Last Revised: March 26, 2019
With Twenty, the user is always in complete control. When you register for Twenty, you will be asked to provide your name, username and phone number of your mobile device and select a photo, icon or picture for your profile. This information will be searchable by other users. You will decide when to share any other personal information with users (including your location and any Hangouts you create).
When using Twenty, you can elect to stop sharing location information with other users at any time. In addition, you can toggle between sharing your precise location, your general “neighborhood” location or no location with each individual user, at your election
What Personal Information Do We Collect?
Personal information may be collected in a number of ways when you use Twenty:
Information You Provide to Us Directly:
- At several places in Twenty, we may collect certain information you voluntarily provide to us, which may contain personal information. For example, if you register for Twenty, send us an email, or submit content, we may collect your name, photo, phone number, email address, list of contacts, and other personal, professional, demographic and business information that you provide.
- We may also collect personal information when you authorize us to collect images and other information from your device’s camera and photos.
- In addition, from time to time we may collect contact or other personal or demographic information you provide in connection with your participation in surveys, promotional offers, forums and other interactive areas of Twenty.
Mobile Device Contacts:
- When you first register for Twenty, you will be asked to provide Twenty with permission to access contact information from your mobile device. If you elect to do so, you will be authorizing us to periodically upload and sync certain personal information stored in your mobile device, including the name and telephone number of your mobile device contacts
- Note that Twenty does not collect the home addresses, email addresses or profile pictures of your mobile device contacts—only their names, telephone numbers and certain metadata indicating the types of those telephone numbers (i.e., “work” or “home” numbers).
Device and Usage Information:
- When you use Twenty, we may collect certain information about your smartphone device. For example, we may collect information about the model of your phone and your operating system, browser type, language and keyboard settings, battery level, and time zone.
- We may also collect information about your activity and pattern of usage on Twenty, including, for example, information about when you login to Twenty, create a Hangout or send a message to other users.
- From time to time we may also collect certain information about your wireless and mobile network connections, such as your service provider and your signal strength.
- When you first register for Twenty, you will be asked to authorize us to access your location information, even when not using Twenty. If you do authorize us to collect such information, Twenty will be able to automatically collect certain location information from your mobile device and/or your mobile carrier.
- We may also collect data regarding the movement of your phone, which may, for example, indicate whether you are walking to a different location or allow us to receive information regarding battery efficiency issues.
Content Posted to Hangouts:
- From time to time, we may collect content, including photos, messages and video and audio files, that you post to a Hangout. You should only post content to a Hangout if you are comfortable with the content being viewable by the public. In particular, note that when you post content to a Hangout, that content may be publicly accessible by many users, including all of the users with whom you have connected and any other users with whom that content is shared.
Information Gathered Through Cookies and Analytics Services:
- From time to time, we may automatically collect certain information through the use of “cookies.” Cookies are small data files that are stored on a user’s hard drive at the request of a website or application to enable the website or application to recognize users who have previously visited them and retain certain information such as users’ preferences and history.
- If we combine cookies with or directly link them to any personally identifying information, we will treat this information as personal information. If you wish to block, erase, or be warned of cookies, please refer to your browser’s or device’s instructions or help screen to learn about these functions.
- In addition to the above, other companies may embed their own cookies or similar tools within Twenty, including third party analytics services such as Google BigQuery (“Analytics Services”), which we engage to help analyze how our users use Twenty or to analyze third parties that deliver content or offers.
- By using our Services, you consent to the processing of data about you by Analytics Services in the manner and for the purposes set out above. For a full list of Analytics Services which we are currently using, please contact us at email@example.com. We do not currently respond to “do not track” signals or other mechanisms that might enable consumers to opt out of tracking on our Site.
Information Gathered From Third Parties:
- Finally, we may receive certain information from third parties with whom we have business relationships, and may combine this information with other personal information we possess.
- In such cases, this Policy governs our use and disclosure of the combined information. No personal information will be shared with any commercial partners or other third parties, except as specifically described in the Policy below.
How Do We Use Personal Information?
- In general, we use personal information that we collect to provide you with information, products and services you request, to administer and assist us with the operation of the Services and improve their functionality, or for any other purposes for which the information was provided. For example, we may use the information we collect to:
- Develop, operate, improve and deliver the Services;
- Communicate with you about Twenty, including to notify you of activities on Twenty or to notify you of new features, product developments or promotions;
- Help personalize Twenty by, among other things, customizing the content we show you;
- Connect you with your friends on Twenty (for example, by identifying those of your mobile device contacts who are Twenty users and connecting you with those users);
- Facilitate communications between you and your friends (for example, by giving you the ability to invite friends on to Twenty through SMS text messages);
- Monitor trends and usage and improve advertising targeting and measurement, including through analysis of location data;
- Verify your identity and prevent fraud or other unauthorized or illegal activity, or to enforce our Terms of Service and other usage policies;
- Respond to your emails, submissions, comments, requests or complaints, or to provide you with customer service;
- Request feedback and to enable us to develop, customize and improve Twenty to enhance users’ experience; or
- Assist with any other specific purpose for which the information was provided.
- Personal information does not include “aggregate” information, which is data we collect about the use of Twenty or categories of Twenty users, from which any personal information has been removed.
- For example, the percentage of Twenty registered users that identify themselves as male or female is aggregate information. Personal information also does not include “anonymous” information, such as information about a particular user’s location or historical activity on Twenty that is not directly linked to any information that specifically identifies the user.
- We collect aggregate data and anonymous data for a number of purposes, including to help us understand trends and user needs so that we can better develop new products and services, and tailor existing products and services to better serve our users.
How Do We Share Personal Information?
We recognize that all of our users trust us to safeguard their personal information, which is why we only disclose personal information in certain limited circumstances described below. We do not sell any of our users’ personal information or use it for advertising purposes.
We may share personal information as follows:
With Other Users of Twenty:
We may share your personal information with others users of Twenty in connection with your usage of the Services. For example, we may share photos, videos or messages that you post to a Hangout with other users who view the Hangout. We may also share your name, icon and mobile number with other Twenty users who have stored your phone number of their own mobile device (for example, by alerting those users that you have recently joined Twenty in order so that you can connect) or other users who search for you.
- You may elect to stop sharing location information with other users and transmitting such information to Twenty at any time simply by pressing the button at the top of the screen. Note that if you are sharing location information, this information may continue to be shared with other users and transmitted to us even if Twenty is minimized or closed; however, you can return to Twenty at any time to disable sharing of location information.
- Twenty allows you to toggle between sharing your precise location, your more general “neighborhood” location or no location with each individual user, at your election. If you elect to only share your “neighborhood” location with a particular user, Twenty will only share your general “neighborhood” location or your presence at a particular Hangout with that user.
With Service Providers:
In the event that we engage or partner with a third party vendor, consultant or other service provider (“Service Provider”), we may share personal information with the Service Provider if it needs access to such information to carry out their work for us and it agrees to comply with the terms of this Policy or similar privacy protections.
With Third Parties for Legal Reasons:
We also may disclose personal information when we are required to comply with the law (e.g., a lawful subpoena, warrant or court order); to enforce or apply this Policy or our other policies or agreements; to protect our or our customers’ rights, property or safety; to protect our customers from fraudulent, abusive, or unlawful use of Twenty; or if we believe that an emergency involving danger or serious physical injury to any person requires disclosure of communications or justifies disclosure of personal information.
In Connection with a Business Transaction:
In addition, information about our users, including personal information, may be disclosed in connection with any merger, acquisition, financing, or sale of company assets, as well as in the event of an insolvency, bankruptcy or receivership in which personal information could be transferred to third parties as one of the business assets of the Company.
With Which Users Should You Share Your Location Information?
- Twenty permits you to block certain users from having access to your location information, or change the nature of the location information that is available to any particular user, at any time. You should only share your location information with people you know and trust not to convey your location to others (especially in the case of sharing precise location information), and you should avoid broadcasting your location information if doing so could subject you to any special risk or danger.
- You should also note that any personal information you share with others may be captured by screen-shot or other imaging-capture technology and/or forwarded to others, and any personal information you share with others has the potential to become publicly available.
What Steps Do We Take to Protect Your Personal Information Online?
- The Company endeavors to secure your personal information from unauthorized access, use or disclosure by putting into place measures to safeguard the information we collect. We encrypt all information over the network and regularly assess our software and servers for potential vulnerabilities.
- Please be aware, however, that despite our efforts, no security measures are perfect or impenetrable, and that we cannot guarantee that the Services will be free of any defects or flaws that affect your use of Twenty or the security of your information.
How Long Does Twenty Store Your Location History?
- Twenty will generally only store personal information relating to your location history for a limited period of time as is necessary in connection with the Services. Our current policy is generally to delete all such information after a period of 30 days.
- Some limited exceptions may apply. For example, we may be required to retain such information for a longer period of time if required to do so by applicable law.
What Happens If You Access Another Site Through Twenty?
- Twenty may provide links to other sites or apps hosted by third parties, or certain features or services provided by third parties (e.g., the ability to hail an Uber or Lyft). Please be aware that although we may link to sites, apps, features or services provided by third parties, we are not responsible for the privacy practices of such third parties.
How Can You Request That We Correct, Remove or Update Your Personal Information?
- If you have any questions or comments about this Policy or the privacy practices relating to Twenty, or you wish to verify, correct or delete any personal information we have collected, please contact us at firstname.lastname@example.org and we will endeavor to respond to your inquiry or to correct, update or remove the personal information you have provided to us as you indicate to the extent possible.
Information for Users Outsides of the United States
- If you are located outside of the United States, please note that Twenty is hosted on computer servers in the United States. Therefore, your information may be processed and stored in the United States. As a result, United States federal and state governments, courts, or law enforcement or regulatory agencies may be able to obtain disclosure of your information through laws applicable in the United States.
- Your use of the Services or your submission of any personal information to us will constitute your consent to the transfer of your personal information outside of your home country, including the United States, which may provide for different data protection rules than are applicable in your home country.
- We do not permit persons under 13 to register for Twenty, and we do not knowingly collect any personal information from persons under the age of 13.
- We reserve the right to change the provisions of this Policy at any time by posting a revised Policy on our website or Twenty and indicating on the Policy the date it was last updated. Your use of Twenty following the posting of such changes shall constitute your acceptance of any such changes.