Privacy Policy

Last Updated: April 2026
Effective Date: April 2026

Twinquility Ltd ("we", "our", "us") is committed to protecting the privacy of children, parents, and families who use our wellbeing app. This Privacy Policy explains how we collect, use, store, and protect your personal information in compliance with UK GDPR, the Data Protection Act 2018, and the ICO Children's Code (Age Appropriate Design Code).

By using Twinquility, you (and your parent or carer if you are under 13) agree to this Privacy Policy.

If you have any questions, please contact us at: holly@twinquility.com\

1. Who We Are

Twinquility is operated by Twinquility Ltd, registered in England and Wales. We are the data controller for information collected through the app and website.

Contact: holly@twinquility.com

2. Who Can Use Twinquility

  • Children aged 7 to 14, using a nickname (not their real name)

  • Children under 13 must have parental or carer consent via an invite code

  • Parents and carers aged 18 or over with parental responsibility

3. What Information We Collect

Child Users

  • A nickname (real names are not permitted)

  • Age group category (7-10, 11-13 or 14+) — exact date of birth is not stored

  • Gender (optional)

  • Custom avatar (no photos allowed)

  • Journal entries (text, voice recordings or drawings)

  • Mood check-ins and emotional reflections

  • App usage patterns (e.g. which tools are used)

  • Interactions with Wendy, our AI wellbeing guide


Parent and Carer Users

  • Email address

  • Nickname and avatar

  • Notification preferences

Technical Data (all users)

  • Device type and browser

  • Anonymised IP address

  • Timestamps

  • Anonymised error logs

4. How We Use Your Information

  • To provide the Twinquility wellbeing app and its features

  • To enable Wendy, our AI guide, to respond to journal entries and mood check-ins

  • To provide parents and carers with gentle, summarised wellbeing insights

  • To monitor for safeguarding concerns and escalate where necessary

  • To improve the app over time through anonymised usage data

We will never use your data for advertising. We will never sell or rent your data to third parties.

5. Wendy — Our AI Wellbeing Guide

Wendy is Twinquility's built-in AI guide. She reads journal entries and mood check-ins to offer gentle reflections, suggest coping tools, and flag if a child may need extra support.

Wendy is powered by Google Gemini AI. Entries are processed to identify emotional themes, risk indicators, and to provide appropriate responses. This data is stored securely for pattern analysis.

Wendy is not a therapist, doctor or emergency service. She cannot diagnose, treat or respond to emergencies. If a child is in immediate danger, please contact 999.

6. What Parents and Carers Can See

Parents and carers receive gentle wellbeing insights and emotional patterns — not full access to their child's private journal or personal conversations. Your child's private space stays private.

Carers can only see journal entries that the child has actively chosen to share, plus anonymised mood summaries and tool usage insights.

In serious safeguarding situations (Tier 3 or Tier 4 escalations), entries may be shared with the linked carer and, where necessary, relevant authorities. See Section 8 for more detail.

7. How We Keep Your Data Safe

  • All data is encrypted in transit using HTTPS

  • All data is encrypted at rest using AES-256 encryption

  • Data is hosted on secure EU infrastructure (AWS, Ireland region) and does not leave the EU

  • Access to data is strictly controlled and regularly audited

  • Real names, addresses, phone numbers and photos are filtered and blocked within the app

8. Safeguarding and Escalation

Twinquility has a built-in safeguarding system. If Wendy detects content that suggests a child may be at risk, the following escalation tiers apply:

  • Tier 1 (Green): General support — no alerts, Wendy responds with wellbeing guidance

  • Tier 2 (Yellow): Moderate concern — carer receives a gentle insight summary within 48 hours

  • Tier 3 (Amber): Significant concern — carer receives a safeguarding alert within 24 hours

  • Tier 4 (Red): Immediate risk — immediate in-app and push notification to the linked carer (bypasses quiet hours and notification preferences), crisis resources shown to child, emergency services may be contacted. Email delivery for Tier 4 is planned for a future release.

Tier 4 alerts send an immediate in-app and push notification to the linked carer, bypassing quiet hours and notification preferences. Email delivery for Tier 4 is planned and will be added in a future release.

9. Data Sharing

We do not sell, rent or share personal data with advertisers or third parties for commercial purposes.

We may share data in the following limited circumstances:

  • With linked parent or carer accounts (subject to the child's sharing choices)

  • With safeguarding authorities (Local Authority Safeguarding Teams, Police or MASH) in serious safeguarding situations

  • With trusted technical partners who help us operate the app securely (under strict data processing agreements)

10. Your Rights

Under UK GDPR, you have the right to:

  • Access the personal data we hold about you

  • Correct inaccurate data

  • Delete your account and associated data

  • Export your data

  • Withdraw consent — this will activate Limited Mode, where coping tools remain available but journal storage is paused

To exercise any of these rights, go to Settings > Legal & Privacy within the app, or contact us at holly@twinquility.com.

11. Data Retention

  • Active accounts: data is kept until deletion is requested

  • Deleted accounts: a 30-day grace period applies before permanent deletion

  • Inactive accounts: configurable auto-deletion is available in Settings

  • Safeguarding logs: retained for 7 years in line with UK safeguarding standards — these cannot be linked back to any individual child

  • Anonymised analytics: retained indefinitely as they contain no personal identifiers

12. Children's Code Compliance

Twinquility is designed in accordance with the ICO's Age Appropriate Design Code (Children's Code). This means:

  • Privacy settings are set to the highest level by default

  • We collect only the minimum data necessary

  • We do not use nudge techniques or data profiling for commercial purposes

  • Children's data is never used to train public AI models

13. Contact Us

If you have any questions about this Privacy Policy or how we handle your data, please contact:

Holly Banfield, Founder — Twinquility Ltd

Email: holly@twinquility.com


Twinquility offers wellbeing tools, not professional care. If you are concerned about a child's safety, please contact 999, Childline (0800 1111) or the Samaritans (116 123).