Chapter One: Introduction and Legal Framework
This policy constitutes the official document governing the principles and standards for the collection, use, processing, and protection of personal data within the comprehensive digital ecosystem of the Twincoin Platform, which is exclusively owned and operated by Fratiro (Simple Limited Partnership), duly registered with the Ministry of Economy and Trade in Beirut under number 1028414, in its capacity as the entity legally and technically responsible for the operation and administration of all applications, systems, and digital services associated with the registered trademark Twinkey Twincoin No. 230003. This includes the Twincoin application dedicated to users, the Twincoin Business application dedicated to commercial partners, in addition to the digital infrastructure, servers, databases, and security systems associated therewith.
Through this policy, Twincoin aims to clarify how it handles personal data collected, processed, stored, or shared within the scope of its services, in accordance with the Lebanese laws in force, and in a manner that aligns with internationally recognized best practices in data protection, including the fundamental principles acknowledged in modern privacy protection legislation such as transparency, data minimization, integrity of processing, and commitment to using data for a clear and legitimate purpose. This policy also explains the rights granted to data subjects and the options available to them, in addition to the obligations borne by Twincoin to protect such data and preserve its confidentiality.
Twincoin affirms that the privacy of its users and commercial partners is an essential component of its value system, and that building a relationship based on trust requires a high level of transparency and clarity in how data is managed, particularly within a system based on rewards, loyalty, and redemption mechanisms that demand precision and sensitivity in handling personal data and digital transactions. Although Twincoin’s services rely on an internal, closed system in which digital currencies operate through non-monetary technical mechanisms, the provision of this service necessarily requires processing certain data that is essential for the effective operation of the platform, verification of users’ eligibility, enabling reward processes, and ensuring full transparency in all redemption stages and the announcement of results making this policy an integral part of the contractual relationship binding the user or commercial partner to the platform.
Your use of the platform whether through browsing, registration, downloading the applications, or interacting with any of the direct or indirect services constitutes an explicit and final acceptance of the content of this policy in all its provisions, and an acknowledgment that data processing shall be carried out in accordance with its terms. Continued use following any update published thereto shall constitute an implicit and binding acceptance of the amended version. Twincoin confirms that this policy complements and parallels the Terms and Conditions of Use and does not replace them, and together they form a unified legal framework governing all relationships within the platform, such that both are interpreted jointly to ensure the protection of rights and the achievement of full transparency in all matters related to personal data and the operations associated therewith.
Twincoin is committed to implementing advanced technical and administrative measures to protect data from unauthorized access, loss, or alteration, and works continuously to update these measures in line with technological developments and accepted information security standards. Twincoin may utilize external servers or service providers inside or outside Lebanon for data storage and processing, provided that they offer an adequate level of protection, without prejudice to Twincoin’s direct responsibility for any processing performed on its behalf. The platform acknowledges that all data collected or processed is subject to strict confidentiality and shall be used solely for purposes consistent with the nature of Twincoin’s services and within the limits necessary for its operation, enhancement, and the assurance of the integrity of its mechanisms.
Reading this chapter forms the basis for understanding how Twincoin handles data and serves as a prelude to the chapters that follow, which detail the types of data collected, the purposes for which it is used, the retention periods, the legal rights of users and commercial partners, and the mechanisms for protection, sharing, and disclosure. This includes the provisions governing the transparency required in announcing unit results and publishing the data of redeemers, based on obligations inherent to the nature of the system to guarantee fairness of experience and users’ trust.
Chapter Two: Scope of Application and Fundamental Definitions
The provisions of this policy apply to all personal data collected, processed, or stored by the Twincoin Platform within the framework of its digital services, whether such data relates to individual users registered in the Twincoin application, or data associated with commercial partners registered in the Twincoin Business application, in addition to data resulting from browsing, interaction, or communication through any of the platform’s interfaces or technical channels. The scope of this policy also encompasses any operations carried out through the applications, the website, the servers, the support systems, or any digital services connected to the operational ecosystem of Twincoin, regardless of the method of access or the type of device used.
A number of fundamental legal terms have been adopted to ensure clarity of meaning, and for the exclusive purpose of this policy, the following definitions shall apply: The term "Platform" or "Twincoin" refers to the digital ecosystem that includes the applications, systems, algorithms, databases, and intellectual property associated with the registered trademark Twinkey Twincoin, managed and operated by Fratiro (Simple Limited Partnership). The term "User" refers to any natural person who creates an account on the Twincoin application or uses its services, whether as a registered user or as a visitor. The term "Commercial Partner" refers to any legal entity or business operator approved within the Twincoin Business application for the purpose of providing offers and rewards to users. The expression "Personal Data" refers to any information that may lead to the identification of a person, whether directly or indirectly, such as name, phone number, email address, location data, usage history, or any data associated with activity within the platform.
These definitions form an essential part of understanding and interpreting this policy, and they shall be exclusively relied upon when applying the provisions related to data protection, provided that they are read and interpreted in conjunction with the applicable Terms of Use.
Chapter Three: Types of Data Collected and Methods of Collection
Twincoin collects a set of data necessary to operate its services, ensure the effectiveness of its systems, and enhance the user and commercial partner experience. This data is collected through multiple legitimate methods and within clear limits that correspond to the nature and purpose of the service. The primary data collected includes identity information provided by the user or commercial partner at the time of registration, such as full name, phone number, email address, date of birth, gender, and nationality, in addition to data related to the commercial activities of partners such as the legal name of the business, commercial address, official documents, and details of approved branches.
The platform also collects automated technical data related to how services are used, including IP address, type of device used, operating system, browser settings, mobile device identifiers, and details regarding login and logout activity within the application. In addition, it collects geographic location data, which is used only when the required permission is granted, for the purpose of providing suitable offers to the user based on their geographic area. The collected data also includes interaction records within the platform, such as purchased offers, earned and spent currencies, units participated in, referrals, friend requests, gift box exchanges, and social activities linked to the system.
Twincoin may also collect additional data when necessary, such as personal preferences, interests, or notes voluntarily provided by the user during communication or through support systems, as well as data related to the images of winners or redeemers that are provided or captured within the transparency framework of the system. This data is obtained through information provided directly by the user or commercial partner, data generated through the use of the application or system, and data automatically recorded by permitted tracking technologies such as cookies and similar tools, all within the limits set out in this policy.
Chapter Four: Purposes of Data Use and Standards of Processing
Twincoin processes personal data within a clear and legitimate scope that aligns with the nature of the services provided, and the use of such data is limited to the purposes necessary for operating the platform, ensuring the integrity of its systems, and improving the experience of users and commercial partners. The primary purpose of data collection is to enable the platform to create accounts, verify identity, confirm legal eligibility to use Twincoin’s services, and manage operations related to rewards, purchases, and redemptions, as well as to ensure the accuracy of records associated with digital currencies and internal activities.
Data is also used to operate the platform’s technical functions, including logging transactions, protecting accounts, preventing fraud or misuse, monitoring suspicious activities, and applying the necessary security controls to maintain the integrity of the systems. The purposes further include enhancing overall performance by analyzing usage patterns, studying user behavior within the application, and developing new features that respond to their needs and expectations, in addition to personalizing content and offers according to their interests or geographic location when permission has been granted for such use.
The platform relies on data to facilitate communication with users and commercial partners, whether for sending necessary notifications, responding to requests and inquiries, providing technical support, or informing users of any changes to services or policies. Within the framework of the unit and redemption system, data relating to the images of winners or redeemers, their names, the number of their selected box, and the date and time of redemption is used as a mandatory part of the transparency procedures on which the system is based, in order to ensure public disclosure of results and to allow clear verification of the fairness of the process.
Twincoin is committed to using data only to the minimum extent necessary to achieve the aforementioned purposes, while observing accuracy, appropriate retention periods, and the adoption of technical and administrative safeguards that ensure the protection of data and prevent its use outside the specified context. The platform further guarantees that data shall not be used for any purpose that is incompatible with the legal and operational foundations of the service or that is not stated in this policy.
Chapter Five: Data Sharing and the Scope of Lawful Disclosure
Twincoin is committed to protecting the complete confidentiality of personal data and does not share or disclose such data except within the lawful and necessary limits required to operate its services and ensure the integrity of its processes. Any data-sharing operation is inherently limited and governed by a clear legal framework, and no personal data is disclosed except to parties that require it directly for the performance of functions related to the platform or for safeguarding the integrity of the operations underlying the rewards and redemption system.
Twincoin may share certain data with commercial partners when needed to complete transactional or technical operations related to offers provided through the platform, enabling them to verify the transaction, process consumer requests, or calculate the rewards granted in gold currencies. The data shared in such cases is restricted to the minimum necessary, and the commercial partner is obligated to maintain the confidentiality of the data and refrain from using it for any purpose other than that for which it was shared.
Twincoin may also engage independent external service providers to perform essential services such as server hosting, payment processing, delivery management, technical analysis, system protection, or any other operational support services. These providers are subject to strict contractual obligations requiring them to protect the data and process it solely on behalf of the platform and in accordance with its instructions, without any right to use the data for their own interests or share it with any other party. Any disclosure of this nature is considered part of the operation of the platform and does not diminish Twincoin’s responsibility to protect the data.
Certain forms of disclosure constitute an essential aspect of the nature of Twincoin’s services, particularly within the unit system, which is based on the principle of transparency in announcing redemption results. In this context, the name of the redeemer, the profile image available in their account, the number of the redeemed box, and the date and time of redemption are published as data necessary to demonstrate the integrity of the process and to allow public verification of the accuracy of the unit’s results. Participation by the user in the redemption process constitutes clear and final acceptance of this publication, without any need for further or subsequent consent.
In situations where Lebanese law or any competent judicial or official authority requires disclosure, Twincoin shall comply with the applicable laws and binding decisions, including sharing data with the relevant authorities in cases involving suspected fraud, violations of law, or an official judicial or security-related request. Such disclosure is carried out strictly within the limits required by law and not exceeding what is necessary to achieve the public interest or to protect the safety of the platform and its users.
Twincoin does not, under any circumstances, sell personal data, commercially exploit it, or use it for purposes unrelated to the service. Data is also not disclosed to marketing partners or external advertisers except in limited cases related to improving service quality or enhancing the efficiency of offers, and such processes never include information that directly identifies the user, but are restricted to non-personal analytical data.
Chapter Six: Data Retention, Storage Periods, and Time Standards
Twincoin retains personal data for periods proportionate to the nature of its use and the purpose for which it was collected, in accordance with the principle of maintaining only the minimum necessary for operation and the protection of rights. Data is stored in secure databases for durations that vary according to its type and the necessity of its continued availability. Essential information related to identity, profile details, and operational records remains stored for the duration of the relationship between the user or commercial partner and the platform, or until a request for account closure is submitted, subject to the conditions set out in this policy and any exceptions required by Lebanese law.
Data is deleted or anonymized using approved technical standards when it is no longer needed or once the purpose for which it was collected has been fulfilled, except in cases where the law requires retention for a longer period, such as financial records, billing data, purchase evidence, or any information linked to judicial review or an official investigation. Such data is subject to mandatory retention requirements until the expiry of the legally defined period.
Data related to behavior within the platform, such as interaction history, redeemed units, referrals, earned and spent currencies, and records of digital social relations, is retained as long as necessary to ensure the accuracy of accounts, prevent repeated misuse, and maintain the integrity of the technical system. Technical retention of such data may continue for a reasonable period after account closure to meet security requirements, prevent the creation of fraudulent accounts, and verify any previous disputes or pending reports.
With respect to images or recordings related to redemption processes or the announcement of winners, such material is considered an integral part of the transparency framework. It may be retained and published for as long as it remains linked to the unit system and necessary for displaying results and demonstrating the fairness of the redemption process, without creating any right for the user to demand its concealment or subsequent deletion, as publication constitutes a core component of the service and its operational mechanism.
Twincoin is committed to applying the highest technical and administrative standards to ensure that data is stored securely, and to performing periodic review and audit procedures to ensure that no unnecessary data is retained. This ensures a balance between operational requirements and the protection of the privacy of users and commercial partners, in accordance with Lebanese law and recognized international practices.
Chapter Seven: Rights of Data Subjects and Mechanisms for Exercising Them
Users and commercial partners enjoy clear and lawful rights concerning their personal data, and Twincoin is committed to enabling the exercise of these rights within the limits permitted by Lebanese law and the available technical standards. Any user has the right to access the basic data recorded in their account, correct any inaccurate information, and update their personal data directly through the application’s features, ensuring record accuracy and the continued operation of the service within a sound legal framework.
A data subject may submit a formal request to obtain a copy of their data, to request the restriction of processing in specific cases, or to object to a particular use of the data that does not fall within the core operational scope of the service. A request may also be submitted for data deletion upon termination of the relationship with the platform, within limits that do not conflict with Twincoin’s legal or operational obligations, particularly those related to security requirements, financial records, or the protection of system integrity. In cases where complete deletion is not possible, the platform applies anonymization techniques or converts the data into a form that cannot be linked to the individual, while preserving only the information strictly necessary for technical purposes.
Requests relating to data must be submitted through designated official channels, with identity verification required to prevent unauthorized parties from accessing another person’s data. Twincoin undertakes to process requests within a reasonable timeframe, taking into account any technical or legal constraints that may necessitate extending the processing period or limiting its scope. Excluded from these rights is any data related to the publication of unit results or transparency records, as such data constitutes an inherent part of the platform’s operating mechanism and is not subject to deletion or concealment after participation.
Twincoin affirms that the exercise of these rights occurs within a context that balances privacy protection with operational requirements, and that any use of data outside the core purposes or without a legitimate basis constitutes a violation of the platform’s policy and shall be addressed in accordance with the applicable legal and regulatory frameworks.
Chapter Eight: Data Protection and Adopted Security Measures
Twincoin employs an integrated framework of technical and administrative measures to ensure the protection of personal data against any unauthorized access, unlawful use, loss, or unjustified alteration. These measures include the use of modern encryption protocols when transferring data between the platform’s servers and users’ devices, the implementation of multi-layer authentication mechanisms to ensure account security, and automated and periodic monitoring systems that detect unusual activities and counter attempts at hacking or misuse.
The platform stores data within secure hosting environments, whether inside Lebanon or abroad, through service providers selected based on their ability to offer an adequate level of protection and their commitment to contractual obligations requiring them to process data exclusively on behalf of Twincoin and in accordance with its instructions. The data infrastructure is subject to regular backups and continuous security updates intended to maintain system stability and minimize the likelihood of exposure to technical vulnerabilities.
Twincoin follows a strict policy for defining internal access permissions for employees and technical personnel, ensuring that access to data is granted only to those whose duties require it, within narrow, monitored limits, and with accurate logging of all access operations. The platform also imposes periodic security assessments on the adopted technical solutions, and its digital infrastructure undergoes repeated testing to identify and proactively address potential vulnerabilities.
In safeguarding the privacy of users and commercial partners, Twincoin commits to refraining from storing any sensitive data that is not necessary for operating its services, and to taking practical measures to ensure that data is not used in a manner that exceeds the purpose for which it was collected. This commitment constitutes a fundamental component of the platform’s philosophy, which is based on transparency and trust, and is aligned with the essential principles of data protection under Lebanese standards and contemporary international practices.
Chapter Nine: Cookies and Similar Technologies
Twincoin may use cookies and similar digital technologies to enhance the platform’s operational performance, facilitate the user experience, and ensure that services are delivered in a more efficient and stable manner. Cookies are small technical files stored on the user’s device when visiting the application or website, and they help identify user preferences, streamline repetitive processes, preserve login sessions, enable essential features such as continuous browsing, verify user identity, and prevent unauthorized access attempts.
The platform may also rely on other lawful tracking technologies such as application-specific SDKs, statistical analytics modules, and performance-measurement or error-monitoring tools, all within well-defined limits that do not aim to collect any data beyond the operational or identification purposes necessary to improve service quality. Cookies in Twincoin are not used for any commercial or advertising purposes outside the platform, nor do they contain any content capable of revealing sensitive personal information without the user’s consent or unless required for the core functions of the service.
Users may manage their cookie settings through their devices or browsers, including enabling, disabling, or limiting their use. However, disabling certain essential types of cookies may affect service stability or prevent the execution of necessary functions such as login processes or operations related to units and redemption. Twincoin is committed to clearly informing users about the use of these technologies and explaining that they are employed exclusively to facilitate interaction with the platform and ensure accurate and continuous performance.
The platform respects the choices made by the user in this regard unless such choices result in disabling essential features that render the service nonfunctional. In such cases, continued use shall be deemed implicit consent to the use of the minimum necessary cookies and similar technologies required to ensure the system operates correctly.
Chapter Ten: Cross-Border Data Transfers
The technical nature of operating the Twincoin Platform and processing its data may require reliance on servers or service providers located inside Lebanon or abroad, including in countries where data protection standards may differ from those applicable locally. Data may be transferred or hosted outside the territory only within lawful and necessary limits to ensure the stability of the platform, maintain system integration, and secure an appropriate level of service performance and protection.
Twincoin ensures that it engages service providers capable of offering suitable security and technical safeguards, and imposes clear contractual obligations requiring them to process data exclusively on behalf of the platform and in accordance with its instructions, and prohibiting any use of the data for other purposes. This includes the implementation of encryption protocols during transfer and the adoption of security mechanisms consistent with international best practices in information protection, thereby achieving a balance between operational requirements and privacy standards.
The transfer of data outside Lebanon is considered an integral part of modern technical infrastructure and does not affect the rights of users or commercial partners, as Twincoin remains directly responsible for any processing carried out on their data, whether inside or outside the territory. The platform confirms that all transfers are carried out under safeguards ensuring that data is not disclosed, not used beyond the scope of the service, and not made available to any unauthorized party, while complying with any mandatory requirements imposed by Lebanese law in the event of an official request from a competent authority.
Such transfers do not constitute a relinquishment of the data nor an unrestricted authorization to manage it, but rather a recognized technical measure necessary to ensure the platform’s performance and to achieve the level of speed, efficiency, and reliability required, in line with the nature of modern services that rely on multi-location cloud infrastructures.
Chapter Eleven: Policy Validity, Amendments, and Official Communication
This policy constitutes the binding legal reference for all matters related to the protection of personal data within the Twincoin ecosystem, and its provisions enter into effect as of the date of their publication on the application, the website, or any of the platform’s official channels. Continued use of the services after this date constitutes explicit acceptance by the user or commercial partner of full compliance with its content, and acknowledgment that it forms an essential part of the contractual relationship governing the use of the platform and the derivation of its rights and obligations.
Twincoin reserves the right to amend this policy, in whole or in part, at any time it deems appropriate to align with legislative, technical, or operational developments, or to enhance the level of protection and transparency. Amendments are published clearly through the official channels, and continued use of the platform after the updated version is published constitutes final acceptance thereof without the need for any additional action. In cases where amendments require renewed consent, Twincoin shall notify users and commercial partners through appropriate mechanisms and shall activate the service only after the required consent has been duly obtained in the legally prescribed manner.
The platform affirms that any matter for which no specific provision is stated in this policy shall be interpreted by reference to the applicable Lebanese laws and the Terms of Use that complement this policy, ensuring legal consistency and avoiding any conflict between provisions. If any clause of this policy is rendered invalid as a result of a judicial ruling or legislative amendment, such invalidity shall not affect the validity of the remaining provisions, which shall remain in force to the broadest extent possible.
For communication related to data rights, requests to exercise such rights, or inquiries regarding any provision of this policy, the following official email address has been designated for receiving correspondence:
The requester must provide the platform with the necessary information to verify identity before any data-protection request is considered, in order to safeguard the confidentiality of accounts and prevent unauthorized access. Twincoin undertakes to handle requests within a reasonable period and in accordance with legal boundaries and operational constraints.
By adopting this policy, Twincoin reaffirms its firm commitment to protecting privacy, building a relationship founded on trust and transparency with its users and commercial partners, and ensuring that all data collected or processed within its systems is subject to the highest levels of protection and recognized standards.
Legal Conclusion
This policy is governed by and shall be interpreted in accordance with the applicable laws of Lebanon, and exclusive jurisdiction over any dispute arising from or related to its application or interpretation shall lie with the courts of Beirut, unless mandatory legal provisions impose a different jurisdiction. Use of the platform constitutes final acceptance of this judicial authority.
This policy has been drafted in the Arabic language as the official and legally binding version. Translations into other languages may be provided for convenience, but they shall not be considered a legal reference. In the event of any discrepancy between the Arabic version and any translated version, the Arabic text shall prevail exclusively.
This policy shall take effect as of the date of its publication on the Twincoin application or website and shall apply to all users and commercial partners from that date onward. Continued use of the platform after the publication of any amendment constitutes explicit acceptance of the amended version without the need for any additional action.
All intellectual property rights related to the Twincoin Platform, including the Twinkey Twincoin trademark and its technical and visual components, remain the exclusive property of Fratiro (Simple Limited Partnership), and they shall be governed by the provisions set forth in the Terms of Use. © All rights reserved.
Version: 1.0
Release Date: 01/11/2025
Last Update: 01/11/2025
Official Language: Arabic