Privacy Policy
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Last Updated: January 2025
1. Introduction
Twilly ("we," "our," or "us") is committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our subscription-based content platform.
By using Twilly's services, you consent to the data practices described in this policy.
2. Information We Collect
2.1 Information You Provide
- Account Information: Name, email address, phone number, date of birth
- Profile Information: Username, bio, profile pictures, creator information
- Payment Information: Stripe Connect account details, tax information, payout preferences
- Content: Videos, streams, episodes, messages, comments
- Communications: Support requests, feedback, marketing preferences
2.2 Information We Collect Automatically
- Usage Data: Pages visited, features used, time spent on platform
- Device Information: IP address, browser type, operating system, device identifiers
- Streaming Data: Stream quality, viewer engagement, technical performance metrics
- Location Data: General location information (country/region level)
- Cookies and Tracking: Session data, preferences, analytics information
2.3 Information from Third Parties
- Stripe: Payment processing and verification information
- Social Media: If you connect social media accounts
- Analytics Providers: Usage and performance data
- Verification Services: Identity verification information
3. How We Use Your Information
3.1 Service Provision
- Process payments and manage subscriptions
- Host and stream your content
- Manage creator collaborations and revenue sharing
- Provide customer support and technical assistance
- Send service-related communications
3.2 Platform Improvement
- Analyze usage patterns to improve our services
- Develop new features and functionality
- Optimize streaming performance and quality
- Conduct research and analytics
3.3 Legal and Security
- Comply with legal obligations and regulations
- Prevent fraud and abuse
- Enforce our Terms of Service and policies
- Protect user safety and platform integrity
3.4 Marketing and Communications
- Send promotional materials (with your consent)
- Provide personalized recommendations
- Share platform updates and announcements
4. Information Sharing and Disclosure
4.1 With Your Consent
We may share your information with third parties when you explicitly consent to such sharing.
4.2 Service Providers
We share information with trusted service providers who assist in:
- Payment processing (Stripe)
- Content delivery and streaming
- Analytics and performance monitoring
- Customer support services
- Legal and compliance services
4.3 Legal Requirements
We may disclose your information when required by law, including:
- Court orders or subpoenas
- Government investigations
- Regulatory compliance
- Protection of rights and safety
4.4 Business Transfers
In the event of a merger, acquisition, or sale of assets, your information may be transferred as part of the transaction.
4.5 Public Content
Content you make public on Twilly (videos, streams, public profiles) may be visible to other users and potentially indexed by search engines.
5. Data Security
5.1 Security Measures
We implement appropriate technical and organizational measures to protect your information, including:
- Encryption of data in transit and at rest
- Regular security assessments and updates
- Access controls and authentication
- Secure payment processing
5.2 Data Breach Response
In the event of a data breach, we will:
- Notify affected users promptly
- Report to relevant authorities as required
- Take immediate steps to contain and remediate
- Provide guidance on protective measures
6. Data Retention
6.1 Retention Periods
We retain your information for as long as necessary to:
- Provide our services
- Comply with legal obligations
- Resolve disputes
- Enforce our agreements
6.2 Account Deletion
When you delete your account:
- Your profile and personal information will be removed
- Your content may be deleted or anonymized
- Payment and transaction records may be retained for legal compliance
- Some information may be retained for security and fraud prevention
7. Your Rights and Choices
7.1 Access and Control
You have the right to:
- Access your personal information
- Correct inaccurate information
- Delete your account and data
- Export your data
- Opt out of marketing communications
7.2 Privacy Settings
You can control your privacy through:
- Account privacy settings
- Content visibility preferences
- Communication preferences
- Cookie and tracking controls
7.3 GDPR Rights (EU Users)
If you are in the European Union, you have additional rights:
- Right to be informed about data processing
- Right of access to your data
- Right to rectification of inaccurate data
- Right to erasure ("right to be forgotten")
- Right to restrict processing
- Right to data portability
- Right to object to processing
- Rights related to automated decision making
8. International Data Transfers
8.1 Global Operations
Twilly operates globally and may transfer your information to countries other than your own. We ensure appropriate safeguards are in place for such transfers.
8.2 EU-US Transfers
For EU users, we rely on appropriate safeguards such as:
- Standard Contractual Clauses
- Adequacy decisions
- Other approved transfer mechanisms
9. Children's Privacy
Twilly is not intended for children under 18 years of age. We do not knowingly collect personal information from children under 18. If we become aware that we have collected such information, we will take steps to delete it promptly.
10. Third-Party Services
10.1 Stripe Integration
Our payment processing is handled by Stripe. Please review Stripe's privacy policy for information about how they handle your payment data.
10.2 External Links
Our platform may contain links to third-party websites. We are not responsible for the privacy practices of these external sites.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by:
- Posting the updated policy on our platform
- Sending email notifications
- Displaying prominent notices
13. Contact Information
For privacy-related questions or to exercise your rights, please contact us at:
Twilly Privacy Team
- Email: privacy@twilly.com
- Address: [Twilly Privacy Address]
- Data Protection Officer: dpo@twilly.com
14. Complaints
If you have concerns about our privacy practices, you may:
- Contact our privacy team directly
- File a complaint with your local data protection authority
- Seek legal remedies as provided by applicable law
This Privacy Policy is effective as of the date listed above and applies to all users of Twilly's services.