Privacy Policy

This Privacy Statement explains our practices, including your choices, regarding the collection, use, and disclosure of certain information, including your personal information in connection with Comedy App Ltd. t/a Twisted Mirror service.

Collection of Information

We receive and store information about you such as:

• Information you provide to us: We collect information you provide to us which includes:
• your name, email address and other identifiers you might use (such as your profile name). We collect this information in a number of ways, including when you enter it while using our service, interact with our customer service, or participate in surveys or marketing promotions;
• information when you choose to provide ratings, taste preferences, account settings (including preferences set in the "Account" section of our website), or otherwise provide information to us through our service or elsewhere.
• Information we collect automatically: We collect information about you and your use of our service, your interactions with us and our advertising, as well as information regarding your network, network devices, and your computer or other Twisted Mirror capable devices you might use to access our service (such as smart TVs, mobile devices, set top boxes, and other streaming media devices). This information includes:
• your activity on the Twisted Mirror service, such as title selections, shows you have watched, ads viewed (if applicable) and search queries;
• your interactions with our emails and texts, and with our messages through push and online messaging channels;
• details of your interactions with our customer service, such as the date, time and reason for contacting us, transcripts of any chat conversations, and if you call us, your phone number and call recordings;
• device IDs or other unique identifiers, including for your network devices (such as your router), and devices that are Twisted Mirror capable on your network;
• resettable device identifiers (also known as advertising identifiers), such as those on mobile devices, tablets, and streaming media devices that include such identifiers (see the "Cookies and Internet Advertising" section below for more information);
• device and software characteristics (such as type and configuration), connection information including type (wifi, cellular), statistics on page views, referring source (for example, referral URLs), IP address (which can be used to tell us your general location, such as your city, state/province, and postal code), browser and standard web server log information;
• information collected via the use of cookies, web beacons and other technologies, including ad information (such as information on the availability and delivery of ads, the site URL, as well as the date and time). (See our "Cookies and Internet Advertising" section for more details.)
• Information from partners: We collect information from other companies with whom you have a relationship (“Partners”). These Partners might include (depending on what services you use): your TV or internet service provider, or other streaming media device providers who make our service available on their device; mobile phone carriers or other companies who provide services to you and collect payment for the Twisted Mirror service for distribution to us or provide pre-paid promotions for the Twisted Mirror service; and voice assistant platform providers who enable interaction with our service through voice commands. The information Partners provide us varies depending on the nature of the Partner services, and may include:
• search queries and commands applicable to Twisted Mirror that you make through Partner devices or voice assistant platforms;
• service activation information such as your email address or other contact information;
• IP addresses, device IDs or other unique identifiers, as well as associated pre-paid promotion, billing and user interface information, that support user authentication, the Twisted Mirror service registration experience, Partner payment processing, and the presentation of Twisted Mirror content to you through portions of the Partner user interface.
• Information from other sources: We also obtain information from other sources. We protect this information according to the practices described in this Privacy Statement, plus any additional restrictions imposed by the source of the information. These sources vary over time, but could include:
• service providers that help us determine a location based on your IP address in order to customize our service and for other uses consistent with this Privacy Statement;
• security service providers that provide us with information to secure our systems, prevent fraud and help us protect the security of Twisted Mirror accounts;
• advertisers that run ad campaigns on Twisted Mirror (“Advertisers”) that might provide us with: identifiers (for example, cookies or resettable identifiers); and information about your interests, including demographic information and your activities online (such as websites visited, apps used and ads viewed);
• service providers that facilitate the sale, operations, and management of ads, in the context of our ad supported subscription plans (“Ad Service Providers”)
• ad measurement companies that support Twisted Mirror and Advertisers in understanding the effectiveness of ad campaigns run on Twisted Mirror (“Ad Measurement Companies”); 
• online and offline information providers to support our ad supported subscription plans;
• publicly-available sources such as publicly available posts on social media platforms and information available through public databases associating IP addresses with internet service providers (ISPs);

Use of Information

We use information to provide, analyze, administer, enhance and personalize our services and marketing efforts, to provide, analyze, administer, enhance and select ads in connection with our ad supported subscription plans, to process your registration, your orders and your payments, and to communicate with you on these and other topics. For example, we use such information to:

• provide you with customized and personalized viewing recommendations for movies, and TV shows we think will be of interest to you (collectively “content”);
• determine your general geographic location (such as your city, state/province, and postal code);
• provide localized content;
• determine your ISP to support network troubleshooting for you (we also use aggregated ISP information for operational and business purposes);
• help us quickly and efficiently respond to inquiries and requests;
• coordinate with Partners on making the Twisted Mirror service available to members and providing information to non members about the availability of the Twisted Mirror service, based on the specific relationship you have with the Partner;
• secure our systems, prevent fraud and help us protect the security of Twisted Mirror accounts;
• prevent, detect and investigate potentially prohibited or illegal activities, including fraud, and to enforce our terms (such as determining whether and for which Twisted Mirror signup offers you are eligible and determining whether a particular device is permitted to use the account consistent with our Terms of Use);
• analyze and understand our audience, improve our service (including our user interface experiences and service performance) and optimize content or ad selection, recommendation algorithms and delivery;
• communicate with you concerning our service so that we can send you news about Twisted Mirror, details about new features and content available on Twisted Mirror, special offers, promotional announcements, consumer surveys, and to assist you with operational requests such as password reset requests. These communications may be by various methods, such as email, push notifications, text message, online messaging channels, and matched identifier communications (described below). Please see the "Your Choices" section of this Privacy Statement to learn how to set or change your communications preferences and to learn more about matched identifier communications.

Our legal basis for collecting and using the personal information described in this Privacy Statement will depend on the personal information concerned and the specific context in which we collect and use it. We will normally collect personal information from you where we need the personal information to perform a contract with you (for example, to provide our services to you), where the processing is in our legitimate interests and not overridden by your data protection interests or fundamental rights and freedoms (for example, our direct marketing activities in accordance with your preferences), or where we have your consent to do so (for example, for you to participate in certain consumer insights activities like specific surveys and focus groups). In some cases, we may also have a legal obligation to collect personal information from you or may otherwise need the personal information to protect your vital interests or those of another person (for example, to prevent payment fraud or confirm your identity). For questions about our use of your personal information (including legal bases and transfer mechanisms we rely on), cookies or similar technologies, please contact us by email at support@twistedmirror.tv.

Disclosure of Information

We disclose your information for certain purposes and to third parties, as described below:

• Service Providers: We use other companies, agents or contractors ("Service Providers") to perform services on our behalf or to assist us with the provision of services to you. For example, we engage Service Providers to provide marketing, advertising, communications, security, infrastructure and IT services, to customize, personalize and optimize our service, to provide bank account or balance information, process credit card transactions or other payment methods, to provide customer service, to analyze and enhance information (including information about users' interactions with our service), and to process and administer consumer surveys. We engage Ad Service Providers in the context of our ad supported subscription plans. In the course of providing such services, these Service Providers may have access to your personal or other information. We do not authorize them to use or disclose your personal information except in connection with providing their services (which includes maintaining and improving their services).
• Partners: As described above, you may have a relationship with one or more of our Partners, in which case we may share certain information with them in order to coordinate with them on providing the Twisted Mirror service to members and providing information about the availability of the Twisted Mirror service. For example, depending on what Partner services you use, we may share information:
• in order to facilitate Partner pre-paid promotions or collection of payment for the Twisted Mirror service for distribution to us;
• with Partners who operate voice assistant platforms that allow you to interact with our service using voice commands;
• so that content and features available in the Twisted Mirror service can be suggested to you in the Partner’s user interface. For members, these suggestions are part of the Twisted Mirror service and may include customized and personalized viewing recommendations.
• Advertisers/Ad Measurement Companies: We may share information collected from or about you with Advertisers and/or Ad Measurement Companies to select advertisements, and measure and improve advertising effectiveness. As a reminder, please see the Information from Other Sources section above if you have questions regarding the role of Advertisers or Ad Measurement Companies.
• Promotional offers: We may offer joint promotions or programs that, in order for your participation, will require us to share your information with third parties. In fulfilling these types of promotions, we may share your name and other information in connection with fulfilling the incentive. Please note that these third parties are responsible for their own privacy practices.
• Protection of Twisted Mirror and others: Twisted Mirror and its Service Providers may disclose and otherwise use your personal and other information where we or they reasonably believe such disclosure is needed to (a) satisfy any applicable law, regulation, legal process, or governmental request, (b) enforce applicable terms of use, including investigation of potential violations thereof, (c) detect, prevent, or otherwise address illegal or suspected illegal activities (including payment fraud), security or technical issues, or (d) protect against harm to the rights, property or safety of Twisted Mirror, its users or the public, as required or permitted by law.
• Business transfers: In connection with any reorganization, restructuring, merger or sale, or other transfer of assets, we will transfer information, including personal information, provided that the receiving party agrees to respect your personal information in a manner that is consistent with our Privacy Statement.

Whenever in the course of sharing information we transfer personal information to other countries, we will ensure that the information is transferred in accordance with this Privacy Statement and as permitted by the applicable laws on data protection. Specifically, we use a variety of contractual, organizational and technical protections as appropriate for such transfers, including data protection agreements and the UK International Data Transfer Addendum (available here) to the EU standard contractual clauses (available here); technical protections such as encryption, and practices to challenge disproportionate or unlawful government authority requests. You can find out more about how we disclose and transfer your personal information internationally further below.

You may also choose to disclose your information in the following ways:

• certain portions of our service may contain a tool which gives you the option to share information by email, text message and social or other sharing applications, using the clients and applications on your smart device;

Social plugins and social applications are operated by the social networks themselves, and are subject to their terms of use and privacy policies.

Access to Account and Profiles

• “Remember me” function: For ease of access to your account, you can use the "Remember me on this device" function when you log in to the website. This function uses technology that enables us to provide direct account access and to help administer the Twisted Mirror service without requiring re-entry of any password or other user identification when your browser revisits the service. 
• Giving others access to your account: If you share or otherwise allow others to have access to your account, they will be able to see shows you have watched, ratings, account information (including your email address or other information in the "Account" area of our website). This remains true even if you use our profiles feature. You might have the option to use seamless account login through the Twisted Mirror mobile app, which enables login to the Twisted Mirror app on smart TVs, set top boxes, and other streaming media devices on the network to which you are connected. If you use that feature, those devices will remain signed into your account unless you later log out of those devices.
• Profiles: Profiles allow users to have a distinct, personalized Twisted Mirror experience, built around the movies and shows of interest to them, as well as separate watch histories. Please note that profiles are available to everyone who uses your Twisted Mirror account, so that anyone with access to your Twisted Mirror account can navigate to and use, edit or delete profiles. You should explain this to others with access to your account, and if you do not wish them to use or change your profile, be sure to let them know.

Your Choices

Email and Text Messages. Click the "unsubscribe" link in the email or reply STOP (or as otherwise instructed) to the text message. Please note that you cannot unsubscribe from service-related correspondence from us, such as messages relating to your account transactions.

Push Notifications. You can choose to receive mobile push notifications from Twisted Mirror. On some device operating systems, you will be automatically enrolled in the notifications. If you subsequently decide you no longer wish to receive these notifications, you can use your mobile device's settings functionality to turn them off. We also offer push notifications on certain web browsers. If you agree to receive those notifications and subsequently decide you no longer wish to receive these notifications, you can use your browser’s settings to turn them off.

Behavioural Advertising. Behavioural advertisements are those that are selected based on your use and/or interactions with various unaffiliated third party apps or websites across the Internet (behavioural advertising). Twisted Mirror can advertise its services using behavioural advertising, and if you are using a browser, then certain cookies and web beacons can be used to collect information to help determine your likely interests. If you are using a mobile device, tablet, or streaming media device that includes a resettable device identifier, then that identifier can be used to help determine your likely interests.

Ad Supported Service - Demographic Information Collection. If you subscribe to our service, we will ask you to provide us with demographic information including your date of birth and gender. This information is optional, and you can choose not to provide that information. We can use this demographic information to select ads to present to you and for other uses as set out in this Privacy Statement.

If you opt out of sharing this demographic information to select ads for you, you will still see ads, but they will not be based on this demographic information.

Cookies and Internet Advertising

We and our Service Providers use cookies and other technologies (such as web beacons), as well as resettable device identifiers, for various reasons. We want you to be informed about our use of these technologies, so this section explains the types of technologies we use, what they do, and your choices regarding their use. 

Cookies and similar technologies, web beacons, and resettable device identifiers

Cookies are small data files that are commonly stored on your device when you browse and use websites and online services. We use other technologies such as browser storage and plugins (e.g., HTML5, IndexedDB, and WebSQL). Like cookies, these other technologies may store small amounts of data on your device. Web beacons (also known as clear gifs or pixel tags) often work in conjunction with cookies. In many cases, declining cookies will impair the effectiveness of web beacons associated with those cookies.

If you use the Twisted Mirror app on a mobile device, tablet, or streaming media device, we may collect a resettable device identifier from your device. Resettable device identifiers (also known as advertising identifiers) are similar to cookies and are found on many mobile devices and tablets (for example, the "Identifier for Advertisers" (or IDFA) on Apple iOS devices and the "Google Advertising ID" on Android devices), and certain streaming media devices. Like cookies, resettable device identifiers are used to make online advertising more relevant and for analytics and optimization purposes.   

Why does Twisted Mirror use these technologies?

We use these types of technologies for various reasons, like making it easy to access our services by remembering you when you return; to provide, analyze, understand and enhance the use of our services; to enforce our terms, prevent fraud; to improve site performance, monitor visitor traffic and actions on our site; and to deliver and tailor our marketing or advertising, and to understand interactions with our emails, marketing, and online ads on third party sites. We may also use these technologies to support the operation of our ad supported subscription plans.

To help you better understand how we use cookies and resettable device identifiers, please see the information below:

• Essential cookies: These cookies are strictly necessary to provide our website or online service. For example, we and our Service Providers may use these cookies to authenticate and identify our members when they use our websites and applications so we can provide our service to them. They also help us to enforce our Terms of Use, prevent fraud and maintain the security of our service. 
• Performance and functionality cookies: These cookies help us to customize and enhance your online experience with Twisted Mirror. For example, they help us to remember your preferences and prevent you from needing to re-enter information you previously provided (for example, during member sign up). We also use these cookies to collect information (such as popular pages, conversion rates, viewing patterns, click-through and other information) about our visitors' use of the Twisted Mirror service so that we can enhance and personalize our website and service and conduct market research. Deletion of these types of cookies may result in limited functionality of our service. 
• Advertising cookies and resettable device identifiers: These cookies and resettable device identifiers use information about your use of this and other websites and apps, your response to ads and emails, and to deliver ads that are more relevant to you and for analytics and optimization purposes.

When we advertise our services on other websites or apps, some of the websites and apps where we advertise, as well as advertising technology companies that we use to purchase, deliver, optimize, and/or measure our advertisements (collectively “Advertising Partners”), may receive information from us as part of our campaign targeting, measurement, and optimization (e.g., steps completed in sign-up and site visit or app open/install information). Common uses of this type of information are to judge the effectiveness of and optimize ad campaigns, by allowing Advertising Partners to see when someone who saw an ad later signed up for our service. Another common use is to make sure we do not serve ads trying to get individuals to sign up for the Twisted Mirror service if they are already a Twisted Mirror user. Twisted Mirror uses contractual and technical measures designed to prevent Advertising Partners from accessing information regarding specific title selections you make, URLs you land on, or shows you have watched on our service. We do not share information about title selections or your shows you have watched on our service. 

In connection with our ad supported subscription plans, Twisted Mirror, our Ad Service Providers, and Ad Measurement Companies can use these technologies to operate and support our ad supported subscription plans, including supporting an Advertiser’s ad campaigns, measurement, and optimization of the same.

Your Information and Rights

You can request access to your personal information, or correct or update out-of-date or inaccurate personal information we hold about you. You may also request that we delete personal information that we hold about you.

You can object to processing of your personal information, ask us to restrict processing of your personal information or request portability of your personal information; if we have collected and process your personal information with your consent, then you can withdraw your consent at any time; withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Retention of Information: We may retain information as required or permitted by applicable laws and regulations, including to honor your choices, for our billing or records purposes and to fulfill the purposes described in this Privacy Statement. Specifically, we retain information for our legitimate interests and essential business purposes, such as operating, maintaining and improving our services; complying with our legal obligations; and exercising our legal rights and remedies, including enforcing our terms of use. Our retention of information is based on many factors such as your relationship with Twisted Mirror (for example, are you a Twisted Mirror current member); the nature of the information; compliance with our legal obligations; defending or resolving actual or anticipated legal claims. We take reasonable measures to destroy or de-identify personal information in a secure manner when it is no longer required.

Security

We use reasonable administrative, logical, physical and managerial measures to safeguard your personal information against loss, theft and unauthorized access, use and modification. These measures are designed to provide a level of security appropriate to the risks of processing your personal information.

Other Websites, Platforms and Applications

The Twisted Mirror service may be provided through and/or utilize features (such as the display of social media content, or the provision of voice controls) operated by third party platforms, or contain links to sites operated by third parties whose policies regarding the handling of information may differ from ours. For example, you may be able to access the Twisted Mirror service through platforms such as smart TVs, mobile devices, set top boxes and a number of other Internet connected devices or ads displayed may allow you to interact with them through clicking them. These websites and platforms have separate and independent privacy or data policies, privacy statements, notices and terms of use, which we recommend you read carefully. In addition, you may encounter third party applications that interact with the Twisted Mirror service.

Children

You must be at least 18 years of age or older to subscribe to the Twisted Mirror service. Minors may only use the service with the involvement, supervision, and approval of a parent or legal guardian.

Changes to This Privacy Statement

We will update this Privacy Statement from time to time in response to changing legal, regulatory or operational requirements. We will provide notice of any such changes (including when they will take effect) in accordance with law. Your continued use of the Twisted Mirror service after any such updates take effect will constitute acknowledgement and (as applicable) acceptance of those changes. If you do not wish to acknowledge or accept any updates to this Privacy Statement, you may cancel your use of the Twisted Mirror service. To see when this Privacy Statement was last updated, please see the "Last Updated" section below.

Contacting Us

If you have general questions about your account or how to contact customer service for assistance, please email us at support@twistedmirror.tv.

The data controller of your personal information is Comedy App Ltd. Please note that if you contact us to assist you, for your safety and ours we may need to authenticate your identity before fulfilling your request.

Disclosure and International Transfers

We take necessary measures to ensure that personal information transferred internationally is protected in accordance with GDPR/UK laws and the internal policies of Comedy App Ltd. t/a Twisted Mirror.

For the purposes stated in our Privacy Statement we may disclose and make international transfers of personal information as follows:

(The following list is subject to change. Not all ad service, customer service, and payments processing providers are in use in all countries.)

Last Updated: Mar 1, 2024