Privacy Policy

Overview

This Privacy Policy (“Policy”) outlines the principles and practices of Twee AI LLC and all its affiliates (“Twee” or “Service”) regarding the collection, use, and disclosure of user data. Twee’s utmost priority is the protection and confidentiality of its users’ personal data. This Policy applies to Twee AI LLC, its affiliates, subsidiaries, products and all related entities, unless otherwise stated in the Policy.

Twee may share personal data internally within our group of companies, for the purposes described in this Policy. In addition, should Twee or any of its subsidiaries or affiliates undergo any change in control or ownership, including by means of merger, acquisition or purchase of substantially all or part of its assets, your personal data may be shared with the parties involved in such an event. If we believe that such change in control might materially affect your personal data then stored with us, we will notify you of this event and the choices you may have via e-mail or prominent notice on our Services.

By using Twee’s services, users acknowledge and agree to this Privacy Policy. If you do not agree with any part of this Policy, please refrain from using our services.

Queries or concerns related to this Policy should be directed to: privacy@twee.com


Definitions:

– “User”: Anyone who accesses or uses the services of Twee.

– “Teacher User”: Anyone who signs up with an account type “Teacher”.

– “Student User”: Anyone who signs up with an account type “Student” via email invitation.

– “Personal Data”: Any information that can identify an individual.

– “Third-party”: Entities other than Twee AI LLC.


Part 1: Teacher User Privacy Policy

I. Collection of Data

When Teacher Users access or engage with Twee, the Company may gather the following:

a. Primary Information: Such as Name, Email Address, and Password.

b. Content that users upload or create on Twee platform.

c. Any other data voluntarily shared by the user.

Additionally, Twee collects non-identifiable information including:

a. Logs from browsers when accessing Twee’s services.

b. User interaction patterns, specific device details, and cookie-related data.

II. Use of Data

Twee uses the collected data for various purposes, including:

a. To improve, provide, and customize our services.

b. For research, to communicate with users, process payments, and offer tailored experience.

c. To safeguard against potential fraud, enhance security measures, and ensure compliance with legal requirements.

User data will be retained for as long as necessary to fulfill the purposes for which it was collected, in compliance with our legal obligations, dispute resolution, and enforcement of our agreements.

Twee uses cookies to enhance user experience. These can be session or persistent cookies, and can be either first-party or third-party cookies. Users can control or opt out of cookies through their browser settings.

Twee is committed to maintaining the privacy and security of your personal data. As part of our operations, we may collect Personal Data through Google APIs, which are subject to strict usage limitations. It is our policy to never utilize this data for advertising purposes, nor will it be accessed by our staff, unless specific circumstances apply. Such exceptions include instances where we have received your explicit permission, when access is essential for security reasons, in order to fulfill legal obligations, or when the data is processed in a manner that renders it anonymous and aggregated.

Our practices concerning the handling, usage, and transfer of Personal Data obtained via Google APIs are fully aligned with the Google API Services User Data Policy, especially regarding the Limited Use Requirements. Rest assured, Twee prioritizes your privacy in compliance with these guidelines.

III. Data Sharing

Twee assures users that their personal data will neither be sold nor rented to third parties. Third-party service providers essential for Twee’s operations might have access to the data based on contractual agreements ensuring the protection of your data.

Entities potentially having access include:

a. Stripe (Billing: manages financial transactions).

b. Brevo (Email Services: handles the sending and management of emails).

c. Amazon AWS (Hosting: ensures the protection of user data and provides service infrastructure).

d. Google Analytics and Microsoft Clarity (Data Analytics: analyze user data to offer insights).

e. OpenAI and Anthropic (Generative AI: generates content based on user input).

f. Other relevant third-party entities as required.

Twee may also anonymize and aggregate data, subsequently sharing such de-identified data with third parties. Additionally, data may be disclosed when required for legal reasons, ensuring safety, or during business transitions, always ensuring adherence to privacy standards.

IV. Cross-border Data Management

Twee might need to transfer user data across borders and jurisdictions, possibly exposing the data to areas with different data protection rules. By using Twee’s services, users consent to such transfers, trusting Twee to uphold protective measures as required by relevant laws

For such cross-border transfers, Twee uses mechanisms like standard contractual clauses to ensure data is protected as per relevant standards.

V. Data Protection

Twee employs several measures to protect users’ data:

a. Storage solutions via Amazon AWS.

b. Encrypted data transmission using HTTPS.

c. Password protection mechanisms; with passwords stored securely in hashed formats.

Users are reminded to maintain their password’s confidentiality and to be vigilant with communications received from Twee.

In the unfortunate event of a data breach, we will notify affected users and take appropriate measures to mitigate the breach as mandated by relevant laws.

VI. Limitations and Third-party Interactions

While Twee is dedicated to maximizing security, the Company cannot assure immunity from all potential breaches or unauthorized access. Interactions with third-party platforms (like browser extensions) might impact users’ data privacy on Twee. The Company isn’t responsible for the security practices of these external entities.

Users are advised to familiarize themselves with the privacy policies of third-party platforms they interact with.

Our platform may contain links to external sites. We are not responsible for the privacy practices or content of such external sites.

VII. Users’ Rights and Control Over Data

Users have the right to:

a. Access their data.

b. Modify their data.

c. Transfer their data.

d. Delete their data.

For exercising these rights, users should contact: privacy@twee.com.

Users can opt out of marketing or promotional communications by clicking on the “unsubscribe” link located on the bottom of our emails or by contacting privacy@twee.com.

VIII. Children’s Data Protection

Twee’s services are designed for individuals above 13 years of age. The Company does not intentionally gather data from those under this age. If unintentional collection occurs, immediate corrective actions, such as deletion, will be initiated.

If you are a parent or guardian and believe that your child has provided personal data to Twee without your consent, please contact us.


Part 2: Student User Privacy Policy

I. Collection of Data

When Student Users access or engage with Twee, the Company may gather the following:

a. Account Information: Name and email address provided during sign-up via Teacher User invitations.
b. Usage Data: Pages visited, interaction history, completed assignments.

II. Use of Data

Collected data is used for:
a. Providing educational services and improving user experience.
b. Compliance with legal requirements and service security.

User data will be retained for as long as necessary to fulfill the purposes for which it was collected, in compliance with our legal obligations, dispute resolution, and enforcement of our agreements.

Twee uses cookies to enhance user experience. These can be session or persistent cookies, and can be either first-party or third-party cookies. Users can control or opt out of cookies through their browser settings.

Twee is committed to maintaining the privacy and security of your personal data. As part of our operations, we may collect Personal Data through Google APIs, which are subject to strict usage limitations. It is our policy to never utilize this data for advertising purposes, nor will it be accessed by our staff, unless specific circumstances apply. Such exceptions include instances where we have received your explicit permission, when access is essential for security reasons, in order to fulfill legal obligations, or when the data is processed in a manner that renders it anonymous and aggregated.

Our practices concerning the handling, usage, and transfer of Personal Data obtained via Google APIs are fully aligned with the Google API Services User Data Policy, especially regarding the Limited Use Requirements. Rest assured, Twee prioritizes your privacy in compliance with these guidelines.

III. Data Sharing

Data is shared with:
a. Associated Teacher Users and schools for educational purposes.
b. Third-party service providers under data protection agreements.

Entities potentially having access include:

– Brevo (Email Services: handles the sending and management of emails).
–  Amazon AWS (Hosting: ensures the protection of user data and provides service infrastructure).
– Google Analytics and Microsoft Clarity (Data Analytics: analyze user data to offer insights).
– Other relevant third-party entities as required.

c. Legal Authorities, if required by law.

IV. Users’ Rights and Control Over Data

Student Users have the right to:

a. Access their data.

b. Modify their data.

c. Transfer their data.

d. Delete their data.

For exercising these rights, users should contact: privacy@twee.com.

V. Guardian Consent for Minors

Student User accounts can be created via email from a Teacher User account only.
By signing up to use Twee’s services, Teacher Users acknowledge, affirm, and pledge to Twee that they or their institution have obtained all necessary parental or eligible student written consent to share the personal data of their students with Twee when consent is the applicable lawful basis, in each case, solely to enable Twee’s operation of the service.

By using Twee’s services, users over the age of 13 acknowledge and agree to this Privacy Policy. Twee’s services are designed for individuals above 13 years of age. The Company does not intentionally gather data from those under this age. If unintentional collection occurs, immediate corrective actions, such as deletion, will be initiated.

VI. Cross-border Data Management

Twee might need to transfer user data across borders and jurisdictions, possibly exposing the data to areas with different data protection rules. By using Twee’s services, users consent to such transfers, trusting Twee to uphold protective measures as required by relevant laws

For such cross-border transfers, Twee uses mechanisms like standard contractual clauses to ensure data is protected as per relevant standards.

Twee employs several measures to protect users’ data:

a. Storage solutions via Amazon AWS.

b. Encrypted data transmission using HTTPS.

c. Password protection mechanisms; with passwords stored securely in hashed formats.

Users are reminded to maintain their password’s confidentiality and to be vigilant with communications received from Twee.

In the unfortunate event of a data breach, we will notify affected users and take appropriate measures to mitigate the breach as mandated by relevant laws.


Contact Information

For questions or to exercise data rights, contact:
Twee Privacy Team
Email: privacy@twee.com.


Updates to this Policy

Twee may update this Policy periodically, notifying users of significant changes via email or platform notifications. Regular review of this Policy is advised.