Privacy Policy


TWAB – PRIVACY POLICY
As part of our mission to spread good vibes, we want you to share the things that matter to you most with your friends, family and anyone else around you. It’s important to us that you feel comfortable and trust us with your information when you use the Twab services (the “Services”). Please take a few minutes to read this Privacy Policy, so that you understand what information we collect, what we do with it and why, how we protect it and what are your rights in relation to this information.
In general, we only collect information that allows us to provide you with our best Services. This includes, for example, simple tasks like allowing other users to see the name and picture you choose to show. It also helps us to keep our Services clear of fraud and spam, and it allows us to get a unique understanding of what additional services may be useful to you, and all other purposes set out in this policy below.


Scope and consent
Before you start twabing, it’s important you understand that by using our Services, you allow us to collect, use, disclose, and retain your personal information and other information but we will never read or listen to the content you are sharing privately. You can be sure that we will only use your information as described in this Policy.
By using the Service, you are also agreeing to our Terms of Use. Please make sure you read and agree with our Terms of Use if you want to use Twab.


Information we collect
We collect the minimum information required to achieve the purposes set out in this Policy (see below), and you have the ability to limit such collection, as specified below under “Your Choices”:
(a) Registration and Account Information: When you use our various Services you voluntarily give us personal information (e.g., name, email, birth date, age, phone number and, when necessary, billing information) and you are not anonymous to us. That means your name and photo (if you choose to provide them) will be visible to other Twab users and they can search you by name unless you change your settings. When you install the Twab App, you’ll also be asked to allow us access to your mobile device’s address book. A copy of the phone numbers and names of all your contacts (whether they’re Twab members or not – but only name and phone number) will be collected and stored on our servers, in order for us to be able to enable you and your contacts to connect.
(b) Activity Information: While using the Twab Services, we will collect, and other users can see should you allow them to, your location at the time of your last scan. if you do not want people or specific users to see your location trail, you can change these options in your twab settings.
We collect information about the way you use twab (for example how often). We may also tell other Twab users that you are using a certain edition in order to recommend them to try that edition as well.
(c) Device and Location Information: We collect additional information when you access our App through a certain device (e.g. your mobile device’s unique identifier; your session’s ip address; information about your device’s operating system, or operating system language.


Specific Accounts – Twab Premium
Premium Edition: Our Premium edition allows you to have complete access to the Panic Button feature (send and receive SOS alerts), adjust your scan radius up to 20 km and adjust the duration that you wish your location trail to remain active at low cost monthly – yearly rates. When you use Twab’s Premium edition, like in the free edition, you will be asked to create a “Twab Account” by selecting a password, and providing certain personal information (e.g., name, email and billing information). We will also keep your Twab/Premium records for billing and legal records, and to make you relevant offers. 
Linking your email to Twab:  When you select to connect your email to your Twab account, we will use information you provided in the registration process (e.g., name, email, password, phone number), as well as your IP address to do so.


Uses and Retention:
Our mission is to constantly improve our Services and provide you with new experiences. As part of this mission, we use your information for the following purposes:
(a) Make our service available: We use your Registration and Account information to (i) register you for the App and create your User Account for Twab; (ii) create your profile and make it visible; (iii) process your payments; (iv) provide customer service, give you information about your account, and respond to your requests; (vi) personalize your experience by providing content on the Service, including targeted advertising of Twab services and other 3rd party services that we believe may be of most interest to you; personalization may include automated decisions about what you will view and when, but be assured that it will not have legal effects on you; (vii) indicate which of your contacts is already a Twab member and notify you when your contacts become active on the Service; (viii) display the name of the contact as it appears in your address book when you get your scan’s results, and (ix) sync your contacts with Twab running on Windows, MacOS, Linux, Android tablets, iPads and Windows Tablets. If you deactivate your Twab account, it will delete the address book from our servers (more about this below), quickly and permanently. Otherwise, we keep your contact information for as long as you use the App so we can provide you all functions.
(b) Provide Interesting Offerings to You and others: As part of value added services provided by us or by a third party within Twab, we may use your information to continuously optimize and personalize those services and send you personal updates about new offerings which we believe you will find relevant. We may share with our service providers unique identifiers to determine the best way to tell potential new users about our services. When you join Twab, the contacts in your address book that are already Twab members may be informed that you’re now on Twab too.
You will be asked to allow the use of your location data before Twab provides you specific location services offerings, and you may also adjust your phone preferences to disable the use of your location data at any time.
(c) Process Your Payments: We may use your Information like your name and phone number to process your payments for our Services through a secured third-party service provider and, on an aggregate basis to determine charges for our phone carriers and other service providers.
(d) Prevent Fraud & Spam; enforcement of law: We really want Twab to be free of spam and fraudulent content so that you feel safe and free. We may use your information to prevent, detect, and investigate fraud, security breaches, potentially prohibited or illegal activities, protect our trademarks and enforce our Terms of Use. This may include URLs included in messages, which were reported as SPAM by other users, or were otherwise suspected to be unsolicited and using your operating system authentication services. We may use automated decisions to close an account based on such data and other logic we have created for this, in order to protect other users and prevent recurring breaches. If your account has been blocked you can contact our support. We may use your information and call log information to comply with applicable laws.
(e) Communicate With You: We want to keep in touch with you. We use your information to contact you (via message or other means) to maintain the App, including your Twab Premium edition, to comply with your stated communication preferences or to provide updates about future Twab services.


Data Retention: Unless otherwise specified, we retain information as long as it is necessary and relevant for us to achieve the purposes referred to above or to enable us to comply with our legal data protection retention obligations. Upon deactivation of your account, we will minimize the personal data we keep about you only to such data which we are required to keep to comply with laws, or other legal reasons. We may keep activity data on a non-identifiable basis to improve our services. 

Disclosure:
Your data is kept safe with us, but we do share your personal information with third parties we trust in order to provide you with our services, as follows:
(a) At Twab: We may share the information we collect about you in order to: (i) provide joint content and our services (e.g., registration, coordination of membership accounts, transactions, analytics and customer support); (ii) help detect and prevent potentially illegal acts, violations of our policies, fraud and/or data security breaches. 
(b) Legal and Law Enforcement: We may disclose your information to law enforcement, governmental agencies, or authorized third-parties, in response to a verified request relating to terror acts, criminal investigations or alleged illegal activity or any other activity that may expose us, you, or any other Twab user to legal liability.
(c) Change of Control – New Owners: We may share your information with another business entity, if we plan to merge with or be acquired by that business, or are involved in a transaction with similar financial effect. In such a situation we would make reasonable efforts to request that the new combined entity or other structure follow this Policy with respect to your personal information. If your personal information was intended to be used differently, we would ask the new entity to provide you with prior notice.
Because Twab is global, the recipients above may be located outside the country in which you are located. See the section on “International Data Transfers” below for more information.


Information You Share Publicly
1.    By using Twab Services none of the information you share is public.  You only share your location with Twab members within your phone contacts and only in case you want to. Even the sharing of your location can be deactivated for selected members or the entire Twab community. The only piece of information that you share is the fact that you have and use Twab, in case someone has your phone number. 


Your Choices
We want you to have control over how you communicate. That is why, for example, we allow you to have full control over the sharing of your location or the duration that you wish your location trail to remain active. Also it is entirely up to you to select the twab members that you wish to receive SOS alerts from.  You can also make additional choices on your phone’s settings by changing our app’s permissions such as location sharing, access to contact list and more.
Every now and then, Twab may send you updates about administration and operation of the Service (for example, about your transactions, policy changes, technical issues, etc.). We may also send notifications/emails about offerings by Twab or third-parties, that we think may be of interest to you. If you do not wish to receive such notifications, you may adjust your system settings to decline them.


Twab Ads, Cookies & Tracking Technologies Policy
Twab does not use cookies & tracking technologies. Our primary and only goal is to make you feel better and safer by connecting you with people that you know in order to meet up or assist you. 

Accessing, Reviewing, and Changing Your Personal Information
As a registered member, you can review and change personal information at any time by accessing your account on the App or contacting our support. Please be sure to update your personal information promptly if it changes or becomes inaccurate. We may retain some information from closed accounts so that we can comply with law, prevent fraud, assist with investigations, resolve disputes, analyze, or troubleshoot programs, enforce our Terms of Use, or take other actions permitted by law. Likewise, if your account or membership is terminated or suspended, we may maintain some information to prevent you from re-registering.


Twab Land Privacy Rights
If you made Twab your daily choice for connecting with friends/family/people that you know, make sure to be using it to make others and yourself feel better and safer. Eventually, this is what Twab is for.


Third-Party websites and Apps:
Our app may contain links to other third-party websites or you may access Apps from a third- party site. We are not responsible for the privacy practices or the content of these third-party sites.


Security
We know that security is important to our users and we care about the security of your information. We maintain technical, physical, and administrative security measures to protect the security of your personal information against loss, misuse, unauthorized access, disclosure, or alteration. Some of the safeguards we use include firewalls, physical access controls to our data centers and information access authorization controls. We need your help too: it is your responsibility to make sure that your personal information is accurate and that your password(s) and account registration information are secure and not shared with third-parties.  


International Transfer
We operate internationally and provide our Services to Twab users worldwide allowing them to communicate SOS alerts with each other across the globe. That means that your personal information may need to be processed in countries where data protection and privacy regulations may not offer the same level of protection as in your home country. We store and process your personal information on our computers in Germany. 


Updates to this Policy
From time to time, as our services evolve, we may update this Policy. You agree that we may notify you about material changes in the way we treat personal information by placing a notice on the App. Please check the App frequently for updates.


Contact Us at [email protected]
You can also contact us in writing at Twab – Dimitrios Chasapis, Patroklou Street 15, 41222, Larisa, Greece 
In the event you read this Privacy Policy in any language other than English, you agree that in the event of any discrepancies, the English version shall prevail.