Privacy Policy

Twnstr Privacy Notice

Last Updated: 16 February 2026

This Privacy Notice applies to the processing of personal information by Twnstr, Inc. (“Twnstr,” “we,” “us,” or “our”) including on our website available at https://www.twnstr.com/ and our other online or offline offerings that link to, or are otherwise subject to, this Privacy Notice (collectively, the “Services”).

Disclosure Regarding Customer Data. This Privacy Notice does not apply to the personal information that we process on behalf of our customers pursuant to a written agreement we have entered into with such customers (“Customer Data”). Our customers’ respective privacy notices or policies govern their collection and use of Customer Data. Our processing of Customer Data is governed by the contracts that we have in place with our customers, not this Privacy Notice. Any questions or requests relating to Customer Data should be directed to our customer.

1. UPDATES TO THIS PRIVACY NOTICE

We may update this Privacy Notice from time to time in our sole discretion. If we do, we’ll let you know by posting the updated Privacy Notice on our website, and we may also send other communications.

2. PERSONAL INFORMATION WE COLLECT

We collect personal information that you provide to us, personal information we collect automatically when you use the Services, and personal information from third-party sources, as described below.

1. Personal Information You Provide to Us Directly

We may collect personal information that you provide to us.

2. Personal Information Collected Automatically

We may collect personal information automatically when you use the Services.

3. Personal Information Collected from Third Parties

We may collect personal information about you from third parties. For example, if you access the Services using a third-party website, application, service, products, or technology (each a “Third-Party Service”), we may collect personal information about you from that Third-Party Service that you have made available via your privacy settings. In addition, users of the Services may upload or otherwise provide personal information about others.

3. HOW WE USE PERSONAL INFORMATION

We use personal information for a variety of business purposes, including to provide the Services, to improve the Services, and to provide you with marketing materials, as described below.

1. Provide the Services

We use personal information to provide the Services, such as:

2. Improve the Services and Develop New Products and Services

We use personal information to improve the Services and to develop new products and services.

3. Operate Our Business

We use personal information to operate our business, such as:

4. Marketing

We may use personal information in connection with our marketing activities including to tailor and provide you with marketing communications, promotions, and offers that may interest you.

We may use personal information: (i) for other purposes that are clearly disclosed to you at the time you provide the personal information, (ii) with your consent, or (iii) as otherwise directed by you.

4. HOW WE SHARE PERSONAL INFORMATION

We share personal information with third parties for a variety of business purposes, including to provide the Services, to protect us or others, or in connection with a major business transaction such as a merger, sale, or asset transfer, as described below.

1. Disclosures to Provide the Services

We may share any of the personal information we collect with the categories of third parties described below.

Any personal information shared with a Third-Party Service will be subject to the Third-Party Service’s privacy policy. We are not responsible for the processing of personal information by Third-Party Services.

Once your personal information is shared with our business partner, it will also be subject to our business partner’s privacy policy. We are not responsible for the processing of personal information by our business partners.

2. Disclosures to Protect Us or Others

We may share your personal information and related information with external parties if we, in good faith, believe doing so is required or appropriate to comply with law enforcement requests, national security requests, or other government requests; comply with legal process, such as a court order or subpoena; protect your, our, or others’ rights, property, or safety; enforce our policies or contracts; collect amounts owed to us; or assist with an investigation or prosecution of suspected or actual unauthorized or illegal activity.

3. Disclosure in the Event of Merger, Sale, or Other Asset Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, receivership, purchase or sale of assets, transition of service to another provider, or other similar corporate transaction, your personal information may be shared, sold, or transferred as part of such a transaction.

5. YOUR PRIVACY CHOICES

The privacy choices you may have about your personal information are described below.

6. INTERNATIONAL TRANSFERS OF PERSONAL INFORMATION

All personal information processed by us may be transferred, processed, and stored anywhere in the world, including, but not limited to, the United States or other countries, which may have data protection laws that are different from the laws where you live.

7. CHILDREN’S PERSONAL INFORMATION

The Services are not directed to children under 18 (or other age as required by local law outside the United States), and we do not knowingly collect personal information from children.

If you are a parent or guardian and believe that your child has uploaded personal information to the Services in violation of applicable law, you may contact us as described in “Contact Us” below.

8. CONTACT US

If you have any questions about our privacy practices or this Privacy Notice, please contact us at info at twnstr dot com.