Privacy Policy
Effective Date: Aug. 31 , 2025
Welcome to the TWT (hereinafter referred to as "this Platform" or "we"). TWT is registered and operated by TWT.com inc. To provide you with more accurate services and a safer network environment, we may collect and process your relevant data during your use of our services. Your trust is very important to us, and we fully understand the importance of user data security. We will take security protection measures in accordance with the Cybersecurity Act 2018, Personal Data Protection Act 2012 (PDPA), the Computer Misuse Act, the Technical Guidelines on Data Protection by Design for ICT Systems of Singapore, as well as other applicable laws, regulations, policies, and technical standards, to protect your personal data.
Accordingly, this Platform has formulated this Privacy Policy (hereinafter referred to as "this Policy" or "this Privacy Policy") to confirm with you how we collect, use, store, disclose, and protect your personal data during your use of this Platform and its related services.
We hereby remind you: Before registering to use this Platform, please read and fully understand these Terms carefully, particularly the clauses in bold or bold underlined text, which you should focus on to ensure comprehension. By confirming your understanding and agreement, you may proceed to register and use this Platform and its services. If you disagree with any content herein, please immediately cease registration and use of this Platform and its services (especially those involving transactional interactions). Otherwise, your registration and use of this Platform shall constitute your full reading, understanding, and agreement to our collection, storage, use, and protection of your relevant data in accordance with these Terms.
Special Reminder: This Privacy Policy shall take effect on the date of publication and shall remain effective unless we adjust and publish a new privacy policy according to relevant legal norms and platform operations.
This Privacy Policy will help you understand the following:
I. Scope of Application
II. How We Collect and Use Your Personal Data
III. How We Use Cookies and Similar Technologies
IV. How We Share, Transfer, and Disclose Your Personal Data
V. How You Delete Your Data and Deactivate Account
VI. How We Store and Protect Your Personal Data
VII. How We Handle the Personal Data of Minors
VIII. Special Declarations (Important Clauses, Please Read Carefully)
IX. Notifications and Amendments
X. How to Contact Us
I. Scope of Application
1.1 This Policy applies to all products and services provided by TWT.com inc. Your access to or use of our Platform, the products and services offered by our Platform, and your access to or use of our Platform’s websites, shall all be governed by these Terms. If our or affiliated companies’ products or services utilize the products or services provided by this Platform but do not have independent personal data protection policies, these Terms shall also apply to such products or services. If the aforementioned products or services have separately established personal data protection policies, such policies shall apply.
1.2 If you have any questions, comments, or suggestions regarding this provision or any related matters, you may contact us at any time via our official email address: support@twt.com.
II. How We Collect and Use Your Personal Data
2.1 Definition and Scope of Personal Data
2.1.1 Personal data refers to various types of data recorded electronically or otherwise that can identify a specific natural person individually or in combination with other data, or reflect the activities of a specific natural person. Such data includes but is not limited to the full name, national identity card number or passport number, photo or video images, personal mobile phone number, email address, residential address, communication records and content, account and password, property and credit data, and transaction records.
Moreover, the Personal Data Protection Commission (PDPC) of Singapore considers that certain personal data, if leaked or misused, may cause significant harm or adverse impact to individuals and should be subject to a higher standard of protection, referred to as "sensitive personal data." Such data includes but is not limited to health and medical data, financial and banking privacy, biometric data such as fingerprints, facial recognition, iris scans, personal data of children under the age of thirteen(13), sexual orientation, religious and political views, among others.
2.1.2 Personal data referred to in this Privacy Policy includes (with bolded parts referring to sensitive personal data):
(1) Account data: email address, username/nickname, login password, verification code;
(2) User Network Identifiers (including UID);
(3) Payment data: transaction and order records, payment account data, the last four digits of the credit card number, and encrypted storage of bank card data or other payment details (excluding the full bank card number);
(4) Device and Browsing data: device type (mobile/PC/tablet), browser and system data, language preferences, time zone, referring URLs, access date and time, mobile device manufacturer and mobile network data;
(5) Log and Application Usage data: including IP address, login/operation/click/scroll records, accessed features, access times and frequency, generated errors, performance data, storage used, user settings and configurations, as well as the device and its location used to access the platform;
(6) Communication and Interaction data: correspondence by email, chat records with customer support, problem descriptions and data required for verification, as well as the recorded and analyzed content of your interactions with TWT;
(7) Federated Authentication Service data: when you choose to log in to the TWT platform using a federated authentication service provider such as Apple or Google, such providers will verify your identity and allow you to share certain personal data with us (e.g., your email address).
2.2 We Collect and Use Your Personal Data Only for the Following Purposes:
The primary purpose of collecting your personal data is to enable you to use the platform services more easily and satisfactorily. You are required to authorize us to collect and use your personal data in circumstances where it is necessary to provide you with our core business functions and additional features. The core functions include those essential for TWT to provide its services, to operate and ensure the security of transactions, and for security and risk control purposes.We may collect and use the following data related to you to achieve these functions. If you do not provide such data, you will not be able to enjoy our core services. This mainly includes becoming a user and using our technical services:
2.2.1 Account Registration, Login, and Deletion
When registering a TWT account, you are required to provide basic registration data, including your email address, username, and login password. We will verify your identity by sending a verification code to your email to ensure the security and validity of the registration process. You may also choose to log in to the TWT platform using supported third-party identity authentication services. In such cases, the relevant service providers will verify your identity and, with your consent, share necessary personal data with us (such as your email address) to complete the login process.
If you request to delete your account, you must submit your application via the official platform email support@twt.com. We will process your deletion request based on your application and the outcome of identity verification. Your bound email address is not only essential for registration and verification, but also serves as a primary channel for us to communicate with you, including sending business notifications and important service-related data.
2.2.2 Payment and Settlement Functions
When you make a payment, you may select the payment services provided by our affiliates or third-party payment institutions. The payment function itself does not collect your personal data, but we need to share your order number and transaction amount data (sensitive personal data) with these payment institutions to confirm your payment instructions and complete the transaction.Unless necessary for settlement and regulatory retention purposes, we do not store full payment card numbers, CVV, or other authentication elements that are directly processed by the payment institutions.
2.2.3 Customer Support and Information Communication
We will provide you with data related to the products and services you subscribe to—such as subscription messages, renewal reminders, service updates, and important announcements—via the message center and your contact details (e.g., email). In addition, when suspicious activities are detected (such as abnormal logins or access attempts from unusual locations), we may send you security alerts to safeguard your account. Communications between you and us (including emails, customer support dialogues, and problem descriptions) will be recorded and analyzed for the purposes of resolving your issues, handling disputes, improving service quality, and, where necessary, for identity verification and compliance record-keeping.
2.2.4 Product Improvement and Personalized Experience
To optimize our products and services, we analyze your use of the platform based on device and browsing data, log data, and application usage data. This enables us to improve performance and compatibility, enhance interface display, troubleshoot problems, and achieve continuous optimization. We may also process de-identified or aggregated data to conduct usage statistics and trend analysis; where applicable, such data may also be used for advertising attribution, channel effectiveness evaluation, and personalized recommendations, in order to provide you with a service experience better tailored to your needs.
2.2.5 Security Assurance and Compliance Risk Control
To maintain the security of the platform and its users, we will utilize the collected data to conduct risk control and compliance management. This includes monitoring and preventing fraudulent transactions, spam, and other illegal activities; identifying and responding to potential risks such as abnormal logins, frequent operations, and suspicious transactions; ensuring the security of payment and transaction processes; and, where necessary, fulfilling data retention and data reporting obligations in accordance with applicable laws, regulations, or regulatory requirements.
2.2.6 Other Authorized Uses
In addition to the purposes stated above, we may collect and use your personal data within the scope of your separate consent or authorization, in order to provide you with additional services or functionalities.
2.3 Circumstances where collection/use of personal data does not require prior consent:
① Necessary to safeguard Singapore’s national interests, including defense, national security, and public safety.
② Required to comply with investigations/litigation or legal obligations.
③ Necessary for public interests, such as health, arts, literature, or news reporting.
④ Necessary to protect vital individual interests (e.g., emergencies affecting health/safety, contacting next of kin).
⑤ Necessary to fulfill a contract with the individual.
⑥ Personal data obtained from public sources or already lawfully disclosed.
⑦ Other circumstances prescribed by law.
2.4 Methods of Data Use
We collect and use your data for the purpose of providing services to you and continuously enhancing the quality of such services. To achieve this purpose, your data may be used for the following purposes. Should it become necessary to use your data for a new purpose not specified in this Policy, to expand the scope of use, or to change the method of transmission, we will promptly notify you through in-app pop-up notifications or other appropriate means, and obtain your explicit consent.
2.4.1 Ensuring Account and Transaction Security
In order to prevent, detect, and investigate fraud, infringement, security threats, unlawful activities, or conduct in violation of agreements, policies, or rules between you and us or our affiliates, and to safeguard the legitimate rights and interests of you, other users, the public, and us or our affiliates, we may use or integrate your account data, service usage data, device and log data, as well as data lawfully shared by affiliates or partners with your authorization. Such data will be applied to comprehensively assess account and transaction risks, conduct identity verification, detect and prevent security incidents, and, in accordance with applicable law, undertake necessary recording, auditing, analysis, and remedial measures.
2.4.2 Integration of Third-Party Services
To ensure the implementation of relevant functionalities and the stable operation of the platform, we may integrate software development kits (SDKs), plug-ins, mini-programs, or other similar applications provided by third parties. Depending on business needs, such third parties may request or utilize certain operating system permissions (such as device identifiers, storage access, etc.). We will conduct strict security testing and assessments of the integrated third-party services to ensure data security and to effectively safeguard your lawful rights and interests.
2.4.3 Permission Usage and Disclosure of Use
For the normal operation of the platform and the provision of its functions, we may request or utilize certain operating system permissions. The types and purposes of such requested or utilized permissions may change due to product version upgrades. We will promptly notify you of any adjustments through appropriate means (such as in-app notifications or update statements) so that you are informed of the status of permission usage. Where you enable such permissions, the platform will collect relevant data only within the lawful, legitimate, and necessary scope. If you choose not to enable certain permissions, you may be unable to use the specific functions associated with such permissions; however, this will not affect your use of other services provided by the platform.
III. How We Use Cookies and Similar Technologies
3.1 Use of Cookies
To ensure the proper operation and security of the website, we may employ cookies or similar technologies on your device (such as local storage, pixel tags, or web beacons). Their primary purposes include maintaining login status, completing CAPTCHA verification, providing basic functionalities, and ensuring security protection.
3.2 Management
The platform does not currently provide in-site cookie management; you may manage or delete cookies, site data, or tracking permissions through your browser or device settings (such as blocking third-party cookies or clearing site data). Disabling or deleting such technologies may result in partial functionality being unavailable or a diminished user experience.
3.3 Links and Email Interactions
We may include links to the platform’s content in notifications or emails; when you click such links, we may record the click and the page accessed for the purposes of service improvement and security auditing.
3.4 Third-Party Tracking
Unless otherwise notified on the page and with your consent, we do not use third-party advertising cookies based on personal profiling. Should we introduce such cookies in the future, we will provide prior notice and options for you to choose.
IV. How We Share, Transfer, or Disclose Your Personal Data
4.1 Sharing
4.1.1 We will not share your personal data with any company, organization, or individual other than the operating entity of the TWT platform, except in the following cases:
(1) Sharing with explicit consent: After obtaining your explicit consent, we will share your user data with other parties:
Sharing with affiliated companies and/or authorized partners: We may entrust trusted partners to provide services, so we may share some of your user data with partners to provide better customer service and optimize the user experience. We will only share your user data for legitimate, proper, necessary, specific, and clear purposes, and only share the user data necessary to provide services. Our partners have no right to use the shared user data for any other purpose. You agree that the TWT may share personal data with the following third parties:
a. We may share your personal data with partners that support our functions. Such support includes service partners providing settlement services for us. The purpose of sharing this data is to enable the core functions of our products and/or services, for example, sharing your username and email address with partners in order to facilitate transactions and ensure the proper completion of settlement services.
b. To comply with laws, enforce or apply our terms of use and other agreements, or to protect the rights, property, and safety of the platform, you, or other users, such as exchanging data with other companies and organizations to prevent fraudulent activities and reduce credit risks. However, this does not include the sale, rental, sharing, or other disclosure of personal data for profit-making purposes in violation of the commitments made in this privacy policy.
(2) Sharing in statutory circumstances: We may share your user data externally in accordance with legal norms, litigation, or arbitration resolution needs, or as required by administrative or judicial authorities according to law.
4.1.2 For companies, organizations, and individuals with whom we share user data, we shall take reasonable steps to ensure that the recipients provide a level of data protection comparable to the standards under the PDPA. We shall also enter into strict confidentiality agreements and data protection undertakings with them, requiring them to process user data in accordance with our instructions, this Privacy Policy, and any other applicable confidentiality and security measures.
4.2 Transfer
We will not transfer your personal data to any company, organization, or individual, except in the following cases:
(1) Transfer with explicit consent: After obtaining your explicit consent, we will transfer your user data to other parties.
(2) In the event of a merger, acquisition, or bankruptcy liquidation of the TWT platform operating entity with other legal entities, or other circumstances involving mergers, acquisitions, or bankruptcy liquidation, if user data transfer is involved, we will require the new holder of your user data to continue to be bound by this terms; otherwise, we will require such company, organization, or individual to re-solicit your authorization and consent.
4.3 Disclosure
We will only disclose your personal data in the following cases:
(1) With your explicit consent or based on your active choice, we may publicly disclose your user data.
(2) In cases where we are required to provide your personal data by legal norms, mandatory administrative law enforcement, or judicial requirements, we may disclose your personal data in the required personal data type and disclosure method. Under the premise of complying with legal norms, when we receive the above requests to disclose personal data, we will require the recipient to issue corresponding legal documents, such as court summonses or investigation letters. We believe that the personal data required to be provided by us should be kept as transparent as possible within the scope permitted by law. We carefully review all requests to ensure that they have a legal basis and are limited to data that law enforcement agencies are lawfully entitled to obtain for specific investigation purposes.
4.4 Exceptions to Prior Authorization and Consent for Sharing, Transferring, and Disclosing Personal Data
The following are situations where sharing, transferring, or disclosing your personal data does not require prior authorization and consent:
① Necessary to safeguard Singapore’s national interests, including defense, national security, and public safety.
② Required to comply with investigations/litigation or legal obligations.
③ Necessary for public interests, such as health, arts, literature, or news reporting.
④ Necessary to protect vital individual interests (e.g., emergencies affecting health/safety, contacting next of kin).
⑤ Necessary to fulfill a contract with the individual.
⑥ Personal data obtained from public sources or already lawfully disclosed.
⑦ Other circumstances prescribed by law.
According to legal regulations, sharing or transferring de-identified personal data and ensuring that the data recipient cannot restore and re-identify the personal data subject does not constitute external sharing, transferring, or publicly disclosing personal data, and the storage and processing of such data will not require separate notification to you or your consent.
V. How You Delete Your Data and Deactivate Account
In accordance with the applicable laws and standards of Singapore, as well as the prevailing practices of other countries and regions, we respect and safeguard your right to request the deletion of your personal data. Upon receipt of your written request, we will review and respond within fifteen (15) business days:
5.1 In the following situations, you may request the deletion of personal data from our platform customer service:
① Where our processing of personal data violates applicable laws or regulations.
② Where we collect or use your personal data without obtaining your authorization or consent.
③ Where our processing of personal data materially breaches our agreement with you.
5.2 Account Cancellation
If you decide to cease using TWT, you may request cancellation by submitting an application to the official platform email address at support@twt.com. To facilitate our verification and processing, you are required to include in your application email the email address bound to your account, the username used at registration, and a brief explanation of the reason for requesting account cancellation.
Please be aware and acknowledge that account cancellation is an irreversible action. Once cancellation is completed, we will immediately cease providing you with services and will delete or anonymize all personal data associated with your account, unless otherwise required by applicable laws and regulations.
VI. How We Store and Protect Your Personal Data
6.1 Storage of Your Personal Data
We retain your personal data only for the period necessary to fulfill the purposes outlined in this Privacy Policy and as required by applicable laws and regulations. If we terminate services or operations, we will promptly cease collecting your personal data and notify you in advance as mandated by law. If you delete your account or request data deletion, we will retain your existing personal data for the minimum period required by law, after which it will be deleted or anonymized, unless otherwise stipulated by law.
6.2 We attach great importance to personal data security, have established a dedicated network security team, and take all reasonable and feasible measures to protect your personal data:
6.2.1 Data Security Technical Measures
We will adopt security protection measures in line with industry standards, including establishing reasonable rules and regulations and security technologies to prevent your personal data from being accessed, used, or modified without authorization and to avoid data damage or loss. A strict data access authority level system is adopted to protect personal data and avoid illegal use of data.
6.2.2 Other Security Measures We Take to Protect Personal Data
①We manage and standardize the storage and use of personal data by establishing a data access authority level system and a data security management system.
②We comprehensively control data security by signing confidentiality agreements with personal data contacts.
③We also conduct security and privacy protection training to strengthen employees' awareness of the importance of protecting personal data and security awareness.
④We only allow employees of us and our affiliated companies and partners who need to know this personal data to access your personal data and have set up a strict data access authority level mechanism for this purpose. We also require all personnel who may come into contact with your personal data to fulfill corresponding confidentiality obligations. Those who fail to fulfill these obligations may be held legally responsible or have their cooperation with us terminated.
The Internet is not an absolutely secure environment, and communication methods with other users such as email, instant messaging, and social software cannot be determined to be fully encrypted. We recommend that you use complex passwords when using such tools and pay attention to protecting your personal data security. You must bear the obligation to keep your account and password data confidential. In any case, please carefully and properly keep them.
We will make every effort to ensure or guarantee the security of any personal data you send to us.
6.3 Cross - Border Transmission of Personal Data
To better provide services to you, our commercial operation or technical support partners may be located in regions other than the location of the TWT network server. Therefore, in some cases, your personal data may be transmitted overseas. We are well aware of the importance of your personal data security, so we will take strict measures to ensure its security and compliance when transmitting your personal data overseas.
We promise that when your personal data is transmitted overseas, we will ensure that it is protected at least at the same standard as in Singapore. To this end, we will sign legally binding agreements with data recipients to clarify the responsibilities and obligations of both parties in data protection. These agreements will cover the purpose, scope, security measures, and rights of data subjects of data transmission to ensure that your personal data is fully protected during cross - border transmission.
6.4 Handling of Security Incidents
6.4.1 In the unfortunate event of a personal data security incident, we will, in accordance with the requirements of legal norms, promptly inform you of: the basic situation and possible impact of the security incident, the disposal measures we have taken or will take, your suggestions for independent prevention and risk reduction, and remedial measures for you, etc. We will also promptly inform you of the relevant situation of the incident by telephone, in - station notification, push notification, and other means. When it is difficult to inform individual data subjects one by one, we will issue a public announcement in a reasonable and effective manner. At the same time, we will also take the initiative to report the disposal situation of personal data security incidents to regulatory authorities as required.
6.4.2 If you have any questions about our personal data protection, you may contact us at support@twt.com. If you find that your personal data has been leaked, especially if your account and password have been leaked, please immediately contact us through the contact data provided in this terms so that we can take corresponding measures.
VII. How We Handle the Personal Data of Minors
7.1 We attach great importance to the protection of minors' personal data. Please be aware that this platform does not provide products, websites, and services to minors under the age of eighteen(18). According to commercial practices, in general, a user's age will be assessed based on the data submitted by the user or other reasonable basis (such as browsing and search records). However, we acknowledge that such assessment is not absolutely accurate. Therefore, we encourage all users (especially users who may be regarded as minors) to be cautious when providing personal data.
7.2 If, upon assessment, we determine that you are a minor under the age of eighteen (18), we will immediately cease providing you with the products or services of this platform and will delete any data already collected that may identify you, unless otherwise required by applicable laws or regulations.
7.3 Before you start using this product, website, and services, you should ensure by yourself that you have the civil capacity appropriate to your conduct as required by the laws and regulations of the Republic of Singapore. If you do not have the above - mentioned civil capacity appropriate to your conduct, you and your guardian shall bear all consequences and responsibilities arising therefrom.
VIII. Special Declarations (Important Terms, Please Read Carefully)
8.1 Please be sure to carefully read and fully understand the entire content of this privacy policy, especially the clauses closely related to your rights and interests. When you access or use this service, it is deemed that you have agreed to all the clauses of this privacy policy and authorized us to collect, use, and disclose your personal data in accordance with the provisions of this policy. If you do not agree with any clause of this privacy policy, please do not continue to access or use this service.
8.2 This privacy policy constitutes a legally binding agreement between you and us. You need to agree to this privacy policy at the same time as accepting the "Terms of Service" before you can use our services.
8.3 Please understand that the Internet is not an absolutely secure environment. Communication methods with other users such as email, instant messaging, social platforms, and transaction platforms cannot be determined to be fully encrypted. Please pay attention to protecting the security of your personal data when using them during interaction.
8.4 Please understand that due to the rapid development of computer and internet technology and the limitation of synchronization speed, various malicious or non-malicious attack methods may exist or emerge. Although we continue to commit to enhancing and strengthening security measures to protect your personal data from accidental or damage, we still cannot always guarantee the absolute security of your personal data.
8.5 Please understand that we cannot control the systems, communication networks, or hardware devices you use when using the product or service. Please understand and pay attention to protecting the security of your personal data. Unless otherwise specified in this privacy policy, to protect your account security, we specially remind you not to provide your property status, account password, or verification code data to us or any third party providing services to you in our name through a public network.
IX. Notifications and Amendments
To provide you with better services and with the development of our business, this privacy policy will also be updated. However, we will not reduce your rights under this privacy policy without your explicit consent. For major changes, we will also provide more prominent notification methods to remind you, and please visit us to learn about the latest privacy policy. Your continued use of the platform after the privacy policy is updated will be deemed as acceptance of the new version of the privacy policy. The major changes referred to in this clause include but are not limited to:
(1) Major changes in our service model, such as the purpose of processing personal data, the type of personal data processed, and the way of using personal data;
(2) Major changes in our ownership structure and organizational structure, such as changes in ownership caused by business adjustments, bankruptcy, or mergers and acquisitions;
(3) Major changes in the main objects of personal data sharing, transfer, or public disclosure;
(4) Major changes in your rights and ways of exercising them in personal data processing;
(5) Changes in the responsible department, contact data, and complaint channels for personal data security;
(6) When a personal data security impact assessment report indicates a high risk.
X. Contact Us
If you have any complaints or reports regarding the security of your personal data, or if you have any questions, comments, or suggestions concerning this Privacy Policy, matters relating to your personal data, or the privacy measures of the Platform, you may contact us at support@twt.com. We will review the relevant matters as soon as possible and, upon verifying your user identity, respond to your inquiries, complaints, or suggestions within fifteen (15) business days.