Privacy Policy

This Privacy Policy explains how 1001435496 ONTARIO INC. ("Twist," "we," "us," or "our") collects, uses, discloses, and protects your information when you use:

• the Twist mobile application;
• our websites; and
• related services (collectively, the "Service").

By using the Service, you agree to the collection and use of information in accordance with this Privacy Policy. If you do not agree, you must not use the Service.

1. Information We Collect

We may collect the following categories of information.

1.1 Information you provide directly

• Account information: username, display name, email address, password (stored in hashed form), age or date of birth where needed to verify eligibility.
• Profile information: profile photo or avatar, biography, preferences, and any information you choose to include in your profile.
• User Content: images, photos, prompts, messages, and other content you upload or create within the Service, including AI Output.
• Communications: information you provide when you contact us, such as support requests, bug reports, or feedback.

1.2 Information we collect automatically

When you use the Service, we automatically collect certain information, which may include:

• Device information: device type, operating system and version, language, device identifiers, and mobile network information.
• Log and usage data: time and duration of sessions, pages or screens viewed, features used, game rounds played, interactions with other users, AI calls and responses (logs and metadata rather than full content where feasible), and crash or performance data.
• Approximate location: derived from IP address, used for security, abuse prevention, analytics, and compliance with regional requirements.
• Cookies and similar technologies (on the Site): small text files, SDKs, and similar tools to remember your preferences, enhance functionality, and measure usage.

We may use third-party analytics providers to help us understand how the Service is used (for example, aggregate usage statistics and performance metrics).

1.3 Information from third parties

We may receive information about you from:

• App store providers: such as Apple, including purchase history, subscription status, and limited account data necessary to process in-app purchases and refunds.
• Social or platform logins (if enabled): if you choose to sign up or log in via a third-party account, we may receive information such as your name, email address, and profile picture as permitted by that provider.
• Third-party AI providers: logs or metadata associated with requests (e.g., model usage statistics) to provide and improve AI features.
• Other users: if they invite you to the Service, mention you, or upload images that include you (subject to their responsibilities and applicable law).

We handle such information in accordance with this Privacy Policy and any additional restrictions imposed by the source.

2. How We Use Your Information

We use your information for the following purposes:

2.1 To provide and operate the Service

• Create and manage your account;
• Facilitate gameplay, including game sessions, matchmaking, and voting;
• Generate AI Output from your prompts and images using third-party AI services;
• Maintain your profile, friends list, and gameplay history;
• Process in-app purchases and subscriptions through app store providers;
• Provide customer support and respond to your inquiries.

2.2 To maintain safety, security, and integrity

• Detect, prevent, and respond to fraud, abuse, cheating, and other harmful or illegal activity;
• Enforce our Terms of Service and content policies, including automated and manual review of content where appropriate;
• Protect our rights, property, and the safety of users and third parties.

2.3 To improve and develop the Service

• Analyze how users interact with the Service;
• Debug and troubleshoot issues;
• Improve performance and user experience;
• Develop new features, game modes, and safety systems;
• Improve AI models and safety filters (for example, by using de-identified or aggregated data where feasible).

2.4 To communicate with you

• Send you service-related messages (e.g., account verification, updates to terms or policies, security alerts);
• Respond to your feedback and support requests;
• With your consent where required, send you optional communications about new features, events, or promotions (you can opt out at any time).

2.5 To comply with legal obligations

• Comply with applicable laws and regulations;
• Respond to lawful requests or legal process;
• Establish, exercise, or defend legal claims.

3. Legal Bases for Processing (where applicable)

If you are located in the European Economic Area, the UK, or another jurisdiction requiring a legal basis for processing, we process your personal data on one or more of the following bases:

• Contract: to provide the Service and perform our agreement with you (e.g., account management, gameplay).
• Legitimate interests: to operate, secure, and improve the Service; to prevent misuse; and to protect our rights and those of users and third parties, where these interests are not overridden by your rights and interests.
• Consent: for certain optional activities (e.g., some marketing communications) or where required by law (you may withdraw consent at any time).
• Legal obligation: to comply with applicable laws and regulations.

4. How We Share Your Information

We do not sell your personal information. We may share your information in the following circumstances:

4.1 Service providers and partners

We share information with trusted third-party service providers who perform services on our behalf. Specifically:

• AI Service Providers (Google LLC, xAI Corp.): User-uploaded photos and text prompts are shared for the purpose of AI-powered image transformation, which is a core feature of the app.
• Cloud Infrastructure (Google Cloud, Firebase): For hosting, database, and data storage.
• Authentication Providers (Apple, Google/Firebase): For secure user sign-in services.
• Payment Processors (Apple, RevenueCat): For in-app purchase processing, subscription management, and receipt validation.
• Analytics and crash reporting: To help us understand how the Service is used and to diagnose issues.

These providers are given only the information reasonably necessary to perform their services and are bound by contractual obligations to protect your information and use it only for the purposes we specify. We do not sell your personal data to any third party.

4.2 Other users

Certain information is visible to other users as part of normal operation of the Service, such as:

• your display name and profile picture;
• User Content and AI Output you submit in a game session;
• reactions and votes you contribute in public rounds.

You should assume that other players in a game can see and potentially capture content displayed there (for example, via screenshots), even if such behavior may violate our Terms.

4.3 Business transfers

If we are involved in a merger, acquisition, reorganization, sale of assets, financing, or similar transaction, your information may be transferred as part of that transaction, subject to confidentiality and data protection obligations. We will take reasonable steps to notify you if your personal information becomes subject to a materially different privacy policy.

4.4 Legal and safety disclosures

We may disclose your information if we believe in good faith that it is reasonably necessary to:

• comply with any applicable law, regulation, legal process, or governmental request;
• enforce our Terms of Service and other agreements;
• protect the rights, property, or safety of Twist, our users, or the public; or
• detect, prevent, or address fraud, security, or technical issues.

4.5 Third-Party AI Services

Our app uses third-party artificial intelligence (AI) services to provide core functionality, specifically AI-powered image transformation within the game.

What data is shared:

• Photos you upload within the app are sent to these third-party AI services for image processing and transformation.
• Text prompts (either submitted by you or auto-generated for gameplay) are sent alongside photos to guide the transformation.

Third-party AI providers we use:

• Google Gemini (Google LLC) — for AI image generation and transformation.
• Grok (xAI Corp.) — for AI image generation and transformation.

How your data is handled:

• Photos and prompts are sent to these services only when you actively participate in the game by submitting a photo.
• Data is transmitted securely and used solely for the purpose of generating your transformed image or game content.
• We do not send any personally identifiable information (such as your name, email, or account details) to these AI services.
• Data shared with these AI providers is processed transiently and is not stored by them beyond the processing of your request, in accordance with their respective data usage policies.

For more information, see:

• Google's AI API Terms
• xAI's Privacy Policy

5. International Data Transfers

Your information may be stored and processed in Canada, the United States, and other countries where we or our service providers operate. Data protection laws in those countries may differ from those in your jurisdiction.

Where required by law, we implement appropriate safeguards (such as contractual clauses) to protect your personal data when it is transferred across borders. By using the Service, you acknowledge that your information may be transferred to and processed in countries other than your own.

6. Data Retention

We retain your personal information for as long as reasonably necessary to:

• provide the Service;
• comply with legal obligations;
• resolve disputes; and
• enforce our agreements.

In determining retention periods, we consider:

• the nature and sensitivity of the information;
• the purposes for which it is processed;
• applicable legal requirements; and
• the potential risk of harm from unauthorized use or disclosure.

We may retain:

• account information for the duration of your account and for a reasonable period thereafter;
• User Content and AI Output associated with shared game histories as needed for gameplay, safety, and legitimate business purposes;
• logs and security records for a limited period for security, analytics, and compliance.

When information is no longer needed, we will delete it or anonymize it, subject to any legal or regulatory retention requirements.

7. Your Rights and Choices

Depending on your jurisdiction, you may have certain rights regarding your personal information, including:

• Access: 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 certain personal information, subject to legal exceptions;
• Restriction: request that we restrict processing in certain circumstances;
• Portability: request a copy of certain data in a structured, commonly used, machine-readable format;
• Objection: object to certain processing (for example, where based on legitimate interests);
• Withdrawal of consent: where processing is based on consent, withdraw that consent at any time (without affecting the lawfulness of prior processing).

To exercise these rights, contact us at info@twistpartygame.com with sufficient detail to identify your account and your request. We may need to verify your identity before responding.

You can also:

• review and update certain information via the App or Site settings;
• manage cookies and similar technologies through your browser or device settings (where applicable);
• opt out of marketing communications by following the unsubscribe instructions in those messages.

Residents of certain jurisdictions (for example, EEA/UK or specific U.S. states) may have additional rights. We will honor those rights as required by applicable law.

8. Children's Privacy

The Service may be rated 9+ in certain app stores based on content guidelines. However, for legal and safety reasons:

• The Service is not directed to children under 13, and we do not knowingly collect personal information from children under 13 without appropriate parental or guardian consent where required by law.
• If you are under 13, you may only use the Service with the consent and active supervision of a parent or legal guardian and only where such use is permitted by applicable law.
• If we become aware that we have collected personal information from a child under 13 without appropriate consent, we will take reasonable steps to delete such information and may disable the associated account.

If you believe that a child has provided us with personal information in violation of this Policy, please contact us at info@twistpartygame.com.

9. Security

We implement appropriate technical and organizational measures designed to protect your information against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or access.

However, no method of transmission or storage is completely secure. We cannot guarantee absolute security, and you use the Service at your own risk. You are responsible for maintaining the security of your devices and your account credentials.

10. Third-Party Services and Links

The Service may include links to third-party websites, apps, or services, and may integrate with third-party tools (including AI providers, analytics, and social login providers).

This Privacy Policy does not apply to those third parties. Their handling of your information is governed by their own privacy policies and terms. We encourage you to review their policies before using their services.

11. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. When we do, we will update the "Last updated" date at the top and, where appropriate, provide additional notice (for example, in-App or by email).

Your continued use of the Service after the updated Privacy Policy becomes effective constitutes your acceptance of the changes. If you do not agree, you must stop using the Service and may request account deletion.

12. Contact Us

If you have questions or requests regarding this Privacy Policy or our privacy practices, please contact us at:

1001435496 ONTARIO INC. (Twist)
Email: info@twistpartygame.com