Privacy Policy

TWENTY is operated by Noles Technology Inc., a Delaware corporation ("we", "us", "our").

This policy explains what happens to information when you use the TWENTY mobile application (the "App"). It is short because the App is built to collect as little as possible.

1. The short version

• TWENTY has no accounts. You never create one, and we never ask for your name, email address or phone number.
• Everything you enter into the App is stored on your device. It is not sent to us and we cannot read it.
• We do not have a server that holds your answers, your check-ins, your writing, or your history.
• We do not sell data. We do not run advertising. We do not share information with data brokers.
• The only third party involved in normal use is our payments provider, and Apple, who processes your purchase.

2. Information stored on your device

When you use TWENTY, the App stores the following locally on your phone, using your device's own storage:

• Your answers to the onboarding questions, including questions about your drinking
• The score derived from those answers
• Your stated goal and target
• Your daily check-ins, including whether you drank and how many drinks
• Your evening plans, including situation and mood
• Records of when you used the twenty-minute timer, how long you stayed, and what you did
• Any free text you write inside the App
• Your settings, including reminder time and cost per drink

This information does not leave your device. It is not transmitted to Noles Technology Inc. We have no ability to access it, retrieve it, or read it.

If you delete the App, this information is deleted with it. You can also erase everything at any time from Settings, using "Reset all data". Both actions are permanent and we cannot recover the data, because we never had it.

3. Information handled by third parties

Purchases (RevenueCat and Apple). Subscriptions are processed through the Apple App Store. To manage your subscription status across devices and to verify that a purchase is valid, we use RevenueCat, Inc. RevenueCat receives an anonymous identifier generated by the App, your subscription status, your purchase and renewal history, your country, and basic device information such as operating system version.

RevenueCat does not receive your drinking data, your check-ins, your writing, or any of your answers. Apple processes your payment directly and we never see your payment details, card number, or billing address.

RevenueCat's privacy policy: www.revenuecat.com/privacy

Apple's privacy policy: www.apple.com/legal/privacy

Crash and performance data. Apple may collect crash reports and performance data from apps on your device, subject to the settings you have chosen in iOS. We may see aggregated, anonymised crash information through Apple's developer tools. This does not identify you and does not contain anything you entered into the App.

Notifications. If you enable reminders, notifications are scheduled locally on your device. No notification content is sent through our servers or anyone else's.

4. What we do not do

We do not:

• Ask for or store your name, email address, phone number, or any other identifier
• Operate a server that receives your personal information
• Sell, rent, or trade personal information
• Show advertising, or share information with advertising networks
• Use tracking technologies to follow you across other apps or websites
• Build profiles about you for marketing purposes

The App does not request permission to track you as defined by Apple's App Tracking Transparency framework, because it does not track you.

5. The website

Our website at gettwenty.co is a static page. If you submit your email address to the mailing list form, that address is processed by our form provider and stored so we can send you occasional updates about TWENTY. You can ask us to delete it at any time by emailing support@gettwenty.co.

We do not run analytics, advertising pixels, or third-party tracking scripts on the website, and we do not set cookies for those purposes.

6. Health information

Some of what you enter into TWENTY concerns your health, including your drinking and, if you use the writing feature, your own words about difficult situations. We treat that as sensitive.

The protection we offer is architectural rather than procedural: that information is never transmitted to us, so it cannot be breached on our side, subpoenaed from us, or disclosed by us. It exists only on your device, protected by your device's own security.

TWENTY is not a healthcare provider and is not a covered entity under HIPAA. Nothing in the App is medical advice.

7. Your rights

Because we do not hold your personal information, most data-protection rights are exercised directly on your device rather than through us.

• Access: everything the App holds about you is visible inside the App.
• Deletion: use "Reset all data" in Settings, or delete the App.
• Portability: we do not currently offer an export. If you want one, tell us at support@gettwenty.co.

If you are in the European Economic Area, the United Kingdom, or a US state with a comprehensive privacy law such as California, you have rights over personal information that a business holds about you. The only personal information we may hold is an email address you gave us voluntarily on the website, and the pseudonymous subscription record held by RevenueCat. To exercise any right over those, email support@gettwenty.co.

We will not discriminate against you for exercising any privacy right.

8. Children

TWENTY is not intended for anyone under 18. It is rated accordingly on the App Store. We do not knowingly collect information from children. If you believe a minor has used the App, contact us at support@gettwenty.co.

9. International use

Noles Technology Inc. is based in the United States. Because your App data stays on your device, using TWENTY outside the United States does not involve transferring that data to us. Information handled by RevenueCat and Apple may be processed in the United States and elsewhere, subject to their own policies.

10. Changes

If we change this policy, we will update the date at the top and post the new version at gettwenty.co/privacy. If a change materially affects how information is handled, we will make that clear in the App.

11. Contact

Noles Technology Inc.
support@gettwenty.co