Privacy Policy

Introduction

Freya Illustration FZCO ("we", "us", "our") operates Twotap. This Privacy Policy explains how we collect, use, store, and protect your personal information when you use our website and services.

Our commitment: We respect your privacy and are committed to protecting your personal data. This policy will help you understand your privacy rights and how the law protects you.

Contact Information:

Email: support@freya.course
Address: Dubai Digital Park – Office A5- Dtec, Dubai Silicon Oasis, Dubai, United Arab Emirates

1. Information We Collect

Personal Information You Provide

Account Registration:

Name
Email address
Username and password
Country/location (optional)

Payment Information:

Billing name and address
Payment card details (processed by third-party payment processors - we do not store complete card numbers)
Transaction history

Communications:

Messages sent through our support chat
Emails you send us
Feedback and survey responses
Course reviews and ratings

User-Generated Content:

Forum posts and comments
Profile information
Uploaded images (if applicable)

Information Collected Automatically

Usage Data:

Pages visited and features used
Time spent on pages
Course progress and completion rates
Device information (browser type, operating system, IP address)
Referral source (how you found our site)

Cookies and Tracking Technologies:

Session cookies (essential for site functionality)
Preference cookies (remember your settings)
Analytics cookies (Google Analytics)
Authentication cookies (keep you logged in)

Information from Third Parties

Social Media:

If you connect via Facebook Messenger, we may receive basic profile information

Payment Processors:

Transaction confirmation data from PayPal, Stripe, and other payment providers

2. How We Use Your Information

Primary Uses

Service Delivery:

Provide access to purchased courses and content
Process payments and send transaction confirmations
Manage your account and user profile
Enable course features (progress tracking, bookmarks, notes)
Provide customer support

Communication:

Send order confirmations and receipts
Notify you about account activity
Respond to your inquiries
Send course updates and announcements
Provide technical support

Improvement and Development:

Analyze how users interact with our courses
Identify popular content and areas for improvement
Test new features and functionality
Optimize site performance and user experience

Marketing (with your consent):

Send promotional emails about new courses
Announce special offers and discounts
Share educational content and tips
Recommend courses based on your interests

You can opt out of marketing emails at any time by clicking the "Unsubscribe" link in any promotional email or contacting us directly.

Legal Bases for Processing (GDPR)

We process your personal data based on:

Contract performance: To provide services you've purchased
Legitimate interests: To improve our services and prevent fraud
Consent: For marketing communications and non-essential cookies
Legal obligations: To comply with tax, accounting, and legal requirements

3. How We Share Your Information

We do not sell, rent, or trade your personal information. We share data only in these limited circumstances:

Service Providers

We share information with trusted third-party service providers who help us operate our business:

Payment Processing:

Stripe, PayPal, Apple Pay, and other payment processors
These providers process payments securely and do not share your payment details with us

Email Services:

Email service providers for transactional and marketing emails
Only necessary contact information is shared

Analytics:

Google Analytics (anonymized usage data)
Helps us understand how users interact with our site

Hosting and Infrastructure:

Cloud hosting providers for site operation
Content delivery networks (CDNs) for faster page loading

All service providers are contractually obligated to protect your data and use it only for specified purposes.

Legal Requirements

We may disclose your information if required by law or to:

Comply with legal processes (subpoenas, court orders)
Enforce our Terms of Service
Protect our rights, property, or safety
Prevent fraud or illegal activity
Protect the rights and safety of our users

Business Transfers

If we merge with, are acquired by, or sell assets to another company, your information may be transferred to the new entity. We will notify you before your information is subject to a different privacy policy.

4. Data Retention

How Long We Keep Your Data

Active Accounts:

Account information: Retained while your account is active
Course progress and completion data: Lifetime (as we provide lifetime access)
Payment records: 7 years (for tax and accounting compliance)

Inactive Accounts:

After 3 years of inactivity, we may contact you about account closure
You can request account deletion at any time

User Contributions:

Comments and reviews: Retained indefinitely to maintain community content integrity
You can request deletion of your contributions

Marketing Data:

Email lists: Until you unsubscribe
After unsubscribing, we keep a suppression record to ensure we don't email you again

Legal and Security Records:

Security logs and fraud prevention data: Up to 5 years
Legal compliance records: As required by applicable law

Deletion Requests

When you request data deletion, we will:

Delete your personal information within 30 days
Retain only what is legally required (e.g., transaction records for tax purposes)
Anonymize any data that must be retained for analytics

5. Your Privacy Rights

Rights Available to All Users

Access: Request a copy of the personal data we hold about you

Correction: Update or correct inaccurate information

Deletion: Request deletion of your personal data (subject to legal exceptions)

Objection: Object to processing of your data for marketing purposes

Data Portability: Receive your data in a structured, machine-readable format

Opt-out: Unsubscribe from marketing communications at any time

Additional Rights for EU/EEA Users (GDPR)

Right to Restriction: Limit how we use your data in certain circumstances

Right to Withdraw Consent: Withdraw consent for data processing at any time

Right to Lodge a Complaint: File a complaint with your local data protection authority

Automated Decision-Making: We do not use automated decision-making or profiling

How to Exercise Your Rights

Your full name and email address
Specific right you wish to exercise
Any relevant details to help us locate your information

We will respond within 30 days (or as required by applicable law).

6. Cookies and Tracking Technologies

What Are Cookies?

Cookies are small text files stored on your device that help websites remember your preferences and improve functionality.

Types of Cookies We Use

Essential Cookies (Required):

Session management (keep you logged in)
Security (prevent fraud and protect your account)
Site functionality (remember language preferences)

Analytics Cookies (Optional):

Google Analytics (track site usage and performance)
Help us understand which content is most valuable
Data is anonymized and aggregated

Preference Cookies (Optional):

Remember your display settings
Store course progress and bookmarks
Improve user experience across sessions

Cookie Consent

When you first visit our site, you can choose which non-essential cookies to accept. You can change your cookie preferences at any time through:

Browser settings (clear or block cookies)
Our cookie preference center (if available)
Contacting support

Note: Disabling essential cookies may affect site functionality.

Third-Party Cookies

Google Analytics: We use Google Analytics to understand site usage. Google may use this data according to their privacy policy. You can opt

out using the Google Analytics Opt-out Browser Add-on.

Do Not Track Signals

Our site does not currently respond to "Do Not Track" browser signals, but you can control cookies through your browser settings.

7. Data Security

How We Protect Your Information

Technical Measures:

SSL/TLS encryption for all data transmission
Encrypted storage for sensitive information
Regular security audits and vulnerability assessments
Secure password hashing (passwords are never stored in plain text)
Firewall protection and intrusion detection

Organizational Measures:

Access controls (only authorized personnel can access user data)
Staff training on data protection and privacy
Data processing agreements with all service providers
Regular backup procedures
Incident response procedures

Your Responsibility

Protect Your Account:

Use a strong, unique password
Never share your login credentials
Log out after using shared devices
Enable two-factor authentication (if available)
Report suspicious activity immediately

Data Breach Notification

If a data breach occurs that affects your personal information, we will:

Notify affected users within 72 hours (as required by GDPR)
Describe what information was compromised
Explain steps we're taking to address the breach
Provide guidance on protecting yourself
Report to relevant authorities as required by law

Important: No system is 100% secure. While we implement industry-standard security measures, we cannot guarantee absolute security.

8. International Data Transfers

Where Your Data Is Stored

Our servers are located in multiple regions to provide reliable service globally. Your data may be transferred to and processed in:

United States (hosting and service providers)
European Union (some service providers)

Protection for International Transfers

When transferring data internationally, we ensure protection through:

Standard Contractual Clauses (EU-approved)
Data processing agreements with all service providers
Compliance with applicable data protection laws
Adequate security measures in all locations

Your Rights

If you are located in the EU/EEA, you have the right to know about international transfers and can object if protections are inadequate.

9. Children's Privacy

Age Requirements

Our services are not intended for children under 16 years old. We do not knowingly collect personal information from children.

If you are under 16:

Do not register for an account
Do not provide any personal information
Ask a parent or guardian to contact us if you need assistance

If you are a parent or guardian:

Monitor your child's internet usage
Contact us immediately if you believe your child has provided information to us
We will delete any information from children under 16 upon notification

COPPA Compliance (US Users)

For users under 13 in the United States, we comply with the Children's Online Privacy Protection Act (COPPA). Parents must provide verifiable consent before we collect any information from children under 13.

10. Third-Party Links and Services

External Websites

Our site may contain links to third-party websites, including:

Social media platforms
Payment processors
Educational resources
Partner websites

We are not responsible for the privacy practices of external sites. We encourage you to read their privacy policies before providing any information.

Embedded Content

Our courses may include embedded content from:

YouTube (videos)
Vimeo (videos)
Other educational platforms

These services may collect data about your viewing activity according to their own privacy policies.

Social Media

If you interact with social media features on our site (share buttons, Facebook Messenger), those platforms may collect information about your activity.

11. Marketing Communications

What We Send

With your consent, we may send:

New course announcements
Special offers and discounts
Educational tips and resources
Platform updates and improvements
Personalized course recommendations

How We Personalize

We may use your:

Course purchase history
Browsing behavior
Stated interests
Course completion rates

To recommend relevant content and offers.

Opting Out

Unsubscribe from marketing emails:

Click "Unsubscribe" at the bottom of any promotional email
Contact support@twotap.art
Update preferences in your account settings

Note: You will still receive transactional emails (purchase confirmations, password resets, important account notifications) even if you opt out of marketing.

12. California Privacy Rights (CCPA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA):

Your CCPA Rights

Right to Know: What personal information we collect, use, and share

Right to Delete: Request deletion of your personal information

Right to Opt-Out: Opt out of the "sale" of personal information (Note: We do not sell personal information)

Right to Non-Discrimination: We will not discriminate against you for exercising your rights

How to Exercise CCPA Rights

Information We Collect (CCPA Categories)

Identifiers (name, email, IP address)
Commercial information (purchase history)
Internet activity (browsing behavior)
Geolocation data (approximate location)

13. Changes to This Privacy Policy

Policy Updates

We may update this Privacy Policy to reflect:

Changes in our data practices
New features or services
Legal or regulatory requirements
Feedback from users

How We Notify You

When we make changes:

Update the "Last updated" date at the top
For material changes, we will send an email notification
Post a notice on the website
Give you an opportunity to review before changes take effect

Your continued use of the site after changes indicates acceptance of the updated policy.

14. Contact Us About Privacy

Privacy Questions or Concerns

If you have questions about this Privacy Policy or our data practices, contact us:

Email: support@twotap.art

Mail:
Freya Illustration FZCO
Privacy Team
Dubai Digital Park – Office A5- Dtec
Dubai Silicon Oasis
Dubai, United Arab Emirates

Response Time: We aim to respond to all privacy inquiries within 5 business days.

Data Protection Officer

For GDPR-related inquiries, you can contact our Data Protection Officer at: support@twotap.art

Complaints

If you believe we have not handled your data properly, you have the right to lodge a complaint with your local data protection authority.

EU/EEA residents: Contact your national data protection authority
UK residents: Information Commissioner's Office (ICO)
UAE residents: UAE Data Protection Office

15. Additional Information

Automated Decision-Making

We do not use automated decision-making or profiling that produces legal effects or similarly significant effects on you.

Data Processing Agreements

We have data processing agreements in place with all service providers who process personal data on our behalf.

Regular Reviews

We regularly review our data collection, storage, and processing practices to ensure compliance with this Privacy Policy and applicable laws.

Your Consent

By using Twotap, you consent to the collection and use of information as described in this Privacy Policy.

This Privacy Policy is designed to be transparent and help you make informed decisions about your personal data. If anything is unclear, please contact us.