Privacy Policy

Twine (“Twine,” “we,” or “us”) provides a mobile line and an intelligence layer that operates on calls made and received on it. This policy explains what we collect, how we use and share it, and the choices you have.

Two things are true of Twine that are not true of most services, and they shape this whole policy: calls on your Twine line are recorded as a matter of course, and we are the telephone line itself rather than an application running over someone else’s.

Account information

Your name, email address, mailing address, telephone number and password. Paid plans require billing details, processed by third parties. We do not store full payment card numbers.

Identity verification

Provisioning a mobile line may require identity verification. Where a verification provider is used, we receive the outcome rather than your underlying documents.

Contacts

With your permission we access your device contacts so the Service can recognise who you are speaking to and organise your calls. You can withdraw that permission at any time in your device settings.

Call content

When you place or receive a call on your Twine line, we collect the audio of the call and a transcript derived from it. From those we generate structured information, which may include a summary of the call, commitments made by either party, follow-up actions, and names, dates, figures and other details mentioned during the conversation.

This information concerns everyone on the call, not only you. Section 4 of the Terms of Service sets out what you owe the other party.

Call and network records

Because your Twine line is a mobile line, we receive information about your use of that line that is classified as Customer Proprietary Network Information (“CPNI”) under 47 U.S.C. § 222: the numbers you call and that call you, and the time, date, duration, destination and type of service used.

We use CPNI to provide, bill and support the Service, and we do not disclose it except as permitted by law or with your approval. We do not use CPNI for marketing without your approval.

Device and usage information

Device type, operating system, application version, and information about how the Service is used, collected to operate and improve it.

Cookies

Our websites use cookies and similar technologies to recognise returning visitors and remember preferences. You can control these in your browser.

Support correspondence

Information you provide when you contact support.

Processing happens in the network rather than on your handset, which is what allows the Service to work without an application running on your phone.

Call audio and transcripts are processed by automated systems operated by Twine and by service providers acting under contract, who may use it only to provide the Service to us.

Recording law differs by jurisdiction. Where notice is required by a law applicable to a call, the Service plays an audible announcement at the start of that call.

Accent conversion and related features process the sound of your voice in real time during the call in order to re-synthesise it. That processing is used to provide the feature you have turned on, not to identify you.

We use information to:

• provision and operate your Twine line;
• record, transcribe and summarise calls, and generate follow-up actions;
• deliver information to Connected Services you authorise;
• verify identity, bill you, and provide support;
• secure the Service and prevent fraud and abuse;
• comply with legal and regulatory obligations, including those applicable to us as a provider of telecommunications service;
• improve the Service, using information that has been de-identified.

We do not sell your personal information. We share it only:

• with service providers who process it on our behalf, including hosting, payments, identity verification and automated processing;
• with the underlying network operator, as necessary to carry your calls and operate your line;
• with Connected Services you have authorised, at your instruction;
• within the CarrierX group of companies, where necessary to operate and support the Service;
• in connection with a merger, acquisition or sale of assets;
• where required by law, legal process or an enforceable governmental request;
• with your consent; and
• as aggregated or de-identified information that does not identify you.

Different categories are kept for different periods:

• Call audio: 30 days, unless you delete it sooner
• Transcripts: for as long as your account is active, unless you delete them
• Summaries and extracted actions: for as long as your account is active, unless you delete them
• Call and network records (CPNI): as required by law and for billing
• Account and billing records: as required for tax, accounting and legal purposes

When you delete a call or close your account we delete or de-identify the associated information, except where we are required to retain it.

We encrypt information in transit and at rest, restrict internal access, and review our controls. You are responsible for protecting your account credentials.

You may access, correct, export or request deletion of your personal information, withdraw consent to optional processing, and object to or restrict certain processing. We honour rights available under applicable law, including the GDPR and the CCPA as amended.

If you are not a Twine customer but were recorded on a call with one and have a question or request, contact us at privacy@twinemobile.com and we will respond.

Information may be transferred to and processed in the United States and other countries under appropriate safeguards.

The Service is not intended for anyone under 18 and we do not knowingly collect their information.

We may update this policy. Where a change is material we will give notice before it takes effect.

privacy@twinemobile.com · Twine, c/o CarrierX, 4300 Pacific Coast Highway, Long Beach, CA 90804