Privacy Policy

Introduction

At TWIN PINES LTD (“we”, “us”, or “our”), we take your privacy seriously. This Privacy Policy explains how we process personal data when you visit our website at https://www.twinpinesapps.com (the “Website”) or write to us at an address published on it.

Each of our apps — Bestie, Pulsoul and Vell — has its own privacy policy, linked from the app’s page on this Website. This policy covers the Website only.

For data protection purposes, and under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and similar laws, TWIN PINES LTD (address: Agias Zonis 12, Limassol, 3027, Cyprus; company number HE 477382) is the company responsible for deciding how and why your personal data is processed (the “controller”).

What We Collect

The Website has no accounts, no forms and no advertising, and it does not set cookies. We process only:

• Technical request data. When your browser loads a page, our hosting provider, Cloudflare, receives your IP address, browser and device information, the page requested and the time. This is necessary to deliver the page and to protect the Website against abuse.
• Privacy-friendly analytics. We use Cloudflare Web Analytics, which counts page views and measures performance without cookies, without storing your IP address and without tracking you across websites.
• Messages you send us. If you email one of the addresses published on the Website, we receive your email address, the content of your message and anything you choose to include.

We do not intentionally collect special categories of personal data, and we ask you not to send them by email.

How and Why We Use Your Data

Purpose	Data	Legal basis (GDPR)
Delivering and securing the Website	Technical request data	Our legitimate interest in operating a secure website (Art. 6(1)(f))
Understanding how the Website is used, in aggregate	Cookieless analytics	Our legitimate interest in improving the Website (Art. 6(1)(f))
Answering your message, including job applications	Your email and its content	Steps at your request before a contract, or our legitimate interest in responding (Art. 6(1)(b) and (f))

We do not sell personal data, use it for advertising, or make decisions about you based solely on automated processing.

Service Providers

• Cloudflare, Inc. — hosting, content delivery, security and web analytics.
• Google LLC (Google Workspace) — our email.

These providers process data on our behalf, under contracts that require them to protect it.

Data Retention

Technical request data is kept by Cloudflare for a short period for security and operational purposes. Analytics data is aggregated. We keep email correspondence for as long as needed to deal with your request and for a reasonable period afterwards, unless the law requires us to keep it longer; job applications are kept for up to 12 months unless you ask us to delete them sooner.

International Transfers

Our service providers may process data outside the European Economic Area, including in the United States. Where they do, we rely on safeguards required by data protection law, such as adequacy decisions or standard contractual clauses.

Your Rights

Depending on where you live, you may have the right to access, correct or delete your personal data, to restrict or object to its processing, and to receive a copy of it in a portable format.

You may exercise your rights by contacting us at support@twinpinesapps.com. We may need to verify your identity before responding. If you believe your rights have not been respected, you may lodge a complaint with a data protection authority — in Cyprus, the Commissioner for Personal Data Protection.

Children

The Website is not directed at children under 13, and we do not knowingly collect their personal data.

Changes to This Policy

We may update this policy from time to time. The “Last updated” date above shows when it last changed.

Contact

TWIN PINES LTD, Agias Zonis 12, Limassol, 3027, Cyprus — support@twinpinesapps.com