Privacy Policy

TWOMSYS Corp. ("Company," "we," "us," or "our") is committed to protecting your privacy and personal information. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our mobile applications, websites, and related services (collectively, the "Services").

We comply with applicable data protection laws, including the General Data Protection Regulation (GDPR), California Consumer Privacy Act (CCPA), Personal Information Protection and Electronic Documents Act (PIPEDA), Japan's Personal Information Protection Act, and other relevant privacy legislation.

1. Information We Collect

1.1 Information You Provide Directly

Data Category	Specific Information	Purpose	Legal Basis
Account Information	Name, email address, username	Account creation and management, authentication	Contract performance, Consent
Profile Information	Profile photos, bio, preferences	Service personalization, user experience	Consent
Communication Data	Messages, posts, comments, support inquiries	Service provision, customer support	Contract performance, Consent
Payment Information	Payment method details, transaction history	Payment processing, fraud prevention	Contract performance, Legal obligation

1.2 Information Collected Automatically

Data Category	Specific Information	Purpose	Legal Basis
Device Information	Device ID, operating system, app version, device model	Service optimization, technical support	Legitimate interest
Usage Data	App interactions, features used, session duration	Service improvement, analytics	Legitimate interest, Consent
Log Data	IP address, access times, pages viewed, clickstream data	Security, fraud prevention, system administration	Legitimate interest, Legal obligation
Location Data	Approximate location (if enabled)	Location-based features, content personalization	Consent

1.3 Third-Party Integration Data

When you connect third-party services to our app:

• Google: Name, email address, profile picture
• Apple: Name, email address (or relay email)
• Social Media: Profile information you choose to share

1.4 Special Categories of Data

We do not intentionally collect sensitive personal information such as health data, biometric data, or information about political opinions, religious beliefs, or sexual orientation unless explicitly required for specific features and with your explicit consent.

2. How We Use Your Information

Purpose	Data Used	Legal Basis
Provide and maintain Services	Account info, usage data, device info	Contract performance
Personalize user experience	Profile info, usage patterns, preferences	Consent, Legitimate interest
Process payments	Payment information, transaction data	Contract performance
Customer support	Communication data, account info	Contract performance
Security and fraud prevention	Log data, device info, usage patterns	Legitimate interest, Legal obligation
Analytics and improvements	Usage data, performance metrics	Legitimate interest, Consent
Marketing communications	Contact information, preferences	Consent
Legal compliance	All data as necessary	Legal obligation

3. Data Sharing and Disclosure

3.1 Service Providers

We share data with trusted service providers who assist us in operating our Services:

• Cloud Storage: Google Cloud Platform, Amazon Web Services
• Analytics: Google Analytics, Firebase Analytics
• Payment Processing: Stripe, Apple Pay, Google Pay
• Customer Support: Zendesk, Intercom
• Marketing: Mailchimp, SendGrid

3.2 Business Transfers

In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of that transaction.

3.3 Legal Requirements

We may disclose your information when required by law, court order, or to protect our rights, property, or safety.

3.4 International Transfers

4. Data Retention

Data Type	Retention Period	Reason
Account Information	Until account deletion + 30 days	Service provision, dispute resolution
Usage and Log Data	3 months	Security, analytics
Payment Records	5 years	Legal compliance, tax requirements
Marketing Data	Until consent withdrawal	Marketing purposes
Support Communications	3 years	Customer service, quality assurance

5. Your Privacy Rights

How to Exercise Your Rights

To exercise your privacy rights, contact us at:

• Email: privacy@twomsys.com
• In-app privacy settings
• Privacy request form on our website

6. Cookies and Tracking Technologies

6.1 Types of Cookies We Use

Cookie Type	Purpose	Duration
Essential Cookies	Core app functionality, security	Session/Persistent
Analytics Cookies	Usage analytics, performance monitoring	Up to 2 years
Preference Cookies	User settings, personalization	Up to 1 year
Marketing Cookies	Advertising, remarketing	Up to 1 year

6.2 Cookie Management

You can control cookies through:

• Browser settings
• In-app privacy preferences
• Third-party opt-out tools

7. Children's Privacy

8. Data Security

We implement comprehensive security measures:

• Encryption: Data encrypted in transit and at rest
• Access Controls: Strict employee access controls
• Security Monitoring: 24/7 security monitoring
• Regular Audits: Security assessments and penetration testing
• Incident Response: Established data breach response procedures

9. Data Breach Notification

In the event of a data breach that poses a risk to your rights and freedoms, we will:

• Notify relevant authorities within 72 hours (where required)
• Inform affected users without undue delay
• Provide clear information about the nature of the breach
• Offer guidance on protective measures

10. Third-Party Links and Services

Our Services may contain links to third-party websites or integrate with third-party services. This Privacy Policy does not apply to such third parties. We encourage you to review their privacy policies.

11. Automated Decision-Making

We may use automated systems for:

• Content recommendations
• Fraud detection
• Customer support routing

You have the right to request human review of automated decisions that significantly affect you.

12. Changes to This Privacy Policy

We may update this Privacy Policy periodically. We will notify you of material changes through:

• In-app notifications
• Email notifications
• Website banners

Continued use of our Services after changes indicates acceptance of the updated policy.

13. Contact Information

14. Supervisory Authorities