Last updated: Sep 11, 2026

Welcome to Twine AI (including our mobile application, dating/conversational simulation features, and associated services) (hereafter referred to as “Twine AI,” “we,” “us,” or “our”). As the data controller under the General Data Protection Regulation (EU) 2016/679 (“GDPR”) and applicable Portuguese data protection law (Lei n.º 58/2019), we are committed to protecting and respecting your personal privacy.

This Privacy Policy sets out how we collect, process, secure, and disclose your Personal Data when you access our mobile application and related services (collectively, the “Service”), as well as your statutory rights regarding that data.

1. Strict Age Policy and Protection of Minors (18+ Only)

Twine AI is strictly intended for individuals who are at least eighteen (18) years of age due to adult conversational themes, emotional roleplay, and dating simulation content. We do not knowingly collect, solicit, or process Personal Data from anyone under 18.

• Age Warranty: By registering for or using the Service, you represent and warrant that you are at least 18 years of age.
• Disclaimer: We expressly disclaim any liability for unauthorized access by minors resulting from fraudulent age declarations. Parents and legal guardians bear sole responsibility for restricting minors' device access.
• Immediate Purge: If we discover that we have inadvertently collected Personal Data from an individual under 18, we will immediately delete that data and terminate the account without prior notice. If you suspect an underage individual is using the Service, notify us immediately at [email protected].

2. Categories of Personal Data We Collect

A. Data You Provide Directly

• Account Credentials: Unique user identifiers (OpenID from Google Sign-In or Apple ID), email address (if provided by OAuth), and account creation timestamps.
• Persona & Profile Details: Display nickname, declared age (18+), preferred pronouns/gender identity, and optional user persona tags.
• User-Generated Content (UGC) & Chat Transcripts: Conversational text prompts, romantic scenarios, voice inputs (if enabled), custom character descriptions, and uploaded profile or avatar images.
• Support Inquiries: Email address and communication history submitted when contacting our technical support team.

B. Data Collected Automatically

• Technical Identifiers: IP address, device model, operating system version, app version, language preference, and unique device tokens (such as Firebase Installation ID).
• Usage & Telemetry: Timestamps of interactions, session duration, feature engagement, navigation events, and diagnostic logs collected via Firebase Crashlytics and Firebase Analytics.

C. Purchase and Subscription Information

• Payments are handled directly by the Apple App Store or Google Play Store. We do not process, collect, or store your credit card numbers or banking credentials. We receive only non-sensitive transactional metadata: purchase timestamps, subscription statuses, expiration dates, and anonymized transaction/order IDs.

3. Processing of Sensitive & Intimate Data (Article 9 GDPR)