Last revised July 6 2017


Twine Holdings Inc. respects your privacy. We strive to use information to provide the best possible service while respecting the confidentiality of the information we are entrusted with. This Privacy Policy (the “Privacy Policy”) explains how the software entitled “Twine ” (“App”) that was create by Twine Holdings Inc., (“Developer”) collects, stores, uses, and discloses information from you when you use the App.  If you do not agree with or are not willing to comply with any portion of this Privacy Policy, do not download or use the  App.


Registration Information


When you register and download the App, Developer may collect your email address (which may contain your name), the date and time at which you registered to use the App and accepted the Twine Holdings Terms of Service and this Privacy Policy, a record of the method by which you registered, and a information about the platform on which you install the App (collectively, your “Registration Information”).  Developer may use your Registration information to contact you from time to time with information regarding the App or Developer’s services, including sending email messages to your registration email address.


Usage Information


Developer does collect the following usage information that is generated by your use of the App: date, time, and duration for each use of the App (“Usage Information”).



How We Use Your Information


In addition to the usage of your information as described above, the information Developer collects is used to comprehensively understand your needs and interests, and permits Developer to deliver a more consistent and personalized experience. For example, Developer may use your information to:


– assist you in completing a transaction;

– communicate with you about products and services;

– provide service and support;

– update you on new services and benefits;

– provide personalized promotional offers from Developer;

– select content to be communicate to you; and

– contact you for market research regarding Developer’s products or services.


Your information may be aggregated with other clients’ information on a purely non-identifiable basis to understand how our products are used to help make them better.


Disclosure and Sharing of Your Information


Developer will not sell, rent or lease your personal information to others.


You agree that Developer may share some or all of the following information with its third party service providers for the purposes of, without limitation, analyzing your use of the App, for the uses and purposes detailed herein and improving the App and Developer’s other products and services: your email address, the date, time, and method by which you registered the app, the UUID, the dial-in numbers for calls and Conferencing Services you called using the Twine Holdings app, your Usage Information, and general information about your interactions with the App (collectively, “Tracking Information”). Developer will only share the minimum portion of your Tracking Information necessary to provide the Conferencing Service and improve the App relevant to your activity. In any such cases, however, we require that the companies or entities adhere to privacy standards and policies at least as restrictive as those Developer has in place.


Developer may also disclose any information you provide or it collects including your Registration Information, Usage Information, Tracking Information, Conference Account Information, and Conference Information as required by law, such as to comply with a subpoena, or similar legal process, or when Developer believes in good faith that disclosure is necessary to protect its rights, your safety or the safety of others, or to investigate fraud, or respond to a government request.  Developer does not have any access to any of the personal information or credit card information that you have provided to Apple or Google in order to register for their services.  You should be familiar with the privacy practices of both Apple and Google before providing such information.


Finally, you agree that Developer may transfer all information you provide, including your Registration Information, Device Information, Conference Account Information, Conference Information in the event of a sale, merger, dissolution, bankruptcy, corporate reformation or other corporate restructuring of Developer, or in the event that Developer sells, assigns, or transfers substantially all of its rights in the App.




You may opt-out of providing information to Developer at any time by uninstalling the App using the standard uninstall processes available on your mobile device or via the applicable Application marketplace or store.




The App is not directed to children under the age of 13.  If a parent or guardian becomes aware that his or her child has provided us with information without their consent, he or she should contact us at [email protected]  We will delete such information from our files within a reasonable time.




Developer takes commercially reasonable steps to help protect your information against loss, misuse and unauthorized access, or disclosure.  However, you agree that by using the App to connect your Device to a Conferencing Service, you are choosing to transmit audio and/or images via such Conferencing Service.  You further agree that Developer has no control over, and does not examine, review, access, record, or store, any communication transmitted by you or any other participant in a teleconference via a Conferencing Service.  You agree to defend, indemnify, release, discharge and hold harmless Developer, its officers, directors, employees, affiliates and suppliers from and against any and all claims and demands including but not limited to, any claims for copyright infringement, defamation, invasion of privacy or right of publicity, arising out of or in connection with your use of the App, Conferencing Service and your Device to transmit such images and/or audio.  Developer expressly disclaims any representation or warranty, whether express or implied, with respect to ensuring, guaranteeing or otherwise offering any definitive promise of security in connection with your information.


Your Consent


By using the App, you are consenting to the use and processing of your information as set forth in these Terms, all of which activities will take place in the United States.  If you reside outside the U.S. your information will be transferred to the U.S., and processed and stored there under U.S. privacy standards.  By using the App and providing information to us, you consent to such transfer to, and processing in, the U.S.


Note To Users Outside Of The United States


Your personal information, including Registration Information, (“Personal Data”) may be processed in the country in which it was collected and in other countries, including the United States, where laws regarding processing of Personal Data may be less stringent than the laws in your country. We adhere to and have certified our compliance with the Safe Harbor Privacy Principles, including notice, choice, onward transfer, security, data integrity, access, and enforcement, of the United States/European Union Data Protection Safe Harbor Framework and the United States/Switzerland Data Protection Safe Harbor Framework, both of which are made available by the U.S. Department of Commerce at Our certification can also be viewed at


Dispute Resolution


If you believe that Developer has not adhered to this Privacy Policy, please contact Developer by e-mail at [email protected] We will do our best to address your concerns. If you feel that your complaint has been addressed incompletely, we invite you to let us know for further investigation. If you and Developer are unable to reach a resolution to the dispute, you and First to File will settle the dispute exclusively under the rules of the American Arbitration Association (


Changes to this Policy


The world of technology changes quickly. If and when there are future changes to our Privacy Policy in response we will post then at www.Twine


Contact Developer


We value your opinions and suggestions. If you have any questions or concerns regarding privacy while using the App, or have questions about Developer’s practices, please contact Developer via email at [email protected], or alternatively you can write us at the following address:


Twine Holdings, Inc.

2040 14th Street, Suite 200

Boulder, CO 80302

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