Privacy Policy

1. Introduction

Welcome to TwinFinder, operated by Devend FZCO ("we", "us", "our").

These Terms & Conditions ("Terms") and Privacy Policy ("Policy") govern your use of TwinFinder.

By downloading, installing, or using the App, you agree to these Terms and this Policy. If you disagree, please do not use the App.

2. Description of Service

TwinFinder enables users to create profiles and compare facial similarity using AI-based image analysis.

3. Information We Collect

We only collect data you voluntarily provide or permit:

• Name
• Profile photo(s)
• Location (if permission granted)
• Date of birth

We do not collect passwords, contacts, payment details, or other sensitive identifiers.

Some limited technical information (e.g., device type, app version, and log events) may be collected automatically by Firebase to maintain service security.

4. Purpose of Processing

Your data is processed solely to:

1. Create and display your profile
2. Perform facial similarity matching
3. Improve and maintain App performance
4. Train and evaluate our AI models using anonymized data

We do not use your information for advertising or resale.

5. Data Storage and Processing

All uploads are transmitted via encrypted channels (HTTPS/TLS) and stored securely on servers located in the Europe.

Access is restricted to authorized personnel only.

Before any image is used for model improvement, all metadata is removed and filenames are randomized.

6. AI Model Training

Images you upload may be used in anonymized form to enhance the accuracy of TwinFinder's AI model.

No retraining is performed after public release without new explicit consent.

By using the App, you grant us a limited, non-exclusive, royalty-free license to process anonymized content for algorithmic improvement.

You may withdraw this consent anytime by deleting your data.

7. Cross-Border Data Transfers

Because our servers are located in the Europe, your information may be transferred and processed outside your country of residence.

We apply appropriate safeguards (encryption, access control, and contractual protections) to ensure your data receives an equivalent level of protection required by applicable privacy laws, including GDPR.

8. Legal Basis for Processing

For users in the EEA or similar jurisdictions, processing relies on:

• Performance of a contract – delivering the TwinFinder service
• Legitimate interest – maintaining and improving functionality
• Consent – when uploading photos, enabling location, or participating in AI model improvement

9. Data Deletion and User Rights

You can delete all your data directly through the Delete My Data option in the App.

When activated:

• Your personal information and uploaded images are permanently erased from all databases within 30 days
• Any derived anonymized data is excluded from future model versions
• We confirm deletion completion via automated system logs

You may also email support@twinfinder.app to request:

• Access to your data
• Correction of inaccurate data
• Withdrawal of consent
• Confirmation of deletion

10. Data Retention

We retain data only while your account is active.

When you delete your account, all information is promptly and irreversibly removed from our servers and backups.

We do not maintain dormant user archives.

11. Third-Party Services

TwinFinder uses secure third-party services for authentication and infrastructure to ensure your data is protected.

These services may process limited, non-identifying technical data to ensure stability and security.

We do not use analytics or advertising services that track you across other apps or websites.

12. Children's Privacy

TwinFinder is intended for individuals aged 16 years and older.

We do not knowingly collect information from anyone under this age.

If we learn such data was provided, it will be deleted immediately.

13. Security

We employ industry-standard security measures to protect your data:

• Encrypted data transfer and storage
• Secure authentication systems
• Role-based access control
• Regular security assessments

While we implement strong security measures, no system is 100% secure; use of the App is at your own discretion and risk.

14. International Users' Rights (GDPR / CCPA / Global)

Depending on your jurisdiction, you may have rights to:

• Access or port your personal data
• Request deletion or restriction of processing
• Object to certain processing
• Lodge a complaint with your local supervisory authority

Requests may be sent to support@twinfinder.app.

15. User Conduct

Users must:

• Provide truthful information
• Not upload unlawful, offensive, or copyrighted material
• Not attempt to misuse or reverse-engineer the service

Violation may result in account suspension or termination.

16. Changes and Version Updates

We may update this Policy periodically to reflect legal, technical, or operational changes.

The latest version will always appear in the App and on our website with a new "Effective Date."

Significant updates may be communicated via in-app notice or email.

Continued use of the App after such notice constitutes acceptance.

17. Governing Law and Jurisdiction

These Terms and this Policy are governed by the laws of the United Arab Emirates.

Any disputes shall be resolved before the competent courts of the UAE.