At TwistApps, operated by SENTEIN Clément EI, we place the utmost importance on protecting your personal data. This Privacy Policy explains what data we collect through our mobile applications available on the iOS App Store (Meme Box, PromptCam, and any future applications), how we use it, and what your rights are regarding this data.
The data controller is:
SENTEIN Clément EI
24 Rue Jean-Baptiste Lapègue, 40990 Saint-Paul-Lès-Dax, France
Email: senteinclement@gmail.com
For more details, see our Legal Notices.
We collect the following types of data:
- Usage Data: Information about how you use our applications (e.g., frequency of use, interactions with sounds in Meme Box, recordings in PromptCam), collected anonymously or in aggregated form.
- Advertising Identifiers: A unique device identifier (IDFA on iOS) for delivering personalized ads via Google AdMob.
- Technical Data: Device type, iOS version, IP address, error logs, to ensure the applications function properly.
- Content Data (PromptCam): Texts entered and videos recorded, stored locally on your device unless you choose to share them.
- Personal Data (if in-app purchases): Transaction-related information via the App Store (e.g., Apple ID), but no banking details are stored by TwistApps.
We do not collect sensitive personal data (e.g., name, email) unless you provide it voluntarily (e.g., via an email to our support).
Your data is used to:
- Provide and maintain the applications’ features (e.g., playing sounds in Meme Box, recording videos in PromptCam).
- Deliver advertisements via Google AdMob to fund the free applications.
- Improve our services by analyzing anonymized usage data (e.g., identifying the most popular sounds).
- Manage potential in-app purchases or premium services via the App Store.
- Respond to your support requests sent to senteinclement@gmail.com.
We do not use your data for marketing purposes without your explicit consent.
The processing of your data is based on:
- Your Consent: For advertising identifiers (subject to consent via Apple’s App Tracking Transparency - ATT framework).
- Contract Performance: To provide the applications’ services (e.g., access to sounds, recordings).
- Legitimate Interest: To improve our applications and ensure their security.
- Legal Obligation: To comply with accounting or judicial requirements.
Your data may be shared with:
- Google AdMob: For delivering personalized ads, in accordance with their privacy policies (see here).
- Apple: For processing downloads and potential in-app purchases via the App Store.
- Legal Authorities: If required by law or a court order.
No other third parties have access to your data unless necessary for technical reasons (e.g., secure hosting) or with your explicit consent.
- Usage and Technical Data: Kept for a maximum of 12 months, then anonymized or deleted.
- Advertising Identifiers: Retained as long as you use the application and until you reset your IDFA.
- Content Data (PromptCam): Stored only on your device unless you export it voluntarily.
- Transaction Data: Retained as required by law (10 years for accounting purposes in France).
Upon your request or after uninstalling the application, data associated with your device is deleted within a reasonable timeframe, unless legally required otherwise.
Our applications do not directly use cookies, but Google AdMob may use similar technologies (e.g., advertising identifiers) to serve ads. You can manage your ad preferences via your iOS device settings (Settings > Privacy > Advertising) or reset your IDFA.
The twistapps.com website may use analytical cookies to track traffic, with prior consent via a dedicated banner.
We implement measures to protect your data, such as:
- Encryption of communications (SSL/TLS) for interactions with our servers.
- Secure storage of technical data via a trusted host.
- Avoidance of unnecessary collection of sensitive personal data.
However, no internet transmission is entirely foolproof; we cannot guarantee absolute security against unpredictable external attacks.
Under the GDPR, you have the following rights:
- Right of Access: View the data we hold about you.
- Right to Rectification: Correct inaccurate data.
- Right to Erasure: Delete your data (except where legally required).
- Right to Restriction: Limit certain processing activities.
- Right to Portability: Retrieve your data in a readable format.
- Right to Object: Refuse the use of your data for advertising purposes.
To exercise these rights, contact us at senteinclement@gmail.com. We will respond within one month, extendable to three months in complex cases.
We may update this policy to reflect changes in our applications, applicable laws, or advertising practices. Users will be notified via in-app notifications or on twistapps.com. The update date is indicated below.
For any questions or requests regarding your personal data, contact:
SENTEIN Clément EI
24 Rue Jean-Baptiste Lapègue, 40990 Saint-Paul-Lès-Dax, France
Email: senteinclement@gmail.com
Last updated: March 27, 2025