Privacy Policy

Last updated: Oct 17th, 2023

DEEP ORIGIN PTE.LTD(hereinafter referred to as "We") is fully aware of the importance of personal information to you. We will protect your personal information and privacy in accordance with laws and regulations.

We have formulated this Privacy Policy with a special note: We hope that you will carefully read and understand this Privacy Policy before using our platform (Twiner hereinafter referred to as the "Platform") and related services so that you can make an appropriate choice.

This Privacy Policy will help you understand that we will collect and use your information in accordance with the Privacy Policy, but will not collect personal information in a forced bundle manner simply because you agree to this Privacy Policy. When you use or enable the relevant functions or services, we will collect and use the relevant information necessary to realize the functions and services. You may refuse to provide other functions or services without affecting other functions or services unless it is necessary for the realization of basic business functions or necessary information as required by laws and regulations. We will specify in the privacy policy what information is necessary.

The following will help you understand the following:

Personal information you disclose to us

In Short: We collect personal information that you agree to provide to us.

We collect personal information that you voluntarily provide to us when you register on the Services, express an interest in obtaining information about us or our products and Services, when you participate in activities on the Services (such as by posting messages in our online forums or entering competitions, contests or giveaways) or otherwise when you contact us.

The personal information that we collect depends on the context of your interactions with us and the Services, the choices you make and the products and features you use. The personal information we collect may include the following:

Personal Information provided by You. We collect email addresses; names; and other similar information.
Social Media Login Data. We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter or other social media account.
All personal information that you provide to us must be true, complete and accurate, and you must notify us of any changes to such personal information.
Information automatically collected

In Short: Some information — such as your Internet Protocol (IP) address and/or browser and device characteristics — is collected automatically when you visit our Services.

We automatically collect certain information when you visit, use or navigate the Services. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Services and other technical information. This information is primarily needed to maintain the security and operation of our Services, and for our internal analytics and reporting purposes.

Like many businesses, we also collect information through cookies and similar technologies.

The information we collect includes:

Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information our servers automatically collect when you access or use our Services and which we record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Services (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called 'crash dumps') and hardware settings).

Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Services. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model Internet service provider and/or mobile carrier, operating system and system configuration information.

Location Data. We collect location data such as information about your device's location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Services. For example, we may use GPS and other technologies to collect geolocation data that tells us your current location (based on your IP address). You can opt out of allowing us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note however, if you choose to opt out, you may not be able to use certain aspects of the Services.

Information collected through our App

In Short: We collect information regarding your mobile device, push notifications, when you use our App.

If you use our App, we also collect the following information:

Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device's social media accounts, and other features. If you wish to change our access or permissions, you may do so in your device's settings.

Mobile Device Data. We automatically collect device information (such as your mobile device ID, model and manufacturer), operating system, version information and system configuration information, device and application identification numbers, browser type and version, hardware model Internet service provider and/or mobile carrier, and Internet Protocol (IP) address (or proxy server). If you are using our App, we may also collect information about the phone network associated with your mobile device, your mobile device’s operating system or platform, the type of mobile device you use, your mobile device’s unique device ID and information about the features of our App you accessed.

Push Notifications. We may request to send you push notifications regarding your account or certain features of the App. If you wish to opt-out from receiving these types of communications, you may turn them off in your device's settings. This information is primarily needed to maintain the security and operation of our App, for troubleshooting and for our internal analytics and reporting purposes.

How do we use your information?

In Short: We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

We use personal information collected via our Services for a variety of business purposes described below. We process your personal information for these purposes in reliance on our legitimate business interests, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations. We indicate the specific processing grounds we rely on next to each purpose listed below.

We use the information we collect or receive:

To facilitate account creation and logon(sign-in) process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract.

To post testimonials. We post testimonials on our Services that may contain personal information. Prior to posting a testimonial, we will obtain your consent to use your name and the content of the testimonial. If you wish to update, or delete your testimonial, please contact us at service@twiner.ai and be sure to include your name, testimonial location, and contact information. Request feedback. We may use your information to request feedback and to contact you about your use of our Services.

To enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user's consent.

To manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.

To send administrative information to you. We may use your personal information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.

To protect our Services. We may use your information as part of our efforts to keep our Services safe and secure (for example, for fraud monitoring and prevention).

To enforce our terms, conditions and policies for business purposes, to comply with legal and regulatory requirements or in connection with our contract.

To respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.

Fulfill and manage your orders. We may use your information to fulfill and manage your orders, payments, returns, and exchanges made through the Services.

Administer prize draws and competitions. We may use your information to administer prize draws and competitions when you elect to participate in our competitions.

To deliver and facilitate delivery of services to the user. We may use your information to provide you with the requested service.

To respond to user inquiries/offer support to users. We may use your information to respond to your inquiries and solve any potential issues you might have with the use of our Services.

Will your information be shared with anyone?

In Short: We only share information with your consent, to comply with laws, to provide you with services, to protect your rights, or to fulfill business obligations.

We may process or share your data that we hold based on the following legal basis:

Consent: We may process your data if you have given us specific consent to use your personal information for a specific purpose.

Legitimate Interests: We may process your data when it is reasonably necessary to achieve our legitimate business interests.

Performance of a Contract: Where we have entered into a contract with you, we may process your personal information to fulfill the terms of our contract.

Legal Obligations: We may disclose your information where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).

Vital Interests: We may disclose your information where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved. More specifically, we may need to process your data or share your personal information in the following situations:

Business Transfers. We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.

Vendors, Consultants and Other Third-Party Service Providers. We may share your data with third-party vendors, service providers, contractors or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Services, which will enable them to collect data on our behalf about how you interact with our Services over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity. Unless described in this notice, we do not share, sell, rent or trade any of your information with third parties for their promotional purposes. We have contracts in place with our data processors, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct.

Other Users. When you share personal information (for example, by posting comments, contributions or other content to the Services) or otherwise interact with public areas of the Services, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our Services and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity, communicate with you within our Services, and view your profile.

Who will your information be shared with?

In Short: We only share information with the following third parties.

We only share and disclose your information with the following third parties as you agreed. We have categorized each party so that you may be easily understand the purpose of our data collection and processing practices. If we have processed your data based on your consent and you wish to revoke your consent

Allow Users to Connect to Their Third-Party Accounts Google account

Cloud Computing Services Google Cloud Platform

Functionality and Infrastructure Optimization Cloud Functions for Firebase , Firebase Realtime Database and Firebase Hosting

User Account Registration and Authentication Google Sign-In

Do we use cookies and other tracking technologies?

In Short: We may use cookies and other tracking technologies to collect and store your information.

We may use cookies and similar tracking technologies (like web beacons and pixels) to access or store information. Specific information about how we use such technologies and how you can refuse certain cookies is set out in our Cookie Notice.

How do we handle your social logins?

In Short: If you choose to register or log in to our services using a social media account, we may have access to certain information about you.

Our Services offers you the ability to register and login using your third-party social media account details (like your Facebook or Twitter logins). Where you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, profile picture as well as other information you choose to make public on such social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use and share your personal information, and how you can set your privacy preferences on their sites and apps.

How long do we keep your information?

In Short: We keep your information for as long as necessary to fulfill the purposes outlined in this privacy notice unless otherwise required by law.

We will only keep your personal information for as long as it is necessary for the purposes set out in this privacy notice, unless a longer retention period is required or permitted by law (such as tax, accounting or other legal requirements). No purpose in this notice will require us keeping your personal information for longer than the period of time in which users have an account with us.

When we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize such information, or, if this is not possible (for example, because your personal information has been stored in backup archives), then we will securely store your personal information and isolate it from any further processing until deletion is possible.

How do we keep your information safe?

In Short: We aim to protect your personal information through a system of organizational and technical security measures.

We have implemented appropriate technical and organizational security measures designed to protect the security of any personal information we process. However, despite our safeguards and efforts to secure your information, no electronic transmission over the Internet or information storage technology can be guaranteed to be 100% secure, so we cannot promise or guarantee that hackers, cybercriminals, or other unauthorized third parties will not be able to defeat our security, and improperly collect, access, steal, or modify your information. Although we will do our best to protect your personal information, transmission of personal information to and from our Services is at your own risk. You should only access the Services within a secure environment.

Scope of Application:

This Privacy Policy applies to all services provided by DEEP ORIGIN PTE.LTD and its affiliates, including the client, website, etc., and does not apply to third-party products or services that have a separate privacy policy and are not included in this Privacy Policy.

This Privacy Policy does not apply to:

1. Other third party products or services, which may include products or websites and advertising content shown to you or

Other products or websites linked to in the software Service;

2. Other third parties that advertise the Software Services.

Your use of these third-party services (including any personal information you provide to these third parties) will be subject to the terms of service and privacy policies of these third parties (not this Privacy Policy). For specific provisions, please read the terms of these third parties carefully. Please protect your personal information properly and only provide it to third parties when necessary.

The software and related services mentioned in this Privacy Policy may vary according to the mobile phone model, system version, software application version and other factors you use. The final products and services are subject to the software and related services used by you.

1. The headings in this Privacy Policy are for convenience and reading only and do not affect the meaning or interpretation of any provisions in this Privacy Policy.

2. Definitions of terms related to this "Privacy Policy" :

(1) Affiliate means any company, institution and legal representative of such company or institution which is or will be controlled, controlled or jointly controlled by a Party. "Control" means having the ability, directly or indirectly, to influence the management of the company, whether through ownership, voting shares, contracts or other legally recognized means.

(2) De-identification refers to the process of technical processing of personal information to make it unable to identify the subject of personal information without the aid of additional information.

(3) Anonymization refers to the process in which the subject of personal information cannot be identified and the processed information cannot be recovered through technical processing of personal information.

3. The copyright of this Privacy Policy belongs to DEEP ORIGIN PTE.LTD. To the extent permitted by law, we have the right to interpret and modify it. Terms of Service and Personal Information Protection Statement (not this Policy), which you are required to read carefully. We will only share your information for legitimate, necessary and specific purposes. We will require them to comply with their confidentiality obligations and take appropriate security measures.

4. Ensure the safety of products, services and users: In order to help us better understand the operation of the software and related services and ensure the safety of operation and service provision, we use third-party statistical tools to record network log information, as well as the frequency, crash data, overall installation, usage, performance data and other information of the software and related services. Please be aware that when collecting and using the above information, we have carried out de-identification/anonymisation processing. Data analysis only corresponds to specific codes that cannot be directly associated with user identities.

5. Handling Changes in the Purpose of collecting and using Personal Information Please understand that with the development of our business, the functions and services of the software may be adjusted and changed. If we collect or use your personal information in a situation that is not directly or reasonably related to the original purpose, we will inform you again and obtain your consent.

6. Personal Information that is exempt by law from collection and use with consent:

Please understand that, in accordance with laws and regulations and/or relevant national standards, we do not need to obtain your authorization to collect and use your personal information under the following circumstances:

(1) Those directly related to national security and national defense security;

(2) those directly related to public security, public health or major public interests;

(3) those directly related to the investigation, prosecution, trial and execution of judgments of crimes;

(4) In order to protect the life, property and other major legal rights and interests of the subject of personal information or other individuals, but it is difficult to get the consent of the person;

(5) Your personal information collected is disclosed to the public by yourself;

(6) Your personal information collected from legally publicly disclosed information, such as legal news reports, government information disclosure channels;

(7) necessary for the signing and performance of the contract according to your requirements;

(8) Other circumstances stipulated by laws and regulations.

In particular, you are reminded that if the information cannot be identified individually or in combination with other information, it does not belong to your personal information in the legal sense; When your information can be identified as your personal identity alone or in combination with other information, or when we use the data that cannot be associated with any specific personal information with other personal information, such information will be treated and protected as your personal information in accordance with this Privacy Policy during the period of combined use.

Use of Cookies and similar technologies:

Cookie and similar technologies are commonly used in the Internet. When you use the software and related services, we may use relevant technologies to send one or more cookies or anonymous identifiers to your device to collect and store information about your access to and use of the Product. We may set cookies or anonymous identifiers for authentication and security to ensure the safe and efficient operation of products and services, and help us improve service efficiency and login and response speed.

How We Store Personal Information:

1. Where the information is stored

In accordance with laws and regulations, we store your personal information collected and generated during our operations in China in a lawful and compliant location.

2. Storage duration

We will only retain your personal information for as long as necessary for the purpose of providing the software and Services. After the necessary period, we will delete or anonymize your personal information, except as otherwise stipulated by laws and regulations.

How We share, transfer and publicly disclose Personal Information:

Step 1 Share

Respecting the privacy of our users is one of our fundamental principles. We will not share your personal information with any company, organization or individual except in the following circumstances:

(1) Sharing with Express consent: With your express consent, we will share your personal information with other parties.

(2) We may share your personal information as required by judicial or administrative authorities.

(3) Sharing with Affiliates: Your personal information may be shared with our affiliates. We will only share necessary personal information subject to the purposes stated in this Privacy Policy. If the Affiliated company wants to change the purpose of processing personal information, it will again seek your authorized consent.

(4) Sharing with Authorized Partners: Some of our services will be provided by authorized partners only for the purposes stated in this Policy. We may share some of your personal information with our partners to provide better customer service and user experience. We will only share your personal information for legal, legitimate, necessary, specific and explicit purposes, and will only share your personal information necessary to provide services, for example, you must share your information with logistics companies when you purchase our products online. Our partners have no right to use shared personal information for any other purpose. We will sign strict confidentiality agreements with companies, organizations and individuals with whom we share personal information, requiring them to handle personal information in accordance with our instructions, this Privacy Policy and any other relevant confidentiality and security measures.

Step 2 Transfer

We will not transfer your personal information to any company, organization or individual except in the following cases:

(1) Transfer with express consent: After obtaining your express consent, we will transfer your personal information to other parties.

3. Public disclosure

We will only publicly disclose your personal information in the following circumstances:

(1) Disclose the personal information specified by you in the manner of disclosure to which you expressly agree

(2) If it is necessary to provide your personal information in accordance with laws, regulations, mandatory administrative enforcement or judicial requirements, we may publicly disclose your personal information according to the type and disclosure method of personal information required. Under the premise of complying with laws and regulations, when we receive the above request for disclosure of information, we will require the issuance of corresponding legal documents, such as subpoenas or investigation letters.

4. Please understand that under the following circumstances, according to laws and regulations and/or relevant national standards, we do not need to obtain your authorization and consent to share, transfer or publicly disclose your personal information

(1) Those directly related to national security and national defense security;

(2) those directly related to public security, public health or major public interests;

(3) those directly related to the investigation, prosecution, trial and execution of judgments of crimes;

(4) To protect your or other individuals' life, property and other major legal rights and interests, but it is difficult to get your consent;

(5) Your personal information disclosed to the public by yourself;

(6) Collecting personal information from legally publicly disclosed information, such as legal news reports, government information disclosure and other channels.

5, how we protect the security of personal information:

We attach great importance to the security of your personal information and will strive to take reasonable security measures (including technical and management aspects) to protect your personal information and prevent the personal information provided by you from being improperly used or unauthorized access, public disclosure, use, modification, damage, loss or disclosure.
We will protect your personal information by reasonable and feasible means, such as encryption technology and anonymization, which are no lower than those of the industry peers, and use security protection mechanism to prevent malicious attacks on your personal information.
We will establish a special security department, security management system and data security process to ensure the security of your personal information. We adopt a strict system of data use and access to ensure that only authorized personnel have access to your personal information, and conduct security audits of data and technology when appropriate.
Although the above reasonable and effective measures have been taken and the standards required by relevant laws and regulations have been complied with, please understand that due to technological limitations and possible malicious means, in the Internet industry, it is impossible to guarantee the security of information 100% even if we do our best to strengthen security measures. We will do our best to ensure the security of the personal information you provide to us. You know and understand that the systems and communication networks you use to access our services may become defective due to factors beyond our control. Therefore, we strongly recommend that you take proactive measures to protect the security of your personal information.
We will formulate emergency response plans and immediately launch them in case of user information security incidents, so as to prevent the impact and consequences of such security incidents from expanding. Once a user information security incident (leakage, loss, etc.) occurs, we will, in accordance with the requirements of laws and regulations, promptly inform you of the basic situation and possible impact of the security incident, the measures we have taken or will take to deal with it, the suggestions you can independently prevent and reduce the risk, and the remedial measures for you. We will timely inform you of the relevant information in the form of push notification, email, letter, SMS, etc. If it is difficult to inform you one by one, we will make announcements in a reasonable and effective way. At the same time, we will also report the handling of user information security incidents according to the requirements of relevant regulatory authorities.
We hereby remind you that the personal information protection measures provided in this Privacy Policy only apply to the software and related services. Once you leave the Software and related services and browse or use other websites, services and content resources, we shall not have the ability and obligation to protect any personal information submitted by you in the software and websites other than the software and related services, no matter whether you log in, browse or use the software or website based on the links or guidance of the software.

Your Rights:

We attach great importance to your management of personal information, and try our best to protect your right to access, modify (update or correct), delete and withdraw your authorized consent to your personal information, so that you have the full ability to protect your privacy and security.
Manage and withdraw Authorized Information You can withdraw your consent, change the scope of your authorization for us to continue to collect personal information, or withdraw your authorization by disabling the function, changing the application permissions in the device Settings, etc. Please understand that specific business functions and services will require your information to be completed. After you withdraw your consent or authorization, we will not be able to provide you with the corresponding functions and services, nor will we process your relevant personal information. However, your decision to withdraw your consent or authorization will not affect the processing of personal information previously conducted based on your authorization.
Access the privacy policy. You can view all contents of the Privacy policy in Settings/My - Privacy Policy on the client.
Cease operations to inform you of your rights If we cease operations, we will promptly stop the collection of your personal information, notify you of the notice of cease operations in the form of one-by-one delivery or announcement, and delete or anonymize your personal information we hold.
Personally Deregister, you can deregister your previously registered account at any time by using the following method: in TwinerAPP, click My - > Account Security - > Deregister to go to the Deregister page, and click the "Apply for Deregister" button. After you cancel your account, we will stop providing you with products or services and delete your personal information upon your request, unless otherwise stipulated by laws and regulations.

Minors Clause

If you are a minor under the age of 18, you shall read and agree to this Privacy Policy under the supervision and guidance of your parents or other guardians before using the Software and related services. We protect minors' personal information in accordance with relevant national laws and regulations, and will only collect, use, share or disclose minors' personal information if it is permitted by law, expressly agreed by parents or other guardians or necessary for the protection of minors; If we find that personal information about minors has been collected without prior verifiable parental consent, we will seek to remove it as soon as possibleIf you are the guardian of a minor, if you have any questions about the personal information of the minor under your custody, please contact us through the contact information published in this Privacy Policy.

Amendment and Notice of Privacy Policy:

1. In order to provide you with better services, the software and related services will be updated and changed from time to time, and we will revise this Privacy Policy at a timely time. Such revisions form a part of this Privacy Policy and have the same effect as this Privacy Policy. However, without your express consent, we will not reduce your rights under this Privacy Policy currently in effect.

2. After this Privacy Policy is updated, we will remind you of the updated content in the application client and before the updated terms take effect, so that you can timely learn about the latest version of this Privacy Policy. If you continue to use our service, you agree to accept the contents of this revised policy. However, if the updated content requires the collection of personal sensitive information such as audio and video, contact information, and geographical location, your consent will be sought again in a prominent manner.

3. For major changes, we will also provide more prominent notices (we will explain the changes to the privacy policy by means including but not limited to emails, short messages, private messages or special prompts on the browsing page, etc. Please read it carefully again).

Material changes referred to in this Privacy Policy include, but are not limited to:

(1) Significant changes have taken place in our service model. Such as the purpose of personal information processing, the type of personal information processing, personal information use, etc.;

(2) Major changes have taken place in our ownership structure and organizational structure. Such as business adjustment, bankruptcy merger and acquisition caused by ownership change, etc.;

(3) The main object of personal information sharing, transfer or public disclosure has changed;

(4) Your rights to participate in personal information processing and the way in which they are exercised have changed significantly;

(5) When the department responsible for handling personal information security, contact information and complaint channels change.