Privacy Policy

This Privacy Policy explains how TimesTwo collects, uses, stores, and protects your personal data when you use our website, web app, membership platform, merchant portal, rewards features, and related services. Please read this policy carefully to understand our practices.

TimesTwo is a Malta-based rewards platform operated by Dejean Pisani trading as TimesTwo. For privacy questions or data rights requests, please contact us at hello@timestwo.com.mt.

We collect the personal data necessary to provide our membership service, process payments, operate the rewards programme, support merchants, and meet our legal obligations.

Member data may include:

• ●Full name, email address, and phone number.
• ●Account login details and authentication information.
• ●Membership status, subscription status, and payment status.
• ●Consent records, including acceptance of Terms and marketing preferences.
• ●A member ID or barcode used to identify your account within the platform.
• ●Points balance, rewards, redemption history, and transaction records.

Merchant and business user data may include:

• ●Business name, contact email, and phone number.
• ●Business profile details, logos, images, and listing information.
• ●Transaction, redemption, and offer management activity.

Technical data collected automatically may include:

• ●Device type, browser information, and IP address.
• ●Session, security, and log data needed to operate the platform securely.

• ●To create and manage your account and membership.
• ●To process payments and subscriptions.
• ●To operate the rewards programme, including points earning, redemptions, and merchant offers.
• ●To verify member status during merchant interactions.
• ●To send transactional and account-related communications.
• ●To send marketing emails, if you have opted in.
• ●To maintain platform security, detect fraud, and prevent abuse.
• ●To comply with legal and regulatory obligations.
• ●To handle support requests and complaints.

We process your personal data under one or more of the following legal bases, depending on the purpose:

• ●Contract: to provide the membership service, process payments, and fulfil our obligations to you.
• ●Legitimate interests: to operate the platform securely, prevent fraud, support merchants, and improve our service.
• ●Legal obligation: to comply with applicable laws, including financial and tax requirements.
• ●Consent: to send marketing communications, where you have opted in.

Marketing emails are optional. During signup, you may choose to opt in to receive offers, rewards updates, and promotional communications from TimesTwo. We record your marketing preference and the date you gave or withdrew consent.

You may withdraw your marketing consent at any time by contacting us at hello@timestwo.com.mt or by using the unsubscribe link in any marketing email we send. Withdrawing marketing consent does not affect your membership or access to the platform.

Payments are processed by a third-party payment provider on our behalf. When you make a payment, your card details are processed directly and securely by that provider. TimesTwo does not store your full card number or payment credentials. Payment providers may process data in accordance with their own privacy policies and applicable financial regulations.

We work with trusted service providers that help us operate, secure, process payments for, and improve TimesTwo. These providers may include payment providers, hosting providers, infrastructure providers, authentication providers, analytics providers, and communication providers where required.

We do not sell your personal data.

Where necessary for the operation of the rewards programme, we may share limited member information with participating merchants. This is limited to what is needed for member verification, transaction processing, reward redemptions, and customer support. Merchants must not use member data for any purpose outside of their legitimate participation in TimesTwo.

TimesTwo may display a member ID or barcode in your account. This is used to identify your membership within the platform during merchant interactions. It does not by itself constitute proof of identity or payment. Merchants and TimesTwo verify account status through our platform.

We retain your personal data only for as long as necessary for the purposes set out in this policy, including:

• ●Account and membership data is retained while your account is active and for a reasonable period afterwards.
• ●Payment and transaction records may be retained as required for tax, accounting, and legal purposes.
• ●Marketing consent records are retained as long as necessary to demonstrate consent or opt-out status.
• ●Security and activity logs are retained for a reasonable operational period.

We use appropriate technical and organisational measures to protect your personal data, including secure authentication, role-based access controls, and trusted service providers. No online system is completely secure, and we encourage you to keep your login details confidential.

Some of our service providers may process data outside Malta or the European Economic Area. Where this occurs, we rely on appropriate safeguards, such as adequacy decisions or standard contractual clauses, in accordance with GDPR requirements.

Subject to applicable law, you have the right to:

• ●Access the personal data we hold about you.
• ●Request correction of inaccurate data.
• ●Request deletion of your data in certain circumstances.
• ●Object to or restrict certain processing.
• ●Request a copy of your data in a portable format.
• ●Withdraw consent where processing is based on consent.

To exercise any of these rights, contact us at hello@timestwo.com.mt. We may need to verify your identity before responding.

You also have the right to lodge a complaint with the Malta Information and Data Protection Commissioner (IDPC).

TimesTwo is intended for users who can lawfully enter into a paid membership. Users under 18 should use the platform only with the involvement and consent of a parent or legal guardian. If we become aware that a minor has created an account without appropriate consent, we may suspend or remove it.

We may update this Privacy Policy from time to time. The latest version will always be available in the app and on our website. We will notify you of material changes where appropriate.

For privacy questions or data rights requests, contact us at hello@timestwo.com.mt.