This Privacy Policy describes how ACORN INC. ("Company," "we," "us," or "our") collects, uses, and handles information in connection with the TwigSNS platform ("Service"). By using the Service, you acknowledge that you have read and understood this Privacy Policy. We reserve the right to update this Policy at our sole discretion; continued use of the Service following notice of any changes constitutes acceptance of the revised Policy.
We collect only the minimum data required for authentication through supported third-party identity providers, including Google, Apple, and Kakao. Depending on the provider and the user's privacy settings, this may include an email address or an anonymized identifier. We do not collect your name, phone number, date of birth, or any other personal identifiers not expressly provided by the authentication provider.
We collect and store the following data generated through your use of the Service:
If you choose to withdraw $TWIG tokens to an external wallet, you voluntarily provide a Solana-compatible wallet address. This address is collected solely upon your initiation of a withdrawal request and is not linked to your authentication identity.
With your explicit permission, the Service may access step count data via HealthKit (iOS) or Health Connect (Android). This data is processed exclusively on your local device and is never transmitted to our servers. It is used solely in connection with DNA Card visualization features and is not used for any advertising or commercial purposes.
We may use the information we collect for the following purposes:
We may use your data for additional purposes that are compatible with the above, including future service features, without further notice, except where required by applicable law.
All health and physical activity data accessed through HealthKit or Health Connect is processed exclusively on your local device. This data is not transmitted to, stored on, or processed by the Company's servers at any time. You may revoke the Service's access to health data at any time through your device system settings without affecting your ability to access other features of the Service.
The Company's access to and use of health data is subject to the following restrictions:
The Company maintains an internal record of your accumulated in-app points and $TWIG token balance for the purpose of operating the platform reward system. This data is associated with your account and retained for the duration of your account's active status.
When you initiate a $TWIG token withdrawal, you voluntarily provide a Solana-compatible wallet address (e.g., Phantom). This address is:
Upon account deletion, your internal token balance and associated account data will be permanently removed. Wallet addresses retained as transaction records under Section 5.2 will continue to be held for the remainder of the applicable five-year retention period before permanent deletion.
If your provided wallet does not have an existing Associated Token Account (ATA) for $TWIG, the Company may create one on your behalf at the Company's expense prior to executing the token transfer. The wallet address used for this purpose is governed by Section 5.2 above.
All token transfers are recorded on the Solana blockchain, which is a public and immutable ledger. The Company has no control over the visibility or persistence of on-chain data. By initiating a withdrawal, you acknowledge that your wallet address and transaction details will be publicly accessible on the blockchain.
To process token transfers on the Solana network, the Company utilizes Helius (https://helius.dev) as its RPC node provider. Your wallet address may be transmitted to Helius solely for the purpose of executing blockchain transactions. Helius operates under its own privacy policy, available at https://helius.dev/privacy.
The following data is collected and processed as a condition of using the Service. If you do not consent to this processing, you will be unable to access the Service:
Survey responses are permanently attributed to your DNA Card profile upon submission and cannot be individually modified while your account remains active. Full deletion is available through account deletion.
The following data may be collected and used for advertising optimization purposes, subject to your consent. You may withdraw consent at any time through your account settings without affecting your ability to use the Service:
Withdrawal of consent under this Section will not affect the lawfulness of processing conducted prior to withdrawal.
All data described in this Section is aggregated and processed using reasonable measures to produce anonymized audience segments before being made available to third-party advertisers. The Company endeavors to ensure that such data cannot reasonably be used to identify any individual user; however, the Company makes no absolute warranty regarding the re-identification risk of anonymized data.
Advertisers receive only aggregated statistical data representing estimated audience reach within a given segment (e.g., "users with high activity and social engagement tendencies"). No individual user data, post content, or identity is shared with, sold to, or disclosed to any advertiser.
The Company uses automated analysis and artificial intelligence tools to process post content and survey responses for the purposes described in this Section. By using the Service, you acknowledge that such automated processing may occur. If you have questions about the logic, significance, or potential consequences of such automated processing, you may contact us at admin@twigsns.com.
Users who withdraw consent under Section 6.2 will continue to receive advertisements within the Service. Such advertisements will not be informed by post content analysis or activity timing data, but may be informed by anonymized survey-based segments under Section 6.1.
By posting content on the Service, you grant ACORN INC. the right to use, reproduce, and display your posts for the purpose of promoting the Service on third-party platforms, including but not limited to X (Twitter), Instagram, and Threads. Such use is limited to showcasing the nature and quality of content available on the Service and does not imply endorsement of any individual user.
Where you have set a display nickname, that nickname may appear alongside your content solely for attribution purposes. Users without a display nickname will have no identifying information attached to their promoted content.
Your content will not be materially altered in a manner that distorts its original meaning, and will not be used in conjunction with third-party paid advertising or commercial sponsorship.
If you do not wish your content to be used for promotional purposes as described in this Section, you may submit a request to admin@twigsns.com. The Company will endeavor to honor such requests within a reasonable timeframe.
The Company retains your data for the following periods, or as otherwise required by applicable law:
Accounts that have not been accessed for a period of one (1) year may be considered inactive at the Company's sole discretion. The Company will endeavor to notify you through your registered authentication channel prior to taking any action on an inactive account. The Company reserves the right to suspend or delete inactive accounts without further obligation.
When you delete a post, the original content is removed from public display within the Service. Analytical data derived from that post (including keyword extraction and sentiment analysis results) may be retained in a form that is dissociated from your account and integrated into anonymized aggregate datasets that cannot reasonably be linked back to you.
Upon account deletion:
Notwithstanding the above, the Company may retain data beyond the periods specified in this Section to the extent required by applicable law, regulatory authority, or for the purpose of establishing, exercising, or defending legal claims.
Subject to applicable law and the limitations set out in Section 9.2, you may have the following rights with respect to your personal data:
The exercise of the rights described in Section 9.1 is subject to the following limitations:
To exercise any rights described in this Section, please contact us at admin@twigsns.com. The Company will endeavor to respond to all requests within thirty (30) days of receipt. Where a request cannot be fulfilled, the Company will provide a written explanation.
If you believe your rights have been violated, you may lodge a complaint with the relevant data protection authority in your jurisdiction. In the Republic of Korea, this is the Personal Information Protection Commission (PIPC).
The Service is distributed through the Apple App Store and Google Play Store under the Social Networking category and complies with the age restrictions and parental consent requirements established by those platforms. Users must meet the minimum age requirements set by Apple and Google in their respective jurisdictions to access the Service.
Your personal data is currently stored and processed on servers located in the Republic of Korea (AWS Seoul Region, ap-northeast-2). No international transfer of your data is currently in effect.
As the Service expands, your data may in the future be transferred to and processed in countries other than your country of residence. In such cases, the Company will endeavor to ensure that appropriate safeguards are in place in accordance with applicable law. The Company will provide reasonable notice of material changes to data storage locations in accordance with Section 13.
In the event of a merger, acquisition, reorganization, asset sale, or similar transaction involving the Company, your data may be transferred to the successor entity as part of that transaction. The Company will endeavor to provide notice of such a transfer and ensure that the successor entity is bound by commitments at least as protective as those set out in this Policy. You acknowledge that the Company cannot guarantee that the terms of any transfer will mirror those of this Policy in every respect.
The Company reserves the right to modify this Privacy Policy at any time at its sole discretion. For material changes, the Company will endeavor to provide advance notice through the Service or via your registered authentication channel. Your continued use of the Service following the effective date of any revised Policy constitutes your acceptance of the changes. If you do not agree to any revised Policy, you must discontinue use of the Service before the effective date of such changes.
The Company implements industry-standard technical and organizational measures to protect your data against unauthorized access, loss, or disclosure. However, no method of transmission or storage is completely secure, and the Company cannot guarantee absolute security. In the event of a data breach affecting your personal data, the Company will endeavor to notify you and the relevant regulatory authority as required by applicable law.
The Service integrates with third-party providers including authentication services (Google, Apple, Kakao), cloud infrastructure (AWS), and blockchain infrastructure (Helius). These providers operate under their own privacy policies, and the Company is not responsible for their data practices. Your use of authentication services is subject to the respective provider's terms.
For questions, concerns, or requests regarding this Privacy Policy, please contact us at:
ACORN INC.
Email: admin@twigsns.com
Website: https://www.twigsns.com
Privacy Policy URL: https://www.twigsns.com/privacy/
Last updated: March 20, 2026