This Privacy Policy explains how Twintip ("we", "our", "us") collects, uses, discloses, and protects personal information when individuals ("Users") access or use our mobile application and related services ("Application" or "App").

By using the Application, you acknowledge and agree to the practices described in this Privacy Policy.

1. Data Controller

Twintip
Twintip Shop
Mzaar Kfardebian, Main Street
Kfardebian, Lebanon

Contact email: Dev@Twintipclub.com

Customer Service: +9613103953

2. Categories of Data We Collect

We may collect and process the following types of personal data:

2.1 Personal Identification Data

First name and last name
Email address
Phone number
Country
Profession
Company name (if applicable)

2.2 Device and Technical Data

Collected automatically when using the App:

IP address
Device identifiers (e.g., IDFA, Google Advertising ID)
Operating system and device type
Usage data (App interactions, session duration, performance logs)
Cookies and similar tracking technologies

2.3 Tracking & Advertising Identifiers

Used for analytics and potential advertising optimization:

Cookies
Trackers
Pixel tags
Unique device identifiers

2.4 Voluntary Data

Any data you provide through:

Forms
Surveys
Marketing opt-ins
Support requests

2.5 Location Information

When you are logged in to Twintip as a teacher, the app collects your precise GPS location (latitude and longitude) while the app is open or running in the background. This data is collected in real time, including when the screen is locked, for as long as you remain logged in as a teacher.

We use your location solely to display your position to students so they can find you on a map.

We do not collect location data from students.

3. Legal Basis for Processing

Where applicable, we process personal data on the following bases:

Consent
Performance of a contract
Legitimate interests (e.g., security, analytics, service improvement)
Compliance with legal obligations

4. How We Use Your Data

We use the collected data to:

4.1 Provide and Operate the App

Account management
Communication
Feature functionality
Support and troubleshooting

4.2 Improve and Secure the App

Analytics
Performance monitoring
Debugging and crash reporting

4.3 Marketing and Advertising

Where permitted by law and with appropriate consent:

Tailored marketing messages
Interest-based advertising
Audience segmentation
Remarketing campaigns

4.4 Compliance & Protection

Legal requests
Prevention of abuse, fraud, or harmful activity

4.5 Teacher Location Sharing

Teacher location sharing: We use your GPS coordinates to show your real-time position to students. Your location is transmitted securely to our servers and made available to students while you are logged in as a teacher.

5. Third-Party Services

The Application may share data with trusted service providers that assist us in operating the App, including:

Advertising & Remarketing Providers

Google Ads Similar Audiences
Facebook Lookalike Audiences
LinkedIn Ads

Marketing Automation

Autopilot HQ

Surveys & Lead Collection

Facebook Lead Ads

Analytics & Tracking

Google Analytics
Google Tag Manager
Facebook Pixel
LinkedIn Retargeting

CRM & User Database Management

HubSpot CRM and others

These services may use cookies, trackers, and cross-platform identifiers.
Users can opt out of interest-based advertising (see Section 8).

All third-party providers process data according to their own privacy policies.

6. Data Sharing

We do not sell personal data.

We may disclose personal data only to:

Authorized employees and contractors
Third-party service providers (listed above)
Legal authorities if required by law
Entities involved in a business transfer (e.g., merger, acquisition), with safeguards
Students: Your precise location is shared in real time with students while you are logged in as a teacher. It is not shared with any other users or third parties.
Infrastructure providers: Location data is processed through our cloud infrastructure (servers at twintip.softigital.com). Our hosting provider may process this data as part of normal server operations but is contractually prohibited from using it for any other purpose.

7. Data Retention

We retain personal data only for as long as required for:

Providing services
Fulfilling legal obligations
Security and fraud prevention
Internal analytics

When data is no longer needed, it is securely deleted or anonymized.

Live location: Real-time coordinates are transmitted to students while you are logged in as a teacher and are not stored persistently on our servers. Once you log out or revoke location permission, your location is no longer transmitted or retained.

8. Opt-Out and Do-Not-Track Options

Users can opt out of interest-based advertising through:

Platform Settings

iOS: Settings → Privacy → Tracking
Android: Google Settings → Ads → Opt out of Ads Personalization

Industry Tools

Network Advertising Initiative
Digital Advertising Alliance
YourOnlineChoices (EU)

Service-Specific Opt-Outs

Links (Google, Facebook, LinkedIn) can be provided upon request.

The Application does not support browser "Do Not Track" requests.

9. User Rights

Where applicable, Users may exercise the following rights:

Access their data
Request correction or updates
Request deletion of personal data
Restrict or object to processing
Withdraw consent at any time
Request data portability
File complaints with relevant authorities

Location Sharing Controls

You can stop location sharing at any time by logging out of the app.
You can revoke location permissions from your device settings (iOS: Settings > Privacy & Security > Location Services; Android: Settings > Apps > Twintip > Permissions).
Revoking location permission will prevent the location-sharing feature from working but will not affect other app functionality.

Requests can be submitted at: Dev@Twintipclub.com

10. Background Location Access

Background Location (Android)

On Android devices, Twintip requests permission to access your location in the background. This permission is used to share your position with students while you are logged in as a teacher and the app is minimized. You will be shown a clear explanation before this permission is requested. You can revoke this permission at any time in your device settings, which will stop location sharing.

Always-On Location Access (iOS)

Twintip requests "Always Allow" location permission on iOS so your location can be shared with students even when the app is in the background. A blue location indicator will appear in your status bar whenever location is being shared. You may change this to "While Using" in iOS Settings > Privacy & Security > Location Services > Twintip, but doing so will stop location sharing when the app is backgrounded.

11. Security Measures

We implement industry-standard technical and organizational controls, including:

Secure servers
Encrypted transmission (HTTPS)
Access restrictions
Regular audits

However, no system is entirely secure, and absolute protection cannot be guaranteed.

12. Children's Privacy

The App is not intended for direct use by children under the age required by applicable law.
Parents or legal guardians may provide data on behalf of minors.

We do not knowingly collect personal data directly from children.

We do not knowingly collect location data from users under the age of 13. Location data is only collected from verified teacher accounts.

13. International Transfers

Data may be processed or stored outside the User's country.
Where applicable, we use appropriate safeguards to protect transferred data.

14. In-App Payments

1. Payment Information Collection

This Application may collect payment information, including credit/debit card details, billing address, and transaction history, to process purchases of services or products offered within the Application.

2. Payment Processing

All payment transactions are processed through secure third-party payment processors (e.g., Areeba, Wish, Stripe, PayPal, Apple Pay, Google Pay). The Owner does not directly store or process full payment card details. Payment processors have their own privacy policies which govern the collection and use of payment data.

3. Security

Payment information is transmitted securely using encryption (e.g., SSL/TLS). The Owner implements reasonable technical and organizational measures to protect Users' payment data in compliance with applicable law.

4. Purpose of Processing Payment Data

Payment data is collected and processed solely for the purpose of:

Processing transactions made within the Application;
Preventing fraud;
Complying with legal obligations.

5. User Rights for Payment Data

Users may request access to, correction of, or deletion of their payment data to the extent permitted by law and applicable payment processor agreements.

15. Changes to This Policy

We may update this Privacy Policy periodically.
Changes will be posted within the Application and on our website, with an updated "Last Updated" date.

Continued use of the App after changes indicates acceptance of the revised policy.

16. Contact Us

Twintip
Twintip Shop
Mzaar Kfardebian, Main Street
Kfardebian, Lebanon

Email: Dev@Twintipclub.com

Customer Service: +9613103953

Last Updated: 04/20/2026

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