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Privacy Policy

Last updated: 12/6/2025

1. Introduction

At Twinly, we are committed to protecting your privacy. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our AI tutoring platform. Please read this policy carefully to understand our practices regarding your data.

2. Information We Collect

2.1 Information You Provide

  • Account information (name, email address, password)
  • Payment information (processed securely through third-party payment processors)
  • Profile information and preferences
  • Questions, problems, and interactions with the AI tutor
  • Whiteboard content and drawings

2.2 Automatically Collected Information

  • Usage data and interaction patterns
  • Device information (browser type, operating system)
  • IP address and location data
  • Cookies and similar tracking technologies
  • Voice recordings (processed in real-time, not stored)

3. How We Use Your Information

We use the information we collect to:

  • Provide, maintain, and improve the Service
  • Process your transactions and manage your account
  • Personalize your learning experience
  • Generate AI responses and educational content
  • Send you service-related communications
  • Monitor and analyze usage patterns
  • Detect, prevent, and address technical issues
  • Comply with legal obligations

4. Data Storage and Security

We implement appropriate technical and organizational measures to protect your personal information:

  • Encryption of data in transit and at rest
  • Secure authentication and access controls
  • Regular security assessments and updates
  • Limited access to personal data on a need-to-know basis

However, no method of transmission over the Internet or electronic storage is 100% secure. While we strive to use commercially acceptable means to protect your information, we cannot guarantee absolute security.

5. Voice and Audio Data

Twinly processes voice conversations in real-time to provide the tutoring service. Voice data is:

  • Processed in real-time for speech-to-text conversion
  • Not permanently stored or recorded
  • Transmitted securely using encrypted connections
  • Used solely to provide the tutoring service

6. AI and Machine Learning

To improve our AI tutoring capabilities, we may use your interactions (questions, problems, whiteboard content) to train and improve our AI models. This data is:

  • Anonymized before use in model training
  • Used to improve educational accuracy and responses
  • Never shared with third parties in identifiable form

7. Information Sharing and Disclosure

We do not sell your personal information. We may share your information only in the following circumstances:

  • Service Providers: With trusted third-party service providers who assist in operating our platform (payment processing, cloud hosting, analytics)
  • Legal Requirements: When required by law or to protect our rights and safety
  • Business Transfers: In connection with a merger, acquisition, or sale of assets
  • With Your Consent: When you explicitly authorize us to share your information

8. Your Rights and Choices

You have the following rights regarding your personal information:

  • Access: Request a copy of the personal information we hold about you
  • Correction: Update or correct inaccurate information
  • Deletion: Request deletion of your personal information
  • Portability: Request transfer of your data to another service
  • Opt-out: Unsubscribe from marketing communications
  • Account Deletion: Delete your account and associated data through account settings

To exercise these rights, please contact us at privacy@twinly.com.

9. Children's Privacy

Twinly is designed for users aged 13 and older. We do not knowingly collect personal information from children under 13. If we become aware that we have collected information from a child under 13, we will take steps to delete such information promptly. If you believe we have collected information from a child under 13, please contact us immediately.

10. Cookies and Tracking Technologies

We use cookies and similar tracking technologies to enhance your experience, analyze usage, and assist with marketing efforts. You can control cookies through your browser settings, though this may affect some functionality of the Service.

11. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence. These countries may have data protection laws that differ from those in your country. We ensure appropriate safeguards are in place to protect your information in accordance with this Privacy Policy.

12. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of any material changes by posting the new Privacy Policy on this page and updating the "Last updated" date. We encourage you to review this Privacy Policy periodically.

13. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please contact us at:

Email: privacy@twinly.com

Support: support@twinly.com