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Privacy Policy

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Twible - Privacy Policy

Your privacy is of highest importance to us. At Twible, we provide complete end-to-end encryption, which means that the only persons who can see your communication are you and the person you are communicating with. Therefore, rest assured that no other person can see your communications.

We remain committed to the privacy and protection of all the data. To provide you with end-to-end encrypted free calling, messaging and other Twible services, we ensure to safeguard the trust you place upon us by sharing of certain information about you. The subsequent document, therefore, explains here in transparent terms how we do so.

This privacy policy is aimed at providing you information on how we collect and process your personal data or information through your use of the App, which includes all kinds of data provided by you by using the App.

Under data protection laws, we are required to provide you with certain information about who we are, how we process your personal data and for what purposes, and your rights in relation to your personal data. This information is provided across this document and it is important that you read that information.

Important information and who we are

Twible Technologies Private Limited is the controller of and is responsible for your personal data (hereinafter referred to as "Twible ", "we", "us" "our" or “App” in this policy).

Contact details

Our complete details are:

Changes to the privacy policy and your duty to inform us of changes in your provided data

We keep our privacy policy under regular review and may update it from time to time. Therefore, please check our privacy policy from time to time for any updates.

It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during our relationship with you.

Third party links

Our App may, from time to time, contain links to and from the websites of our partner networks and affiliates. Please note that these websites and any services that may be accessible through them have their own privacy policies which the users must read before submitting any personal data to these websites or using these services.

The types of data we process

With a full and completely safe end-to-end encryption, we may collect, use, store and transfer different kinds of personal data about you, the details of which are as follows:

  • Identity Data: mobile number, nickname, and profile picture (profile picture is optional).
  • Contact Data: mobile number, so we could tell you which of your contacts are also using Twible to enable you to start safe and end-to-end encrypted conversations with them.
  • Device Data: the mobile phone number used by the device, your mobile operating system - only if it is android or iOS, the time zone setting, log files, crashes, reports on performance, etc., get registered in our system to keep the App technically viable at all times.
  • Content Data: includes information stored on your device, including friends' lists, end-to-end encrypted photos, videos or other digital content, etc., so as to allow you to share such content with other Twible users.
  • Profile Data: includes your username
  • Usage Data: includes details of your use of any of our Apps or your visits to any of Our Sites including, but not limited to, traffic data and other communication data, whether this is required for our own billing purposes or otherwise.
  • Messages Data: user’s messages, which our end-to-end encryption services secure by encrypting them (including chats, calls, and multimedia content like photos, videos, and voice messages) and which remain in our system up to the point of delivery, which is a maximum of 30 days.
  • Calling Data: end-to-end encrypted call logs generated through the use of our App. Calling Data will show the date and timestamps. Please note that we never store or record your conversations or call-related information.
  • Status Data: your status information while using our App which is automatically updated in our system as well, including your online/offline status and your recent usage of our services (last seen).
  • Location Data: includes your current location that you may choose to share with your connections on the App when you use the location sharing feature available to you in the App. This is done only after your express permission. We never track location in the background.
How is your personal data processed?

We will collect and process the following data about you:

  • Information you give us. This information includes Identity, Contact, and communications data, you consent to give us about you by filling in the forms on the App Website, or the Services Sites (together Our Sites), or by corresponding with us via, for example, email or chat. It also includes information you provide when you register to use the App Site, download or register an App, subscribe to any of our services, search for an App or service, share data via an App's social media functions, enter a competition, promotion or survey, or other activities commonly carried out in connection with an app, including bug reports, and reporting of any other problem with the App, our services, objectionable content, etc. If you contact us, we will keep a record of that correspondence.
  • Information we collect about you and your device. Each time you visit or use one of our Apps we will automatically process personal data specified in the above paragraphs in a safe and end-to-end encrypted manner.
  • Location Data. You may choose to share your location with your connections on the App when you use the location sharing feature available to you in the App. For this, we use GPS technology to determine your current location in a fully encrypted manner. This is done only after your express permission. We never track location in the background.
How is your personal data collected?

We will only process your data when the law allows us to do so. Most commonly, we will process your personal data under the following circumstances:

  • Where you have consented before the processing.
  • Where we need to perform a contract we are about to enter or have entered with you.
  • Where it is necessary for our legitimate interests (or those of a third party) and your interests.
  • Where we need to comply with a legal or regulatory obligation.

We process the aforementioned data of yours to improve, customise, and optimise our services. 

This information helps us to understand the usage of our services; we assess and upgrade our services as per your requirements. Furthermore, we use your information to reply to your queries. 

To make sure that users do not violate our Terms of Services/Use, including the usage of our service for any illegal purpose, all accounts, and their activities are verified with end-to-end encryption. 

Commercial Messaging: We will permit businesses to communicate with you for commercial purposes such as appointment information, transactions, product order, and delivery notifications, etc. 

Additionally, we use the information for the following purposes: 

  • To connect you with your friends and family. 
  • To analyse your preferences and personalise your account accordingly.
  • To report your updates and changes made periodically in the App or any part associated with it. 
  • To make the experience free of suspicious or illicit activities. 
  • To market our services and widen the Twible community.
  • To remove technical errors and improve the overall experience.
  • To provide you with customer support and effectively solve the issues arising from your usage of the App. 
In addition to the above, more specific details regarding the type of data and the purposes for which we may use it are provided in the table below:

Purpose/activity Type of data
To install the App and register you as a new App user
  • Mobile Number
  • Nickname 
  • Profile Picture (Optional)
To manage our relationship with you including notifying you of changes to the App or any Services
  • Identity Data
  • Contact Data
  • Profile Data
To enable you to participate in a survey (if any)
  • Identity Data
  • Contact Data
  • Device Data
  • Profile Data
To administer and protect our business and this App including troubleshooting, data analysis and system testing
  • Identity Data
  • Contact Data
  • Device Data
Disclosures of your personal data

During your usage of the App, some third parties may also provide us with certain information about you. Typically, this includes your friends on our App, who automatically deliver your phone number(s) when they contact you. Similarly, any profile detail, including your name, phone number, or any other personal detail made public by you will be storable or usable by other users of the App. Any message sent to other users using the service will also be available to them for use in whichever way they like. It is, therefore, your responsibility not to disclose anything that may be sensitive to you in nature.

Similarly, when you involve a third-party service on our App, say to share some of your Twible activities over their platform, we may receive some of the data those services may have of you. Furthermore, for our marketing and commercial requirements, a part of the profiling done on the user may be shared with a third-party vendor to optimise the resources invested. Please note that the privacy policies and terms of such third-parties govern the usage of shared information, and not of Twible’s.

We do not store your messages or communications. If you decide on your own to store your Twible messages on third party cloud storages (like Google Drive or iCloud), please be informed that in such cases, the privacy policies and terms of use of such third-party services come into effect when you use their services.

We may share your data once consent is given by you to our sister companies or if we go for a merger or organizational restructure.

We ensure your personal data is protected by requiring all our group companies to follow the same rules when processing your personal data. These rules are called "binding corporate rules".

Your communication with Twible

All your correspondence with Twible, including feedback, suggestions, bug reports, reporting of objectionable content, or any conversations conducted either via the App or through other means of contact including emails or website contact form, are kept saved for recordkeeping and continuous improvement purposes.

International Transfers

If you are based in the European Economic Area (EEA), the processing of your personal data by our external third parties will involve the transfer of your data outside the EEA, as many of them are based outside that region.

Whenever we transfer your personal data out of the country of your residence, we ensure a similar degree of protection is afforded to it by ensuring that such service providers give us a written undertaking that they will give personal data the same protection it has in the EEA and in this privacy policy.

Please contact us if you want further information on the specific mechanism used by us when transferring your personal data out of the country of your residence.

Data security

Since our App deals extensively with the exchange of information, we understand how vital it is to safeguard that information. For that, we have placed the best security protocols in the structure of the App, including end-to-end encryption for your messages. End-to-end encryption means that nobody, except the generator of the message and the intended receiver, will have the access to your private conversations. The protocol also covers end-to-end encrypted one-on-one calls so that no unintended third-party can eavesdrop.

All information you provide to us is stored on our secure servers. Where we send you an OTP (which is temporary and valid only for a limited time), you are responsible for keeping this OTP confidential. We ask you not to share this temporary OTP with anyone.

Once we have received your information, we will use reasonable procedures and security features to try to prevent your personal data from being accidentally lost, used or accessed in an unauthorised way.

Your Data is stored directly on your own device storage.

We have put in place procedures to deal with any suspected personal data breach and will notify you and any applicable regulator when we are legally required to do so.

If at any time in future we add the payment features to our App (in which case you will be informed in advance), any payment transactions facilitated by us or our chosen third-party provider of payment processing services will be encrypted using appropriate encryption technology.

Data retention

We retain your data for a maximum period of 30 days, in a secure end-to-end encrypted manner. We do not store your data on any of our servers beyond that period.

However, law might require us to keep some basic information about our customers including contact, identity etc. In such conditions, we are bound to comply with laws and if we do so, we will keep the minimum possible data and for the shortest possible time as prescribed by law.

Your messages, which our end-to-end encryption services secure by encrypting them (including chats, calls, and multimedia content like photos, videos, and voice messages), remain in our system up to the point of delivery, which is a maximum of 7 days. Your device, however, may independently accumulate sent and received messages. To know more about how your chat is made secure, read the section on ‘Data Security’.

Under certain circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.

Your Control on Information

As a Twible user, you are free to control, alter, delete, or primarily; manage your information, whenever you want. More details regarding your account information are provided below:

Information Accessibility: Your information such as, profile name, photo, online status, status message, recently viewed items, or phone number may be accessible to someone who uses our services. You can go to service settings to manage who can see, store, or share your personal information.

Account Deletion: If you choose to delete your account, your messages too will be erased, including the undelivered ones. We will also delete any other data that is not necessitated by law for retention. Even the messages that remain undelivered will erase from our systems after a period of maximum 30 days.

Information Management

Settings: At any time, you can change the information available to others. You can use the block feature to prevent certain users from making contact.

Under certain circumstances, you have the following rights under data protection laws in relation to your personal data:

  • Request access to your personal data.
  • Request correction of your personal data.
  • Request erasure of your personal data.
  • Object to processing of your personal data.
  • Request restriction of your personal data.
  • Request transfer of your personal data.
  • Right to withdraw consent.
  • You can exercise any of these rights at any time by contacting us at privacy@twible.com
Children Under 16

We neither permit nor encourage the use of the App by children under the age of 16. If you as a parent are setting up an account for such minors, you must do so under your credentials and supervision. In essence, we do not intentionally store any personal information of any minor.

Applicable Laws and Dispute Resolution

Our Privacy Policy, and any relationship between us and you in connection with your usage of our App shall be governed by and construed in accordance with the laws of the India, as applied in the India.

In case of a dispute arising from any function/part of the App, or any clause stated in the Privacy Policy, it shall be resolved in the following manner:

Approaching Twible: You will email the details of your dispute/complaint at the email address provided in the contact section, and Twible will attempt to satisfy you or resolve your claim within a period of 3 months from the date of receipt of your complaint/dispute notice. Your email must have the following particulars stated explicitly:

  • Your name
  • Operational contact details (Email Address, Phone Number, Mailing Address, etc.)
  • Details of the claim along with any measures you took on your own to correct the issue at hand
  • What remedy or corrective measure you seek from Twible for your inconvenience

If your complaint or dispute raised by you is not resolved pursuant to the above paragraph, such dispute shall be referred to and finally resolved by the courts of India. Additionally, if you are a user of the services based in the United States or Canada, we both agree that all the matters of grievance will be resolved through individual action before the court of India and not a class action before any court or tribunal. We agree that there will be no consolidated disputes or disputes involving any third party/entity.

Similarly, if we have a claim, complaint or dispute against you, we may at our own discretion, either file such claim or complaint before a court in the place of user’s/your residence or before the courts of India, whichever we find convenient.

Acceptance and Consent

By clicking on the “Accept” button linked to this document and our App, you (‘user’) acknowledge and agree to the terms and policies stated in this document, our terms of use and any updates made to these from time to time. You also agree that these policies and documents apply to all the information you provide us periodically throughout your usage of the App. The stated policies will also govern any information collected either through your doing or through the initiatives of any third-party.

Glossary

Lawful Basis means based on the law which governs this Privacy Policy.

Consent means agreeing to this privacy policy or any updates made to it from time to time. By accessing or downloading or using our App, you provide us with your consent and agree to this privacy policy.

Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests.

Performance of Contract means processing your data where it is necessary for the performance of a contract to which you are a party or to take steps at your request before entering into such a contract.

Comply with a Legal Obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.

Third parties

Internal third parties: Our affiliates, sister companies, parent company, or subsidiaries.

External third parties: Service providers acting as processors based in or outside the country of your residence who provide IT and system administration services.

Professional advisers including lawyers, bankers, auditors and insurers based in or outside the country of your residence who provide consultancy, banking, legal, insurance and accounting services.