Privacy Policy
1. Who this policy applies to
This Privacy Policy describes how Twlip (“we”, “us”) handles information when you use the Twlip Gallery mobile application (the “App”) available on Google Play. It does not apply to cloud storage services or other third parties you choose to connect; those are covered by their own privacy policies.
2. Who is responsible
- Operator: Dhananjoy Maji, sole proprietor, India.
- Contact: support@twlip.com
For the purposes of the Digital Personal Data Protection Act, 2023 (India), the Operator also serves as the Grievance Officer. Grievances will be acknowledged within seven (7) working days and resolved within thirty (30) days.
3. What information we handle
3.1 Information that stays on your device
The App reads the photos and videos already stored on your phone so that it can show them, organise them, and (if you ask it to) back them up. As you browse the App, it may also create helpful information about your media — for example, grouping photos that contain the same face, recognising places, or detecting that an image looks like a document. All of this information stays on your device. We do not receive your photos, your videos, the thumbnails, the face groupings, or any of the other categorisation data.
When you sign in to a cloud storage service from inside the App, the sign-in credentials returned by that service are stored only on your device, in protected app storage. We do not receive or store these credentials.
3.2 Information your account record contains
To run your subscription, the App talks to a small Twlip-operated service over a secure connection. That service knows:
- The Google identifier and email address you signed in with.
- Which plan you are on, when it expires, and what that plan includes.
- How many photos/videos you have backed up this month against your plan's monthly allowance.
- The version of the App you are using, so that we can show you the right release notes or notices.
- Standard information any web server sees when an app makes a request: your IP address and a generic identifier of the App.
This service does not receive or store your photos, your videos, the contents of your cloud accounts, your contacts, or your location.
3.3 Purchases
If you buy a paid plan, the purchase is handled by Google Play. Google Play notifies our service of the purchase so that the paid features can be enabled on your account. We never see your payment card or other payment-instrument details.
3.4 No tracking or analytics
The App does not contain advertising networks, behavioural analytics, attribution toolkits, or third-party crash reporters. Google may collect general technical metrics for any app distributed on Google Play in accordance with Google's own privacy policy; we do not receive identifiable information from Google through that channel.
4. Why we handle this information
| What we do | Why |
|---|---|
| Show, organise, and back up the photos and videos you have on your device | To provide the App you have asked for |
| Group faces and categorise scenes, places, documents, and other content | With your consent, to make the App easier to use |
| Sign you in and remember which plan you are on | To run your account and apply the correct plan limits |
| Show in-app notices and update prompts | Legitimate interest in keeping the App safe and current |
| Detect abuse or misuse of the service | Legitimate interest in protecting users and the service |
Where the General Data Protection Regulation (EU) 2016/679 applies, the legal bases above are performance of contract (Art. 6(1)(b)), consent (Art. 6(1)(a)), and legitimate interest (Art. 6(1)(f)). Where the Digital Personal Data Protection Act, 2023 (India) applies, the basis is consent (Section 7(a)) or legitimate use (Section 7(j)).
5. Permissions the App asks for
The App only asks for the permissions it needs for the features you use. You can revoke any of these at any time from your phone's system settings.
- Photos and videos — so the App can display and back up your media library.
- Media location — so location tags already embedded in your photos can be shown on the map. The App does not access your live device location.
- Notifications — to show backup progress and let you pause backups from the notification shade.
- Background operation — to finish a backup that is running while you are using other apps.
- Run after reboot — to resume scheduled backups after you restart your phone.
- Internet — to talk to the cloud accounts you connect, to the sign-in service, and to our account service.
6. How your media reaches your cloud accounts
When you start a backup, the selected files are sent directly from your device to the cloud account you chose, over a secure connection. They do not pass through any system we operate. Once written to that cloud account, the files are governed by that provider's privacy policy and terms.
If you have signed in to the same Google account on more than one device, the App can synchronise your personal album definitions and a few related records between those devices through your own Google Drive. No data is sent peer-to-peer, and no Twlip-operated server is used to broker that synchronisation.
7. Children
The App is not directed to children under thirteen (13) and we do not knowingly collect personal information from them. If you believe a child has used the App, please contact us at the address below and we will delete the information we hold.
8. Who else is involved
The App interacts with the following independent services. Each has its own privacy policy, which you are encouraged to review.
| Service | What it is used for |
|---|---|
| Google Sign-In | Signing you in to the App and confirming your identity to our account service |
| Google Drive, Microsoft OneDrive, Dropbox, Telegram, MEGA | Cloud storage for backups you choose to make |
| Google Play Billing | Processing paid plan purchases |
| Google Play Services | Delivering in-app updates from Google Play |
| OpenStreetMap tile providers | Showing map tiles for the Map feature |
We do not sell, rent, or otherwise share personal information with advertising networks, data brokers, or analytics aggregators.
9. Where the information is processed
Most information stays on your phone. The account service described in Section 3.2 may be hosted in a country different from the one you are in, and the cloud accounts you connect may also process your data in countries different from where you live. When that happens, your data is protected by the standard safeguards each provider relies on for international transfers.
10. How we keep information secure
All communication between the App and our service uses a secure encrypted connection. Sign-in tokens, plan information, and your cloud account credentials are kept in protected app storage on your device. Because we do not hold copies of your photos or videos, the part of our service that could be attacked is small. No system can be made completely secure, however; if a security incident materially affects you, we will notify you as required by law.
11. How long we keep information
- On-device information (your media index, the categorisation records, your preferences, and any sign-in credentials) is removed when you uninstall the App or clear its data from your phone's settings.
- Backed-up files remain in your cloud accounts until you delete them there.
- Permissions you granted to cloud accounts remain in force until you disconnect them inside the App or revoke them from that provider's account settings.
- Your account record on our service is kept while your account is active and for a reasonable period after, to satisfy taxation, accounting, and dispute-handling obligations. You can ask us to delete it sooner — see Section 13.
12. Your rights
Depending on where you live, you may have the right to:
- Ask whether we hold information about you and obtain a copy of it.
- Have inaccurate information corrected.
- Have your information deleted — see Section 13 below.
- Restrict or object to certain uses of your information.
- Withdraw any consent you have given (without affecting things we did before).
- Complain to your local supervisory authority, including, for users in India, the Data Protection Board of India.
To exercise any of these rights, contact us at support@twlip.com. We may ask you to confirm your identity before we respond.
13. Account and data deletion
You can remove your data in the following ways:
- Everything stored on your phone — uninstall the App, or open your phone's system settings and choose “Clear data” for the App.
- Files in your cloud accounts — delete them from the relevant provider's interface. You can also revoke the App's access to any cloud account from that provider's account permissions page.
- Your Twlip account record — send an email from the Google account associated with the App to support@twlip.com with the subject “Account deletion request”. We will process the request within thirty (30) days. Where applicable law requires us to keep certain transaction records for a longer period, those records will be retained only for the minimum required time and used for no other purpose.
14. Contact
For any question or request relating to this policy:
Twlip — Privacy & Grievance Office
Attention: Dhananjoy Maji, Grievance Officer
Email: support@twlip.com
15. Changes to this policy
We may update this policy from time to time. When we make a material change, we will update the effective date at the top and, where appropriate, show a notice inside the App. Continuing to use the App after that means you accept the updated policy.