent or guardian, please contact us at privacy@twiddle.me.


International Users

We welcome users from all the parts of the world where our service is provided. Please keep in mind that your personal information may be shared with us, collected, transferred to, stored and processed in the United States, Greece, and other countries outside of where you live.

If you will be using our service from the European Union or other regions with laws governing data collection and use, please note that we are committed to protecting and respecting your privacy and data, and to comply with the General Data Protection Regulation ("GDPR") in effect for Member States of the European Union.

Our data protection officer may be contacted at dpo@twiddle.me.

Where We Store Your Personal Data: We transfer your Personal Data to the servers of our host provider Google Cloud Services in the United States of America. Any video content of the users is also transferred to the servers of our host provider Google Cloud Services using the Cloud Storage in the United States of America, Europe and Asia Pacific. It may also be processed by staff operating in Greece who work for us, or outside your country where you live or the European Union, for one of our suppliers or one of our business partners.

By using the Service, you consent to any transfer and processing in accordance with this Privacy Policy, as well as in accordance to all the Terms of Use, which may be found at www.twiddle.me/Terms-Of-Use. By choosing to visit or use the Service, or/and provide any information to us, you agree that any dispute in relation to the terms contained in this Privacy Policy and our Terms of Use will be governed by the laws of the State of California.

Your Rights: You have the right to require free of charge information about your personal data that we hold about you and to correct, update, amend, suppress, delete (unless we have to keep it for legal or legitimate purposes), or otherwise modify any personal data if it is inaccurate.

If the processing of your personal data is based on your consent, you have the right to withdraw your consent at any time, this is without impact to data processing activities that have taken place before such withdrawal. If you object the processing of your personal data, we may ask you the grounds of your objections so we may examine alternative adjustments. You also have the right to take legal actions in relation for any breach of your rights regarding the processing of your personal data. In cases where we permit selected third parties to provide you with information about goods or services we feel may interest you, they will contact you by electronic means only if you have consented to this (Art. 6 (1) lit a GDPR).


Analytics, Advertising, and Third-Party Integrations

We may use information collected through our services regarding the performance of audio used by the users, as well as the performance of ads so as to deliver more relevant and user focused content on behalf of us or other companies.

We may also collect information about your activity on third-party links or services or integrations, like for example links to providers of audio to or through our App, by using cookies and other related technologies. We may also let other companies use cookies, web beacons, and similar technologies on our services. Either us or these third-party companies may collect information about how you use our services over time and combine it with similar information from other services and companies for the purpose of determining the popularity of certain content, as well as for improving advertising services, and better understand your online activity.

Through such third-party links, you may be providing personal information directly to the third party. You acknowledge and agree that we are not responsible for how any such third party collects or use your information. As always, we encourage you to review the privacy policies of every third-party service that you visit or interact in any way through our services.

Analytics: We use third-party analytics tools to help us measure traffic and usage trends for the Services. These collect information sent by your device or our Services, including the web pages you visit and other information that assists us in improving the Service. Our third party analytics tool is Microsoft Azure Application Insights provided by Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-7329, USA. For information on how Microsoft Azure Application Insights collects and processes information please refer to Microsoft Azure Online Services Terms & Microsoft Privacy Statement.


Updating And Controlling Your Information

You can access and update basic account information via your user profile, as well as -depending on the platform of your device- change any settings through the Settings page of the App. If you need to access, update, or delete other personal information that we may have, you can send a request to our data protection officer at privacy@twiddle.me. For reasons of security we may ask you to verify your identity or provide additional information in advance. We intend to update your information for free, but if it would require a disproportionate amount of effort we may charge a fee, that we’ll communicate with you in advance for your approval.

Please also note that there are limits in the requests we may accommodate, and we may also reject requests for reasons such as, for example, that they might risk the privacy of other users, have repetitive character, requires disproportionate technical effort, or is not lawful.

And, while we hope you’ll be a lifelong user of Twiddle, if for some reason you ever want to delete your account, you can contact us at contact@twiddle.me and we will take care of this for you, or -depending on the platform of your device- you may do this by yourself, please go to the section “profile settings” and chose the option “delete account”. You will be asked to type your password, to confirm the action. Upon deletion, your account and data will be deleted permanently from our servers and will not be possible to retrieve later.


Privacy Policy Revisions

We may, from time to time, make any adjustments to the Privacy Policy. In any such case the revised version will be effective when it is posted. We will use commercially reasonable efforts to let you be aware either by revising the date at the top of the Privacy Policy available on our website and your mobile application (please review it periodically if you are concerned about how your information is used), or we may add a statement on our website’s homepage or provide you with an in-app notification. Your continued access to or use of the Services after the date of the updated Policy constitutes your acceptance of the updated Policy. If you do not agree to the updated Policy, you must stop accessing or using the Services.


If You Have a Question or Suggestion

We welcome your constructive suggestions for improving this Privacy Policy. For suggestions or questions please contact us preferably by email at privacy@twiddle.me , or otherwise by postal mail at:

Twiddle, Inc.
2100 Geng Rd., Suite 210
Palo Alto, CA 94303