(Effective Date: 28 November 2025)
This Privacy Policy is incorporated by reference into the Twist Games Terms of Service. The terms “Twist,” “we,” and “us” include Twist Games. This Privacy Policy explains our online and offline information practices, the kinds of information we may collect, how we intend to use, store, protect, disclose and share that information, and how you can opt out of a use or correct or change such information.
This Privacy Policy applies to Personal Information that is Processed by Twist in the course of our business, including on Twist websites (each a “Site”), mobile applications, forums, blogs, and other online or offline offerings (together with any and all future online and offline offerings operated by or on behalf of Twist (the “Services”)). All individuals whose responsibilities include the Processing of Personal Information on behalf of Twist are expected to protect that data by adhering to this Privacy Policy. This Privacy Policy is intended to meet requirements globally, including those in North America, Europe, Turkey, APAC, and other jurisdictions. By visiting, installing, using or otherwise accessing the Services, you agree to this Privacy Policy and Terms of Services of Twist and give an explicit and informed consent to the processing of your Personal Information in accordance with this Privacy Policy. Please do not install or use the Services if you do not agree to this Privacy Policy or Terms of Services. Please note that Twist is not responsible for the actions of Third Parties, the content of their sites, the use of information you provide to them or any services they may offer. Twist reserves the right to modify this Privacy Policy and your continued use of the Services shall mean your acceptance of the changes to this Privacy Policy.
The types of Personal Information we may collect (directly from you or from Third-party sources) and our privacy practices depend on the nature of the relationship you have with Twist and the requirements of applicable law. Some of the ways that Twist may collect Personal Information include: you may provide Personal Information directly to Twist through interacting with the Services, participate in Services feedback, questionnaires, surveys, or contests or participating in forums discussions, and requesting Services, or information; and as you navigate the Services, certain passive information may also be collected about your visit, including through Cookies and similar technologies as described below. Primary goals in collecting information are to provide and improve our Services, to administer your use of the Services and to enable you to enjoy and easily navigate our Services. We endeavor to collect only that information that is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
Twist collects Personal Information regarding its current, prospective, and former clients, customers, users, visitors, and guests (collectively “Individuals”).
If you play any of the games or use any of the Services on connected Third-party applications or connect the Services to any Third-party applications, like Apple, Google, Amazon and/or from Social Networking Sites (“SNS”) such as Facebook, Twist may receive certain information about you from the provider of the Third-party application. The information received depends the Third-party application, your privacy settings and, if applicable, your friends' privacy settings on that Third-party application When you connect with the Services through an SNS, the information that Twist collects may include your first and last name, your SNS user identification number and/or user name, your profile picture or its URL, location, sex, the login e-mail you provided to that Third-party application when you registered with the SNS, age-range (e.g. min 21), locale, language of your application, time zone and the SNS user identification numbers for your friends who are also connected to the Services.
When you use any of the Services, games or applications on a mobile platform, Twist may collect and record certain information such as your unique device ID (persistent/non-persistent), your device operating system, version, model, CPU, amount of RAM and disk space, hardware type, Identifier For Advertising (IDFA), Advertising ID, the version of your operating system ("OS"), your device name, Game Center ID, and your location based on your Internet Protocol ("IP") address. This information is useful to Twist for troubleshooting and helps Twist understand usage trends.
As part of the payment processing through Third Parties, Twist does not collect, store and use personally identifiable information, such as your name, address, credit card number, phone number, and your e-mail address. Twist does not have access to your credit card or bank account data. However, Third Party payment processors may share non-financial information with us related to your purchases, like the items purchased to fulfill your order.
You can manage the information Twist receives about you from a Third-party application on which you play our games, like Facebook, and you will need to follow the instructions for the Third-party application for changing your privacy settings. You also can manage some aspects of information collection and use by visiting the settings page of your mobile device and reviewing the permissions of each application (app). If you access our Services from a Third-party application or connect our Services to a Third-party application, you should also read that Third-party application’s terms of service and privacy policy.
When you use the services or engage in certain activities, such as Registering for an Account with our games, responding to surveys, requesting services or information, or contacting us directly, we may ask you to provide some or all of the following types of information.
We or the Service Providers acting on our behalf, such as Firebase, Google Analytics, Applovin, may store log files and use tracking technologies such as Cookies, web beacons and/or tracking pixels. We may collect certain information automatically by using such technologies through our Services or other methods of web analysis, such as your Internet protocol (IP) address, cookie identifiers, mobile advertising identifiers, your mobile device’s identifiers like your Identifier For Advertising (IDFA), Advertising ID, Game Center ID, the type of computer or mobile device you are using, your device's operating system, version, model, hardware type and other device identifiers that are automatically assigned to your computer or device when you access the Internet, browser type and language, hardware type, operating system, Internet service provider, pages that you visit before and after using the Services, the date and time of your visit, the amount of time you spend on each page, information about the links you click and pages you view within the Services and other actions taken through use of the Services such as preferences. In some cases, we will connect this information with your social network ID, Device ID, Game Center ID or Advertising ID. For more information on the tracking technologies, please refer to Section 3.3.
You agree that Twist is free to use the content of any communications you submit via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing and/or marketing the Services. Twist will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
Twist may feature advertising within the Services. The advertisers may collect and use information about you such as: performance and game contextual data like your games session activity; aggregated and/or de-identified information that is not intended to specifically identify a user; and technical information such as device identifier, Advertising ID, and IP address. Ad Networks may use this information to provide interest-based or targeted advertisements to you.
The Services includes Social Media Features, such as the Facebook and Twitter button, and Widgets, such as the “Share” button or interactive mini-programs that run on the Services. These features may collect your IP address and which page you are visiting on the Services and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a Third Party or hosted directly on the Services. Your interactions with these features are governed by the privacy policy of the company providing it. To protect you from such a data transfer to the social media provider, we implemented technical protection measures (“2 click solution”). This allows you to agree to the data transfer to the corresponding social media provider on a case-by-case basis or permanently by activating the respective sharing button. You can withdraw a permanent agreement at any time.
Our primary goals of using the information that we collect and store are to provide a better gaming experience, provide the Services to you, improve the Services, contact you, conduct marketing and research activities and create reports for internal use. We store information on servers via Amazon Web Services and Azure and may store information on servers, cloud technologies and equipment in other countries. We collect, store, use and process Personal Information for a variety of business purposes, including:
We, as well as Third Parties that provide content, advertising or other functionality on our Services, may use Cookies, pixel tags and other technologies (“Technologies”) to automatically collect information through the Services. We use Technologies that are essentially small data files placed on your computer, tablet, mobile phone or other devices (referred to collectively as a "device") that allow us to record certain pieces of information whenever you visit or interact with our sites, services, applications, messaging, and tools and to recognize you across devices.
Our uses of such Technologies fall into the following general categories.
Opting Out of Cookie Tracking: You can set your web browser to warn you about attempts to place Cookies on your computer or limit the type of Cookies you allow. Flash Cookies operate differently than browser Cookies, and cookie management tools available in a web browser may not remove flash Cookies. Please be advised that if you disable Cookies, you may lose some of the features and functionality of our Services because the Cookies are necessary to track and enhance your game activities.
The Site may contain links to other websites, and other websites may reference or link to our Site or other Services. These other domains and websites are not controlled by us, and we do not endorse, screen or approve and are not responsible for the privacy practices or content of such other websites or applications. We encourage our users to read the privacy policies of each and every website and application with which they interact. You visit these other websites or applications at your own risk.
Twist’s Services may include publicly accessible blogs, community forums or private messaging features. The Site and our other Services may also contain links and interactive features with various social media platforms (e.g., widgets). If you already use these platforms, their Cookies may be set on your device when using our Site or other Services. You should be aware that Personal Information that you voluntarily include and transmit online in a publicly accessible blog, chat room, social media platform or otherwise online or that you share in an open forum may be viewed and used by others without any restrictions. We are unable to control such uses of your information when you interact with a social media platform, and by using such services, you assume the risk that the Personal Information you provided may be viewed and used by Third Parties for any number of purposes.
We may sell Virtual Items or Merchandise through our Services. When you make purchases through the Services, we process your payments through a Third-party application, including the Apple App Store, Google Play App Store, Amazon App Store (together with any similar applications, “App Stores”) and Social Networking Sites (“SNS”) such as Facebook. The Third-party application may collect certain financial information from you to process a payment on behalf of Twist, including your name, email address, address and other billing information. App Stores do not share this information they collect from you with us.
We may share your information as described in this Privacy Policy (to provide the Services with our Third-party Service Providers; to comply with legal obligations; to protect and defend our rights and property) or with your consent.
All Personal Information collected via or by Twist may be stored anywhere in the world, including, but not limited to, in Turkey, the United States, the European Union, in the cloud, on our servers and on the servers of our affiliates or the servers of our Service Providers. When we transfer your Personal Information internationally, we will take reasonable steps to ensure that it is treated securely, lawfully and in the manner, we describe here. Please note that laws vary from jurisdiction to jurisdiction, so the privacy laws applicable to the places where your information is transferred to or stored, used or processed in may be different from the privacy laws applicable to the place where you are resident. By providing information to Twist, you consent to the storage of your Personal Information in these locations. If you are using our Services from the European Union or other regions with laws governing data collection and use, please note that you are agreeing to the transfer of your information to Turkey and the United States and to Processing of your data globally. By choosing to visit the Site, utilize the Services or otherwise provide information to us, you agree that any dispute over privacy or the terms contained in this Privacy Policy will be governed by the laws of Turkey and the adjudication of any disputes arising in connection with Twist or the Site will be in accordance with the Terms Services.
You have the right to opt out of certain uses and disclosures of your Personal Information. When you have consented to Twist’s processing of your Personal Information or Sensitive Personal Information, you may withdraw that consent at any time and opt out to further Processing by opening an in-game support ticket or, alternatively, by contacting support@twist.gs. Even if you opt out, we may still collect and use anonymized, non-Personal Information regarding your activities on our Services. Please also note that certain records, for example, those relating to payments or customer service matters, will be held for legal and accounting purposes. If you have sent content through or posted content on the Service, we may not be able to delete it.
On mobile devices, you can reset the Advertising Identifier (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous Advertising Identifier. Furthermore, depending on the platform provider (such as Apple or Google), you may be able to download apps, such as the Digital Advertising Alliance’s “AppChoices” app, that provide you with control regarding the collection and use of cross-app data for tailored advertising. Like the opt out tools mentioned for web, these opt out tools are provided by Third Parties, and Twist does not operate or control these tools or the choices that advertisers and others provide through these tools. To be clear, whether you are using our opt out or an online industry opt out, these cookie-based opt outs must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt out will not be effective on your mobile device.
You have the right to request access to and rectification or erasure of Personal Information or restriction of processing, the right to object and the right to data portability. The general right to object applies to all types of processing described in this Privacy Policy. Unlike the right to object against processing for direct marketing purposes, we are only obliged to follow an objection if you state specific grounds relating to your particular situation. When otherwise permitted by applicable law, you can open a support ticket within the Games or, alternatively, send an e-mail to support@twist.gs to request access to, receive (port), seek rectification or request erasure of Personal Information held about you by Twist. Please include your full name, user identifier, the email address associated with your account and a detailed description of your data request. Such requests will be processed in line with applicable laws. Although Twist makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which Twist is unable to provide access, including but not limited to when the information contains legal privilege, would compromise others’ privacy or other legitimate rights, when the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or when it is commercially proprietary. If Twist determines that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, Twist will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
If you are an individual in the European Economic Area (EEA), Switzerland or the United Kingdom, we collect and process personal data about you only where we have legal bases for doing so under applicable EU, Swiss or UK laws. The legal bases which we rely upon are the following:
Twist retains the Personal Information collected as described in this Privacy Policy for as long as you use our Services or as necessary to fulfill the purpose(s) for which it was collected, provide our Services, resolve disputes, establish legal defenses, conduct audits, pursue legitimate business purposes, enforce our agreements and comply with applicable laws.
The Personal Information that you provide to Twist is stored on servers that are located in secured facilities and protected by protocols and procedures designed to ensure industry-standard security of such information, such as firewalls and data encryption. However, no server, computer or communications network or system or data transmission over the Internet can be guaranteed to be 100% secure. As a result, while Twist strives to protect your information, Twist cannot ensure or warrant the security of any information you transmit to Twist or through the Services. By using the Services or providing Personal Information to us, you agree that we may communicate with you electronically regarding security privacy, and administrative issues related to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Services or sending an e-mail to you or via push notification.
The Services are not directed to children under 13, and Twist does not knowingly collect Personally Identifiable Information from children under 13. If you are a parent or legal guardian of a child under the age of 13 (or under 16 in certain jurisdictions in the European Union) who uses our games, please contact us at support@twist.gs. We will delete your child’s Personal Information if we are able to identify your child unless you provide us with your verifiable consent for your child to continue to use our games.
If you have any questions about our privacy practices or this Privacy Policy, please contact Twist by email at support@twist.gs. We will address your concerns and attempt to resolve any privacy issues in a timely manner.
Revision to the Privacy Policy. We may revise this Privacy Policy at our sole discretion, so review it periodically. If you continue to visit this Site and use the services made available to you after such changes have been made, you hereby provide your consent to the changes.
Posting of Revised Privacy Policy. If there are any material changes to this Privacy Policy, Twist will notify you by email or as otherwise required by applicable law. We will post adjustments to the Privacy Policy on this web page, and the revised version will be effective immediately when it is posted (or upon notice as applicable). If you are concerned about how your information is used, bookmark this page and read this Privacy Policy periodically.
New Uses of Personal Information. Additionally, before we use Personal Information for any new purpose not originally authorized by you, we will endeavor to provide information regarding the new purpose and give you the opportunity to opt out. When consent of the Individual for the Processing of Personal Information is otherwise required by law or contract, Twist will endeavor to comply with the law or contract.
California law permits users who are California residents to request and obtain from us, once a year and free of charge, a list of the Third Parties to whom we have disclosed their Personal Information (if any) for their direct marketing purposes in the prior calendar year, as well as the type of Personal Information disclosed to those parties. Twist does not share Personal Information with Third Parties for their own marketing purposes.
If you have any questions about the privacy practices or this Privacy Policy, please contact Twist’s data protection officer by email at support@twist.gs
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