twinko

Privacy Policy

Last updated: September 6, 2026

1. What this policy covers

This policy explains what data Twinko ("we") collects from parents and children who use the platform, how it is used, who it is shared with, and what your rights are. Twinko is intended for families with children aged 6 to 12: we pay particular attention to protecting minors' data.

2. Who creates and controls the child's account

A child cannot create their own account: the parent creates the account and links their child's account to it. The parent retains control of the child's account at all times (tracking progress, managing the subscription, deletion). It is the parent's consent, given when the account is created, that authorizes the processing of the child's data described below.

3. Data we collect

Parent account: name, email, address, phone number (if provided), password (never stored in plain text, only its encrypted version).

Child account: name, subjects studied and minutes per subject (set by the parent), history of lessons completed and experience points earned, rewards claimed.

Billing: handled entirely by our payment partner, Stripe (see section 5) — Twinko never stores your card number.

4. The child's voice and homework photos

These are the two most sensitive points, and we want to be perfectly clear:

Voice (microphone): when a child asks a question out loud, speech recognition is performed directly by the browser (a standard browser technology, not by our servers) — only the resulting TEXT is transmitted to us, never the audio recording. No child's voice is ever sent to a third party or retained by Twinko.

Homework photos: a photo taken with the camera is securely sent to the Google Gemini API solely to analyze the exercise and generate an educational response. It is never saved on our servers or in our database, and disappears as soon as the response is generated.

Likewise, the content of live exchanges with Prof Twinko (questions, answers) is not retained once the session ends — only a summary (subject and points earned) is kept for the progress tracking shown to the parent.

5. Who we share data with

Twinko relies on trusted subprocessors, each limited to what it needs to operate:

  • Google Gemini — generates Prof Twinko's responses from the text of the question (and the photo, where applicable), with no retention by Twinko.
  • ElevenLabs — converts the text of Prof Twinko's responses into speech; never receives the child's voice.
  • Stripe — processes payments and subscriptions (the parent's email and billing information only).
  • Resend — delivers our transactional emails (e.g., password reset).
  • Google Ads — measures how our ads perform on public pages and in the parent area (which ad led to a subscription). It is never loaded in the child area or in the mobile app, and receives no data about your child.

We do not sell or rent any personal data for advertising purposes, to anyone.

6. Cookies

Twinko uses cookies that are essential to the Service: a session cookie (encrypted and httpOnly) to keep you signed in, and a language and region preference cookie.

On public pages and in the parent area, we also use the Google Ads measurement tag, which sets third-party advertising cookies to identify which ads lead to a subscription. It is never loaded in the child area (child dashboard, 3D classroom, courses, tutoring) or in the mobile app: no advertising cookie is set while your child is using Twinko.

7. Compliance — Quebec's Law 25, PIPEDA, GDPR, COPPA

Twinko applies the principles of data minimization (we collect only what is necessary for the Service), parental consent for children's accounts, and reasonable security (encrypted passwords, secure connections, protected sessions). Families outside Quebec/Canada benefit from the same protections, aligned with the principles of the GDPR (Europe) and COPPA (United States, protection of minors online) to the extent they apply.

8. Data retention

Account data is retained for as long as the account remains active. At the parent's request, we delete the account and its associated data (see section 9) — subject to legal retention obligations (e.g., billing records).

9. Your rights — access, correction, deletion

As a parent, you may at any time request to view, correct, or delete the data in your account and your child's account by writing to contact@twinko.ca. We process these requests within a reasonable timeframe, generally within 30 days.

10. Changes to this policy

We may update this policy to reflect changes to the Service or to the law. The update date at the top of this page indicates the latest revision. Significant changes will be communicated to parents by email.

11. Contact us

For any question about this policy or your data: contact@twinko.ca.