Privacy Policy

Contents

1. Scope of this Policy

This Privacy Policy applies to information processed through Twunked, including its website, member accounts, profiles, social wall, posts, photographs, comments, likes, follows, direct messages, chat rooms, Twunk or Not photo rating, Battles, Battle photo uploads, Battle voting, win/loss statistics, streaks, public rating and ranking pages, Battle scoreboards, virtual credits, profile gifts, Spotlight, post boosts, notifications, reports, analytics, advertising, and account-security features.

This Policy does not apply to independent websites, services, or applications operated by third parties, even when they are linked from Twunked.

By using the service, you acknowledge the information practices described in this Policy.

2. Information we collect

Account information

When you register or manage an account, information collected may include:

• Username.
• Email address.
• Securely hashed password.
• Display name.
• Birth date or age-confirmation information.
• Account role and account status.
• Registration and account-update dates.

Profile information

You may choose to provide profile information such as:

• Biography.
• Location.
• Relationship status.
• Profile photograph or avatar.
• Profile cover image.
• Privacy and online-status preferences.

Some profile fields are optional. Information you add to your profile may be visible to other members, depending on your privacy settings.

Posts and community content

Information submitted through community features may include:

• Posts and captions.
• Uploaded photographs, including photographs submitted specifically to Twunk or Not or Battles.
• Comments and replies.
• Likes and reactions.
• Follow relationships and follow requests.
• Content visibility selections.
• Content-editing and creation dates.
• Twunk or Not votes, rating totals, ranking positions, Battle votes, Battle pairings, wins, losses, current streaks, best streaks, win percentages, Battle ranking positions, and related activity.

Messages and chat rooms

When you use messaging or chat features, information may include direct-message content, chat-room messages, photographs or other supported media sent in a room, sender and recipient or room identifiers, message dates, deletion status, blocking information, and moderation information associated with those communications.

Chat-room content may be visible to other members who can access the room. Direct messages are intended for the participants in the conversation, subject to processing reasonably necessary to deliver the service, enforce blocks and safety rules, investigate reports, protect security, comply with law, and operate backups.

Virtual credits and transactions

When virtual credits or paid features are offered, information may include credit balances, credit grants, purchases, spending history, gifts sent or received, Spotlight placements, post boosts, transaction dates, transaction identifiers, and records needed to investigate billing errors, fraud, refunds, or charge disputes.

When you purchase virtual credits or another eligible paid feature, payment may be processed by PayPal. PayPal may collect and process payment-card, bank, billing, account, device, or other payment-related information under its own privacy practices and terms.

Twunked does not need to receive your full payment-card or bank-account details from PayPal to operate these features. Twunked may receive and retain information reasonably necessary to confirm and administer the transaction, such as transaction identifiers, payment status, amount, purchased credit quantity or feature, account identifiers, dates, refunds, reversals, disputes, and related fraud-prevention or support information.

Safety and moderation information

When you use safety features or staff review content, information may include:

• Members you block.
• Reports you submit.
• Report reasons and supporting details.
• The reported profile, post, comment, message, chat-room activity, Twunk or Not photo, or Battle photo.
• Moderation decisions and staff notes.
• Account restrictions, suspensions, or bans.

Login and security information

To operate and protect accounts, the service may process:

• Internet Protocol address.
• Login-attempt dates and results.
• Password-reset requests.
• Password-reset token hashes and expiration dates.
• Session identifiers.
• Recent account activity.
• Security and error logs.

Password-reset tokens are stored in hashed form rather than storing the reset link’s original secret token.

Device and technical information

When you access the service, servers and hosting systems may automatically receive technical information such as:

• Browser type.
• Device and operating-system information.
• Requested pages and access dates.
• Referring page or website.
• General network and connection information.
• Error, performance, and security events.

Analytics and advertising information

The service may use analytics and advertising technologies to understand site usage, measure traffic and performance, prevent abuse, and support advertising. Depending on the provider, configuration, consent settings, and applicable law, these technologies may process information such as IP address, device or browser information, page views, approximate location derived from IP address, referral information, advertising identifiers, cookie identifiers, and interaction data.

Third-party analytics or advertising providers may process information under their own privacy policies. Where required, consent or other privacy controls should be provided before non-essential advertising or analytics technologies are used.

Communications

When you contact support, the service may retain your email address, account information, the contents of your request, attachments you provide, and responses sent by support staff.

3. How information is used

Information may be used to:

• Create, maintain, and authenticate member accounts.
• Display profiles and community content according to selected privacy settings.
• Provide posts, comments, likes, follows, direct messages, chat rooms, and notifications.
• Process profile photographs, chat-room media, Twunk or Not photographs, Battle photographs, and other uploaded content.
• Record Twunk or Not votes, calculate rating totals and rankings, record Battle votes and matchup history, calculate wins, losses, win percentages, current and best streaks, and rankings, and display eligible photos on rating, Battle, ranking, profile, and discovery pages.
• Maintain virtual-credit balances and process eligible gifts, Spotlight placements, post boosts, and related transactions.
• Send password-reset and account-security communications.
• Remember login sessions and account preferences.
• Detect spam, fraud, abuse, unauthorized access, and security threats.
• Enforce blocks and privacy restrictions.
• Review member reports and moderate content.
• Investigate violations of the Terms of Service.
• Respond to support questions and account requests.
• Diagnose technical errors and improve reliability.
• Measure traffic, feature usage, and site performance through analytics.
• Display, measure, limit, or support advertising where advertising is enabled.
• Maintain backups and protect the integrity of the service.
• Comply with lawful requests and legal obligations.
• Protect members, staff, the service, and the public.

Information should not be used for a materially different purpose without updating this Policy or providing another appropriate notice.

4. Profile and content visibility

Twunked is a social community. Information you publish may be visible to other members or the public depending on the feature and your selected settings.

Public profiles

Information visible on a public profile may include:

• Username and display name.
• Avatar and cover image.
• Biography and location.
• Public posts and photographs.
• Follower and following counts.
• Public comments and interactions.
• Online status when enabled.

Private profiles

Private profiles restrict some profile information and posts to accepted followers. Certain basic information, such as username, display name, avatar, and private-profile status, may remain visible so members can identify and request to follow the account.

Twunk or Not visibility

Photographs intentionally submitted to Twunk or Not may be displayed to members for rating and may also appear on Top Rated displays, public rating pages, ranking pages, profiles, or other discovery areas supported by the feature. Those displays may include the photograph, username or display name, vote totals, ranking position, and links to the associated profile.

Twunk or Not is separate from ordinary wall-photo visibility. Members should not submit a photograph to Twunk or Not if they do not want that photograph displayed in the rating and ranking areas described above.

Battle visibility

Photographs intentionally submitted to Battles may be shown in head-to-head Battle matchups and may also appear on Battle scoreboards, ranking pages, member profiles, or other supported discovery areas. Those displays may include the photograph, username or display name, wins, losses, win percentage, current streak, best streak, ranking position, and links to the associated profile.

Battle-photo visibility is separate from ordinary wall-photo visibility. Members should not submit a photograph to Battles if they do not want that photograph displayed in Battle and ranking areas supported by the feature.

Chat-room visibility

Messages and media posted in a chat room may be visible to other members who have access to that room. Room rules may vary, including whether photographs are permitted.

Post visibility

Posts may support visibility options such as:

• Public.
• Followers.
• Private.

Privacy controls limit how the service displays information, but they cannot prevent another person from photographing, copying, saving, or redistributing content they were permitted to view.

Do not publish information that you would not want another person to retain or share.

5. When information may be shared

With other members and visitors

Profile information, posts, photographs, comments, likes, follow activity, chat-room content, Twunk or Not photographs, vote totals and rankings, and Battle photographs, votes, win/loss statistics, streaks and rankings may be displayed according to the service’s features, applicable visibility controls, and the choices you make when using those features.

Hosting and service providers

Information may be processed by companies that help operate the service, such as:

• Website-hosting providers.
• Database and storage providers.
• Email-delivery providers.
• PayPal, when it processes purchases or other eligible payment transactions.
• Backup and security providers.
• Technical-support providers.
• Analytics providers, when analytics tools are enabled.
• Advertising providers, when advertising is enabled.

These providers should receive only the information reasonably necessary to perform services on behalf of Twunked.

Legal and safety disclosures

Information may be preserved or disclosed when reasonably believed necessary to:

• Comply with applicable law, a court order, or another valid legal request.
• Investigate fraud, abuse, harassment, threats, or illegal conduct.
• Prevent imminent harm or protect someone’s safety.
• Protect the rights, property, and security of members, staff, or the service.
• Enforce the Terms of Service.

Business changes

Information may be transferred as part of a merger, acquisition, financing, reorganization, asset sale, or transfer of the service to another operator.

Where reasonably possible, notice will be provided before personal information becomes subject to a materially different privacy policy.

With your direction

Information may also be shared when you request, authorize, or direct the disclosure.

6. Sale of information and advertising

Twunked does not sell members’ personal information for money.

The service may display advertising and may use third-party advertising technologies. Depending on how those services are configured, advertising providers may use cookies, device information, advertising identifiers, approximate location, page activity, or similar information to deliver, limit, measure, or personalize advertising.

The service may also display promotions for its own features, memberships, events, or community activities. Internal promotions are separate from third-party advertising.

Where applicable law treats certain advertising-related disclosures or uses as a “sale,” “sharing,” or targeted advertising, Twunked should provide the notices and choices required by that law. Available controls may vary by location and by the advertising provider in use.

7. Cookies and session storage

The service may use cookies or similar browser-storage technologies to:

• Keep members logged in.
• Protect forms from unauthorized submissions.
• Remember security and interface preferences.
• Support account and session security.
• Prevent repeated display of certain notices.
• Diagnose technical problems.
• Measure traffic and usage when analytics is enabled.
• Support advertising, frequency limits, measurement, or personalization when advertising is enabled and permitted.

Essential cookies are necessary for login, account security, and core site functions. Analytics and advertising cookies or similar technologies may be non-essential and may be subject to consent or opt-out requirements depending on location and configuration.

Disabling essential cookies may prevent registration, login, password recovery, posting, or other account features from working correctly.

Browser session storage may also be used for temporary interface settings or notices. Session-storage information is generally removed when the browser session ends, although browser behavior may vary.

8. How long information is retained

Information is retained only for as long as reasonably necessary for the purpose for which it was collected, to operate the service, resolve disputes, protect safety, enforce agreements, and comply with legal obligations.

Account information

Core account information is generally retained while an account remains active.

After an account is closed, limited account and security information may be retained when necessary for fraud prevention, abuse prevention, legal compliance, dispute resolution, or enforcement of a permanent ban.

Posts and uploaded content

Posts, photographs, and comments are generally retained until they are deleted by the member, removed through moderation, or removed as part of account closure.

Deleted content may remain temporarily in backups, logs, caches, or moderation records before being overwritten or securely removed.

Messages, chat rooms, Twunk or Not, and Battle activity

Direct messages, chat-room messages, Twunk or Not photos, votes and ranking-related records, and Battle photos, votes, matchup history, wins, losses, streaks and ranking-related records may be retained while needed to provide those features. Content deleted by a member or removed by moderation may remain temporarily in backups, logs, caches, security records, or moderation evidence before being overwritten or removed.

Vote and transaction records may also be retained when reasonably needed to prevent manipulation, investigate abuse or fraud, preserve ranking integrity, resolve disputes, or comply with legal obligations.

Reports and moderation records

Reports, moderation actions, account restrictions, and related records may be retained longer than ordinary content when needed to:

• Identify repeated violations.
• Prevent ban evasion.
• Respond to appeals or disputes.
• Protect member safety.
• Establish or defend legal claims.

Security records

Login attempts, password-reset records, Internet Protocol addresses, and security logs may be retained for a limited period appropriate to detecting abuse, investigating incidents, and protecting accounts.

Legal preservation

Information may be retained beyond ordinary periods when preservation is required by law, litigation, investigation, court order, or a valid government request.

9. Data security

Twunked uses administrative, technical, and organizational measures intended to protect information from unauthorized access, alteration, loss, misuse, or disclosure.

Security measures may include:

• Password hashing.
• Hashed password-reset tokens.
• Expiring, one-time password-reset links.
• Form-request security tokens.
• Prepared database statements.
• Login and request rate limits.
• Access restrictions for moderation features.
• File-type and upload-size restrictions.
• Account blocking and privacy controls.
• Server, database, and file-system access controls.

No website, server, database, or transmission method can be guaranteed completely secure.

Members should use a unique password, protect their login information, log out from shared devices, and report suspected unauthorized access promptly.

Twunked staff will not ask you to provide your account password.

10. Your privacy choices

Edit profile information

Logged-in members can edit profile information, avatar, cover image, biography, location, and relationship status from the profile-editing page.

Profile privacy

Members may be able to:

• Make their profile public or private.
• Enable or disable online-status visibility.
• Enable or disable follow requests.
• Select post visibility.
• Remove posts or comments they created.
• Unfollow another member.
• Cancel a pending follow request.
• Block or unblock another member.
• Delete eligible messages or chat-room content when self-delete controls are available.
• Remove eligible Twunk or Not photographs from the feature when removal controls are available.
• Remove eligible Battle photographs from the feature when removal controls are available.

Email communications

Essential security communications, including password-reset emails, may be sent when requested or necessary to protect an account.

Because these communications are related to account security, they may not include an unsubscribe option.

Account closure

A member may request account closure or deletion by contacting:

support@twunked.com

Identity verification may be required before an account or personal information is deleted.

Some information may be retained after closure where required or permitted for security, fraud prevention, moderation, legal compliance, or dispute resolution.

11. Location-dependent privacy rights

Depending on where you live and which privacy laws apply to Twunked, you may have rights concerning your personal information.

These rights may include the ability to request:

• Confirmation that personal information is being processed.
• Access to certain personal information.
• Correction of inaccurate information.
• Deletion of certain information.
• A portable copy of certain information.
• Restriction of certain processing.
• Objection to certain processing.
• Information about categories of data collected, used, or disclosed.
• Opt-out from sale or qualifying sharing of personal information.
• Limitation of certain uses of sensitive personal information.
• Equal service without unlawful discrimination for exercising a privacy right.

These rights are not absolute. A request may be limited or denied when an exception applies, when the requester’s identity cannot be reasonably verified, or when the request would affect another person’s rights.

Submitting a privacy request

Privacy requests may be sent to:

support@twunked.com

Include:

• Your account username.
• The email address connected to the account.
• The privacy request you are making.
• Enough information to locate the account and reasonably verify your identity.

Do not send your password, password-reset token, government identification, or payment information unless support specifically explains why a particular verification document is legally necessary and provides a secure submission method.

Authorized agents

Where applicable law permits an authorized agent to submit a request, Twunked may require proof of authorization and direct confirmation from the account holder.

Appeals

Where required by applicable law, instructions for appealing a denied privacy request will be provided with the response.

12. Underage users

Twunked is intended only for adults who are at least 18 years old.

The service is not directed to children or teenagers under 18, and they may not create accounts.

Twunked does not knowingly seek to collect personal information from anyone under 18.

When an account is reasonably believed to belong to someone under 18, the account may be suspended while the issue is reviewed and may be permanently removed.

A parent, guardian, or other person who believes an underage individual has provided personal information should contact:

support@twunked.com

The report should include the username or profile address involved, but should not include unnecessary sensitive information about the underage person.

13. International processing

Twunked may be accessed from locations outside the country where its servers, hosting provider, or operators are located.

Information may therefore be stored or processed in countries with privacy laws different from those in your location.

Where required, reasonable measures should be used to protect personal information transferred across national borders.

14. External websites and services

Posts, profiles, or site pages may contain links to websites or services operated by third parties. The service may also integrate third-party services for payments, analytics, advertising, email delivery, hosting, security, or other operational purposes.

Twunked does not control the privacy, security, availability, or content practices of those services.

Review the privacy policy of any third-party service before providing personal information or downloading software.

15. Changes to this Privacy Policy

This Privacy Policy may be updated to reflect changes to:

• Site features.
• Information practices.
• Hosting or service providers.
• Security practices.
• Legal or regulatory obligations.
• Business operations.

The effective date at the top of the page will be changed when the Policy is revised.

Material changes may also be announced through the service, account notifications, email, or another reasonable method.

Continued use of the service after an updated Policy takes effect means the updated Policy applies to information processed after its effective date, subject to applicable law.

16. Privacy contact

Questions, privacy requests, account-deletion requests, and concerns about this Policy may be sent to:

Twunked Privacy

Email: support@twunked.com

This Privacy Policy describes the current Twunked feature set but is not a substitute for legal advice. It should be reviewed against the service’s actual hosting, email, analytics, advertising, payment-processing, cookie, data-retention, moderation, and business practices. A qualified privacy attorney should review it for the jurisdictions where the service operates.