Privacy Policy

Last updated: July 04, 2025

This Privacy Policy describes (i) what Personal Data we collect when you use the Twin AI mobile application (the “Service”), (ii) how we use, store and share that data, and (iii) what rights you have. By using the Service, you agree to the terms below.

1. Interpretation and Definitions

1.1 Interpretation

Capitalised words have the meanings given in section 1.2, whether they appear in singular or plural.

1.2 Definitions

• Account – a unique account created for You to access the Service.
• Affiliate – an entity that controls, is controlled by, or is under common control with a party.
• Application / Service – the Twin AI software program provided by the Company.
• Company (“Twin AI”, “we”, “us”, “our”).
• Country – Georgia.
• Device – any device that can access the Service (computer, phone, tablet).
• Face Data – see 2.1.3 (photo, face embedding, generated portrait).
• Personal Data – any information relating to an identified or identifiable individual.
• Service Provider – a natural or legal person who processes data on behalf of the Company.
• Usage Data – data collected automatically (e.g. IP address, session length, device ID).
• You / User – the individual or legal entity accessing the Service.

2. Collecting and Using Your Personal Data

2.1 Types of Data Collected

2.1.1 Personal Data

While using the Service we may ask you to provide Personal Data, including (but not limited to) Account credentials and Usage Data.

2.1.2 Usage Data

Collected automatically when you interact with the Service (device information, IP address, pages visited, timestamps, crash logs, etc.).

2.1.3 Face Data We Collect

When you create an AI Portrait, we collect the following categories of “Face Data” (Apple DPLA §3.3.3 L):

• Original Uploaded Photos – the images you select (user-provided).
• Face Embeddings – 512-dimensional numeric vectors computed on our servers.
• Generated Portraits – stylised images returned to you after processing.
• Avatar Thumbnails – a low-resolution copy of the first photo in each avatar set, shown in the app list.

We do not collect depth maps, live camera video, or any biometric template suitable for authentication. Facial-landmark points are produced transiently during processing and discarded together with the Original Photos.

2.2 Use of Your Personal Data

The Company uses Personal Data to:

• 2.2.1 provide, operate and maintain the Service;
• 2.2.2 manage your Account and purchases;
• 2.2.3 contact you with service-related notices;
• 2.2.4 respond to your requests and improve our Service;
• 2.2.5 carry out business transfers (if applicable);
• 2.2.6 perform analytics and develop new features (aggregated, non-identifiable).

2.2.7 How We Use Face Data

Face Data is used exclusively to:

1. Train a personalised AI model that generates your portraits.
2. Render those portraits inside the app and let you download them.
3. Display a thumbnail for each avatar set in the “My Avatars” screen.

Face Data is never used for identification, advertising, marketing or analytics.

All original photos, deleted automatically 30 days after upload, except copy of first photo used as thumbnail.

3. Sharing and Disclosure of Personal Data

3.1 Disclosure of Face Data

Face Data is stored and processed only by Microsoft Azure Blob Storage under a signed Data Processing Addendum (DPA).

• Purpose: storage and processing of Face Data required to provide the Service
• Recipient: Microsoft Azure Blob Storage (data processor)
• Location: West Europe data-centre
• Security: AES-256 encryption at rest; TLS 1.2+ in transit

We do not sell, license or share Face Data with any other third parties.

3.2 General Sharing Scenarios

Personal Data may also be shared:

• 3.2.1 with Service Providers acting on our instructions;
• 3.2.2 during corporate transactions (merger, acquisition);
• 3.2.3 with Affiliates that comply with this Policy;
• 3.2.4 with business partners to offer relevant promotions;
• 3.2.5 publicly if you choose to share content;
• 3.2.6 with your explicit consent;
• 3.2.7 when required by law (court order, government request).

4. Retention and Deletion of Personal Data

4.1 Face Data Retention

Face Data is retained for 30 days after upload and then permanently deleted, except first photo as your avatar thumbnail. You may send a request to kadekim2046@gmail.com to erase it. Thumbnails are never stored longer than your Twin AI account. To delete all Face Data sooner, email us from the address linked to your account at kadekim2046@gmail.com; we will erase the data and confirm within 30 calendar days.

4.2 Other Personal Data

We keep other Personal Data only as long as necessary to comply with legal obligations, resolve disputes, or enforce agreements. Usage Data for analytics is generally retained for a shorter period or anonymised.

5. Transfer of Personal Data

Personal Data may be processed outside your jurisdiction (including in the EU) where data-protection laws differ. We implement appropriate safeguards and only transfer data where adequate protection is ensured.

6. Security of Personal Data

We employ administrative, technical and physical measures to protect Personal Data, but no system is 100 % secure. We cannot guarantee absolute security.

7. Children’s Privacy

The Service is not directed to children under 13. We do not knowingly collect data from them. Parents may contact us to delete any data collected inadvertently.

8. Links to Other Websites

Our Service may contain links to external sites. We are not responsible for their content or privacy practices.

9. Changes to This Privacy Policy

We may update this Policy from time to time. We will notify you by updating the “Last updated” date and, where material, by email or in-app notice.

10. Contact Us

For questions about this Privacy Policy or your Personal Data, contact us at: kadekim2046@gmail.com