Privacy Policy
Last updated: March 9, 2026
Twinning ("we," "us," or "our") operates the Twinning application and related services (collectively, the "Service"). This Privacy Policy explains how we collect, use, and protect information when you use the Service.
Twinning is built on a privacy-first architecture. Your data stays on your device. We designed the product this way because we believe your personal and professional information belongs to you — not to us, not to advertisers, and not to any third party.
1. Information We Collect
Account Information. When you create an account, we collect basic registration information such as your name, email address, and profile photo. This is used solely to identify your account and enable the Service.
Data Sources You Connect. To power your digital twin, you may connect third-party services (email, calendar, messaging apps, productivity tools, etc.). The data from these connected sources is pulled directly to your device and stays on your device. We do not have access to this data and do not store it on our servers.
On-Device Data. Your twin builds a context graph of your relationships, routines, preferences, and goals. This context graph — along with all connected data, tasks, conversations, and twin activity — is stored locally on your device. We never see it, collect it, or transmit it to our servers.
Usage Analytics. We may collect anonymous, aggregated usage metrics (such as feature usage frequency, crash logs, and app performance data) to improve the Service. These metrics do not contain any personal content, messages, or data from your connected sources.
2. How Your Data Is Processed
On-Device Architecture. Twinning is built with an on-device-first architecture. Your connected data is stored and processed locally on your device. Your device communicates directly with third-party LLM providers (such as OpenAI, Anthropic, Google, and others) to perform AI tasks for your twin.
Direct LLM API Calls. When your twin performs an action that requires AI processing, your device makes API calls directly to the LLM provider. These calls go from your device to the LLM provider — they do not pass through our servers. We currently provide the API keys for these LLM services as part of your subscription. However, the data in the API calls is transmitted directly from your device and is not accessible to us.
No Server-Side Storage of Your Content. We do not store, log, or have access to the content of your messages, emails, documents, tasks, twin conversations, or any outputs generated by your twin. All of this stays on your device.
3. How We Use Information
The limited information we do collect (account information and anonymous analytics) is used to:
- Provide, maintain, and improve the Service
- Create and manage your account
- Send service-related communications (e.g., updates, security alerts)
- Monitor aggregate usage patterns to improve performance and features
- Detect and prevent abuse, fraud, or security issues
- Comply with legal obligations
4. What We Do Not Do
We do not store your content. Your emails, messages, documents, twin activity, and AI-generated outputs never touch our servers.
We do not train AI models on your data. Your personal data is not used to train, fine-tune, or improve any machine learning models — ours or anyone else's.
5. Data Sharing
We share information only in the following limited circumstances:
- LLM Providers. When your twin performs AI-powered tasks, your device sends data directly to third-party LLM providers. These providers have their own privacy policies governing how they handle data received via API calls. We encourage you to review them. We select providers that do not use API call data for model training.
- Connected Third-Party Services. When your twin acts on your behalf (e.g., sending an email, booking a cab), it interacts with the relevant third-party service using the permissions you granted. The data shared is limited to what is necessary to complete the action.
- Collaborative Spaces. If you invite another user into a collaborative LivingRoom (Space), data within that Space is shared with the other participant's twin. Only data relevant to the shared goal is visible — your private data outside the Space remains private.
- Legal Requirements. We may disclose account information if required by law, regulation, legal process, or governmental request, or to protect the rights, safety, or property of Twinning, our users, or the public.
- Business Transfers. In the event of a merger, acquisition, or sale of assets, your account information may be transferred. We will notify you before any such transfer and any new entity will be bound by this Privacy Policy.
6. Data Ownership
You own all of your data. This includes:
- All content you connect or input into the Service
- All context, preferences, and behavioral patterns your twin learns
- All outputs, drafts, summaries, and actions generated by your twin
- All data within your Spaces, tasks, and widgets
You may export or delete your data at any time. If you delete your account, all account information held by us is permanently removed. Since your content data lives on your device, you retain full control over it even after account deletion.
7. Data Security
We implement industry-standard security measures to protect your account information. Your on-device data is protected by your device's own security mechanisms (device encryption, biometric locks, etc.). While we take reasonable precautions, no method of electronic transmission or storage is 100% secure, and we cannot guarantee absolute security.
8. Third-Party LLM Providers
The Service uses third-party large language model (LLM) providers to power your twin's AI capabilities. Currently, we provide the API keys for these services. Data sent to LLM providers is transmitted directly from your device and is subject to the respective provider's privacy policy and data handling practices. We select LLM providers that offer API terms prohibiting the use of customer data for model training, but we encourage you to review their policies independently.
9. Children's Privacy
The Service is not directed to individuals under the age of 18. We do not knowingly collect personal information from children. If we become aware that a child has provided us with personal information, we will take steps to delete it promptly. If you believe a child has provided us with personal information, please contact us.
10. Your Choices and Rights
You have the right to:
- Access your account information that we hold
- Correct inaccurate account information
- Delete your account and all associated data on our servers
- Export your on-device data at any time
- Disconnect any third-party data source at any time
- Opt out of non-essential communications
- Control autonomy levels — decide what your twin can do automatically and what requires your approval, on a per-Space basis
11. International Data Processing
Your on-device data stays on your device regardless of your location. Your account information may be processed in countries other than your own. When your device communicates with LLM providers, data may be transmitted internationally based on the provider's infrastructure. By using the Service, you acknowledge this processing.
12. Changes to This Policy
We may update this Privacy Policy from time to time. We will notify you of material changes by posting the updated policy within the Service and updating the "Last updated" date. Your continued use of the Service after changes constitutes acceptance of the revised policy.
13. Contact Us
If you have questions about this Privacy Policy or our data practices, please contact us at:
Email: privacy@twinnings.ai