TWENTY PRIVACY POLICY

This Privacy Policy ("Privacy Policy") applies to the websites, mobile applications, and other online products and services (the "Services") operated by Twenty Holdings, Inc., its subsidiaries, and other affiliates ("Twenty," "we," "us," and "our"). This does not apply to personal information collected offline. This Privacy Policy also explains the choices you have about the ways your personal information is collected and used. Please read this Privacy Policy carefully because by registering for or using the Services, you agree to be bound to this Privacy Policy, which is incorporated into our Terms of Service, available at www.twenty.co. We encourage you to periodically review this Privacy Policy to keep up to date on how we are handling your personal information.

TYPES OF PERSONAL INFORMATION WE COLLECT

When you use our Services, we may collect your personal information. The types of personal information we collect from you depends on the services and the features you use on the Services. This information includes:

Registration, Profile, and Device Identification Information. We may collect information from you when you register directly with us. That information may include, among other things, your full name, email addresses, birthday, phone numbers, photograph, school affiliation, device identifiers, and other information you provide. Depending on how you access our Services, we may also collect device identification information, including MAC address and IP address. If you choose to connect your mobile device contacts or address book with our Services, we will collect, synchronize and store your contacts or address book information, including the phone numbers and names of your contacts, to enable you and your contacts to connect and use our Services. We will not copy to our servers or otherwise collect your name, telephone number or other account registration information until you confirm that you are 13 years of age or older by entering your birthdate during sign-up.

Customer Support Information. We will collect and store the contact information you provide to our customer support personnel, information about your use of our Services, and your user ID number. We will also store the communications you have with us and any information contained in those communications.

Technical and Usage Information. When you access our Services, we collect information about your mobile device or computer system, including MAC address, IP address and mobile device ID. We also collect usage statistics about your interactions with the Services. This information is typically collected through the use of server log files or web log files ("Log Files"), mobile device software development kits and tracking technologies like browser cookies to collect and analyze certain types of technical information. Some of the cookies the Services place on your computer are linked to your user ID number.

Location Information. With your consent, our Services collect precise geo-location information using iOS and Android location services. These services may use a combination of GPS, WiFi, Cellular, and IP address to triangulate your location. You can go offline at any time to hide your location when you need extra privacy. Additionally, you can stop the collection of location information at any time by changing the preferences on your device.

HOW WE COLLECT INFORMATION

We collect information in various ways, including the following:

Information Collected Directly From You and Other Users. When you use our Services, we collect and store certain information that you provide directly. We also collect information about your use of the Services and your interaction with other users.

Information Collected by Cookies and Other Technologies. Like most online services and mobile applications, we may use cookies and other technologies, such as web beacons, web storage, and unique advertising identifiers, to collect information about your activity, browser, and device. We may also use these technologies to collect information when you interact with services we offer through one of our partners, such as advertising and commerce features. Most web browsers are set to accept cookies by default. If you prefer, you can usually remove or reject browser cookies through the settings on your browser or device. Keep in mind, though, that removing or rejecting cookies could affect the availability and functionality of our services.

Communications Features. You may be able to take part in certain activities on our Services that allow you to communicate and share information with us and other users of our Services. These include participating in forums and message boards, posting status updates, posting comments to other users' profiles or boards, sending private or group messages or invitations, chatting with other users, and posting photos, videos and other files. We may record and store archives of these communications on our servers.

Other Sources. We may collect or receive information from other sources including other Twenty users who choose to upload their mobile device contacts. This information may be used to supplement your profile and it will be combined with other information we collect. We may also use this information to facilitate communications between you and such other users, including SMS messages sent to you by the user.

HOW WE USE THE INFORMATION WE COLLECT

We use your information primarily as necessary to provide you with the Services, including in one or more of the following ways:

Service Support and Improvement. We may use your personal information to create your account, allow use of our Services, suggest and make connections with other users, enable user-to-user communications, provide technical support and respond to user inquiries, and analyze what our users prefer, so that we can design better products and services. We may analyze the information that is collected with cookies and other tracking technologies to help us improve our function and to modify the services and information that we provide.

Communications. We also use your information to communicate with you about your inquiries, our company, and related news, as well as to send you promotional emails, surveys, newsletters, or notifications. If you have provided your email address or phone number to us, we may use it to (i) respond to customer support inquiries, (ii) keep you informed of your activity, including comments from friends, notifications about application status, and (iii) send you informational messages concerning Twenty and/or the Services. We may send promotional messages directly or in partnership with parties other than Twenty. These messages notify you of application activity, provide application updates and other relevant information and may allow you to use the applicable application on your phone. The sending of SMS notifications may be handled through a third-party service provider. With your consent, we may send push notifications to your mobile device to provide application updates and other relevant messages. You may be able to manage push notifications from the applicable application or from your device's settings. Our Services may also have direct messaging features built in (In-Band Messages). When available, we may send In-Band Messages directly to your mobile device to notify you of application activity, advertisements, offers and other relevant communication.

ADDITIONALLY, IF YOU HAVE CHOSEN TO SYNCHRONIZE ALL OR PORTIONS OF YOUR MOBILE DEVICE CONTACTS WITH OUR SERVICES, YOUR DECISION MAY INITIATE SMS NOTIFICATIONS TO YOUR FRIENDS TO INVITE THEM TO OUR SERVICES OR ALERT THEM TO RELEVANT APPLICATION ACTIVITY. If you choose to send your contacts invitational messages through the Services, you may be prompted to confirm that you are choosing to initiate SMS messages to the contacts you have selected before such SMS notifications are further transmitted. You agree that the subscribers of the phone numbers to which you initiate any text messages through the Services have consented or otherwise opted in to the receipt of your messages as required by any applicable law or regulation. You are solely responsible for your communications with any other parties through the Services. To invite your friends to join you in using our applications and other Services, the messages sent to your friends may include your name, school network and profile photo.

Fraud Prevention and Legal Compliance. We may use your information to prevent fraud or potentially illegal activities, and enforce our Terms of Service.

Customized User Experiences. We may use your personal information to create customized experiences, or to provide you information or services tailored to your interests and preferences. We may use your IP address and other similar information to make our Services easier to use and navigate as well as to personalize the content provided on the Services.

Product Improvement. If you choose to download our apps, subscribe to our products, participate in our online services, or to register for other Twenty products or services, we will collect the information that you disclose and analyze the data to discover new facts that could help us better understand our products and services. We may use this information for our internal business purposes, such as research to improve our products and analyses that may help us better market our products.

Advertising, Marketing, and Promotions. We may use your information for generating web analytics to compile user information, conducting marketing analysis, providing you with recommendations for products or services based on your profile, and promotional material planning and distribution. In particular, we may use your information to notify users of application updates, to provide application leader boards and promote application user achievements, to solicit input and feedback to improve our products and services, to inform users about new products or promotional offers, and target third parties that may be interested in accessing the Services.

We may create anonymous, aggregated or deidentified data from your personal information and other individuals whose personal information we collect. We make personal information into anonymous, aggregated or de‐identified data by removing information that makes the data personally identifiable to you. We may use this anonymous, aggregated or de‐identified data and share it with third parties for our lawful business purposes, including to analyze and improve the Services and promote our business.

SHARING YOUR INFORMATION

We may share your personal information, with third parties in the following circumstances:

  1. If we have a good faith belief that we are required to disclose the information by law,
  2. In response to legal process (for example, a court order, search warrant or subpoena),
  3. To satisfy applicable laws,
  4. If we believe that the Services are being used to commit a crime, including, but not limited to, to report such criminal activity or to exchange information with other companies and organizations for the purposes of fraud protection and credit risk reduction,
  5. If we have a good faith belief that there is an emergency that poses a threat to the health or safety of a person or the general public,
  6. In order to protect the rights or property of Twenty, including to enforce our Terms of Service,
  7. To third party companies to perform services on our behalf, including data analysis, message delivery, hosting services, customer service, and marketing,
  8. With our subsidiaries and affiliates, and
  9. In connection with a business transaction (or potential business transaction) such as a corporate divestiture, merger, consolidation, acquisition, reorganization or sale of assets, or in the event of bankruptcy or dissolution.

We may also share your information with other users of the Services when such sharing is integrated within the features of the Services, and as directed by you. For example, your username will be included in SMS messages you send to your contacts through the Services, such as invitations to join the Services, and in notifications to existing users of the Services, such as notifications that you have added a user to your “friends” group. Please see the “Notice of Public Posting Areas” section below for more information. Additionally, some of your profile information may be exposed to other users when you participate in the Services, such as by posting content, chatting with other users, or commenting on content. Personal information that may be exposed to other users includes: your name, profile photos, username, school or network name, bio and descriptions of your activity.

NOTICE OF PUBLIC POSTING AREAS AND USER GENERATED CONTENT

We may make available on our Services, or link to, features that allow you to generate your own content or share information online. Please do not include personal information in the content you generate or share personal information online in public or community forums such as “hangouts” or group messages. Whenever you voluntarily disclose personal information online, that information becomes public and can be collected and used by others. We have no control over, and take no responsibility for, the use, storage, dissemination or erasure of personal information embedded in user-generated content or shared publicly. By posting personal information online in public or community forums, you may receive unsolicited messages from other parties.

SECURITY OF YOUR INFORMATION

We implement security measures we believe are reasonable to protect your information. It is important that you protect and maintain the security of your account and you need to immediately notify us of any unauthorized use of your account. No website, mobile application or Internet transmission is completely secure, and therefore we cannot guarantee that unauthorized access, hacking, data loss, or other breaches or other type of misuse will never occur. We may post a notice via the Services if a security breach occurs. We may also send you notice by the contact information you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive written notice of a data privacy or security breach. If you have reason to believe that your personal information that we have collected or our Services' security has been breached, please notify us at hello@twenty.co

YOUR CHOICES

Accessing and Updating Your Information If you have an account on our Services, you can access and edit your profile information directly within the profile page of the app.

Deactivating and Deleting Your Account. You may deactivate your account by following the instructions within the app settings. Deactivating your account does not delete your information. To delete your information, please contact us directly at [insert contact information]. Please note that you must follow these instructions to deactivate or delete your account. Otherwise, your account will remain active, even if you delete or uninstall the app.

Opting Out of Push Notifications. We may send push notifications or alerts to your mobile device. You can deactivate push notifications and alerts at any time by deleting the app, changing your device settings or changing the push notification settings within the app.

Opting Out of SMS Communications. We, or other users of the Services, may send you notifications and other SMS messages. You may opt out of SMS communications by responding to any SMS with the single-word command, “STOP.” In addition, if you have an account, you can opt out of SMS communications by changing the settings within the app. You may opt back in to SMS communications at any time by adjusting your account settings within the Services. Please note that if you do not follow these instructions to opt out of SMS communications, you may continue to receive SMS communications even if you delete or uninstall the app, or block the number that delivers the communications.

Opting Out of Marketing Communications. You may opt out of marketing communications by clicking on the "unsubscribe" link in an email or by replying with the single word "STOP" to text messages. We will process your requests as soon as possible, but please be aware that it may take us some time to respond to your request and, in some circumstances regarding opt-out requests, you may receive a few more messages until your request is processed.

Opting Out of Location Tracking. If you initially consented to our collection of geo-location information through the Services, you can subsequently stop the collection of this information at any time by deleting the app or changing the preferences on your mobile device. Please note, however, that if you withdraw consent to our collection of location information, you will no longer be able to use some features of the Services.

OUR POLICY TOWARD CHILDREN

Our Services are not intended for children under the age of 13, and we do not knowingly collect any personal information from such children. Children under the age of 13 should not use our Services at any time.

CHANGES TO OUR PRIVACY POLICY

We may update this Privacy Policy from time to time. If we make material changes to our Privacy Policy, we will notify you and other users by posting the changes on the Services or by using the contact information you have on file with us and will indicate when such changes will become effective. By continuing to use our Services you are agreeing to be bound by any changes or revisions made to this Privacy Policy.

CALIFORNIA PRIVACY RIGHTS & HOW WE RESPOND TO DO-NOT-TRACK DISCLOSURES

California Civil Code Section 1798.83 permits visitors to the Services who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us at the address provided at the bottom of this Privacy Policy. We do not share personal information with third parties for their direct marketing purposes unless you affirmatively agree to such disclosure, typically by "opting in" to receive information from a third party that is participating in a sweepstakes or other promotion on one of our Services. If you do ask us to share your personal information with a third party for its marketing purposes, we will only share information in connection with that specific promotion, as we do not share information with any third party (other than our service providers) on a continual basis.

At this time our Services do not recognize automated browser signals regarding tracking mechanisms, which may include ”do not track” instructions.

CONTACTING US

If you have any questions, comments, or concerns regarding this Privacy Policy or our privacy practices, please send an email to hello@twenty.co or write to us at the following address:

Twenty Holdings, Inc.
381 Park Avenue South, 17th Floor
New York, NY 10016, ATTN: Legal.

Effective: July 24, 2019