Twelu

Privacy Policy

Last updated: 27 July 2026

This Privacy Policy explains how Twelu ("we", "us", "our") collects, uses, shares, and protects personal information when you use our mobile applications, websites, and related services (the "Service").

We designed this Policy to meet expectations under the EU/UK General Data Protection Regulation ("GDPR"), the South African Protection of Personal Information Act, 2013 ("POPIA"), and other applicable privacy laws. Where those laws differ, we apply the standard required for your situation.

1. Who we are and how to contact us

Twelu provides a mobile-first, real-time chat platform organised around discoverable rooms, hashtags, and communities.

  • Website: https://www.twelu.com
  • Contact: use the Contact page on www.twelu.com, or email the address shown there
  • Privacy / data protection requests: use the same Contact channels and mark your message "Privacy request"

If we appoint a formal Information Officer (POPIA) or EU/UK representative, we will publish those details on the Contact page or in this Policy.

2. Scope

This Policy applies to personal information we process about:

  • people who create Twelu accounts or use the apps;
  • visitors to our marketing website;
  • people who contact us; and
  • people whose information appears in content others share on Twelu (for example, if someone mentions you).

It does not cover third-party websites, stores, or sign-in providers that have their own policies.

3. Personal information we collect

Depending on how you use Twelu, we may process:

3.1 Account and identity

Email address, password or authentication tokens, handle, display name, date of birth (where required for age assurance), account identifiers, and third-party sign-in identifiers (for example Google, Apple, or Facebook) if you choose those methods.

3.2 Profile and preferences

Avatar, status, bio, privacy settings, notification preferences, language/locale, and similar choices you make in the product.

3.3 Content and social activity

Messages, reactions, media you upload, room follows, invites, reports, moderation actions that involve you, and related activity metadata needed to operate chat rooms.

3.4 Device, usage, and diagnostics

App version, device type/OS, coarse diagnostics, crash reports, performance logs, IP address, approximate network information, and similar technical data. We may collect approximate location only when you enable location features (for example local/nearby rooms).

3.5 Communications with us

Messages and attachments you send through Contact Us or support channels, and our replies.

3.6 Website data

Standard server logs and similar technical data when you visit www.twelu.com. If we use cookies or similar technologies beyond what is strictly necessary, we will provide appropriate notice and choices.

3.7 Information from others

Content other users post that refers to you; reports; and information from service providers that help us secure the Service.

We do not require you to provide more personal information than needed for the relevant purpose. Some features will not work without certain data (for example, an account needs an email and handle).

4. Why we process personal information (purposes)

We process personal information to:

  1. create and manage accounts, authenticate you, and provide the Service;
  2. operate real-time messaging, presence, discovery, follows, and related features;
  3. personalise experience where appropriate and consistent with your settings;
  4. keep the Service safe (fraud prevention, abuse detection, enforcement of Community Guidelines and Terms);
  5. moderate content and handle reports;
  6. send transactional notices (verification codes, security alerts, important service messages);
  7. respond to contact and support requests;
  8. improve product quality, reliability, and performance;
  9. comply with law, regulate requests, and protect rights and safety; and
  10. establish, exercise, or defend legal claims.

We do not sell your personal information.

5. Legal bases (GDPR) and justifications (POPIA)

5.1 GDPR (EEA/UK and similar regimes)

Where GDPR applies, we rely on one or more of:

  • Contract - processing needed to provide the Service you request;
  • Legitimate interests - for example securing the platform, preventing abuse, improving reliability, and understanding product usage in a privacy-aware way, balanced against your rights;
  • Consent - where we ask for it (for example optional location features or certain marketing), which you can withdraw;
  • Legal obligation - when we must process data to comply with law; and
  • Vital interests - in rare cases to protect someone's life or safety.

5.2 POPIA (South Africa)

Where POPIA applies, we process personal information in a manner that is adequate, relevant, and not excessive, for lawful purposes related to our functions, with appropriate security safeguards. We process information with consent where required, or where processing is necessary for a contract with you, to comply with law, to protect a legitimate interest of yours or ours (subject to your rights), or as otherwise permitted by POPIA.

5.3 Special / sensitive information

We do not seek to collect special-category data (GDPR) or special personal information (POPIA) as a core product requirement. If such data appears in user-generated content, we process it only as needed to operate moderation and safety systems, comply with law, or otherwise as permitted.

6. How we share information

We may share personal information with:

  • Other users, according to your privacy settings and what you choose to post or display in rooms;
  • Service providers (processors/operators) that host infrastructure, deliver email/push, store media, provide analytics/crash reporting, or support customer operations, under contracts that require appropriate protection;
  • Professional advisers and insurers when needed;
  • Authorities and rights holders when required by law, valid legal process, or to protect users, the public, or Twelu; and
  • A buyer or successor if we are involved in a merger, acquisition, or asset transfer, with appropriate safeguards and notice where required.

We do not allow service providers to use your personal information for their own unrelated marketing.

7. International transfers

Twelu may process personal information in countries other than where you live, including countries that may not provide the same legal protections.

Where required (including under GDPR and POPIA), we use appropriate safeguards such as standard contractual clauses, transfer assessments, contractual operator terms, and technical/organisational measures. You can contact us for more information about relevant safeguards.

8. Retention

We keep personal information only as long as needed for the purposes above, including:

  • while your account is active;
  • for a limited period after closure or inactivity for security, abuse prevention, backups, and legal compliance; and
  • longer where we must retain records for disputes, investigations, or legal obligations.

When retention ends, we delete or irreversibly de-identify information where feasible.

9. Security

We use technical and organisational measures designed to protect personal information, including access controls, encryption in transit where appropriate, monitoring, and staff/process controls. No method of transmission or storage is completely secure. Please use a strong unique password and protect your devices.

10. Your rights

Depending on where you live, you may have rights to:

  • access the personal information we hold about you;
  • correct inaccurate or incomplete information;
  • delete information (subject to legal exceptions);
  • restrict or object to certain processing;
  • port data in a structured, commonly used format where applicable;
  • withdraw consent where processing is consent-based;
  • lodge a complaint with a supervisory authority; and
  • under POPIA, request confirmation of whether we hold your information, request a description/record, object to processing in certain cases, and complain to the Information Regulator.

To exercise rights, contact us via the Contact page and describe your request. We may need to verify your identity. We will respond within the timeframes required by applicable law.

You may also adjust in-product privacy and notification settings where available.

Supervisory authorities (examples)

  • EEA: your local data protection authority
  • UK: Information Commissioner's Office (ICO)
  • South Africa: Information Regulator (https://inforegulator.org.za)

11. Children and age-appropriate design

Twelu is not directed at children below the minimum age required in your region. We use age-related checks and, where applicable, guardian or restricted features. If you believe a child has provided personal information in violation of this Policy, contact us and we will take appropriate steps.

12. Automated decision-making

We use automated systems to help detect spam, abuse, and policy violations, and to rank or recommend rooms/hashtags. These systems support human moderation and product features. They are not intended to produce legal or similarly significant effects about you without appropriate human involvement where required by law. You may contact us to ask about meaningful information related to such processing where GDPR or similar laws apply.

13. Marketing

We may send product or marketing messages only where allowed (for example with consent or soft opt-in rules). You can opt out of marketing emails using unsubscribe links or by contacting us. Transactional and safety messages are not marketing and may still be sent when needed to operate your account.

14. Third-party platforms

If you sign in with a third party, that provider may share certain profile data with us according to your settings with them. App stores (Google Play, Apple App Store, Huawei AppGallery) process purchase and install data under their own policies.

15. Changes to this Policy

We may update this Policy from time to time. We will change the "Last updated" date and, for material changes, provide additional notice in the app or on the website where appropriate. Continued use after an update means you acknowledge the revised Policy, except where applicable law requires a different approach (for example fresh consent).

16. Contact

Questions, privacy requests, or complaints: use https://www.twelu.com/contact or the email shown on that page.