Privacy Policy

Last Updated: February 8, 2026 · Effective: February 8, 2026

1. Introduction

Twin Technologies, Inc. ("Company," "we," "us," or "our") operates the Twin mobile dating application ("App" or "Service"), accessible at https://thetwin.app. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our Service.

By accessing or using Twin, you consent to the collection, use, and disclosure of your information as described in this Privacy Policy. If you do not agree with the terms of this Privacy Policy, please do not access or use the Service.

We reserve the right to modify this Privacy Policy at any time. Changes will be effective immediately upon posting to https://thetwin.app/privacy. We will notify you of material changes through the App or via email. Your continued use of the Service after any modifications constitutes acceptance of the revised Privacy Policy.

2. Information We Collect

2.1 Information You Provide Directly

  • Identity Information: Name, username, date of birth, gender, sexual orientation, relationship goals
  • Contact Information: Email address, phone number
  • Profile Information: Biography, interests, preferences, lifestyle choices, values, prompts and answers
  • Visual Content: Photos, videos, profile pictures
  • Social Media Data: Instagram account information, photos, follower counts, profile data, connected social accounts
  • Communication Data: Messages, chat history, communications with other users, AI conversation transcripts
  • Preference Data: Matching preferences, visual preferences, location preferences, age preferences, distance preferences
  • Verification Data: Identity verification documents, selfies for verification, phone number verification
  • Payment Information: Subscription purchases processed through Apple App Store or Google Play Store (we do not directly collect or store credit card numbers)
  • Feedback: Survey responses, reviews, support inquiries, app ratings

2.2 Information Collected Automatically

  • Device Information: Device type, model, operating system version, unique device identifiers (IDFA, IDFV, Android Advertising ID), mobile network information, screen resolution, device language
  • Usage Data: Features used, actions taken, time and duration of use, interaction patterns, swipe behavior, match acceptance/rejection rates, message frequency
  • Location Data: Precise GPS location (with your permission), approximate location based on IP address, city-level location, location history
  • Log Data: IP address, browser type, access times, pages viewed, referring URLs, crash reports, performance data
  • Cookies and Tracking: Cookies, web beacons, pixel tags, similar tracking technologies on our website
  • Push Notification Tokens: Device tokens for delivering push notifications
  • Sensor Data: Accelerometer, gyroscope, and other device sensor data as permitted by your device settings

2.3 Information from Third Parties

  • Social media platforms (Instagram, Google, Apple) used for authentication
  • Identity verification services
  • Payment processors (Apple, Google) for subscription status
  • Analytics providers and advertising partners
  • Fraud prevention services
  • Other users who may provide information about you (e.g., reports, referrals)

2.4 Derived and Inferred Information

We create and derive additional information about you through analysis, including compatibility scores and matching predictions, behavioral patterns and preferences, photo analysis results, risk assessments and trust scores, interest and preference inferences, demographic inferences, and activity-based engagement scores.

3. How We Use Your Information

3.1 Core Service Operations

Creating and managing your account, authenticating your identity, facilitating matches and connections, enabling communication, processing subscription transactions, providing customer support, verifying identity, preventing fraud, and enforcing age requirements (18+).

3.2 Matching and Recommendations

Analyzing your profile, preferences, and behavior to suggest compatible matches; ranking and prioritizing potential matches using AI algorithms; personalizing your experience; improving matching algorithms; and generating compatibility scores and explanations.

3.3 Artificial Intelligence and Machine Learning

You expressly consent to the use of your data, including photos and personal information, for AI and machine learning purposes, including:

  • Photo Analysis: Analyzing photos to extract characteristics such as physical attributes, style indicators, lifestyle signals, grooming patterns, fitness levels, fashion choices, and other visual factors
  • Authenticity Assessment: Evaluating photos for editing, filters, and authenticity
  • Behavioral Modeling: Creating models of user behavior, preferences, and compatibility
  • Algorithm Training: Training and improving AI and machine learning models
  • Content Moderation: Automatically detecting and moderating inappropriate content
  • Pattern Recognition: Identifying patterns in user data to improve services and detect abuse
  • Predictive Analytics: Predicting user preferences, behaviors, and compatibility
  • Conversational AI: Powering AI-assisted matching conversations, icebreaker generation, and date suggestions
  • Face Detection: Verifying that uploaded photos contain a human face

3.4 Safety, Security, Research, Marketing, and Legal Compliance

We also use your information for detecting and preventing fraud, abuse, and policy violations; conducting research and analysis; sending promotional communications (with opt-out options); displaying targeted advertisements (with consent where required); complying with applicable laws and regulations; and any other lawful purpose consistent with this Privacy Policy.

4. Photo Analysis and Visual Data Processing

4.1 Comprehensive Photo Analysis

When you upload photos to Twin, you consent to comprehensive analysis using artificial intelligence and machine learning technologies. This analysis may include extracting and processing physical attributes, style and fashion indicators, grooming and presentation quality, lifestyle indicators, environmental context, photo quality metrics, authenticity metrics (editing detection, filter usage, photo manipulation), expression and demeanor analysis, and face detection for profile verification.

4.2 Biometric Data Notice

Our photo analysis technology may process biometric identifiers or biometric information as defined under certain state laws (e.g., Illinois Biometric Information Privacy Act, Texas Capture or Use of Biometric Identifier Act). By uploading photos and using the Service, you provide informed written consent to the collection, use, and storage of your biometric data for the purposes described in this Privacy Policy. We retain biometric data only for as long as necessary to fulfill the purposes for which it was collected, or as required by law, and will destroy such data when the initial purpose has been satisfied or within three (3) years of your last interaction with the Service, whichever comes first.

4.3 Consent to Visual Processing

By uploading photos to Twin, you provide explicit consent for us to process your visual data in any manner we determine necessary or beneficial for operating the Service, improving our technology, or pursuing our business interests. You may withdraw this consent by deleting your photos or your account, though previously derived analytical data may be retained in anonymized form.

5. Information Sharing and Disclosure

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

  • With Other Users: Your profile information, photos, and certain activity data are visible to other users as part of the matching and communication features
  • Service Providers: Cloud hosting (AWS), payment processors (Apple, Google), analytics providers, customer support services, marketing partners, identity verification services, AI/ML service providers, push notification services, error tracking (Sentry), SMS verification (Twilio)
  • Business Partners: Joint marketing initiatives, co-branded services, or collaborative efforts
  • Legal Purposes: To comply with laws, respond to legal requests, protect rights and safety, enforce Terms of Service, investigate violations, and cooperate with law enforcement
  • Business Transfers: In connection with a merger, acquisition, reorganization, bankruptcy, or asset sale
  • With Your Consent: For other purposes with your consent or at your direction
  • Aggregated/De-Identified Data: Data that cannot reasonably identify you, for any purpose
  • Third-Party AI Services: Your data may be processed by third-party AI providers that power certain App features

6. Auto-Renewable Subscriptions

Twin offers optional auto-renewable subscriptions ("Twin+") that provide access to premium features. Key details:

  • Payment will be charged to your Apple ID or Google Play account at confirmation of purchase
  • Subscriptions automatically renew unless auto-renew is turned off at least 24 hours before the end of the current period
  • Your account will be charged for renewal within 24 hours prior to the end of the current period
  • You can manage and cancel subscriptions in your App Store or Google Play Store account settings
  • Any unused portion of a free trial will be forfeited upon subscription purchase

For subscription management, we receive from Apple or Google: subscription status, purchase date, expiration date, and subscription tier. We do not receive or store your payment card information.

7. Your Rights and Choices

Depending on your location, you may have the following rights:

  • Access: Request a copy of your personal data
  • Correction: Update or correct inaccurate information
  • Deletion: Request deletion of your account and personal data
  • Portability: Receive your data in a structured, machine-readable format
  • Opt-Out: Opt out of marketing communications and push notifications
  • Restrict Processing: Request limitation of how we process your data
  • Withdraw Consent: Withdraw consent for data processing at any time
  • Object: Object to processing based on our legitimate interests

You may request deletion of your account through the App (Settings > Account > Delete Account) or by contacting support@thetwin.app. Upon deletion: your profile will be removed from public view within 24 hours, personal data deleted within 30 days (except as required by law), and backup copies may persist for up to 90 days.

To exercise these rights, contact us at privacy@thetwin.app or use the in-app privacy settings.

8. California Privacy Rights (CCPA/CPRA)

California residents have the following rights under the California Consumer Privacy Act (CCPA) as amended by the California Privacy Rights Act (CPRA):

  • Right to Know: Request disclosure of categories and specific pieces of personal information collected
  • Right to Delete: Request deletion of personal information, subject to certain exceptions
  • Right to Correct: Request correction of inaccurate personal information
  • Right to Opt-Out: Opt out of the "sale" or "sharing" of personal information for targeted advertising
  • Right to Limit: Limit use of sensitive personal information to purposes necessary to provide the Service
  • Non-Discrimination: We will not discriminate against you for exercising your rights

Categories of personal information collected in the preceding 12 months include: identifiers, personal information (CCPA definition), protected classifications (age, gender, sexual orientation), commercial information, biometric information, internet/network activity, geolocation data, sensory data (photos, audio), inferences, and sensitive personal information.

To exercise your California privacy rights, contact privacy@thetwin.app.

9. European Privacy Rights (GDPR)

If you are located in the European Economic Area (EEA), United Kingdom, or Switzerland, you have additional rights under the General Data Protection Regulation (GDPR):

  • Access your personal data
  • Rectify inaccurate personal data
  • Erase your personal data ("right to be forgotten")
  • Restrict processing of your personal data
  • Data portability — receive your data in a structured, machine-readable format
  • Object to processing based on legitimate interests
  • Withdraw consent at any time
  • Lodge a complaint with a supervisory authority

Our legal bases for processing include: consent (photo analysis, AI processing, marketing, biometric data, location tracking), contract performance (account creation, matching, messaging, subscriptions), legitimate interests (service improvement, fraud prevention, security, analytics), and legal obligation (law enforcement, regulatory compliance).

International transfers are protected by Standard Contractual Clauses (SCCs) approved by the European Commission and other legally recognized mechanisms.

Our Data Protection Officer can be reached at dpo@thetwin.app.

10. Additional State Privacy Rights

Residents of Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and other states with privacy laws have additional rights including access, correction, deletion, data portability, and opt-out of targeted advertising, sale of personal data, and profiling.

To exercise your rights under any state privacy law, contact privacy@thetwin.app or use the in-app privacy settings at Settings > Privacy > Exercise My Rights.

11. Children's Privacy

Twin is not intended for users under the age of 18. We do not knowingly collect personal information from children under 18. If we become aware that we have collected personal information from a child under 18, we will take immediate steps to delete such information and terminate the associated account.

We comply with the Children's Online Privacy Protection Act (COPPA) and do not knowingly collect information from children under 13. Our age verification process requires users to confirm they are 18 or older during registration.

If you are a parent or guardian and believe your child has provided personal information to Twin, please contact us immediately at safety@thetwin.app.

12. Data Security

We implement industry-standard administrative, technical, and physical security measures to protect your information, including:

  • Encryption of data in transit (TLS/SSL) and at rest (AES-256)
  • Secure authentication mechanisms (OAuth 2.0 via Google and Apple)
  • Regular security assessments and vulnerability testing
  • Access controls and employee training
  • Incident response procedures
  • Secure cloud infrastructure with leading providers

However, no method of transmission over the Internet or electronic storage is completely secure. We cannot guarantee the absolute security of your information. In the event of a data breach, we will notify you and relevant authorities as required by applicable law.

13. Data Retention

We retain your information for as long as necessary to fulfill the purposes described in this Privacy Policy:

  • Active account data: Duration of account
  • Deleted account data: 30 days after deletion request
  • Backup data: 90 days after deletion
  • Anonymized/aggregated data: Indefinitely
  • Legal compliance data: As required by law
  • AI training data (anonymized): Indefinitely
  • Transaction records: 7 years
  • Safety investigation records: 5 years

14. International Data Transfers

Your information may be transferred to and processed in countries other than your country of residence, including the United States. We ensure that international transfers are conducted in compliance with applicable data protection laws, using appropriate safeguards such as Standard Contractual Clauses, data processing agreements, and other legally recognized mechanisms.

15. Third-Party Links and Services

The Service may contain links to third-party websites, applications, or services. We are not responsible for the privacy practices of these third parties. Third-party services we integrate with include:

16. Advertising, Analytics, and Tracking

We use analytics tools to understand how users interact with our Service. We may display advertisements within the App or on our website. You can opt out of personalized advertising through your device settings (iOS: Settings > Privacy > Tracking; Android: Settings > Google > Ads).

On iOS 14.5 and later, we will request your permission before tracking your activity across other companies' apps and websites via Apple's App Tracking Transparency framework.

Some browsers transmit "Do Not Track" (DNT) signals. We currently do not respond to DNT signals. You can manage your privacy preferences through the App settings.

17. Changes to This Privacy Policy

We may update this Privacy Policy from time to time. We will notify you of material changes by: posting the new Privacy Policy at https://thetwin.app/privacy, updating the "Last Updated" date, sending a notification through the App, and sending an email for material changes.

18. Contact Us

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

Twin Technologies, Inc.

Consent Acknowledgment

By using Twin, you acknowledge that: you have read and understood this Privacy Policy; you consent to the collection, use, and disclosure of your information as described herein; you consent to the processing of your photos and visual data by AI and machine learning systems; you consent to the extraction and use of derived characteristics from your photos; you consent to the use of your data for algorithm training and improvement (in anonymized form); you consent to international data transfers as described in this Policy; you understand that subscription payments are processed by Apple or Google, not directly by us; and you understand that Twin is intended for users aged 18 and older.

Your use of Twin constitutes your agreement to this Privacy Policy in its entirety.