Twigo — Privacy Policy
Last updated: 23 September 2026
1. Introduction
This Privacy Policy explains how Twigo ("Twigo," "we," "us," or "our") collects, uses, and protects your information when you use the Twigo application, the website at thetwigo.com, and related services (the "Service").
Twigo is operated by Javid Nasirov (the "data controller"). We may assign the operation of the Service and responsibility under this Policy to an affiliated entity.
By using the Service, you agree to the practices described in this Policy. If you do not agree, do not use the Service.
2. Information We Collect
2.1 Information you provide:
- Account information — such as your name or username, email address, password, and profile details (bio, profile photo).
- User content — the video takes you record, comments, votes, sides you pick, and other content you submit. Video takes are recorded through your device camera and microphone within the app.
- Communications — information you send us (e.g. support requests, reports).
2.2 Information collected automatically:
- Usage and interaction data — how you use the Service, such as debates viewed, takes watched, votes, taps, and features used.
- Device and technical data — device type, operating system, app version, language, and similar technical information. This includes a device identifier and, where you have allowed notifications, a push notification token so we can deliver them. We also record information used to confirm that the app is genuine and running on a real device.
- Log and connection data — your IP address and the time, device and app version of each sign-in. We keep a record of sign-ins to operate the Service, to keep your account secure, and to detect abuse.
- Approximate location — we may infer general/approximate location (e.g. from IP address). We do not collect precise GPS location unless you grant permission for a feature that needs it. Because we derive it from your IP address at sign-in, we hold a record of the approximate locations you have signed in from.
- Identifiers and analytics data — identifiers used to operate the Service, measure performance, and attribute installs/referrals (for example, to understand which link or referral brought a user to Twigo).
2.3 If you join the waitlist or apply to be a creator:
Before you have an account, you can give us your email address to join our waitlist, or apply to be a founding creator. If you apply, we collect the name, email address, social media handle, audience size and description of your content that you provide. We use this only to contact you about Twigo and to assess the application. You can ask us to delete it at any time by writing to apps@thetwigo.com.
2.4 Permissions we request:
- Camera and microphone — required to record your video takes. We only access them when you are recording; we do not record without your action.
- Notifications — if you allow them, to send you relevant updates (e.g. activity on your debates).
3. How We Use Your Information
We use your information to:
- provide, operate, and maintain the Service (including hosting and displaying your content and debates);
- create and manage your account;
- enable core features — recording, sharing, voting, commenting, following;
- measure and improve performance, and understand how the Service is used;
- attribute installs and referrals (e.g. via shared links) so we can understand how people find Twigo;
- moderate content and enforce our Terms, keep the Service safe, and prevent abuse or fraud;
- communicate with you (e.g. service updates, responses to your requests, notifications you opt into);
- comply with legal obligations.
3.1 Our legal basis for using your information
If you are in the European Economic Area or the United Kingdom, data-protection law requires us to have a legal basis for each use. Ours are:
| What we use it for | Legal basis |
|---|---|
| Creating and managing your account, and providing the core features — recording, sharing, voting, commenting, following | Performance of a contract with you. Without this information we cannot provide the Service. |
| Moderating content, enforcing our Terms, keeping the Service safe, preventing abuse and fraud | Our legitimate interests in running a safe service, and in some cases a legal obligation. |
| Measuring and improving performance, understanding how the Service is used, and attributing installs and referrals | Our legitimate interests in understanding and improving the Service. You can object to this — see section 7. |
| Sending you push notifications, and using your camera and microphone | Your consent, given through your device permissions. You can withdraw it at any time in your device settings, and withdrawing it does not affect anything we did before you did so. |
| Responding to your requests, and keeping records of reports and moderation decisions | Our legitimate interests in answering you and in keeping an accurate record. |
| Meeting legal, regulatory and law-enforcement obligations | Compliance with a legal obligation. |
4. How We Share Your Information
We do not sell your personal information. We share information only as follows:
- Publicly, as part of the Service — your username, profile, video takes, comments, votes, and debate participation are visible to other users and, where content is shared, on the web version of debates. Please only post what you are comfortable being public.
- Service providers — we use third-party services to host, run, and analyze the Service (for example: hosting/cloud infrastructure, analytics, and install/referral attribution and deep-linking providers). These providers process data on our behalf under appropriate obligations.
- Third-party platforms you share to — if you share your takes to platforms such as Instagram or TikTok, that sharing and those platforms are governed by their own policies.
- Legal and safety — we may disclose information if required by law, or to protect the rights, safety, or property of Twigo, our users, or others.
- Business transfer — if the operation of Twigo is assigned or transferred to an affiliated entity, information may be transferred to that entity, subject to this Policy.
5. Content You Share Publicly
Twigo is a social service. Content you post — video takes, comments, votes, and profile information — is visible to others and may be shared beyond the app (for example, the web version of a debate, or when you or others share a debate). Do not include private or sensitive information in content you post.
6. Data Retention
We keep your information for as long as your account is active or as needed to provide the Service. If you delete your content or account, we will delete or de-identify your personal information within a reasonable period, except where we must retain it for legal, security, backup, or fraud-prevention purposes, or where content has already been shared with others.
7. Your Rights and Choices
- Access, update, or delete — you can access and update your profile information in the app, and delete your content or your account.
- Notifications — you can control notification permissions in your device settings.
- Camera/microphone — you can manage these permissions in your device settings (disabling them will prevent recording).
- Withdraw consent — where we rely on your consent (notifications, camera and microphone), you can withdraw it at any time in your device settings. Withdrawing consent does not affect anything we did before you withdrew it.
- Regional rights (e.g. EU/UK GDPR) — depending on where you live, you may have rights to access, correct, delete, restrict, or object to the processing of your personal data, and to data portability. Where we rely on our legitimate interests, you have the right to object, and we will stop unless we have compelling grounds not to. To exercise any of these, contact us at apps@thetwigo.com. We answer within one month.
- Complain to a regulator — if you are in the EEA or the UK and you think we have handled your personal data wrongly, you can complain to your national data protection authority. You do not have to contact us first, though we would rather you did so we can put it right.
8. Children's Privacy
Twigo is not intended for anyone under 16 years old. We do not knowingly collect personal information from anyone below that age. If we learn that we have collected such information, we will delete it. If you believe a child below the minimum age has provided us information, contact us at apps@thetwigo.com.
9. Security
We take reasonable measures to protect your information. However, no method of transmission or storage is completely secure, and we cannot guarantee absolute security. Please protect your account credentials.
10. Where Your Information Is Stored
Your information is stored in Europe. Our systems run on Amazon Web Services in Frankfurt, Germany and in London, United Kingdom, and that is where your account, your content and the data described in this Policy are held. The United Kingdom is recognised by the European Commission as providing an adequate level of data protection.
Twigo is operated from Azerbaijan, so the people who run the Service may access that information from there in order to operate, support and secure it. Azerbaijan is not covered by a European Commission adequacy decision, and we put appropriate safeguards in place for that access.
A small amount of information reaches providers outside Europe in order to deliver specific features — for example, sending a push notification to your device, or working out the approximate location associated with an IP address. Where that happens, we rely on the recognised transfer mechanisms available to us, such as adequacy decisions or standard contractual clauses.
If you would like more detail about any of this, contact us at apps@thetwigo.com.
11. Third-Party Links and Services
The Service may contain links to, or integrations with, third-party services (such as social platforms). We are not responsible for their privacy practices. Review their policies before using them.
12. Changes to This Policy
We may update this Policy from time to time. If we make material changes, we will provide notice (for example, in the app or by updating the "Last updated" date). Your continued use of the Service after changes take effect constitutes acceptance.
13. Contact
Questions or requests about your privacy? Contact us at apps@thetwigo.com.