Privacy Policy

Effective October 6, 2026

This policy explains what information the Twirl: Questions & Party Game app for iPhone and iPad ("Twirl" or "the app") and the website twirlcards.com ("the website") handle, why, and the choices you have. Twirl is run by Nomad Tracker LLC, 1209 Mountain Road Pl NE, Ste N, Albuquerque, NM 87110, United States ("we", "us"). If you have any question, write to [email protected].

1. Information that stays on your device

Twirl does not have its own servers for the game. Everything you create while playing is stored only on your device, in the app's local storage, and is never sent to us:

• the names of the players you add for Hot seat, and the colors you pick for them;
• your progress in each deck, the cards you mark as "Love it" or "Nah", and your own decks built from them;
• your settings, such as sound, music, the deck filter, the game mode and your answers to the first launch quiz.

Deleting the app deletes all of this. You can also reset your decks from the app's settings. If your device backs up apps to iCloud or to a computer, this data may be included in that backup, which is handled by Apple under your own settings.

2. Purchases and subscriptions

Purchases are processed by Apple through the App Store. We never see or store your payment card or your Apple Account details. To unlock Premium on your device and to restore purchases, the app usesRevenueCat, a subscription service. RevenueCat receives:

• an anonymous app user ID that RevenueCat creates for your install (it is not linked to your name or email);
• your purchase history from Apple: which product you bought, when, the price, currency, trials and renewals;
• basic device and app information, such as the iOS version, app version, country and language.

We use this to give you access to what you paid for, to restore purchases and to understand how subscriptions perform.

3. Analytics

To understand which decks and features people enjoy and where the app can get better, Twirl sends usage events toAmplitude, a product analytics service. For example: the app was opened, a deck was opened, how many cards a game lasted, the paywall was shown or a purchase was completed. Along with the events, Amplitude receives:

• a random identifier for your install, not linked to your name, email or Apple Account;
• device and app information, such as the device model, iOS version, app version, language and time zone;
• an approximate country that Amplitude may estimate when the events arrive. Twirl asks Amplitude not to store your IP address, city or region.

Analytics never include what you type, such as player names. Twirl does not use the advertising identifier (IDFA), does not track you across apps or websites owned by other companies, does not ask for permission to track, and does not show ads. We do not sell or share your information for advertising.

You can turn analytics off at any time in the app: tap Twirly in the library to open settings, then switch offShare usage stats.

4. Other features

Question of the day widget

The widget shows a card from the decks that come inside the app. It does not connect to the internet or read any of your other data.

Sharing a card

When you share a card, the app draws the image on your device and opens the iOS share sheet. Nothing is sent to us. Whatever app you choose to share with handles the image under its own privacy policy.

Ratings

When the app asks for a rating, it uses Apple's standard rating prompt. Your rating and review go to Apple, not to us.

5. The website

The website has no cookies, no analytics and no third party trackers. It is hosted on Cloudflare, which processes technical data such as IP addresses to deliver the pages and protect them from abuse.

6. Why we use your information

• To provide what you bought (purchase records through RevenueCat): needed to perform our agreement with you.
• To improve the app and keep it working (anonymous analytics, website security): our legitimate interest in making a better app, with data that does not identify you directly.

7. Who processes your information

We only share information with the service providers named above, who process it on our behalf: Apple (App Store purchases), RevenueCat (subscriptions), Amplitude (analytics) and Cloudflare (website hosting). Some of them are based in the United States or process data in other countries. Where the law requires it, these transfers are covered by appropriate safeguards such as the European Commission's standard contractual clauses. We may also disclose information if the law requires it.

8. How long we keep it

• Game data on your device: until you reset it or delete the app.
• Purchase records: as long as needed to provide your purchases and to meet tax and accounting obligations.
• Analytics data: only as long as it is useful to improve the app, after which it is deleted or aggregated.

9. Your rights and choices

Depending on where you live, you may have the right to access, correct, delete or export your personal information, to object to or restrict how it is used, and to withdraw consent. To use any of these rights, email[email protected]. Because the app has no accounts and its analytics and purchase records are anonymous, we may not be able to link them to you, but we will do everything we reasonably can. You can manage or cancel subscriptions in your Apple Account settings. If you are in the European Economic Area, the United Kingdom or Switzerland, you can also complain to your local data protection authority. We do not sell personal information and do not share it for cross context behavioral advertising, as those terms are used in California law.

10. Children

Twirl is rated 16+ on the App Store because some decks include flirty and mature themes. It is not directed to children under 13, and we do not knowingly collect personal information from children under 13. If you believe a child has given us personal information, contact us and we will delete it.

11. Security

We keep the information we handle to a minimum, use providers with strong security practices, and send data over encrypted connections. No system is perfectly secure, but we will tell you and the authorities when the law requires it if something goes wrong.

12. Changes to this policy

If we change how Twirl handles information, we will update this page and its effective date. If a change is significant, we will also mention it in the app or on the website before it applies.

13. Contact

Nomad Tracker LLC
1209 Mountain Road Pl NE, Ste N, Albuquerque, NM 87110, United States
[email protected]