Privacy Policy

Effective Date: October 26, 2026
Last Updated: October 26, 2026

This Privacy Policy explains how Sigmund Holdings LLC, a Delaware limited liability company (“Twizzy,” “we,” “us,” or “our“), 3030 NE 188th St, Aventura, FL 33180, collects, uses, discloses, and protects personal information. It also explains the choices and rights you have.

It applies to everyone who uses:

our website at twizzy.com, including its informational pages, podcast, newsletter, and sign-up and interest forms;
our iOS and Android mobile applications;
any current or future Twizzy web application;
any other website, domain, or app operated by or for Twizzy that links to this Policy or to our Terms of Service, including any preview, staging, or landing site;
any related services that link to this Policy.

Together these are the “Services.” It applies to visitors, newsletter subscribers, Users, and Advisors. Capitalized terms not defined here have the meanings given in our Terms of Service.

Key points

Sessions are recorded and transcribed. Every Session is recorded, transcribed, and stored in the cloud for legal, safety, dispute-resolution, and compliance purposes. Recordings and transcripts may be made available to the User and the Advisor in that Session and are accessible to authorized Twizzy staff when needed, but are not routinely reviewed (see Section 5).
We do not sell your personal information for money. See Section 8 for how cookies and advertising tools are handled and how to opt out.
The Services are for adults 18 and over only.
The Services are not for emergencies. Call 911, or call or text 988.

1. Information We Collect

1.1 Information you provide

Category	Examples
Account and contact information	Name, email address, phone number, password, confirmation that you are 18 or older, state or location of residence, time zone
Profile information	Photo, display name, bio, tagline, topics, categories, pricing and availability (Advisors), saved Advisors and preferences (Users)
Identity verification information (mainly Advisors)	Government ID details and images, a selfie or live photo, and verification results, collected and stored by our third-party identity-verification provider, not by Twizzy; Twizzy receives the verification result (see Section 1.4)
Payment and payout information	Payment card or wallet details (collected and stored by our payment processor, not by Twizzy), billing ZIP code, transaction history; for Advisors: payout account and tax information (such as a W-9 or TIN)
Session content	Audio and, if used, video of Sessions; transcripts; any Twizzy-generated notes or summaries; booking details; intake information you choose to provide
Communications	Support requests and screenshots, reports, reviews and ratings, survey responses
Website and marketing information	Newsletter sign-ups, interest-form and waitlist submissions, podcast questions or guest submissions, contest entries

1.2 Information collected automatically

Device and usage data: IP address, device type and identifiers, operating system, app version, browser type, pages and screens viewed, features used, referring URLs, crash and performance logs, and timestamps.
Session technical data: join and leave times, connection quality, and call duration.
Approximate location: inferred from your IP address or device settings, and the state or location you provide at sign-up. We use it, among other things, to determine whether the Services are available where you are. We do not collect precise geolocation unless you separately allow it.
Cookies and similar technologies: cookies, pixels, SDKs, and local storage, used on the Site and in the App for essential functions, preferences, analytics, and (on the Site) marketing. See Section 8.

1.3 Information from third parties

Payment processors (payment status and fraud signals)
Identity-verification providers (verification results)
App stores (download data)
Sign-in providers such as Apple or Google, if you choose to use them (name and email)
Analytics and advertising partners
Other Members (for example, when a User reports an Advisor, or the reverse)

1.4 Sensitive information

What you choose to share. Users and Advisors may choose to discuss personal matters during Sessions or in intake forms. That can include information about health, mental well-being, relationships, sex life or sexual orientation, religion, finances, or other sensitive topics. This is voluntary. Please share only what you are comfortable sharing. By sharing it, you consent to our processing it as described in this Policy, mainly to provide the Session, keep the recording and transcript, and support safety and dispute resolution. We do not use sensitive information to infer characteristics about you for advertising.

Identity verification. Identity verification may involve a third-party provider comparing your selfie to your ID photo using facial-recognition technology. That process may generate biometric identifiers. The provider collects and stores your ID and selfie images on its own systems, and Twizzy receives only the verification result. Where required by law (for example, in Illinois, Texas, or Washington), we or our provider will:

tell you about it and obtain your written consent before collecting biometric identifiers;
use them only for identity verification and fraud prevention;
not sell them;
destroy them when the initial purpose has been satisfied, or within the period required by applicable law, whichever comes first.

Twizzy does not use Session recordings to create voiceprints or facial templates to identify individuals.

2. How We Use Information

We use personal information to:

Provide the Services. That means creating and managing accounts; matching, scheduling, and hosting Sessions; processing payments, refunds, and payouts; and providing customer support.
Record, transcribe, and store Sessions. See Section 5.
Keep the Services safe. That includes verifying identity; detecting, investigating, and preventing fraud, abuse, prohibited content (including sexual content and solicitation), and security incidents; and enforcing our Terms.
Resolve disputes, including refund requests and chargebacks.
Communicate with you. That includes transactional messages, reminders, and service announcements; with your consent, marketing emails, newsletters, podcast updates, and texts; and responses to your inquiries and interest forms.
Improve and develop the Services. That includes analytics, debugging, research, and new features. We use aggregated or de-identified data wherever reasonably possible.
Personalize the Services, for example by recommending Advisors based on the topics you select.
Comply with law and protect rights. That includes tax reporting, responding to lawful requests, and establishing, exercising, or defending legal claims.
Carry out any other purpose we disclose when we collect the information, or that you consent to.

3. AI and Automated Processing

We use automated tools, including speech-to-text transcription and artificial-intelligence processing supplied by third-party service providers, to process Session audio and other content. We use them to:

produce transcripts;
help detect safety risks, fraud, and policy violations;
support dispute resolution;
power features we disclose to you, such as Session notes or summaries.

Our providers process this content on our behalf and under our instructions, and do not use it to train their AI models. Under their own terms, they may keep the content they process for a limited time, for example up to 30 days for abuse monitoring, and some keep transcription data until it is deleted, with deleted data remaining in their backups for up to 30 days. We do not use your Session recordings or transcripts to train generalized AI models offered to third parties without your consent.

We do not make decisions about you that produce legal or similarly significant effects based solely on automated processing without human review. Automated outputs may contain errors.

4. How We Disclose Information

We disclose personal information only as described below.

Between Members.
- When you book a Session, the Advisor sees the information needed to conduct it: for example, your first name, the topic and time you requested, and any intake information you provide.
- Users see Advisor profile information, ratings, and reviews.
- Reviews you post are public.
- Recordings and transcripts of a Session may be made available to the User and the Advisor who took part in that Session (see Section 5.4).
Service providers. These are vendors that act on our behalf under contracts restricting their use of the information. The categories are:
- cloud hosting and data storage;
- real-time audio and video communications;
- transcription and AI processing;
- payment processing and payouts;
- identity verification;
- email-marketing and messaging services;
- analytics and crash reporting;
- customer support tools;
- website hosting;
- professional advisers such as lawyers and accountants.
Legal, safety, and compliance. We disclose information when we believe in good faith that it is necessary to:
- comply with law, a subpoena, court order, or other legal process, or a government request;
- enforce our Terms;
- protect the rights, property, or safety of Twizzy, our Members, or others, including by reporting suspected child exploitation to the National Center for Missing & Exploited Children (NCMEC) and to law enforcement, or by sharing information in an emergency involving risk of death or serious injury;
- detect and prevent fraud or security issues.
Payment networks and dispute processes. When a charge is disputed, we may share relevant booking, Session, and communication records with our payment processor, card networks, and issuing banks.
Business transfers. We may share information in connection with an actual or proposed merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our business or assets. If that happens, information may be transferred as a business asset, subject to this Policy.
Affiliates. We may share information with companies under common control with Sigmund Holdings LLC, consistent with this Policy.
With your consent or at your direction.
Aggregated or de-identified information that cannot reasonably be used to identify you.

5. Session Recording, Transcription, and Consent

5.1 What we record. Every Session conducted through the Services, audio and (if used) video, is recorded and transcribed. The recordings, transcripts, and related metadata are stored with our cloud hosting provider in the United States and are encrypted at rest.

5.2 Why we record. We record Sessions for:

legal and regulatory compliance;
safety and trust (including investigating reports of harassment, sexual content or solicitation, threats, or other prohibited conduct);
resolving refund, payment, and chargeback disputes;
fraud prevention;
enforcing our Terms.

5.3 Consent from every party. Florida, California, and several other states require the consent of all parties before a conversation is recorded. We obtain consent from every participant through clear disclosure in our Terms and this Policy, which you must accept by checking the box at sign-up (for Advisors, also during Advisor onboarding).

If you do not consent, do not book, accept, or join a Session. You are responsible for making sure that anyone who can be heard or seen on your side of the Session knows about the recording and consents. Members may not make their own recordings.

5.4 Who can access recordings and transcripts.

Session participants. Recordings and transcripts of a Session may be made available to the User and the Advisor who took part in that Session. Participants may use them only for personal reference and dispute resolution and may not publish or share them without the other participant’s consent.
Authorized Twizzy staff and service providers. Recordings and transcripts are accessible to a small number of authorized Twizzy staff, and to service providers acting on our behalf, for dispute resolution (including refund, payment, and chargeback disputes), safety, trust and safety review, legal compliance (including responding to legal process), and enforcing our Terms, as well as to provide support you request and to maintain the security of the Services.
Not routinely reviewed. Recordings and transcripts are not routinely accessed or reviewed. Staff access them only when reasonably necessary for one of the purposes above.

We do not publish recordings or transcripts or use them in marketing without the participants’ consent.

5.5 Retention. We keep Session recordings and transcripts until they are deleted. We do not delete them automatically on a fixed schedule. When you delete your account, we delete your recordings and transcripts as described in Section 6, unless:

they are subject to an open report, investigation, dispute, or chargeback;
they are needed to establish or defend legal claims;
the law or a legal hold requires it.

6. Data Retention

We keep personal information for as long as reasonably necessary for the purposes described in this Policy, including:

providing the Services;
meeting legal, tax, accounting, and reporting obligations;
resolving disputes;
enforcing our agreements.

Guidelines:

Account and profile data: kept for the life of the account. When you delete your account, we delete your profile, Session recordings, and transcripts, including copies held by our transcription and AI providers, except as described in Sections 5.5 and 9.3.
Transaction and payout records: kept for at least 7 years, for tax and accounting purposes.
Basic Session records (such as date, time, duration, participants, and amount): kept for about 18 months after the Session, to handle card disputes and chargebacks.
Session recordings and transcripts: see Section 5.5.
Identity-verification data: see Section 1.4.
Marketing lists: kept until you unsubscribe. We then keep a suppression record so we honor your choice.
Support communications: kept for as long as reasonably necessary to resolve the request and for our legal and record-keeping purposes.

Deleted information may remain in backups, including our service providers’ backups, for a limited time (for some providers, up to 30 days) before it is permanently removed.

7. Data Security

We use reasonable administrative, technical, and physical safeguards designed to protect personal information. These include encryption in transit, encryption at rest (AES-256) for stored recordings and transcripts, access controls, and access to recordings limited to a small number of authorized staff. Recordings are not end-to-end encrypted, because our systems need to process them to create transcripts. However, no method of transmission or storage is completely secure, and we cannot guarantee the security of your information. You are responsible for keeping your password confidential. If we learn of a security breach affecting your personal information, we will notify you and the relevant authorities as required by applicable law.

8. Cookies, Analytics, and Advertising; Your Choices

8.1 Cookies. We and our partners use cookies and similar technologies to:

operate the Site and App;
remember your preferences;
understand usage;
on the Site, measure and support marketing.

You can control cookies through your browser settings and, where available, our cookie banner or preferences tool. Blocking some cookies may affect how the Site works.

8.2 Targeted advertising and “sale/sharing.” We do not sell personal information for money. We may allow advertising or analytics partners to collect information through cookies or pixels on the Site for analytics and to show you Twizzy ads on other sites. Some state privacy laws may treat this as a “sale,” “sharing,” or “targeted advertising.” You can opt out by:

enabling a Global Privacy Control (GPC) signal in your browser, which we treat as an opt-out request for that browser;
emailing help@twizzy.com.

We do not use Session recordings, transcripts, intake information, or other sensitive information for targeted advertising.

8.3 Do Not Track. There is no common industry standard for “Do Not Track” browser signals. We do not respond to them, other than honoring GPC as described above.

8.4 Marketing communications. You can unsubscribe from marketing emails at any time using the link in any message. You can opt out of marketing texts by replying STOP. You can manage push notifications in your device settings. You will continue to receive transactional and account messages.

9. Your Privacy Rights

9.1 Rights we offer. Depending on where you live, and subject to verification and legal exceptions, you may have the right to:

Know and access the personal information we have about you, and obtain a portable copy.
Correct inaccurate personal information.
Delete personal information.
Opt out of the “sale” or “sharing” of personal information, targeted advertising, and profiling that produces legal or similarly significant effects.
Limit the use of sensitive personal information, where applicable.
Withdraw consent where processing is based on consent. Withdrawal does not affect processing that already happened. Because recording is a condition of Sessions, withdrawing recording consent means you can no longer participate in Sessions.
Appeal a decision we make about your request.
Not be discriminated against for exercising these rights.

We extend these core rights to all U.S. users, whether or not their state requires it, subject to the same exceptions.

9.2 How to make a request. Email help@twizzy.com with the subject line “Privacy Request,” or use the in-app account settings where available. We will verify your identity, generally by matching information on your account, before fulfilling a request. You may use an authorized agent; we may require proof of the agent’s authority and may ask you to verify your identity directly. We will respond within the time required by applicable law (generally 45 days, which may be extended where the law allows). To appeal a decision, reply to our response with the subject line “Privacy Appeal.” If your appeal is denied, you may contact your state attorney general.

9.3 Exceptions. We may keep information when the law requires or permits it. Examples include:

completing transactions;
security and fraud prevention;
tax and legal obligations;
resolving disputes;
establishing or defending legal claims;
preserving Session recordings that are subject to a report, dispute, or legal hold.

Deleting your account does not delete reviews you posted, or information other Members already received, but your reviews will be shown as posted by “Deleted user.”

9.4 Additional disclosures for California residents. In the past 12 months we may have collected the following categories of personal information under the California Consumer Privacy Act (as amended), for the purposes described in Section 2, and disclosed them for business purposes to the recipients described in Section 4:

identifiers;
customer records;
commercial information;
internet and network activity;
approximate geolocation;
audio and visual information (Session recordings);
professional or employment-related information (background or experience that Advisors choose to describe in their profiles; Advisors are not professionals or experts and are not verified);
inferences (for example, topic preferences);
sensitive personal information (account login, government ID for verification, and information you voluntarily disclose in Sessions).

The only categories we may have “sold” or “shared” (as those terms are defined by law) are identifiers and internet activity, through Site cookies, as described in Section 8.2. We do not knowingly sell or share the personal information of consumers under 16. We use sensitive personal information only for purposes the law permits, so we do not offer a right to limit it beyond those purposes. California residents may also request information about disclosures of personal information to third parties for their own direct-marketing purposes under California Civil Code § 1798.83 (“Shine the Light”). We do not make such disclosures.

9.5 Nevada residents. We do not sell covered information as defined under Nevada law. You may still submit an opt-out request to help@twizzy.com.

9.6 Consumer health data. Twizzy is not a health care provider and does not ask Users to share health information. If you choose to discuss health-related topics in a Session or elsewhere on the Services, we handle that information under this Policy and do not sell it. Residents of Washington, Nevada, and other states with consumer health data laws may exercise their rights by contacting us at help@twizzy.com.

10. Children

The Services are intended only for adults 18 years of age or older. You confirm that you are 18 or older when you sign up. We do not knowingly collect personal information from anyone under 18. If we learn that we have collected information from someone under 18, we will delete it and close the account. If you believe a minor has provided us with information, contact help@twizzy.com.

11. Location of Processing

Twizzy is based in the United States, and the Services are intended for users in the United States. Your account information and Session recordings are stored in the United States. Some of our service providers may process information on their own systems in the United States or in other countries. Those countries may have data-protection laws different from those where you live. If you access the Services from outside the United States, you do so on your own initiative and understand that your information will be transferred to and processed in the United States.

12. Third-Party Links and Services

The Services may link to or integrate third-party websites and services, such as app stores, payment processors, podcast platforms, and social networks. Their privacy practices are governed by their own policies, and we are not responsible for them.

13. Changes to This Policy

We may update this Policy from time to time. If we make material changes, we will notify you by email, in-app notice, or a prominent notice on the Site before they take effect, and update the “Last Updated” date. Where the law requires, we will obtain your consent.

14. Contact Us

Sigmund Holdings LLC (“Twizzy”)
Attn: Privacy
3030 NE 188th St, Aventura, FL 33180

Privacy requests, questions, and support: help@twizzy.com