22.01.2024

v.0.2

TWINN APP PRIVACY POLICY

As Twinn App, your trust is invaluable to us, and we deeply appreciate the confidence you place in us when sharing your information. We take this responsibility seriously and handle your data with the utmost care and diligence.

Twinn App introduces a new dimension to your everyday experiences. As an AI-enhanced 3D digital interaction platform customized to individual preferences, it engages users through natural conversations, enriched with personalized characters and an intuitive interface.

We value your personal data and we are committed to being transparent about what we collect from you.

Privacy by Design. Our commitment to safeguarding your privacy is at the core of our AI governance strategies. We engage professionals across diverse domains such as legal, security, engineering, and product design to ensure that every decision we make reflects the highest regard for your privacy.

Transparency & User Choice. As an AI company, we strive to convey our approach to handling your personal data through easily understandable privacy notices. It's crucial for our users to grasp our privacy practices, empowering you to use the Twinn App’s supercharged AI while maintaining control over your personal data.

Our commitment to security. Our teams work tirelessly to ensure the safety and security of your data. We consistently update and invest in our security practices, aiming to fortify the protection of your information.

Data Controller : HEXAMON OYUN YAZILIM VE PAZARLAMA TIC. A.S.

Data Controller Address : Kasüstu Mah. Devlet Karayolu Cad. Köleoğlu İş Merkezi No: 31/403 Yomra/ TRABZON

Yomra Mal Müdürlüğü 462 093 7746

Data Controller Website : Hexamon Games / https://hexamongames.com/

This Privacy Policy applies to Hexamon Oyun ve Yazılım ve Pazarlama TIC. A.S. (hereinafter ‘’Twinn App’’), that provides an AI-enhanced 3D digital interaction app on mobile devices.

In order to ensure transparency, this privacy policy ("Privacy Policy") governs how we process personal data we collect or receive from or about you.

Table of contents

1. Information We Collect and How We Process It
2. Retention and Security of Personal Data
3. Transfers of Personal data
4. Third Party Services
5. Your Rights
6. Use by Children
7. How we handle California Residents Personal Information
8. How to Contact Us

Information we collect and how we process it

When you create an account

Personal Data

• Apple ID
• User Token
• First name(optional)
• Payment information
• Device Information
• Network Information
• Any other information that you provide us (e.g. in the context of product support)

Source

• We obtain the personal data directly from you

Purpose of Collecting

• To be able to create a user account / profile
• To be able to login and use the service
• To perform activities within the product,

Legal Basis

• Processing is necessary for the performance of a contract

Third Parties We Share Data With

Retention Period

We retain your collected personal information as long as necessary for providing our services, addressing disputes, legal compliance, and fulfilling business purposes.

When you interact with AI characters and generate usage data

Personal Data

• Usage Data : For optimal functionality, Twinn App relies on access to your device’s microphone to enable voice to voice interactions with our 3D digital personal assistants. Your voice data never leaves your phone. We convert your spoken words into text files, known as transcripts, directly on your device. This process is designed to safeguard your privacy and keep sensitive information like audio files within the confines of your phone.
• Aggregated or De-Identified Information: We may use personal information to create de-identified or aggregated data, including demographics and device details, for lawful purposes such as research and analytics. This information, no longer personally identifiable, can be shared, disclosed, and retained in accordance with applicable laws.

Source

• We obtain the personal data directly from you

Purpose of Collecting

• To perform activities within the product,
• To provide, administer, maintain and/or analyze the Services;
• To improve our Services and conduct research;
• To prevent fraud or misuses of our Services;
• To comply with legal obligations and legal process and to protect our rights, privacy, safety, or property, and/or that of our affiliates, you, or other third parties.

Legal Basis

• Processing is necessary for the performance of a contract
• Voice data is processed based on your consent

Third Parties We Share Data With

Retention Period

Twinn App allows users to access their past chats. Users have control, with the ability to select specific conversations for deletion or wipe all data. A private mode without recording is available, and temporary transcription is provided without any storage.

However, it is important to keep in mind, data sent to OpenAI APIs are based on servers hosted in the US, and OpenAI does store the data you send via API for abuse monitoring purposes for up to 30 days.

When we share information with OpenAI APIs

By using the Twinn App, you expressly acknowledge that the OpenAI services are integral to our operation. The smooth experience and engagement with 3D digital assistants within the Twinn App are facilitated by OpenAI API services and we comply with OpenAI API Policy. You hereby acknowledge that your use of Twinn App adheres to OpenAI's Terms of Use.

Furthermore, you recognize that we solely share text files, referred to as transcripts, with OpenAI API services. Data sent to their APIs is stored on servers located in the U.S. and retained for up to 30 days for the purpose of abuse monitoring.

Personal Data

• User Transcripts (if private mode is not enabled)
• Session Information

Source

• We obtain the personal data directly from you

Purpose of Collecting

• To provide, administer, maintain and/or analyze the Services;
• To improve our Services and conduct research;
• To communicate with you;
• To prevent fraud, criminal activity, or misuses of our Services, and to protect the security of our IT systems, architecture, and networks;

Legal Basis

• Processing is necessary for the performance of a contract

Third Parties We Share Data With

Retention Period

Twinn App allows users to access their past chats. Users have control, with the ability to select specific conversations for deletion or wipe all data. A private mode without recording is available, and temporary transcription is provided without any storage.

However, it is important to keep in mind, data sent to OpenAI APIs are based on servers hosted in the US, and OpenAI does store the data you send via API for abuse monitoring purposes for up to 30 days.

When you interact with us through our marketing events, on our social media profiles and our blog (e.g., Instagram, Twitter, Discord)

Personal Data

• Social Media Handle
• Any other information you provide us

Source

• We obtain the personal data directly from you
• We obtain personal data from third parties

Purpose of Collecting

• To help us show more targeted and relevant content
• To gather analysis or valuable information so that we can improve our product
• To generate leads and contact prospective customers

Legal Basis

• Consent to processing of personal data in events, accessing content & marketing communications

Third Parties We Share Data With

Retention Period

We retain your collected personal information as long as necessary for providing our services, addressing disputes, legal compliance, and fulfilling business purposes.

Internal Logs

We may also use some other information like session and usage information for fraud prevention and security purposes.

The information inside the log files includes IP addresses, device type, Internet Service Provider, date/time stamp, clicked pages and any other information your mobile device may send to us. We use such information for security purposes and to analyze trends, administer the mobile app, track users’ movement around the Twinn App, and gather demographic information.

Retention and Security of Personal Data

Twinn App allows users to access their past chats. Users have control, with the ability to select specific conversations for deletion or wipe all data. A private mode without recording is available, and temporary transcription is provided without any storage.

However, it is important to keep in mind, data sent to OpenAI APIs are based on servers hosted in the US, and OpenAI does store the data you send via API for abuse monitoring purposes for up to 30 days.

We have implemented commercially-reasonable technical, organizational and security measures designed to protect your personal data. However, please note that we cannot guarantee that the information will not be compromised as a result of unauthorized penetration to our servers.

Transfers of personal data

The personal data collected are being stored on Unity Cloud in the United States, pursuant to Standard Contractual Clauses for international transfers. When we transfer personal data outside of EU/EEA, we will obtain contractual commitments from the recipients of data.

In addition to the third parties mentioned above, we may share your personal data as follows: (i) with courts or competent authorities, to comply with applicable laws, regulations and requests of law enforcement; (ii) in case we sell or transfer, or we consider selling or transferring, some or all of our business, shares or assets to a third party; (iii) in the event that we are acquired by, or merged with, a third party entity, or in the event of bankruptcy; (iv) where you have provided your consent to us sharing or transferring your personal data.

Third Party Services

We enable you to interact with third party websites, products or services that are not controlled by us (“Third Party Service”). Please be aware that Third Party Services can collect Personal Data from you. Therefore, we encourage you to read the terms and conditions and privacy policies of each Third Party Service.

We conduct due diligence on such third-party service providers prior to sharing your Personal Data with them. We share your Personal Data with such third-party service providers only on a contract basis where such service providers assure that they are and shall be in compliance with the applicable data protection laws.

We reserve the right to remove or add new processors, which shall be notified to you and included in our privacy policy.

Your Rights

The following rights shall apply to certain individuals (some of which only apply to individuals protected by the GDPR) :

• You can access the personal data we held about you. This can normally be exercised free of charge, however we reserve the right to charge an appropriate fee where applicable;
• You can request that we correct any personal data we hold that is inaccurate;
• You can request the deletion of your personal data. Please note that in certain situations we are required to keep your personal data where applicable;
• You can object to or request restriction of processing your personal data;
• You can request to receive your personal data in a structured, commonly used and machine-readable format, and transmit that data to another controller;
• You can object to profiling;
• You can withdraw your consent at any time.
• You can request certain details of the basis on which your personal data is transferred outside the European Economic Area.
• You have a right to lodge a complaint with your local data protection supervisory authority.

When processing your request, we may ask you for additional information to confirm or verify your identity and for security purposes. We reserve the right to charge a fee where permitted by law, for instance if your request is manifestly unfounded or excessive. You can exercise your rights by submitting a request here: [email protected].

How long do we store your Personal Information?

We store your Personal Information for different time periods depending on the category of Personal Information and the nature of relationship that you have with us. We determine how long we need Personal Information on a case-by-case basis, but our goal is to keep your Personal Information for as short period as possible to achieve the purpose for which Personal Information is collected. We consider the following criteria when we are making decisions on how long we will retain your Personal Information:

• The category of Personal Information.
• Whether the Personal Information is typically deleted based on specific schedules, such as marketing information.
• Whether the Personal Information is necessary to operate or provide our services. For example, account information may be retained for a longer period of time based on the Agreement you have with us.
• How long we need to retain the Personal Information to comply with our legal obligations.
• Our legitimate interests or legal purposes, such as network improvement, fraud prevention, record-keeping, promoting safety, security and integrity, or enforcing our legal rights.

Additional information for consumers in the United States

Under the California Privacy Rights Act (‘CPRA’) residents of California have certain rights regarding the Personal Information that businesses collect and process about them. This includes the rights to request access or deletion of your Personal Information, as well as the right to direct a business to stop selling or sharing your Personal Information.

We are required to detail the categories of Personal Information that we that we collect and/or share for the purposes described in “Information We Collect and How We Process It” section of this privacy policy.

While Twinn App does not engage in the sale of Personal Information in exchange for monetary compensation, we do share Personal Information for other benefits as outlined in Cal. Civ. Code 1798.140(ad)(2). We have detailed the data categories we collect and the associated "business purposes" in the "Information We Collect and How We Process It" section of our policies. This includes the sharing of personal identifiers, commercial information, and internet or other electronic network activity with entities such as payment processing providers, customer relationship management firms, consulting services, email service providers, product feedback management, customer success services, advertising networks, analytics companies, and sponsors. You have the right to instruct Twinn App not to sell or share your Personal Information. Additionally, please note that Twinn App does not sell or share the Personal Information of individuals under 18 years of age.

For more information on how to exercise your rights, including the list of privacy rights that may be available to you, please see section “Your Rights” of this privacy policy. If you would like to access, review, update, correct, delete any Personal Information we hold about you, or exercise any other privacy rights available to you, including the right to opt out from selling or sharing your Personal Information, you can send your request to: [email protected] .

We endeavor to respond to a Privacy Rights Request within the required timeframes. If we need more time, we will inform you of the reason and extension period in writing. If you submit your Privacy Rights Request electronically through our request form, we will deliver our written response to the verified email associated with the request. If you did not submit the request with us via the online webform, we will deliver our written response by mail or electronically, at your option. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Appeal

If Twinn App does not take action on your Privacy Rights Request within the 45 days response period, or in the event of an extension, within the maximum 90-day response period, we will inform you in writing of the reasons for not taking action, as well as provide an explanation of any rights you have to appeal the decision.

“Do Not Track” disclosures

Privacy regulations in the United States, such as the laws of California and Delaware, require Twinn App to indicate whether it honors your device’s “Do Not Track” and “Do Not Sell My Personal Information” signals concerning targeted advertising. Twinn App adheres to the standards set out in this Notice and does not track visitor who prefer not to be monitored.

Deleting your account

You may delete your account by submitting a request to [email protected]. If you delete your account, any association between your account and personal data we store will no longer be accessible.

Use by children

We do not offer our products or services for use by children and, therefore, we do not knowingly collect personal data from, and/or about children under the age of 18. If you are under the age of 18, do not provide any personal data to us without the consent of a parent or a legal guardian.

Contact us

If you have any questions, concerns or complaints or if you wish to exercise your rights, we encourage you to contact us at [email protected].