Privacy Policy

Website: kylosi (kylosi.com)
Company: Twubsy, Inc.
Contact: team@twubsy.com
Effective date: 2025-12-21

We are based in United States.

Data Controller

For purposes of applicable data protection laws, the data controller is:

Twubsy, Inc.
Email: team@twubsy.com
United States

This Privacy Policy explains how Twubsy, Inc. ("we", "us", or "our") collects, uses, discloses, and protects information when you visit or use kylosi.com (the "Website").

This policy is intended to describe our practices in a clear manner, but it does not create any contractual rights for any person, and it does not limit any rights we may have under applicable law.

1) Definitions

For purposes of this Privacy Policy:

• "Personal information" / "personal data" means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked (directly or indirectly) with you or your device.
• "Processing" means any operation performed on personal information (e.g., collection, use, storage, disclosure).
• "Service providers" means vendors that process information on our behalf to provide services such as hosting, analytics, email delivery, security, and advertising.
• "Controller" (or "business", where applicable) means the entity that determines the purposes and means of processing personal information. For the Website, the Controller is Twubsy, Inc..

2) What we collect

A) Information you provide

• Newsletter sign-ups: If you subscribe, we collect information such as your email address (and any optional fields you choose to provide).
• Contact us: If you contact us (for example, by email), we collect your contact details and the contents of your message, and we may keep records of our correspondence.

B) Information collected automatically

• Device & usage data: IP address, browser type, device identifiers, pages viewed, time spent, referral URLs, and similar diagnostics.

• Cookies / similar tech: We use cookies, pixels, tags, local storage, or similar technologies to operate the site, remember preferences, measure performance, and (if enabled) serve ads. Some of these technologies may be provided by third parties and may operate across websites and apps.

• Log and security data: We (and our service providers) may collect logs and related information to maintain the security and integrity of the Website (e.g., detecting suspicious activity, preventing abuse, and troubleshooting).

3) How we use information

We may use information to:

• Provide and operate the Website
• Maintain security and prevent fraud/abuse
• Respond to your inquiries and provide customer support
• Understand Website usage and improve content and performance
• Send newsletters or updates you request (you can unsubscribe anytime)
• Display advertising and measure ad performance

We may also use information to:

• Enforce our Terms of Use and other agreements
• Comply with legal obligations and respond to lawful requests
• Protect the rights, safety, and property of us, our users, and others

4) Advertising (AdSense) and cookies

We may display ads served by third-party advertising partners, such as Google AdSense. These partners may use cookies or similar technologies to:

• Serve ads based on your visits to this and/or other websites
• Measure ad performance and limit ad frequency
• Detect invalid traffic and protect against fraud

Depending on your region and settings, ads may be personalized (interest-based) or non-personalized.

Use of Google AdSense is subject to Google's privacy policy.

Google’s use of advertising cookies enables it and its partners to serve ads to users based on their visits to this site and/or other sites on the Internet. Users may opt out of personalized advertising by visiting Google’s Ads Settings.

Your choices:

• You can adjust cookie settings in your browser.
• Where applicable, you may be shown a consent banner and/or preference center for ad/analytics cookies.
• Google provides ad personalization controls in its user settings (availability depends on region).
• You may also be able to opt out of certain interest-based ads through industry programs (availability depends on region and device).

5) Analytics

We may use analytics tools to understand how the Website is used and to improve performance.

Examples of analytics vendors:

• Google Analytics (GA4)

These vendors may process device and usage data (which can include IP address or truncated IP, depending on configuration).

6) Newsletter and email communications

If you subscribe, we will send you emails related to the newsletter and/or site updates.

Email providers (examples):

• Email newsletter provider

You can unsubscribe at any time by clicking the unsubscribe link in any email. We may keep a record of unsubscribes to ensure we respect your preferences.

7) Sharing and disclosures

We may share information:

• With service providers who help operate the Website (hosting, email delivery, analytics, security)
• To comply with legal obligations or lawful requests
• To protect our rights, safety, and property, and that of users
• In connection with a merger, acquisition, or sale of assets (users will be informed when required)

We do not authorize third parties to use personal information we share with them except as necessary to provide services to us or to comply with applicable law.

We may also share aggregated or de-identified information that cannot reasonably be used to identify you.

Examples of categories of third parties we may use:

• Hosting/CDN providers
• Analytics providers
• Email newsletter providers
• Advertising partners (e.g., AdSense)
• Security and anti-abuse tools

8) Data retention

We retain personal information only as long as needed for the purposes described in this policy, unless a longer retention period is required or permitted by law.

Examples:

• Newsletter subscription data: retained until you unsubscribe (plus a short period to process and maintain suppression lists)
• Technical logs: retained for security and operational purposes for a limited period

9) Security and Your Rights

We use reasonable technical and organizational measures to protect information. No method of transmission or storage is 100% secure, so we cannot guarantee absolute security. You may have rights depending on your location, including:

• Access, correction, or deletion of personal information
• Objection or restriction of processing
• Data portability
• Withdrawal of consent (where processing is based on consent)

To exercise rights, contact: team@twubsy.com

GDPR (EEA/UK) notes

If you are in the EEA/UK, we will rely on a legal basis for processing such as:

• Consent (e.g., newsletter subscriptions and, where required, advertising and analytics cookies)
• Legitimate interests (e.g., site security, fraud prevention, and basic operational analytics where permitted by law)
• Contract (where applicable)

We rely on consent for newsletter subscriptions and, where required, for advertising and analytics cookies. We rely on legitimate interests for essential site security, fraud prevention, and basic operational analytics where permitted by law.

Where we rely on legitimate interests, we consider and balance any potential impact on your rights and may limit processing where required.

You also have the right to lodge a complaint with your local data protection authority.

California (CCPA/CPRA) notes

We may collect identifiers (e.g., IP address) and internet activity information (e.g., browsing interactions) for site operation, analytics, and advertising.

We do not "sell" personal information in the traditional sense, but some ad-tech practices may be considered "sharing" under CPRA. Where required, we provide mechanisms to opt out of such sharing (e.g., consent banner/controls).

If you submit a request to exercise your rights, we may need to verify your identity, which may require additional information. We will use verification information only for this purpose.

10) Do Not Track signals

Some browsers transmit "Do Not Track" signals. We do not respond to Do Not Track signals because there is no consistent industry standard. Where required, users can manage cookie preferences through browser settings and any consent tools we provide.

11) International visitors

If you access the Website from outside United States, your information may be processed in countries where our service providers operate, which may have different data protection laws.

Where required by applicable law, we use recognized mechanisms to legitimize cross-border transfers of personal data (such as Standard Contractual Clauses or other lawful transfer mechanisms).

12) Links to other websites

The Website may contain links to other websites that are not operated by us. If you click on a third-party link, you will be directed to that third party's site. We strongly advise you to review the Privacy Policy of every site you visit. We have no control over and assume no responsibility for the content, privacy policies, or practices of any third-party sites or services.

13) Children's privacy

The Website is not intended for children under 13 (or the minimum age required by your jurisdiction). We do not knowingly collect personal information from children. If you believe a child provided us data, contact team@twubsy.com.

14) Sensitive personal information

We ask that you do not send us, and you not disclose, any sensitive personal information (e.g., social security numbers, information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometrics or genetic characteristics, criminal background, or trade union membership) on or through the Website or otherwise to us.

15) Changes to this policy

We may update this policy from time to time. The updated version will be posted on this page with a revised effective date.

16) Contact

Questions about this Privacy Policy: team@twubsy.com