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Twine Campus

Twine Privacy Policy

Last Updated: May 2025

Our Privacy Commitment

At Twine Campus, we believe privacy is fundamental to building trust within college communities. This policy explains how we collect, use, protect, and share your information.

Key Principles:

  • We never sell your personal data
  • You control your information
  • Transparency in our practices
  • Security by design

1. Information We Collect

1.1 Account Information

What we collect:

  • Name and email address
  • University affiliation
  • Phone number (for verification)
  • Profile photo (optional)
  • Year of study
  • Major/interests (optional)

Why we collect it:

  • Verify your student status
  • Connect you with classmates
  • Provide personalized experiences
  • Ensure community safety

1.2 Content You Create

  • Messages and chat history
  • Posts in Circles
  • Event details you create
  • REMI conversation history
  • Photos and files you share

1.3 Usage Information

Automatically collected:

  • App interactions and features used
  • Event attendance (via QR check-ins)
  • Study session duration in Circles
  • REMI query patterns
  • Device information (type, OS, app version)
  • IP address and approximate location

Analytics we track:

  • Feature popularity
  • User engagement patterns
  • Performance metrics
  • Error reports

1.4 REMI AI Interactions

  • Text queries and responses
  • Voice recordings (temporarily, for transcription)
  • Study preferences and patterns
  • Academic interests

2. How We Use Your Information

2.1 Core Services

  • Enable connections: Match you with classmates and study groups
  • Deliver features: Messaging, events, Circles, REMI assistance
  • Personalize experience: Recommend events, groups, and content
  • Maintain safety: Detect and prevent harmful behavior

2.2 REMI AI Processing

  • Provide academic assistance
  • Generate study plans
  • Answer questions
  • Improve AI responses
  • Detect crisis situations for support resources

2.3 Communications

  • Service announcements
  • Security alerts
  • Feature updates
  • Event reminders (if enabled)
  • Community guidelines updates

2.4 Improvements

  • Develop new features
  • Fix bugs and issues
  • Optimize performance
  • Understand user needs

3. Information Sharing

3.1 What Others See

Public to verified students at your university:

  • Your name and profile photo
  • Year and major (if provided)
  • Public posts in Circles
  • Events you create

Private unless you share:

  • Direct messages
  • Private Circle discussions
  • REMI conversations
  • Contact information

3.2 When We Share Information

We may share data with:

  • Service providers: Hosting, analytics, payment processing
  • AI providers: OpenAI/Anthropic for REMI (anonymized)
  • Legal requirements: Court orders, legal obligations
  • Safety: Imminent harm prevention
  • Business transfers: Mergers or acquisitions (with notice)

We never share with:

  • Data brokers
  • Advertisers
  • Universities (unless legally required)
  • Other students without your consent

3.3 Third-Party Integrations

  • University SSO: For verification only
  • Payment providers: Website payment processors for subscriptions
  • Cloud services: AWS for secure storage

4. Data Security

4.1 Protection Measures

  • End-to-end encryption for sensitive data
  • TLS/SSL for data transmission
  • Regular security audits
  • Access controls and authentication
  • Secure cloud infrastructure

4.2 Data Breaches

If a breach occurs, we will:

  • Notify affected users within 72 hours
  • Provide details of compromised information
  • Offer guidance on protective steps
  • Implement measures to prevent recurrence

5. Your Rights & Controls

5.1 Access Your Data

Request a copy of your information:

  • Profile data
  • Content you've created
  • REMI conversation history
  • Account activity logs

5.2 Control Your Information

You can:

  • Edit or delete your profile
  • Delete messages and posts
  • Leave Circles and events
  • Clear REMI history
  • Adjust privacy settings
  • Opt out of analytics

5.3 Delete Your Account

Via app settings:

  • Tap "Delete Account"
  • Confirm deletion
  • 30-day recovery period
  • Permanent deletion after 30 days

What happens:

  • Profile removed
  • Messages deleted from your view
  • Events you created remain (anonymized)
  • Some data retained for legal/safety reasons

5.4 Data Portability

Export your data in JSON format:

  • Messages
  • Profile information
  • REMI conversations
  • Event history

6. Children's Privacy

  • Minimum age: 16 years old
  • Under 18 requires parental consent
  • We don't knowingly collect data from children under 16
  • Parents can request deletion: support@twinecampus.com

7. REMI AI Specific Privacy

7.1 How REMI Works

  • Queries processed by AI partners
  • No personal info sent with queries
  • Conversations stored for continuity
  • Voice converted to text immediately

7.2 Your Control

  • Delete individual conversations
  • Clear all REMI history
  • Opt out of REMI improvements
  • Request human support instead

7.3 Safety Features

  • Crisis detection triggers resources
  • No human review without consent
  • Academic integrity preserved
  • Mental health resources prioritized

8. Data Retention

8.1 Active Accounts

Retained while active:

  • Profile information
  • Recent messages (1 year)
  • REMI history (6 months)
  • Event history (1 semester)

8.2 Inactive Accounts

  • Reminder after 6 months inactive
  • Deletion after 12 months inactive
  • University verification expires yearly

8.3 After Deletion

May be retained for:

  • Legal obligations (up to 7 years)
  • Safety investigations (90 days)
  • Aggregated analytics (anonymized)

9. Location Information

9.1 How We Use Location

  • Show nearby events
  • Connect with local students
  • Provide campus-specific content
  • Emergency notifications

9.2 Your Control

  • Precise location optional
  • Use university location only
  • Disable location services
  • Clear location history

10. California Privacy Rights (CCPA)

California residents have additional rights:

  • Know what personal information is collected
  • Know if information is sold (we don't sell data)
  • Request deletion of personal information
  • Non-discrimination for exercising rights
  • Authorized agent requests accepted

To exercise rights: privacy@twinecampus.com

11. European Users (GDPR)

EU residents have rights to:

  • Access personal data
  • Rectification of inaccurate data
  • Erasure ("right to be forgotten")
  • Data portability
  • Object to processing
  • Withdraw consent

Data controller: Twine Campus, Inc. Contact: privacy@twinecampus.com

12. International Data Transfers

  • Data processed in the United States
  • EU-US Data Privacy Framework participant
  • Standard contractual clauses implemented
  • Appropriate safeguards in place

13. Cookies & Tracking

13.1 Technologies Used

  • Essential cookies for functionality
  • Analytics cookies (optional)
  • No advertising cookies
  • Local storage for app preferences

13.2 Your Choices

  • Disable analytics in settings
  • Clear app data anytime
  • Browser cookie controls
  • Do Not Track honored

14. Changes to Privacy Policy

  • Review updates in-app
  • Email notification for material changes
  • 30-day notice for significant changes
  • Previous versions available on request

15. Contact Us

Privacy Questions

Email: privacy@twinecampus.com
Response time: Within 48 hours

Data Requests

Email: privacy@twinecampus.com
Portal: twinecampus.com/privacy

General Support

Email: support@twinecampus.com
In-app: Settings > Help

Mailing Address

Twine Campus, Inc.
Attn: Privacy Team
[Address to be determined]

Data Protection Officer

legal@twinecampus.com

16. Specific State Rights

16.1 Nevada

Nevada residents may opt out of sale of personal information (we don't sell data): privacy@twinecampus.com

16.2 Vermont

Vermont residents have additional data broker rights (we're not a data broker).

16.3 Virginia

Virginia Consumer Data Protection Act rights available: privacy@twinecampus.com

17. Legal Basis for Processing

We process data based on:

  • Consent: You agree via Terms of Service
  • Contract: Necessary to provide Services
  • Legitimate interests: Safety, improvements
  • Legal obligations: Compliance requirements

18. Special Categories

We don't intentionally collect:

  • Health data (except crisis support)
  • Religious or political views
  • Sexual orientation
  • Genetic/biometric data

If shared in messages/posts, you control this information.

19. Security Reports

Found a vulnerability? Report to: safety@twinecampus.com

  • Responsible disclosure program
  • Bug bounty available
  • Hall of fame recognition

20. Accessibility

This policy is available in:

  • Screen reader compatible format
  • Large print version
  • Plain language summary

Request alternatives: help@twinecampus.com

Your Privacy Matters

We're committed to protecting your privacy while helping you make the most of your college experience. If you have questions or concerns about our privacy practices, please don't hesitate to contact us.

Effective Date: This Privacy Policy is effective as of May 2025 and replaces all previous versions.

Twine Campus, Inc. is committed to transparency, user control, and data protection in accordance with global privacy standards.