Twintro Privacy Policy

Last Updated: December 17, 2025

This Privacy Policy ("Policy") describes how Twintro, owned by Hoontos AI ("Twintro," "we,"

"us," or "our"), collects, uses, discloses, and protects personal information in connection with

our website and AI-driven service (collectively, the "Service"). By accessing or using the Service,

you acknowledge you have read and understood this Policy. This Policy is incorporated by

reference into our Terms of Service.

1. Scope

This Policy applies to information we collect when you access or use the Service, including when

you upload a resume/CV or other information for creation of a Digital Card and related outputs

("Outputs").

2. Definitions

 "Personal Information" means information that identifies, relates to, describes, is

reasonably capable of being associated with, or could reasonably be linked to an identified

or identifiable individual.

 "Sensitive Personal Information" has the meaning given under applicable law. Twintro does

not require Sensitive Personal Information to provide the Service.

 "User Content" means the resume/CV and any other information or materials you upload,

submit, or provide through the Service.

 "Outputs" means content generated by the Service from User Content, including Top Traits,

Synopsis, Key Competencies, and the Digital Card.

 "Third-Party Services" means third-party websites, platforms, or services that may be linked

from or integrated with the Service.

3. Information We Collect

3.1 Information You Provide

Depending on how you use the Service, you may provide:

 Resume/CV and Professional Details: employment history, education, skills, certifications,

and other professional information included in User Content.

 Contact Information: name, email address, phone number, and social/profile links you

provide (if any).

 Communications: messages you send to us (e.g., support requests).

If you are an employer or organization and you upload or submit information about candidates

or other individuals, you represent and warrant that you have provided any required notices

and obtained any required consents or other lawful basis to share that information with Twintro

for processing under this Policy.

3.2 Information Collected Automatically

We may automatically collect:

 Usage Data: pages viewed, features used, timestamps, clicks, and referring URLs.

 Device and Connection Data: IP address, browser type, operating system, device identifiers,

and approximate location derived from IP (where permitted).

 Diagnostics and Security Data: log files, crash reports, and performance metrics.

4. How We Use Your Information

4.1 Provide the Service and Generate Outputs

 Process User Content to generate Outputs (e.g., Top Traits, Synopsis, Key Competencies,

and the Digital Card).

 Operate, maintain, and support the Service (including customer support).

4.2 Operate, Secure, and Improve Service Functionality (No Model Training)

 Monitor performance, fix bugs, and improve reliability and user experience.

 Detect, prevent, and respond to fraud, abuse, and security incidents.

 Conduct analytics using aggregated or de-identified information where practicable.

We do not use User Content or Outputs to train AI models. We process User Content and

Outputs only to provide the Service, maintain and secure the Service, and comply with

applicable law.

4.3 Compliance and Enforcement

 Comply with legal obligations and lawful requests.

 Enforce our Terms and protect the rights, safety, and security of Twintro, our users, and

others.

4.4 Communications

 Send administrative messages (e.g., policy updates, security alerts).

 Respond to inquiries and provide support.

5. Sharing and Disclosure

We do not sell your Personal Information and we do not share Personal Information for cross-

context behavioral advertising.

We may share information only as follows:

5.1 Service Providers

We may share information with vendors that help us operate the Service (e.g., hosting, security,

analytics, customer support). They are contractually required to protect information and

process it only on our instructions.

5.2 Legal and Safety

We may disclose information to comply with law, respond to lawful requests, protect rights and

safety, and investigate or prevent fraud or abuse.

5.3 Business Transfers

If we are involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of

assets, information may be transferred as part of that transaction, subject to appropriate

safeguards.

6. Data Retention

We retain Personal Information only as long as necessary to provide and maintain the Service,

comply with legal obligations, resolve disputes, and enforce agreements. We may retain

aggregated or de-identified information longer where permitted by law.

7. Your Rights and Choices

Depending on where you live, you may have rights to access, correct, delete, or obtain a copy of

your Personal Information, and to object to or restrict certain processing. To exercise rights,

8. Automated Processing and AI

Twintro uses automated processing, including AI-based analysis, to generate Outputs from User

Content. Outputs are intended for informational and drafting purposes and do not replace user

review or independent verification.

If you are an employer or organization, you remain responsible for compliance with

employment, hiring, and anti-discrimination laws and for ensuring appropriate human oversight

of any decisions.

9. Security

We maintain reasonable administrative, technical, and physical safeguards designed to protect

information. However, no system is 100% secure.

10. Cookies and Tracking Technologies (No Ads)

We use cookies and similar technologies that are necessary to operate the Service and to

understand general usage (e.g., performance and reliability). We do not use cookies for targeted

advertising. Where required by law, we provide cookie controls.

11. Children’s Privacy

The Service is not directed to, and is not intended for, individuals under 18. We do not

knowingly collect Personal Information from individuals under 13. If we learn that we have

collected Personal Information from an individual under 13, we will delete it in accordance with

applicable law.

12. California Notices (if applicable)

Twintro does not sell Personal Information and does not share Personal Information for cross-

context behavioral advertising. California residents may request access, correction, or deletion

of Personal Information as permitted by law by contacting support@twintro.com.

13. Changes to This Policy

We may update this Policy from time to time. We will update the “Last Updated” date and,

where required, provide additional notice.

14. Contact Us

Email: support@twintro.com

Mailing Address: Hoontos AI, 2525 S. Jackson St, Denver, CO 80210, United States