Twickr Privacy Policy

At Twickr, we believe privacy is a fundamental part of trust. This Privacy Policy explains how Twickr ("Twickr", "we", "our", or "us") collects, uses, stores, protects, shares, and processes information when you access or use the Twickr platform, websites, applications, products, features, and services (collectively referred to as the "Service").

By creating an account, accessing, or using Twickr, you acknowledge that you have read and understood this Privacy Policy and agree to the collection and processing of information as described herein.

1. Information We Collect

We collect information necessary to operate, improve, secure, and personalize the Twickr experience.

• Account Information: username, email address, profile photo, cover photo, biography, account settings, and authentication credentials.
• User Content: posts, comments, reactions, messages, photos, videos, SoundBites, uploads, media files, profile information, and other content you choose to publish.
• Device Information: IP address, browser type, operating system, hardware model, language preferences, network information, device identifiers, and crash diagnostics.
• Usage Information: interactions with content, engagement metrics, searches, feature usage, session duration, clicks, views, and navigation activity.
• Location Information: approximate or precise location data where enabled by you or required for platform functionality.
• Communications: support requests, feedback submissions, moderation appeals, and communications with Twickr.

2. SoundBites & Record Label Data

SoundBites allow users to create and share short audio experiences, voice clips, reactions, and creative recordings within Twickr. This includes music, podcasts, and other audio content that may be associated with record labels, publishers, or other rights holders.

When you use SoundBites, Twickr may process:

• Audio recordings uploaded by users.
• Audio metadata such as duration, upload time, and engagement information.
• Record label information, publisher details, and rights holder metadata when provided.
• Interactions including likes, saves, shares, comments, and discovery activity.
• Reports related to harmful, abusive, or unauthorized audio content.
• Copyright infringement claims and DMCA takedown notices.

SoundBites data is used to provide audio features, improve discovery, maintain platform safety, prevent abuse, and enhance user experiences.

Record Label & Rights Holder Information

When you upload SoundBites associated with record labels or third-party rights holders, Twickr may process additional information including:

• Record label names, logos, and branding provided by users.
• Artist names, performer credits, and songwriter information.
• Publisher details and licensing information when provided.
• Copyright claims, takedown notices, and counter-notices.
• Communications with rights holders regarding content authorization.

Twickr may share information with record labels, publishers, or rights holders when necessary to:

• Respond to valid copyright infringement claims or DMCA notices.
• Verify authorization for uploaded audio content.
• Comply with legal obligations or court orders.
• Protect intellectual property rights.
• Investigate claims of unauthorized content distribution.

Users are responsible for ensuring they have permission to upload any voices, music, sounds, or recordings shared through SoundBites, and for obtaining all necessary licenses from record labels, publishers, and other rights holders.

3. Verification & Identity Verification Data

Twickr offers a voluntary identity verification program that allows users to request a verification badge to confirm their authenticity.

Verification Data Collection

For identity verification purposes, Twickr may collect and process the following sensitive information:

• Government-issued identification documents (e.g., national ID card, passport, driver's license)
• Personal identification information including full legal name, date of birth, and identification numbers
• Photographs of identification documents submitted through the verification request system
• Selfie photographs for identity confirmation purposes
• Additional documentation or evidence as requested by Twickr verification administrators
• Timestamps and metadata related to verification request submission and review
• Administrative notes and review decisions regarding verification requests

How Verification Data Is Used

Twickr processes verification data for the following legitimate purposes:

• Identity verification to confirm user authenticity and prevent impersonation
• Age verification to ensure compliance with age restrictions and legal requirements
• Preventing fraud, fake accounts, and abusive behavior
• Enhancing platform security and trustworthiness
• Compliance with legal and regulatory obligations
• Reviewing and processing verification requests by authorized administrators
• Displaying verification badges to users who successfully complete the verification process

Verification Data Protection

Twickr implements industry-standard security measures to protect verification data:

• All verification documents are stored securely using Firebase Storage with encryption in transit and at rest
• Verification data is only accessible to authorized Twickr administrators with admin privileges
• Access to verification documents is logged and audited regularly
• Verification documents are deleted immediately after the verification request is approved or rejected
• Verification metadata (approval status, timestamps) may be retained for audit and compliance purposes
• Verification data is never shared with third parties except as required by law
• Verification data is never used for advertising, marketing, or commercial purposes

Your Rights Regarding Verification Data

You retain the following rights regarding your verification data:

• Participation in verification is voluntary and optional
• You may withdraw your verification request at any time before review
• You may request deletion of your verification data at any time
• You may request access to what verification data Twickr holds about you
• Verification data will be permanently deleted upon account deletion
• You may request correction of inaccurate verification data

Legal Basis for Verification Data Processing

Where applicable under laws such as the General Data Protection Regulation (GDPR), verification data is processed based on:

• User consent (explicit consent for identity verification)
• Contractual necessity (providing the verification service)
• Legitimate interests (preventing fraud, ensuring platform integrity)
• Legal obligations (compliance with identity verification regulations)
• Vital interests (preventing identity fraud or platform abuse)

Data Retention for Verification

Verification data retention follows these principles:

• Verification documents (ID photos, selfies) are deleted immediately after verification review
• Verification metadata may be retained for audit and compliance purposes
• All verification data is permanently deleted upon account deletion
• Users may request deletion of verification data at any time through account settings or support request

4. How We Use Information

We use information to:

• Provide and maintain the Service.
• Create and manage user accounts.
• Authenticate users and prevent unauthorized access.
• Deliver personalized feeds, SoundBite discovery, and recommendations.
• Improve platform performance and reliability.
• Protect users against abuse, spam, fraud, harassment, and illegal activity.
• Investigate violations of our Terms of Service.
• Comply with legal obligations and lawful requests.
• Develop new features, services, and functionality.
• Send account, security, and service-related notifications.

5. Legal Bases For Processing

Where applicable under laws such as the General Data Protection Regulation (GDPR), Twickr processes personal information under one or more of the following legal bases:

• Your consent.
• Performance of a contract.
• Legitimate business interests.
• Compliance with legal obligations.
• Protection of vital interests.
• Public interest or regulatory requirements.

6. Data Sharing & Disclosure

Twickr does not sell personal information.

We may share information only when reasonably necessary, including:

• With infrastructure providers such as Firebase and Google Cloud for storing posts, media, and SoundBites.
• With payment processors if premium services become available.
• To comply with court orders, subpoenas, or lawful government requests.
• To investigate fraud, abuse, threats, or violations.
• To protect the safety, rights, and security of users and the public.
• During mergers, acquisitions, or business transfers.

6. Security

We implement administrative, technical, and organizational safeguards designed to protect personal information against unauthorized access, loss, alteration, disclosure, or destruction.

Despite our efforts, no technology platform can guarantee absolute security. Users are responsible for maintaining the confidentiality of their credentials.

7. Data Retention

We retain information only as long as reasonably necessary for business, security, legal, operational, and regulatory purposes.

Certain information may remain in backups, archives, security logs, or legal records after deletion requests where permitted or required by law.

8. International Data Transfers

Your information may be processed and stored in countries outside your jurisdiction where Twickr or its service providers operate.

By using Twickr, you consent to such transfers where permitted by law.

9. Your Privacy Rights

• Access personal information.
• Correct inaccurate information.
• Request deletion of personal information.
• Object to certain processing activities.
• Request portability of eligible information.
• Withdraw consent where applicable.

10. Children's Privacy

Twickr is not directed toward children under the age of 13. Users under applicable minimum age requirements may not create accounts.

If we discover that personal information has been collected from a child in violation of applicable law, we will take reasonable steps to delete it.

11. Third-Party Services

The Service may integrate with third-party technologies and providers. Those providers operate under their own policies and practices.

Twickr is not responsible for third-party privacy practices.

12. Changes To This Privacy Policy

We may revise this Privacy Policy from time to time. Updated versions become effective upon publication unless otherwise stated.

Continued use of the Service after modifications constitutes acceptance of the updated Privacy Policy.

13. GDPR Compliance

Twickr is committed to complying with the General Data Protection Regulation (GDPR) and other applicable data protection laws. This section outlines our GDPR compliance framework.

Lawful Basis for Processing

We process personal data based on one or more of the following lawful bases under GDPR:

• Consent: You have given clear, informed consent for us to process your personal data for specific purposes.
• Contractual Necessity: Processing is necessary for the performance of our contract with you to provide the Service.
• Legitimate Interests: Processing is necessary for our legitimate business interests, provided your interests and fundamental rights do not override those interests.
• Legal Obligation: Processing is necessary for us to comply with applicable laws and regulations.
• Vital Interests: Processing is necessary to protect your vital interests or those of another person.
• Public Task: Processing is necessary for the performance of a task carried out in the public interest.

Data Subject Rights

Under GDPR, you have the following rights regarding your personal data:

• Right to Access: You may request access to the personal data we hold about you, including information about the purposes of processing, the categories of data concerned, and the recipients to whom data is disclosed.
• Right to Rectification: You may request correction of inaccurate or incomplete personal data.
• Right to Erasure: You may request deletion of your personal data where the data is no longer necessary for the purposes for which it was processed, or where you withdraw consent and there is no other lawful basis for processing.
• Right to Restrict Processing: You may request restriction of processing where you contest the accuracy of the data, processing is unlawful but you oppose erasure, we no longer need the data but you require it for legal claims, or you have objected to processing.
• Right to Data Portability: You may request transfer of your personal data in a structured, commonly used, machine-readable format, or request that we transfer it directly to another controller where technically feasible.
• Right to Object: You may object to processing based on legitimate interests, processing for direct marketing, or processing for scientific or historical research purposes.
• Right to Withdraw Consent: Where processing is based on consent, you may withdraw your consent at any time without affecting the lawfulness of processing based on consent before its withdrawal.
• Right to Lodge a Complaint: You have the right to lodge a complaint with a supervisory authority in the European Economic Area if you believe our processing of your personal data infringes GDPR.

Data Controller & Representative

Twickr acts as the data controller for personal data processed through the Service. Our data protection officer can be contacted at the contact information provided in this Privacy Policy.

Where required by GDPR, Twickr has appointed a representative in the European Economic Area to facilitate communication with data subjects and supervisory authorities.

Data Protection Impact Assessments

Twickr conducts data protection impact assessments where processing is likely to result in a high risk to the rights and freedoms of individuals, particularly when using new technologies or processing special categories of personal data.

Such assessments evaluate the necessity and proportionality of processing, assess risks to individuals, and identify measures to mitigate those risks.

International Data Transfers

Twickr may transfer personal data to countries outside the European Economic Area where such transfers are necessary for the operation of the Service and where appropriate safeguards are in place to protect your personal data.

Such safeguards may include standard contractual clauses approved by the European Commission, binding corporate rules, adequacy decisions by the European Commission, or other appropriate legal mechanisms.

14. CCPA Compliance

Twickr is committed to complying with the California Consumer Privacy Act (CCPA) and other applicable state privacy laws. This section outlines our CCPA compliance framework.

California Resident Rights

If you are a resident of California, you have the following rights under the CCPA:

• Right to Know: You may request disclosure of the categories of personal information we have collected about you, the categories of sources from which we collected personal information, the business or commercial purpose for collecting or selling personal information, and the categories of third parties with whom we share personal information.
• Right to Delete: You may request deletion of personal information we have collected about you, subject to certain exceptions provided by law.
• Right to Opt-Out: You may direct us not to sell your personal information. We do not sell personal information as defined by the CCPA.
• Right to Non-Discrimination: We will not discriminate against you for exercising your CCPA rights, including by denying goods or services, charging different prices, or providing a different level or quality of goods or services.

Request Process

To exercise your CCPA rights, you may submit a request through your account settings or by contacting Twickr support at the contact information provided in this Privacy Policy.

We will verify your identity before processing your request and will respond within the timeframes required by law.

Authorized Agents

You may designate an authorized agent to make requests on your behalf under the CCPA. We will require verification of your identity and the authorized agent's authority before processing such requests.

15. Data Breach Notification

Twickr maintains incident response procedures to detect, investigate, and respond to data security incidents.

In the event of a personal data breach that is likely to result in a risk to the rights and freedoms of individuals, Twickr will notify affected individuals without undue delay and, where feasible, not later than 72 hours after becoming aware of the breach.

Such notifications will include:

• Description of the nature of the personal data breach, including the categories and approximate number of data subjects concerned.
• Name and contact details of the data protection officer or other contact point where more information can be obtained.
• Description of the likely consequences of the personal data breach.
• Description of the measures taken or proposed to address the personal data breach, including measures to mitigate its possible adverse effects.

Where required by law, Twickr will also notify supervisory authorities of personal data breaches without undue delay and, where feasible, not later than 72 hours after becoming aware of the breach.

16. Third-Party Processors

Twickr may engage third-party service providers to process personal data on our behalf for the purposes described in this Privacy Policy.

Such third-party processors are selected based on their ability to provide appropriate security measures and are bound by contractual obligations to protect personal data in accordance with applicable data protection laws.

Third-party processors may include:

• Cloud infrastructure providers (e.g., Firebase, Google Cloud)
• Analytics and measurement services
• Customer support and communication platforms
• Security and fraud prevention services
• Content moderation and safety services
• Payment processing services (if applicable)
• Email and notification services

Twickr remains responsible for ensuring that third-party processors process personal data in accordance with our instructions and applicable data protection laws.

17. Data Retention Policies

Twickr retains personal data only for as long as necessary for the purposes for which it was collected, or as required by law.

Account Data

Account data is retained while your account is active and for a reasonable period after account closure for legal, security, and business purposes.

User Content

User content is retained while your account is active and may be retained after account deletion where required by law or for legitimate business purposes, such as evidence of violations or legal claims.

Security Logs

Security logs and access records may be retained for extended periods for security analysis, fraud prevention, and legal compliance purposes.

Legal Holds

Where Twickr is subject to legal holds, litigation, or regulatory investigations, data may be retained beyond standard retention periods until the legal hold is lifted.

18. Special Categories of Personal Data

Twickr does not collect or process special categories of personal data (sensitive data) such as racial or ethnic origin, political opinions, religious beliefs, biometric data, health data, or data concerning sex life or sexual orientation, except where:

• You have given explicit consent to such processing.
• Processing is necessary for the establishment, exercise, or defense of legal claims.
• Processing is necessary for reasons of substantial public interest in the area of public health.
• Processing is necessary for archiving purposes in the public interest, scientific or historical research purposes, or statistical purposes.
• Processing is necessary for the provision of health or social care services.

19. Automated Decision Making

Twickr may use automated systems for certain aspects of the Service, including content moderation, spam detection, and fraud prevention.

Where automated decision making has legal or similarly significant effects on you, you have the right to request human intervention, express your point of view, and obtain an explanation of the decision and challenge the decision.

20. Children's Privacy (Enhanced)

Twickr is not directed toward children under the age of 13 and does not knowingly collect personal information from children under 13.

If we discover that we have collected personal information from a child under 13 without parental consent, we will take immediate steps to delete such information.

Parents and guardians may contact Twickr to request access to, correction of, or deletion of personal information collected from their children.

We may request verification of parental or guardian identity and authority before responding to such requests.

21. Contact Information

Questions regarding privacy, data protection, or your rights under GDPR, CCPA, or other data protection laws may be directed to:

Email: twickrsupport@gmail.com
Phone: +256 756 521 424

For GDPR-related inquiries, please include "GDPR Request" in the subject line of your email.

For CCPA-related inquiries, please include "CCPA Request" in the subject line of your email.

For general privacy inquiries, please include "Privacy Inquiry" in the subject line of your email.