Who we are

Twine is a wellness app based in England and Wales. We are responsible for your personal data under UK GDPR. You can contact us about privacy at privacy@twine.app.

What we collect

We collect your email address and login information when you create an account. We collect basic technical logs necessary to run the app securely.

Your conversation content — reflections and drafted messages — is stored on your device by default and is not transmitted to our servers unless you choose otherwise (see 'How your data is stored' below) or unless our safety systems require it (see 'Safety scanning' below).

Why we use your data

We use your account details to run the service under our contract with you. Because your reflections may contain sensitive personal information about your relationships and feelings, we ask for your explicit consent before storing them on our servers. You can withdraw this consent at any time by deleting your content or closing your account.

How your data is stored

Twine is designed to minimise the data we hold about you. By default, your conversation content is stored on your device only. This means:

• • Your reflections and message drafts remain private to your device
• • If you uninstall the app or switch devices, locally stored content will not be recoverable
• • We cannot access your conversation content unless you have opted into server-side storage

You can choose to store your conversation summaries on Twine's secure servers. This is opt-in and allows your history to carry across sessions and devices. If you enable this, summaries are encrypted at rest, remain within your account, are not shared externally, and are deleted when you close your account. You can request a copy at any time by emailing privacy@twine.app. You can switch this setting off at any time, at which point server-side summaries will be deleted.

Safety scanning

To meet our legal obligations under the Online Safety Act 2023 and UK GDPR, Twine runs an automated safety check on messages that match certain patterns. This applies regardless of your storage preference.

How it works: a lightweight keyword filter runs on your device. The vast majority of messages never match any pattern and are never transmitted to our servers. Where a message matches a pattern associated with illegal content or serious risk to life, that message is sent to our secure servers for assessment. If the assessment confirms the content falls within a category requiring action, we will take the steps described below.

Categories and actions:

• • Child sexual exploitation or abuse (CSEA): content is preserved as evidence and reported to the National Crime Agency.
• • Terrorism: content is preserved as evidence and reported to the Counter Terrorism Internet Referral Unit.
• • Credible, specific, and imminent threat of violence against an identified person: content is preserved as evidence and reported to the relevant police force.
• • Urgent mental health crisis (imminent risk with stated method or current injury): an urgent support email is sent to you and a police welfare check is requested.

In all cases where content is reported to authorities, your account will be suspended. Grounds for suspension are set out in our Terms of Service.

Where content is assessed and does not meet any of the above thresholds, it is not retained on our servers.

Legal basis: vital interests (Art 6(1)(d)) for urgent crisis welfare checks; legal obligation (Art 6(1)(c)) for CSEA and terrorism reporting; legitimate interests (Art 6(1)(f)) for threat assessment and account suspension.

How AI processing works

Twine uses third-party AI services to generate reflections and draft messages. This means content you enter is processed by AI providers, currently Anthropic (Claude) and OpenAI (GPT-4o mini). Both are bound by data processing agreements with Twine. Anthropic and OpenAI are US-based companies. We rely on Standard Contractual Clauses as the legal basis for transferring your data outside the UK. Neither provider uses your content to train their models under our agreements with them.

AI processing applies only to content you actively submit within a session. Locally stored content that you do not submit in a session is never transmitted to AI providers.

Sharing your data

We do not sell your data. We share it only with the AI providers named above and with the technical services that host Twine. All hosting is within the UK or EEA except where AI processing requires transfer as described above. In exceptional circumstances where we believe someone is in immediate danger, we may share limited information with emergency services under our vital interests obligations.

How long we keep your data

Locally stored content is under your control and is deleted when you uninstall the app or clear your data.

Server-side summaries (if you have opted in) are deleted when you close your account or switch the setting off.

Account data is retained for up to 90 days after account closure for legal and audit purposes, after which it is permanently deleted.

Content reported to authorities under our statutory obligations is retained until law enforcement advises otherwise. Safety metadata (timestamps and classification records) is retained for 90 days.

Your rights

Under UK GDPR you have the right to access, correct, delete, or restrict the use of your personal data. You also have the right to object to any automated processing. Email privacy@twine.app and we will respond within 30 days.

Note: locally stored content is on your device and is not held by us. Rights requests in relation to locally stored data should be exercised through your device settings.

Cookies and tracking

Twine does not use non-essential cookies or third-party analytics. We collect only what is necessary to run the app.

Changes to this policy

We will notify you of any significant changes to this policy. Continued use of Twine after notification constitutes acceptance.

Contact

For any privacy questions or to exercise your rights, contact privacy@twine.app.