Privacy Policy

1. Introduction

Welcome to our application ("App," "we," "our," "us," or "Company"). We are committed to protecting your privacy and ensuring you have a positive experience on our platform. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our application available on Google Play and other platforms.

Please read this privacy policy carefully. If you do not agree with our policies and practices, please do not use our App.

2. Developer Information & Contact

If you have questions about this privacy policy or our privacy practices, please contact us at:

3. Information We Collect

3.1 Information You Provide Directly

• Account Information: If you create an account, we collect information such as your name, email address, phone number, and profile information
• User-Generated Content: Any content you create, upload, or share within the App
• Communication Data: Messages, feedback, and any communications you send through the App
• Payment Information: If applicable, transaction and billing information (processed securely through third-party payment processors)

3.2 Information Collected Automatically

• Device Information: Device model, operating system version, unique device identifiers (IDFA, Android Advertising ID), device settings
• Usage Data: Features accessed, actions performed, time and duration of use, pages viewed, interactions within the App
• Location Data: Precise or approximate location (only if you grant permission)
• Crash Reports & Performance Data: Error logs, performance metrics, and app stability information
• Analytics Data: Aggregated usage statistics and user behavior patterns

3.3 Information from Third Parties

• Third-Party Services: Information from analytics providers, advertising networks, and social media platforms (if you link your accounts)
• Public Sources: Publicly available information you have made accessible

3.4 Special Categories of Data

If the App collects health, biometric, financial, or other sensitive personal data, we ensure enhanced protections and obtain explicit consent where required by law.

3.5 Google User Data (Google Search Console)

Twelver lets you connect a Google account so our AI agent can read your own sites' data in Google Search Console. Connecting is optional and happens only when you press "Connect Google" and approve access on Google's consent screen.

• What we access: your Google account email address (to show which account is connected) and, with the read-only webmasters.readonly permission, the Search Console properties you have access to, their search analytics (queries, pages, countries, devices, clicks, impressions, click-through rate and average position), URL inspection results and sitemaps. We cannot change anything in your Search Console.
• How we use it: only to answer your requests in the chat — to show and explain your own sites' search performance, indexing and sitemap status. Data is fetched when you or your agent ask for it.
• What we store: the connected account's email address and the OAuth access and refresh tokens, encrypted. Search Console reports are not stored separately from the chat conversation in which you asked for them.
• What we do not do: we do not sell Google user data, do not share it with third parties except as needed to provide this feature (for example, the AI model that writes the answer in your chat), do not use it for advertising, and do not use it to develop, improve or train generalized AI or machine-learning models. No person at Twelver reads it unless you ask us to for support, it is needed for security, or the law requires it.
• Removing access: press "Disconnect" on the Connected accounts page — we revoke our access at Google and delete the stored tokens. You can also remove Twelver's access at any time at myaccount.google.com/permissions. To have chats containing this data deleted, delete them in the app or write to help@twelver.app.

Twelver's use and transfer to any other app of information received from Google APIs will adhere to the Google API Services User Data Policy, including the Limited Use requirements.

4. How We Use Your Information

We use the information we collect for the following purposes:

• App Functionality: To provide, maintain, and improve the App and its features
• User Support: To respond to your inquiries and provide customer support
• Personalization: To customize your experience and deliver personalized content
• Analytics & Improvement: To analyze usage patterns, track performance, and identify areas for improvement
• Marketing & Communications: To send you promotional materials, updates, and notifications (with your consent where required)
• Security & Fraud Prevention: To detect, investigate, and prevent fraudulent activities and security incidents
• Legal Compliance: To comply with legal obligations, governmental requests, and applicable laws
• Payment Processing: To process transactions and manage billing

5. How We Share Your Information

We do not sell or rent your personal data to third parties. However, we may share your information in the following circumstances:

• Service Providers: With vendors and contractors who assist us in operating the App and delivering services (e.g., hosting providers, analytics providers, payment processors)
• Business Partners: With partners for joint offerings (with your consent)
• Legal Requirements: When required by law or to protect our legal rights, your safety, or the safety of others
• Business Transfers: In connection with mergers, acquisitions, or sale of assets (your data would remain protected under this Privacy Policy)
• With Your Consent: With third parties when you explicitly authorize us to share your information

6. Data Security & Protection Measures

We implement comprehensive technical, administrative, and physical safeguards to protect your personal data:

6.1 Technical Measures

• Encryption: Data transmitted to and from the App is encrypted using SSL/TLS protocols
• Secure Storage: Sensitive data is stored in encrypted databases with restricted access
• Firewalls & Intrusion Detection: Network security measures to prevent unauthorized access
• Regular Security Audits: Periodic assessments to identify and address vulnerabilities

6.2 Administrative Measures

• Access Controls: Only authorized personnel can access personal data
• Data Minimization: We collect only the information necessary for stated purposes
• Retention Limits: Personal data is retained only as long as necessary
• Employee Training: Staff are trained on data privacy and security protocols

6.3 Physical Measures

• Secure Facilities: Data centers and offices with restricted physical access
• Surveillance Systems: Security monitoring to prevent unauthorized entry

6.4 Data Breach Protocol

In the event of a data breach, we will notify affected users and relevant authorities as required by applicable law, typically without undue delay.

7. Data Retention

We retain your personal data for as long as necessary to provide the App's functionality and comply with legal obligations. Retention periods vary based on the purpose:

• Account Data: Retained for the duration of your account and a reasonable period thereafter
• Usage Analytics: Typically retained for 12-24 months in identifiable form, then aggregated
• Transaction Records: Retained as required by financial regulations (typically 7 years)
• Marketing Preferences: Retained until you opt out or delete your account

You may request deletion of your data at any time, subject to legal and contractual requirements.

8. Your Rights & Choices

Depending on your location, you may have the following rights:

8.1 Data Subject Rights (GDPR, CCPA, and similar laws)

• Right to Access: Request a copy of your personal data
• Right to Rectification: Correct inaccurate or incomplete data
• Right to Erasure: Request deletion of your data ("Right to be Forgotten")
• Right to Restrict Processing: Limit how we use your data
• Right to Data Portability: Receive your data in a structured, portable format
• Right to Object: Opt out of certain processing activities
• Right to Withdraw Consent: Withdraw previously given consent at any time

8.2 Marketing Communications

You can opt out of promotional emails by clicking the "unsubscribe" link in any email or adjusting your preferences in the App settings.

8.3 Device-Level Permissions

You can control App permissions through your device's settings:

• Location: Disable location access in device settings
• Camera & Microphone: Deny access through device permissions
• Contacts & Calendar: Restrict access to sensitive data
• Advertising: Reset your advertising ID or opt out of interest-based advertising

8.4 Exercising Your Rights

To exercise any of these rights, please contact us at help@twelver.app with your request. We will respond within the timeframe required by applicable law (typically 30 days).

9. Children's Privacy

The App is not designed for children under the age of 13 (or the applicable age of digital consent in your jurisdiction).

• No Intentional Collection: We do not knowingly collect personal data from children under 13
• Parental Consent: If we become aware a child has provided information without parental consent, we will delete such data immediately
• Enhanced Protections for Minors: If the App serves users under 18, we apply additional safeguards and restrictions on data usage, advertising, and third-party sharing
• Parental Access: Parents or guardians may request access to their child's data or request deletion

If you believe a child has provided personal data to us, please contact us immediately at help@twelver.app.

10. Third-Party Links & Services

The App may contain links to third-party websites and services that are not operated by us. This Privacy Policy does not apply to third-party services, and we are not responsible for their privacy practices. We encourage you to review their privacy policies before providing any information.

Third-party analytics providers and advertising networks may collect and use your data in accordance with their own privacy policies.

11. International Data Transfers

Your personal data may be transferred to, stored in, and processed in countries other than your country of residence. These countries may have different data protection laws than your home country.

If your data is transferred internationally, we implement appropriate safeguards such as:

• Standard Contractual Clauses (SCCs)
• Binding Corporate Rules (BCRs)
• Your explicit consent

12. Cookies & Tracking Technologies

The App and our website may use cookies, web beacons, pixels, and similar tracking technologies to:

• Remember your preferences and settings
• Understand how you use the App
• Deliver targeted advertising
• Measure campaign effectiveness

You can control cookie settings through your browser or device settings. Note that disabling cookies may affect certain App functionality.

13. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA):

• Right to Know: What personal information is collected, used, shared, or sold
• Right to Delete: Request deletion of personal information collected from you
• Right to Opt-Out: Opt out of the sale or sharing of your personal information
• Right to Correct: Request correction of inaccurate personal information
• Right to Limit: Limit our use of sensitive personal information

To submit a CCPA/CPRA request, please email help@twelver.app.

14. European Union Rights (GDPR)

If you are located in the European Union, you are protected by the General Data Protection Regulation (GDPR). We process your data based on the following legal grounds:

• Consent: You have given explicit consent
• Contract: Processing is necessary to fulfill a contract with you
• Legal Obligation: We are required by law to process your data
• Legitimate Interests: Processing is necessary for our legitimate business interests

You have the right to lodge a complaint with your local Data Protection Authority if you believe your rights have been violated.

15. Changes to This Privacy Policy

We may update this Privacy Policy from time to time to reflect changes in our practices, technology, or applicable laws. We will notify you of material changes by:

• Posting the updated policy with a new "Last Updated" date
• Sending you an email notification (if required)
• Requiring your consent if legally required

Your continued use of the App following posted changes constitutes your acceptance of the updated Privacy Policy.

16. Do Not Track Signals

Some browsers include a "Do Not Track" (DNT) feature. Currently, there is no industry standard for recognizing DNT signals. We do not respond to DNT browser signals but provide you with choices regarding the collection and use of your information as described in this Privacy Policy.

17. Contact Us

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

18. Additional Information

Governing Law: This Privacy Policy is governed by the laws of the app developer's jurisdiction, without regard to its conflict of law provisions.

Entire Agreement: This Privacy Policy, along with our Terms of Service, constitutes the entire agreement between you and us regarding privacy matters.