Privacy Policy

Updated at 2022-08-22


TwoShot (“we,” “our,” or “us”) is committed to protecting your privacy. This Privacy Policy explains how your
personal information is collected, used, and disclosed by TwoShot.

This Privacy Policy applies to our website, and its associated subdomains (collectively, our “Service”)
alongside our application, TwoShot. By accessing or using our Service, you signify that you have read,
understood, and agree to our collection, storage, use, and disclosure of your personal information as described
in this Privacy Policy and our Terms of Service. This Privacy Policy was created with Termify.


Definitions and key terms
To help explain things as clearly as possible in this Privacy Policy, every time any of these terms are
referenced, are strictly defined as:

Cookie: small amount of data generated by a website and saved by your web browser. It is used to identify your
browser, provide analytics, remember information about you such as your language preference or login
information.
Company: when this policy mentions “Company,” “we,” “us,” or “our,” it refers to TwoShot LTD, (71-75 Shelton
Street, Covent Garden, London, United Kingdom, WC2H 9JQ), that is responsible for your information under this
Privacy Policy.
Country: where TwoShot or the owners/founders of TwoShot are based, in this case is United Kingdom
Customer: refers to the company, organization or person that signs up to use the TwoShot Service to manage the
relationships with your consumers or service users.
Device: any internet connected device such as a phone, tablet, computer or any other device that can be used to
visit TwoShot and use the services.
IP address: Every device connected to the Internet is assigned a number known as an Internet protocol (IP)
address. These numbers are usually assigned in geographic blocks. An IP address can often be used to identify
the location from which a device is connecting to the Internet.
Personnel: refers to those individuals who are employed by TwoShot or are under contract to perform a service on
behalf of one of the parties.
Personal Data: any information that directly, indirectly, or in connection with other information — including a
personal identification number — allows for the identification or identifiability of a natural person.
Service: refers to the service provided by TwoShot as described in the relative terms (if available) and on this
platform.
Third-party service: refers to advertisers, contest sponsors, promotional and marketing partners, and others who
provide our content or whose products or services we think may interest you.
Website: TwoShot’s site, which can be accessed via this URL: twoshot.app
You: a person or entity that is registered with TwoShot to use the Services.

What Information Do We Collect?
We collect information from you when you visit our website/app, register on our site, place an order, subscribe
to our newsletter, respond to a survey or fill out a form.

Name / Username
Email Addresses

When does TwoShot use end user information from third parties?
TwoShot will collect End User Data necessary to provide the TwoShot services to our customers. End users may
voluntarily provide us with information they have made available on social media websites. If you provide us
with any such information, we may collect publicly available information from the social media websites you have
indicated. You can control how much of your information social media websites make public by visiting these
websites and changing your privacy settings.


When does TwoShot use customer information from third parties?
We receive some information from the third parties when you contact us. For example, when you submit your email
address to us to show interest in becoming a TwoShot customer, we receive information from a third party that
provides automated fraud detection services to TwoShot. We also occasionally collect information that is made
publicly available on social media websites. You can control how much of your information social media websites
make public by visiting these websites and changing your privacy settings.


Do we share the information we collect with third parties?
We may share the information that we collect, both personal and non-personal, with third parties such as
advertisers, contest sponsors, promotional and marketing partners, and others who provide our content or whose
products or services we think may interest you. We may also share it with our current and future affiliated
companies and business partners, and if we are involved in a merger, asset sale or other business
reorganization, we may also share or transfer your personal and non-personal information to our
successors-in-interest.

We may engage trusted third party service providers to perform functions and provide services to us, such as
hosting and maintaining our servers and the website/app, database storage and management, e-mail management,
storage marketing, credit card processing, customer service and fulfilling orders for products and services you
may purchase through the website/app. We will likely share your personal information, and possibly some
non-personal information, with these third parties to enable them to perform these services for us and for you.

We may share portions of our log file data, including IP addresses, for analytics purposes with third parties
such as web analytics partners, application developers, and ad networks. If your IP address is shared, it may be
used to estimate general location and other technographics such as connection speed, whether you have visited
the website/app in a shared location, and type of the device used to visit the website/app. They may aggregate
information about our advertising and what you see on the website/app and then provide auditing, research and
reporting for us and our advertisers.

We may also disclose personal and non-personal information about you to government or law enforcement officials
or private parties as we, in our sole discretion, believe necessary or appropriate in order to respond to
claims, legal process (including subpoenas), to protect our rights and interests or those of a third party, the
safety of the public or any person, to prevent or stop any illegal, unethical, or legally actionable activity,
or to otherwise comply with applicable court orders, laws, rules and regulations.


Where and when is information collected from customers and end users?
TwoShot will collect personal information that you submit to us. We may also receive personal information about
you from third parties as described above.


How Do We Use The Information We Collect?
Any of the information we collect from you may be used in one of the following ways:

To personalize your experience (your information helps us to better respond to your individual needs)
To improve our website/app (we continually strive to improve our website/app offerings based on the information
and feedback we receive from you)
To improve customer service (your information helps us to more effectively respond to your customer service
requests and support needs)
To process transactions
To administer a contest, promotion, survey or other site feature
To send periodic emails

How Do We Use Your Email Address?
By submitting your email address on this website/app, you agree to receive emails from us. You can cancel your
participation in any of these email lists at any time by clicking on the opt-out link or other unsubscribe
option that is included in the respective email. We only send emails to people who have authorized us to contact
them, either directly, or through a third party. We do not send unsolicited commercial emails, because we hate
spam as much as you do. By submitting your email address, you also agree to allow us to use your email address
for customer audience targeting on sites like Facebook, where we display custom advertising to specific people
who have opted-in to receive communications from us. Email addresses submitted only through the order processing
page will be used for the sole purpose of sending you information and updates pertaining to your order. If,
however, you have provided the same email to us through another method, we may use it for any of the purposes
stated in this Policy. Note: If at any time you would like to unsubscribe from receiving future emails, we
include detailed unsubscribe instructions at the bottom of each email.


How Long Do We Keep Your Information?
We keep your information only so long as we need it to provide TwoShot to you and fulfill the purposes described
in this policy. This is also the case for anyone that we share your information with and who carries out
services on our behalf. When we no longer need to use your information and there is no need for us to keep it to
comply with our legal or regulatory obligations, we’ll either remove it from our systems or depersonalize it so
that we can't identify you.


How Do We Protect Your Information?
We implement a variety of security measures to maintain the safety of your personal information when you place
an order or enter, submit, or access your personal information. We offer the use of a secure server. All
supplied sensitive/credit information is transmitted via Secure Socket Layer (SSL) technology and then encrypted
into our Payment gateway providers database only to be accessible by those authorized with special access rights
to such systems, and are required to keep the information confidential. After a transaction, your private
information (credit cards, social security numbers, financials, etc.) is never kept on file. We cannot, however,
ensure or warrant the absolute security of any information you transmit to TwoShot or guarantee that your
information on the Service may not be accessed, disclosed, altered, or destroyed by a breach of any of our
physical, technical, or managerial safeguards.


Could my information be transferred to other countries?
TwoShot is incorporated in United Kingdom. Information collected via our website, through direct interactions
with you, or from use of our help services may be transferred from time to time to our offices or personnel, or
to third parties, located throughout the world, and may be viewed and hosted anywhere in the world, including
countries that may not have laws of general applicability regulating the use and transfer of such data. To the
fullest extent allowed by applicable law, by using any of the above, you voluntarily consent to the trans-border
transfer and hosting of such information.


Is the information collected through the TwoShot Service secure?
We take precautions to protect the security of your information. We have physical, electronic, and managerial
procedures to help safeguard, prevent unauthorized access, maintain data security, and correctly use your
information. However, neither people nor security systems are foolproof, including encryption systems. In
addition, people can commit intentional crimes, make mistakes or fail to follow policies. Therefore, while we
use reasonable efforts to protect your personal information, we cannot guarantee its absolute security. If
applicable law imposes any non-disclaimable duty to protect your personal information, you agree that
intentional misconduct will be the standards used to measure our compliance with that duty.


Can I update or correct my information?
The rights you have to request updates or corrections to the information TwoShot collects depend on your
relationship with TwoShot. Personnel may update or correct their information as detailed in our internal company
employment policies.

Customers have the right to request the restriction of certain uses and disclosures of personally identifiable
information as follows. You can contact us in order to (1) update or correct your personally identifiable
information, (2) change your preferences with respect to communications and other information you receive from
us, or (3) delete the personally identifiable information maintained about you on our systems (subject to the
following paragraph), by cancelling your account. Such updates, corrections, changes and deletions will have no
effect on other information that we maintain, or information that we have provided to third parties in
accordance with this Privacy Policy prior to such update, correction, change or deletion. To protect your
privacy and security, we may take reasonable steps (such as requesting a unique password) to verify your
identity before granting you profile access or making corrections. You are responsible for maintaining the
secrecy of your unique password and account information at all times.

You should be aware that it is not technologically possible to remove each and every record of the information
you have provided to us from our system. The need to back up our systems to protect information from inadvertent
loss means that a copy of your information may exist in a non-erasable form that will be difficult or impossible
for us to locate. Promptly after receiving your request, all personal information stored in databases we
actively use, and other readily searchable media will be updated, corrected, changed or deleted, as appropriate,
as soon as and to the extent reasonably and technically practicable.

If you are an end user and wish to update, delete, or receive any information we have about you, you may do so
by contacting the organization of which you are a customer.


Personnel
If you are a TwoShot worker or applicant, we collect information you voluntarily provide to us. We use the
information collected for Human Resources purposes in order to administer benefits to workers and screen
applicants.

You may contact us in order to (1) update or correct your information, (2) change your preferences with respect
to communications and other information you receive from us, or (3) receive a record of the information we have
relating to you. Such updates, corrections, changes and deletions will have no effect on other information that
we maintain, or information that we have provided to third parties in accordance with this Privacy Policy prior
to such update, correction, change or deletion.


Sale of Business
We reserve the right to transfer information to a third party in the event of a sale, merger or other transfer
of all or substantially all of the assets of TwoShot or any of its Corporate Affiliates (as defined herein), or
that portion of TwoShot or any of its Corporate Affiliates to which the Service relates, or in the event that we
discontinue our business or file a petition or have filed against us a petition in bankruptcy, reorganization or
similar proceeding, provided that the third party agrees to adhere to the terms of this Privacy Policy.


Affiliates
We may disclose information (including personal information) about you to our Corporate Affiliates. For purposes
of this Privacy Policy, "Corporate Affiliate" means any person or entity which directly or indirectly controls,
is controlled by or is under common control with TwoShot, whether by ownership or otherwise. Any information
relating to you that we provide to our Corporate Affiliates will be treated by those Corporate Affiliates in
accordance with the terms of this Privacy Policy.


Governing Law
This Privacy Policy is governed by the laws of United Kingdom without regard to its conflict of laws provision.
You consent to the exclusive jurisdiction of the courts in connection with any action or dispute arising between
the parties under or in connection with this Privacy Policy except for those individuals who may have rights to
make claims under Privacy Shield, or the Swiss-US framework.

The laws of United Kingdom, excluding its conflicts of law rules, shall govern this Agreement and your use of
the website/app. Your use of the website/app may also be subject to other local, state, national, or
international laws.

By using TwoShot or contacting us directly, you signify your acceptance of this Privacy Policy. If you do not
agree to this Privacy Policy, you should not engage with our website, or use our services. Continued use of the
website, direct engagement with us, or following the posting of changes to this Privacy Policy that do not
significantly affect the use or disclosure of your personal information will mean that you accept those changes.


Your Consent
We've updated our Privacy Policy to provide you with complete transparency into what is being set when you visit
our site and how it's being used. By using our TwoShot, registering an account, or making a purchase, you hereby
consent to our Privacy Policy and agree to its terms.


Links to Other Websites
This Privacy Policy applies only to the Services. The Services may contain links to other websites not operated
or controlled by TwoShot. We are not responsible for the content, accuracy or opinions expressed in such
websites, and such websites are not investigated, monitored or checked for accuracy or completeness by us.
Please remember that when you use a link to go from the Services to another website, our Privacy Policy is no
longer in effect. Your browsing and interaction on any other website, including those that have a link on our
platform, is subject to that website’s own rules and policies. Such third parties may use their own cookies or
other methods to collect information about you.


Cookies
TwoShot uses "Cookies" to identify the areas of our website that you have visited. A Cookie is a small piece of
data stored on your computer or mobile device by your web browser. We use Cookies to enhance the performance and
functionality of our website/app but are non-essential to their use. However, without these cookies, certain
functionality like videos may become unavailable or you would be required to enter your login details every time
you visit the website/app as we would not be able to remember that you had logged in previously. Most web
browsers can be set to disable the use of Cookies. However, if you disable Cookies, you may not be able to
access functionality on our website correctly or at all. We never place Personally Identifiable Information in
Cookies.


Blocking and disabling cookies and similar technologies
Wherever you're located you may also set your browser to block cookies and similar technologies, but this action
may block our essential cookies and prevent our website from functioning properly, and you may not be able to
fully utilize all of its features and services. You should also be aware that you may also lose some saved
information (e.g. saved login details, site preferences) if you block cookies on your browser. Different
browsers make different controls available to you. Disabling a cookie or category of cookie does not delete the
cookie from your browser, you will need to do this yourself from within your browser, you should visit your
browser's help menu for more information.


Payment Details
In respect to any credit card or other payment processing details you have provided us, we commit that this
confidential information will be stored in the most secure manner possible.


Kids' Privacy
We collect information from kids under the age of 13 just to better our services. If You are a parent or
guardian and You are aware that Your child has provided Us with Personal Data without your permission, please
contact Us. If We become aware that We have collected Personal Data from anyone under the age of 13 without
verification of parental consent, We take steps to remove that information from Our servers.


Changes To Our Privacy Policy
We may change our Service and policies, and we may need to make changes to this Privacy Policy so that they
accurately reflect our Service and policies. Unless otherwise required by law, we will notify you (for example,
through our Service) before we make changes to this Privacy Policy and give you an opportunity to review them
before they go into effect. Then, if you continue to use the Service, you will be bound by the updated Privacy
Policy. If you do not want to agree to this or any updated Privacy Policy, you can delete your account.


Third-Party Services
We may display, include or make available third-party content (including data, information, applications and
other products services) or provide links to third-party websites or services ("Third- Party Services").

You acknowledge and agree that TwoShot shall not be responsible for any Third-Party Services, including their
accuracy, completeness, timeliness, validity, copyright compliance, legality, decency, quality or any other
aspect thereof. TwoShot does not assume and shall not have any liability or responsibility to you or any other
person or entity for any Third-Party Services.

Third-Party Services and links thereto are provided solely as a convenience to you and you access and use them
entirely at your own risk and subject to such third parties' terms and conditions.


Tracking Technologies

Local Storage

Local Storage sometimes known as DOM storage, provides web apps with methods and protocols for storing
client-side data. Web storage supports persistent data storage, similar to cookies but with a greatly enhanced
capacity and no information stored in the HTTP request header.


Information about General Data Protection Regulation (GDPR)
We may be collecting and using information from you if you are from the European Economic Area (EEA), and in
this section of our Privacy Policy we are going to explain exactly how and why is this data collected, and how
we maintain this data under protection from being replicated or used in the wrong way.


What is GDPR?
GDPR is an EU-wide privacy and data protection law that regulates how EU residents' data is protected by
companies and enhances the control the EU residents have, over their personal data.

The GDPR is relevant to any globally operating company and not just the EU-based businesses and EU residents.
Our customers’ data is important irrespective of where they are located, which is why we have implemented GDPR
controls as our baseline standard for all our operations worldwide.


What is personal data?
Any data that relates to an identifiable or identified individual. GDPR covers a broad spectrum of information
that could be used on its own, or in combination with other pieces of information, to identify a person.
Personal data extends beyond a person’s name or email address. Some examples include financial information,
political opinions, genetic data, biometric data, IP addresses, physical address, sexual orientation, and
ethnicity.

The Data Protection Principles include requirements such as:

Personal data collected must be processed in a fair, legal, and transparent way and should only be used in a way
that a person would reasonably expect.
Personal data should only be collected to fulfil a specific purpose and it should only be used for that purpose.
Organizations must specify why they need the personal data when they collect it.
Personal data should be held no longer than necessary to fulfil its purpose.
People covered by the GDPR have the right to access their own personal data. They can also request a copy of
their data, and that their data be updated, deleted, restricted, or moved to another organization.

Why is GDPR important?
GDPR adds some new requirements regarding how companies should protect individuals' personal data that they
collect and process. It also raises the stakes for compliance by increasing enforcement and imposing greater
fines for breach. Beyond these facts it's simply the right thing to do. At TwoShot we strongly believe that your
data privacy is very important and we already have solid security and privacy practices in place that go beyond
the requirements of this new regulation.


Individual Data Subject's Rights - Data Access, Portability and Deletion
We are committed to helping our customers meet the data subject rights requirements of GDPR. TwoShot processes
or stores all personal data in fully vetted, DPA compliant vendors. We do store all conversation and personal
data for up to 6 years unless your account is deleted. In which case, we dispose of all data in accordance with
our Terms of Service and Privacy Policy, but we will not hold it longer than 60 days.

We are aware that if you are working with EU customers, you need to be able to provide them with the ability to
access, update, retrieve and remove personal data. We got you! We've been set up as self service from the start
and have always given you access to your data and your customers data. Our customer support team is here for you
to answer any questions you might have about working with the API.


California Residents
The California Consumer Privacy Act (CCPA) requires us to disclose categories of Personal Information we collect
and how we use it, the categories of sources from whom we collect Personal Information, and the third parties
with whom we share it, which we have explained above.

We are also required to communicate information about rights California residents have under California law. You
may exercise the following rights:

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of
Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are
collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific
pieces of Personal Information we have collected about you.
Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
Right to Delete. You may submit a verifiable request to close your account and we will delete Personal
Information about you that we have collected.
Request that a business that sells a consumer's personal data, not sell the consumer's personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights,
please contact us.

We do not sell the Personal Information of our users.

For more information about these rights, please contact us.


California Online Privacy Protection Act (CalOPPA)
CalOPPA requires us to disclose categories of Personal Information we collect and how we use it, the categories
of sources from whom we collect Personal Information, and the third parties with whom we share it, which we have
explained above.

CalOPPA users have the following rights:

Right to Know and Access. You may submit a verifiable request for information regarding the: (1) categories of
Personal Information we collect, use, or share; (2) purposes for which categories of Personal Information are
collected or used by us; (3) categories of sources from which we collect Personal Information; and (4) specific
pieces of Personal Information we have collected about you.
Right to Equal Service. We will not discriminate against you if you exercise your privacy rights.
Right to Delete. You may submit a verifiable request to close your account and we will delete Personal
Information about you that we have collected.
Right to request that a business that sells a consumer's personal data, not sell the consumer's personal data.
If you make a request, we have one month to respond to you. If you would like to exercise any of these rights,
please contact us.

We do not sell the Personal Information of our users.

For more information about these rights, please contact us.


Contact Us
Don't hesitate to contact us if you have any questions.

Via Email: contact@twoshot.app