Section A: Collection, Use, and Disclosure of Personal Information

The Categories of Personal Information We Collect

We collect the following categories of personal information from users of the aTwist mobile app:

• Account and Login Information: When you register or log in to aTwist, we collect your email address, username, password (encrypted), and other identifiers you provide, such as your first and last name, phone number, date of birth, and profile photo.
• Payment Details: If you make in-app purchases or subscribe to a paid plan within aTwist, we collect payment method details, billing address, transaction history, and any promotional or gift codes you redeem. Payment processing is handled by secure third-party providers.
• Usage and Analytics Information: We automatically collect data about how you interact with the App, including features you use, actions you take (such as taps, swipes, and navigation paths), session duration, crash reports, error logs, search queries within the App, and content you create or engage with.
• Location Data: With your permission, we collect precise or approximate location information from your mobile device. This may be used to personalize your experience, provide location-based features, and deliver relevant content or advertisements. You can manage location permissions in your device settings at any time.
• Advertising Information: We collect data to support in-app advertisements, including resettable device identifiers (such as Apple's Identifier for Advertisers or Google Advertising ID), IP address, inferences about your interests based on your in-app activity, and information from advertising partners about your interactions across other apps and websites.
• Device and Network Information: We collect information about the device you use to access aTwist, including device type and model, operating system version, unique device identifiers, IP address, mobile network and Wi-Fi connection data, and app performance data such as crash reports and timestamps.
• Communications: If you contact us for support, participate in surveys, or communicate with us through the App, we collect the content of those communications and your interaction with messages we send (such as push notifications, emails, and in-app messages).

Where We Collect Personal Information From

We collect your personal information from the following sources:

• Directly from you — when you register, update your profile, make purchases, or contact us.
• Automatically — through your use of the App, including interactions, device signals, and crash data.
• From third-party partners — such as analytics providers, advertising networks, payment processors, and social login providers (e.g., Google or Apple Sign-In) you choose to use.
• From advertising companies — who may provide demographic data, interest profiles, and interaction history to help deliver relevant ads.

How We Use Your Personal Information

We use your personal information for the following purposes:

• To provide and operate the App, including account creation, content delivery, and feature access.
• To process payments and manage your subscription or in-app purchases.
• To personalize your experience, including content recommendations and app customization based on your usage and location.
• To send you transactional messages such as payment confirmations, account alerts, and security notifications.
• To send marketing and promotional communications about new features, offers, and updates (you can opt out at any time).
• To serve in-app advertisements, including behavioral advertisements targeted based on your activity and interests. You may opt out of behavioral ads in your App settings.
• To analyze usage trends and improve the performance, reliability, and features of the App.
• To ensure safety, security, and fraud prevention, including detecting and preventing unauthorized access or illegal activity.
• To comply with applicable laws, regulations, and legal obligations.

Who We Disclose Personal Information To

We may share your personal information with the following parties:

• Service Providers: Third-party vendors who assist us in operating the App, such as cloud hosting, payment processing, analytics, customer support, and push notification services. They are authorized to use your information only to perform services on our behalf.
• Advertising Companies: We share data with advertising partners, ad networks, and measurement companies to deliver, optimize, and measure the effectiveness of in-app advertisements.
• Analytics Providers: We use analytics tools (such as Firebase or similar) that collect and process usage data to help us understand how users interact with the App.
• Business Partners: If you access aTwist through a partner integration or promotion, we may share relevant account or activity data with that partner.
• Corporate Transactions: In the event of a merger, acquisition, or sale of assets, your personal information may be transferred to the acquiring entity, subject to the commitments in this Privacy Policy.
• Legal and Safety Disclosures: We may disclose your information when required by law, regulation, or legal process, or when necessary to protect the rights, safety, and security of aTwist, its users, or the public.

Section B: Your Rights and Controls

Your Privacy Rights

Depending on your location, you may have the following rights regarding your personal information:

• Access and Portability — Request a copy of the personal information we hold about you.
• Correction — Request that we correct inaccurate or incomplete information.
• Deletion — Request that we delete your personal information, subject to legal obligations.
• Objection and Restriction — Object to or request restriction of certain processing activities.
• Withdrawal of Consent — Where processing is based on consent, you may withdraw it at any time without affecting prior lawful processing.
• Right to Complain — You have the right to lodge a complaint with your local data protection authority.

To exercise any of these rights, please contact us at info@atwist.com . We will respond to verified requests in accordance with applicable law.

Communication and Marketing Preferences

• Push Notifications: You can manage push notification preferences in your device settings or within the App under Settings > Notifications.
• Email Marketing: You may unsubscribe from promotional emails by clicking "Unsubscribe" in any marketing email or updating your preferences in the App. Transactional messages (such as receipts and security alerts) cannot be disabled.
• In-App Messages: You can manage in-app communication preferences under Settings > Privacy & Data in the App.

Advertising Choices

aTwist may display behavioral advertisements based on your activity within the App and across other services. You have the following choices:

• Behavioral Advertising Toggle: Visit Settings > Privacy & Data in the App to turn off behavioral advertising. You will still see ads, but they will not be personalized.
• Device-Level Opt-Out: You can reset or limit your device's advertising identifier through your iOS or Android privacy settings.
• Industry Opt-Out Programs: aTwist supports opt-out tools provided by the Digital Advertising Alliance (DAA), EDAA (Europe), and DAAC (Canada).

Section C: Location Data

aTwist requests access to your device location to provide location-based features and personalized content. Specifically:

• Precise Location: Used when you opt in to features that require your exact position (e.g., nearby content or events).
• Approximate Location: Derived from your IP address for general content localization and ad targeting, even without explicit location permission.

You can revoke location access at any time in your device Settings > Privacy > Location Services > aTwist. Revoking access may limit certain features of the App.

Section D: Cookies and Similar Technologies

Although aTwist is a mobile application, we and our partners use similar tracking technologies including:

• Resettable Device Identifiers (e.g., IDFA on iOS, GAID on Android) to personalize ads and measure campaign effectiveness.
• SDKs and Analytics Libraries embedded in the App to collect usage and performance data.
• Pixel Tags in any web-based features or emails to understand user interactions.

To limit the use of these technologies, you can reset your advertising identifier or enable "Limit Ad Tracking" in your device settings. Note that doing so will not prevent all data collection, but will limit behavioral advertising.

Section E: Data Security and Retention

Security

We implement industry-standard administrative, technical, and physical safeguards to protect your personal information from unauthorized access, disclosure, alteration, or destruction. These include encrypted data transmission (TLS), secure storage, and access controls.

Specifically, we maintain administrative, technical, and physical safeguards designed to protect your personal information against unauthorized access, disclosure, alteration, and destruction. These safeguards include:

• Encryption of personal information in transit using TLS 1.2 or higher, and at rest using AES-256 or equivalent industry-standard encryption.
• Role-based access controls and the principle of least privilege for personnel and systems handling personal information.
• Multi-factor authentication (MFA) for administrative access to systems containing personal information, and MFA available to users for account login.
• Regular security assessments, vulnerability scanning, and penetration testing of our infrastructure and applications.
• Logging and monitoring of access to systems containing personal information, with alerting on anomalous activity.
• A formal incident response process to investigate, contain, and remediate security incidents.
• Vendor security review prior to engaging third-party service providers that process personal information on our behalf.

However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security. In the event of a security incident that results in the unauthorized access, disclosure, or loss of your personal information, aTwist will notify affected users and applicable regulatory authorities without undue delay and in accordance with the timeframes and requirements of applicable law. Where required, notification to supervisory authorities will be provided within 72 hours of becoming aware of the incident. Notifications to users will describe, to the extent known, the nature of the incident, the categories of information affected, the steps we are taking in response, and any actions you may take to protect yourself.

If you believe you have identified a security vulnerability in aTwist, please report it to security@atwist.com . We commit to acknowledging legitimate reports promptly and investigating in good faith.

Retention

We retain your personal information only for as long as necessary to fulfill the purposes described in this Privacy Policy or as required by law. Specific retention periods by data category are as follows:

• Account information (email, username, profile data): retained for the duration of your active account, and for up to 12 months following account closure, after which it is deleted or de-identified.
• Payment and transaction records: retained for 7 years to comply with tax, accounting, and audit obligations.
• Usage and analytics data: retained in identifiable form for up to 13 months; aggregated or de-identified data may be retained indefinitely.
• Device and advertising identifiers: retained for up to 13 months from last activity.
• Support communications: retained for up to 24 months following resolution.
• Crash logs and error reports: retained for up to 90 days.

Section F: Children's Privacy

aTwist is not directed to children under the age of 13 (or the applicable minimum age in your jurisdiction, which may be higher). We use the following measures to enforce this age limitation:

• Age gate at registration: During account creation, users are required to provide a date of birth. Users who indicate they are under the applicable minimum age are prevented from creating an account.
• Parental involvement for minors: Users between 13 and 18 (or the local age of majority) are required to confirm that a parent or legal guardian has reviewed and accepted these Terms on their behalf.
• Detection and removal: If we become aware that we have collected personal information from a child below the applicable minimum age without verifiable parental consent, we will promptly delete such information and terminate the associated account.
• Parental requests: A parent or legal guardian who believes their child has provided us with personal information may contact privacy@atwist.com to request review and deletion.

Section G: International Data Transfers

aTwist operates globally, and your personal information may be transferred to and processed in countries other than your country of residence. These countries may have different data protection laws. Wherever we transfer personal information internationally, we apply appropriate safeguards, such as standard contractual clauses or other legally recognized mechanisms, to ensure your information receives an adequate level of protection.

Section H: Third-Party Links and Services

The App may contain links to third-party websites, services, or advertisements. We are not responsible for the privacy practices of these third parties, and this Privacy Policy does not apply to them. We encourage you to review the privacy policies of any third-party services you access through the App.

Section I: Universal Opt Out Signals

aTwist recognizes and honors the Global Privacy Control (GPC) browser signal as a valid request to opt out of the sale or sharing of personal information for cross-context behavioral advertising, where required by applicable law (including the California Consumer Privacy Act as amended by the CPRA, and the Colorado Privacy Act). When we detect a GPC signal from a browser-based interaction associated with your account or device, we will treat it as a request to opt out and will apply that preference to the associated identifiers to the extent technically feasible.

Section J: Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, legal requirements, or other factors. When we make material changes, we will notify you via a prominent in-app notice or email prior to the changes taking effect. Your continued use of aTwist after such updates constitutes your acknowledgment of the revised Privacy Policy.

If you do not agree to the updated Privacy Policy, you should discontinue use of the App and may request deletion of your account by contacting info@atwist.com .

Contacting Us

For questions about this Privacy Policy or to exercise your privacy rights, please contact our Privacy Team at:

For general support, please visit our Help Center within the App or at help.atwist.app .