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Privacy Policy

Last updated: October 13, 2026

1. Who we are

Twiny ("we", "us") is a platform where creators and businesses build an AI twin that learns their voice and style, plans and generates social content (text, images, video and audio) and can reply to their audience on messaging channels. Twiny is operated by LOUM MATAR, ditta individuale (an Italian sole proprietorship), which is the data controller for the personal data described here. Website: twiny.dev. Privacy contact: privacy@twiny.dev.

2. Data we collect

We collect only what we need to run the service:

  • Account data: name, email and profile picture, through our sign-in provider Clerk.
  • Twin content: persona and style notes, knowledge you add (text, files, links, videos), reference images, and the voice samples and face photos you upload (see section 3).
  • Generated content: the images, videos, music, audio, scripts and storyboards your twin creates for you.
  • Connected accounts: when you connect Instagram, YouTube, TikTok, X, WhatsApp or Telegram, we store the access tokens needed to publish or reply on your behalf. You can disconnect them at any time.
  • Audience conversations: messages people send to your twin and its replies (see section 4).
  • Payment data: handled by Stripe. We never see or store full card numbers.
  • Usage data: technical logs and anonymous page statistics (Vercel Analytics, which uses no cookies), used to keep the service secure and working. Our server logs do not record the text of audience messages.
  • Activity in the app: while you are signed in, we record when you last used Twiny and in which section (for example Media Studio), so our team can see who is online and help you. We do not record your IP address, your location or what you write. Only Twiny administrators can see it.

3. Voice and face data

Voice samples and face photos you upload to create your twin (for example to clone your voice or to generate images and videos of you) can identify you. We treat them as special-category (biometric) data and process them only with your explicit consent (Article 9(2)(a) GDPR).

  • You give consent with a checkbox when you upload a voice sample or a face photo. Without it the upload does not go ahead.
  • We use this data only to create and run your twin: to generate your voice and images or videos of you when you ask for them. We do not use it to identify you or anyone else for other purposes.
  • To create a cloned voice, the voice sample is sent to ElevenLabs, which creates and stores the voice model for us. Face photos are sent to the image and video models listed in section 6 only when you generate content with them.
  • You can withdraw consent at any time by deleting the voice or photo in Twiny, or by deleting your account. We then delete the files from our storage and the cloned voice from ElevenLabs. Withdrawal does not affect processing that happened before it.
  • Only upload the voice or face of another person if they have given you their explicit written consent. If someone uploaded your face or voice without permission, write to privacy@twiny.dev and we will remove it.

4. If you chat with a creator's twin

This section is for fans and customers who write to a creator's or business's twin on WhatsApp, Telegram, Instagram or the web chat. The creator decides to use Twiny; we process your data to run their twin for them.

  • Replies are written by AI, not by the creator in person. The creator can read the conversation and may step in.
  • What we store: your messages and the twin's replies, your phone number or username on that channel, your display name if the channel shares it, and, if you subscribe to the creator, your subscription and payment status (payments go through Stripe).
  • Why: to deliver replies, keep the context of the conversation for that creator, and handle subscriptions you choose to buy.
  • How long: while the creator's account and twin exist. If the creator deletes the twin or the account, the conversation is deleted too.
  • Your choices: send STOP on WhatsApp to stop messages, or ask for a copy or deletion of your conversation by writing to privacy@twiny.dev with the channel and the number or username you used.

5. Why we use it (legal bases)

  • To provide the service you signed up for: your twin, generation, publishing and messaging (performance of a contract).
  • To process voice samples and face photos: your explicit consent (see section 3).
  • To process payments and keep accounting records (contract and legal obligation).
  • To send service emails about your account, billing and important changes (contract).
  • To keep Twiny secure, prevent abuse and fix problems (legitimate interest).
  • To reply to people who message a creator's twin: the creator's legitimate interest in answering their audience, and the contract when a fan buys a subscription.
  • To measure our advertising with the Meta Pixel, only if you click "Accept all" in the cookie banner (consent, which you can withdraw).
  • We do not use your content to train AI models, and we never sell your personal data.

6. Who processes data for us

We share data only with providers that help us run Twiny, and only what each one needs:

  • Kie.ai: access to AI models (including Anthropic Claude and other text, image and video models) that write and generate your content, and to Suno for music generation (Suno is reached through Kie.ai).
  • OpenAI: knowledge-base search (embeddings) and some AI replies.
  • ElevenLabs: voice generation, voice cloning (only when you create a custom voice) and transcription.
  • Hera: motion graphics videos.
  • Neon: database hosting in the EU (Frankfurt, Germany).
  • Cloudflare R2: storage of your media files.
  • Vercel: website hosting and cookieless page statistics (Vercel Analytics).
  • Render and Inngest: background processing (video rendering, AI backend, job queue).
  • Clerk: sign-in and account management.
  • Stripe: payments and subscriptions.
  • Resend: service emails.
  • Meta, Google (YouTube), TikTok, X and Telegram: only when you connect those accounts, to publish and deliver messages for you. Meta also receives Pixel data if you accept advertising cookies.
  • Slack: internal notifications to our team (for example a new sign-up or a support message).

Some of these providers are based outside the European Economic Area, mainly in the United States. In those cases data is transferred under the EU-US Data Privacy Framework or the European Commission's Standard Contractual Clauses.

7. How long we keep it

We keep your account data and content while your account is active. You can delete a twin, a voice, a photo, its content or your whole account at any time from the app and from Settings. When you delete a twin or your account, we delete its records from our database straight away, its media files (images, videos, audio, uploads) from storage shortly after, and any cloned voice from ElevenLabs. Conversations with your audience are kept while the twin exists and are deleted with it. Technical logs are kept for a short time to fix problems and do not contain message text. Database backups roll off within 30 days. We keep invoices and payment records for as long as tax law requires.

8. Your rights

Under the GDPR (EU and EEA), the UK GDPR and similar laws, you can:

  • Access the personal data we hold about you and get a copy of it.
  • Download your data in a machine-readable format (portability) from Settings → Download my data.
  • Correct data that is wrong or incomplete.
  • Delete your data ("right to be forgotten"), including your whole account from Settings.
  • Restrict or object to some processing.
  • Withdraw consent at any time, for example for voice and face data or for advertising cookies.
  • Lodge a complaint with the Italian supervisory authority, the Garante per la protezione dei dati personali (garanteprivacy.it), or with the authority of the EU country where you live or work.

To use any of these rights, email privacy@twiny.dev from the email address of your account. We reply within one month.

9. Cookies and third-party content

We use necessary cookies and local storage to keep you signed in and remember your choices. Advertising cookies (Meta Pixel) load only if you click "Accept all"; with "Necessary only" they never load. You can change your choice at any time from "Cookie settings" in the footer. Our page statistics (Vercel Analytics) use no cookies. Details are in our Cookie Policy at twiny.dev/cookies.

10. How we use AI

Twiny uses AI models to write, plan and generate your content and, if you turn it on, to reply to your audience. To do this we send the material needed for each task (your prompts, twin notes and knowledge, reference images, face photos and voice samples you upload, and text to be spoken) to the AI providers listed in section 6. They process it to return the result to us.

  • We do not use your content or your audience's messages to train AI models. Each provider handles data under its own terms.
  • Twiny does not make decisions about you based solely on automated processing that have legal or similarly significant effects.
  • Content made with Twiny is generated by AI. If you publish images, video or audio that could look real, label them as AI-generated, as the EU AI Act and platform rules require. When the platform allows it, we mark posts we publish for you as AI-generated (for example on TikTok and YouTube).
  • You are responsible for what you publish and for having the rights and permissions for the faces, voices and material you upload.

11. Security

We use HTTPS everywhere, private storage for media files, signature checks on incoming webhooks and access controls on all data stores.

12. Minimum age

You must be at least 16 to use Twiny or to chat with a twin, and at least 18 to open a creator account (see our Terms of Service). We do not knowingly collect data from children under 16. If you believe a child has given us their data, write to privacy@twiny.dev and we will delete it.

13. Outside the EU

We apply the same protections to everyone, wherever they live. If you are in California or another US state with a privacy law: we do not sell or share your personal information for cross-context behavioural advertising except through the Meta Pixel, which only loads after you opt in, and you can use the rights in section 8 by emailing us.

14. Changes

We may update this policy. If the changes are significant, we will tell registered users by email before they apply.

15. Contact

Data controller: LOUM MATAR, ditta individuale (Italy). Questions or requests about privacy: privacy@twiny.dev.