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") – Individual entrepreneur ULADZISLAU KREMENEUSKI, registered in Georgia.
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.
Third-Party AI Provider – external artificial intelligence service providers used to generate or process content.
UGC (User Generated Content) – any content created, uploaded, or published by users through the Service.
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.
2.1.4 Authentication Data
We support multiple authentication methods:
Telegram: Telegram user ID, premium status
Apple Sign-In: Apple UID, email (if provided), name
Google Sign-In: Google sub ID, email, name, profile picture URL
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:
Train a personalised AI model that generates your portraits.
Render those portraits inside the app and let you download them.
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 are deleted automatically 30 days after upload, except copy of first photo used as thumbnail.
3. User Generated Content (UGC) & Public Features
3.1 What You Can Publish
The Service includes a social feed where you may choose to publish AI-generated content. When you publish content, the following becomes visible to other users:
Media: AI-generated images or videos you choose to make public
Caption: Optional text description you add to your post (up to 2,000 characters)
Prompt: The text prompt used to generate the content (visible to enable "repeat" feature)
Model name: The AI model used for generation
3.2 Public Profile Information
If you use the social features, the following profile elements may be visible to others:
Username: Your chosen public username (3-30 characters)
Display name: Optional display name (up to 100 characters)
Bio: Optional biography text (up to 500 characters)
Avatar: Profile picture you upload or select
Statistics: Follower/following counts, total likes received
3.3 Social Interactions
We collect data about your social interactions:
Likes: Posts you have liked
Follows: Users you follow and users following you
Shares: When you copy prompts or repeat generations
Repeats: When you recreate content based on another user's post
3.4 Visibility Controls
You control the visibility of your generated content:
Private (default): Content is only visible to you
Public: Content appears in the public feed and on your profile
You can change visibility or unpublish content at any time.
3.5 Media Metadata
AI-generated content does not contain EXIF metadata, GPS coordinates, or camera information, as it is synthetically created. If you upload reference images, we do not extract or store EXIF metadata from them.
3.6 Legal Basis for UGC Processing
We process UGC data for the following purposes:
Displaying your content in the feed and on profiles (contract performance)
Enabling social features like likes, follows, and repeats (contract performance)
Content ranking, trending, and recommendations (legitimate interest)
Moderation and abuse prevention (legitimate interest, legal obligation)
Investigating reports and enforcing community guidelines (legitimate interest)
Promotional use: Public posts may be featured within the app or used in Twin AI marketing materials (legitimate interest)
4. AI Processing & Third-Party AI Providers
4.1 How AI Generation Works
Twin AI uses generative artificial intelligence to create images and videos. When you request a generation, the following data may be sent to AI processing systems:
Input images: Photos you upload or select as reference
Text prompts: Your description of what to generate
Face embeddings: Numeric vectors representing facial features (for personalised models)
Generation parameters: Resolution, style settings, model preferences
4.2 Third-Party AI Providers
We use the following categories of third-party AI providers to process your generation requests:
Image Generation Providers:
Provider Category
Purpose
Data Shared
Flux Models (Black Forest Labs)
High-quality image generation
Prompts, reference images, parameters
OpenAI (GPT Image/DALL-E)
Image generation and editing
Prompts, reference images
Proprietary Models
Specialised portrait generation
Face data, prompts, parameters
Video Generation Providers:
Provider Category
Purpose
Data Shared
Google Veo
AI video generation
Prompts, reference images
OpenAI Sora
AI video generation
Prompts, reference images
Runway
AI video generation
Prompts, reference images
Kling (Kuaishou)
AI video generation
Prompts, reference images
Hailuo (MiniMax)
AI video generation
Prompts, reference images
4.3 Your Consent for AI Processing
Important: By using the generation features, you explicitly consent to your data being processed by third-party AI providers as described above. This consent is obtained when you:
Upload photos for AI model training
Submit a generation request
Use the "repeat" feature on public posts
You may withdraw consent by discontinuing use of generation features. Previously generated content will remain unless you request deletion.
4.4 Data Processing by AI Providers
Third-party AI providers process your data under their own privacy policies and terms. We have data processing agreements with our providers that require:
Data to be used only for providing the requested service
Appropriate security measures
No use of your data for training their models (where contractually possible)
Deletion of data after processing (typically within 24-72 hours)
4.5 AI-Generated Content Notice
All content generated through our Service is created by artificial intelligence. When you publish AI-generated content:
You represent that you have rights to any input images used
You are responsible for ensuring content does not violate laws or third-party rights
AI-generated content may be removed if it violates our guidelines
5. Moderation & Safety
5.1 Content Moderation
To maintain a safe community, we employ:
Automated filtering: AI-based systems to detect prohibited content before publication
Human review: Manual review of flagged content and reports
Prompt filtering: Blocking of prompts that may generate harmful content
5.2 Reporting System
Users can report:
Posts: Report inappropriate, harmful, or policy-violating content
Users: Report accounts engaging in abuse or violations
Resolved: Action taken (content removed, user warned/banned)
Dismissed: No violation found
5.4 Enforcement Actions
We may take the following actions for policy violations:
Remove specific content
Restrict publishing privileges
Temporarily suspend accounts
Permanently ban accounts for severe or repeated violations
5.5 User Blocking
You can block other users to prevent them from viewing your profile or interacting with your content.
5.6 Contact for Abuse Reports
For urgent safety concerns or to report serious abuse, contact us at: [email protected]
6. Sharing and Disclosure of Personal Data
6.1 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.
6.2 Third-Party Service Providers
We share data with the following categories of service providers:
Category
Purpose
Examples
Cloud Hosting & Storage
Data storage, CDN, media delivery
Microsoft Azure
AI Processing
Image and video generation
See Section 4.2
Payment Processing
Subscription and purchase handling
Apple In-App Purchase
Push Notifications
Sending app notifications
Firebase Cloud Messaging (FCM)
Analytics
App usage analytics, crash reporting
Internal analytics system
6.3 General Sharing Scenarios
Personal Data may also be shared:
6.3.1 with Service Providers acting on our instructions;
6.3.2 during corporate transactions (merger, acquisition);
6.3.3 with Affiliates that comply with this Policy;
6.3.4 publicly if you choose to publish content (see Section 3);
6.3.5 with your explicit consent;
6.3.6 when required by law (court order, government request).
7. Retention and Deletion of Personal Data
7.1 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 [email protected] to erase it. Thumbnails are never stored longer than your Twin AI account.
7.2 UGC Retention
Published posts: Retained while published; deleted when you unpublish or delete your account
Private generations: Retained for your access; deleted upon account deletion
CDN caches: May persist for up to 24 hours after content deletion
Thumbnails/previews: Deleted together with source content
7.3 Moderation Logs Retention
Reports: Retained for 12 months after resolution for safety and legal purposes
Enforcement actions: Retained for 24 months to prevent repeat violations
Audit logs: Retained for 6 months for security investigations
7.4 Account Data
Active accounts: Data retained while account is active
Deleted accounts: Personal data anonymised or deleted within 30 days
Legal holds: Data may be retained longer if required for legal proceedings
7.5 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.
8. User Controls
8.1 Content Controls
You can:
Delete posts: Remove any content you have published
Change visibility: Switch posts between public and private
Edit profile: Update username, bio, and avatar at any time
Hide profile: Set all your content to private
8.2 Social Controls
Unfollow: Stop following any user
Block: Prevent specific users from seeing your content
Unlike: Remove your likes from posts
8.3 Data Rights
You have the right to:
Access: Request a copy of your personal data
Correction: Request correction of inaccurate data
Deletion: Request deletion of your data and account
Portability: Request export of your data in a portable format
Objection: Object to certain processing activities
Withdraw consent: Withdraw previously given consent
You may delete your account at any time. Upon deletion:
Your profile and all published content will be removed
Your generation history will be deleted
Face Data and trained models will be permanently erased
Some anonymised analytics data may be retained
Moderation logs may be retained as described in Section 7.3
9. Transfer of Personal Data
Personal Data may be processed outside your jurisdiction (including in the EU and US) where data-protection laws differ. We implement appropriate safeguards and only transfer data where adequate protection is ensured.
10. Security of Personal Data
We employ administrative, technical and physical measures to protect Personal Data:
Encryption at rest (AES-256) and in transit (TLS 1.2+)
Access controls and authentication
Regular security assessments
Secure development practices
However, no system is 100% secure. We cannot guarantee absolute security.
11. Children's Privacy
The Service is not directed to children under 13 (or 16 in certain jurisdictions). We do not knowingly collect data from them. Parents may contact us to delete any data collected inadvertently.
12. Links to Other Websites
Our Service may contain links to external sites. We are not responsible for their content or privacy practices.
13. 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.
14. Contact Us
For questions about this Privacy Policy, your Personal Data, or to exercise your rights, contact us at:
Twin AI