Privacy Policy

Last updated: 23 August 2026

1. Who this policy applies to

Twinkle is made for children between roughly 8 and 14 years old, used with the involvement of a parent or legal guardian. A child cannot create an account on their own. The account belongs to the parent, and the parent decides whether their child uses Twinkle, on which devices, and for how long.

This policy applies to the ThinkHumanly website, the Twinkle app, and the Twinkle Anywhere browser extension. When we say "we" or "us", we mean ThinkHumanly. When we say "you" and "your child", we mean the parent or guardian and the child they have registered.

2. The short version

• We collect: what the parent provides (account, email, payment handled by our payment provider, things they share about their child), and what the child does inside Twinkle (their conversations with Twinkle, progress in adventures, and choices), which is the product working as intended.
• We do not collect: precise location, photos, contacts, browsing history, or anything from third-party sites beyond the text a child explicitly selects to share with Twinkle in the extension.
• We never: sell data, show ads, build ad profiles, or share a child's data with other families or with anyone for marketing.
• Voice: when a child talks to Twinkle by voice, the audio is processed in real time for speech recognition and is not stored by us.
• Parental control: the parent dashboard shows what Twinkle has noticed, the weekly note summarizes it, and a parent can stop the notes, delete what was shared, or ask us to delete the account, at any time.

3. What we collect and why

3.1 From the parent

When a parent creates an account we collect their email address and a password (stored as a one-way hash, never in plain text). Sign-in can also use a time-limited magic link sent to that email. We use this to identify the account, keep it secure, and send the weekly note if the parent opts in.

If the parent subscribes, payment is processed entirely by Paddle, our payment provider. We never see or store card numbers. We receive only the subscription status (for example, active, trial, or cancelled) so we can unlock the right experience.

When a parent uses the dashboard we store the things they choose to share about their child (for example, "she has been quieter than usual about school"), the interests they tell us about, and their rating of the weekly note. These are used to make Twinkle's understanding more accurate and are shown back to the parent. Parent input is never quoted to the child.

3.2 From the child

Twinkle's core promise is a companion that remembers. To keep that promise, we store what the child says to Twinkle and what they do in Twinkle's worlds:

• the child's first name (as they introduce themselves) and anything they say about their age;
• conversations with Twinkle, which become the child's episodic memories (the things they care about, the questions they ask);
• progress through adventures and activities, and the choices they make in them;
• an evolving "understanding" of how the child thinks and communicates, derived by our software from the above, expressed as gentle hypotheses with confidence levels, never as labels or diagnoses;
• the open thread of whatever the child was thinking about, so Twinkle can pick it up next time.

This is the product. A companion that forgot everything would not be a companion. The parent can see the same understanding on the dashboard, and can delete it.

3.3 From the child's voice

When the child talks to Twinkle by voice, the audio is streamed to our speech recognition provider for live transcription, used only to turn speech into text for the conversation, and is not stored by us. Twinkle's spoken replies are generated on the fly and are not kept as recordings.

3.4 From the browser (Twinkle Anywhere)

The extension is a context bridge: it lets a child share a piece of text they are reading so Twinkle can talk about it. Only text the child explicitly selects and shares is sent, and only to Twinkle. The extension stores the child's identifier so their memories follow them, reads the parent's sign-in state to check the subscription, and stores a small local preference (for example, voice on or off) on the device. The extension does not read browsing history and does not send anything from third-party pages on its own.

3.5 Technical information

Like most services we keep basic technical logs (IP address, browser type, timestamps) for security, abuse prevention, and reliability. These are retained for a limited period (around 90 days) and are not used for advertising.

4. How we use the data

• to run Twinkle: conversations, memories, progress, and the weekly note;
• to keep children safe: every reply is screened by our safety layer before it reaches the child;
• to improve the product: we study patterns in aggregate form, without identifying individual children;
• to respond to parents: contact messages, support, and rights requests;
• to meet legal obligations: consent records, tax records, and lawful requests from authorities.

We do not use a child's data for targeted advertising, for automated decision-making that affects the child in a significant way, or for anything the parent cannot see or undo.

5. Our AI safety commitments

Because this product is for children, we hold ourselves to a higher standard than a general chatbot, and we wrote it down:

• Twinkle never compares a child to other children, never grades them, and never diagnoses.
• Our "understanding" of a child is expressed as tentative hypotheses backed by evidence, which weaken when the child changes or when a parent corrects them.
• All AI-generated content passes a safety screen, and the weekly letter passes a strict guard that rejects anything invented, comparative, or diagnostic.
• Parent input is used to understand, never to label, and is never repeated to the child.
• We do not train general-purpose AI models on your child's data. The models we use are third-party, and we do not feed them your child's data for their training.

6. Who we share data with (and who we never share it with)

We never sell data and we never share a child's data with other families, advertisers, or data brokers. The only organisations that process data on our behalf are service providers, each bound by contract:

• Groq (United States): AI inference for conversations and speech recognition.
• ZeptoMail (European Union): sending the weekly notes and account emails.
• Paddle (United States / Ireland): payment processing. We never see card details.
• DigitalOcean (United States / Europe): hosting our servers.
• GitHub (United States): hosting our code and running our scheduled maintenance jobs. No child data is processed there.

We may also disclose data where the law requires it (for example, to a court or regulator), and we will tell parents before we do so where we are permitted to. If ThinkHumanly is acquired or merged, your data stays under this policy, and we will notify you before any change.

7. Cookies and local storage

• a session cookie (th_session) so the parent stays signed in, valid for 30 days;
• a child identifier cookie (v3_child) so Twinkle knows which child she is talking to, valid for one year and tied to the family account, not to advertising;
• local preferences in the extension (for example, voice on or off) stored on the device.

We do not use advertising cookies or third-party tracking cookies, and there are no analytics trackers on our site.

8. How long we keep data

• the child's memories, progress, and understanding: for as long as the family account is active;
• conversation context shared from pages (the extension): a short time, hours to days, then removed;
• session tokens: 30 days, or on sign-out;
• guest sessions: when a child uses Twinkle without a parent account, that session's data is kept for 30 days and then deleted automatically;
• technical logs: around 90 days;
• after an account is closed: we delete or anonymise personal data within 30 days, keeping only what the law requires (for example, payment records held by our payment provider).

9. Parental rights

Because you are the account holder, you control your child's data. You can, at any time and without charge:

• see what Twinkle has noticed, in the parent dashboard;
• stop the weekly notes, with one click in the email or in the dashboard;
• correct or remove the things you shared about your child;
• download a copy of your child's data at /account, or ask us by writing to privacy@thinkhumanly.co;
• delete the account and all associated data directly at /account, or by writing to privacy@thinkhumanly.co. Direct deletion is immediate; email requests are honoured within 30 days.

10. Children's privacy laws

We design for the strictest of the laws that apply:

• COPPA (United States): Twinkle is a children's service. We obtain parental consent before collecting a child's personal information: only a parent can create an account, using their own email address, and the child's profile is created by the parent before any child data is collected. Parents can review and delete the child's information at any time, as required by COPPA.
• GDPR / UK GDPR: for children under 13 in the EU and UK, consent is obtained from the parent in the same way. Parents can exercise access, rectification, erasure, restriction, portability, and objection rights by contacting privacy@thinkhumanly.co.
• DPDP Act (India): we treat every user as a child under the Act. We collect data with parental consent and only for the stated purposes, keep it secure, and appoint a point of contact for data-principal requests (privacy@thinkhumanly.co).

11. Security

We use encryption in transit (HTTPS) everywhere, store passwords and session tokens as one-way hashes, restrict access to systems on a need-to-know basis, keep our dependencies patched, and never store payment card data. No system is perfectly secure, and we ask parents to keep their account credentials private and to contact us promptly if they suspect misuse.

12. International transfers

Your data is processed on servers in the United States and the European Union by the providers listed above. Where data crosses borders, we rely on appropriate safeguards, including the providers' data-protection commitments. We do not transfer children's data outside these arrangements.

13. Changes to this policy

If we change this policy, we will update the date above and, for material changes, email the parent account holder before the change takes effect. Continued use after a material change means acceptance of the new policy.

14. Contact

ThinkHumanly Technologies
Data protection and privacy: privacy@thinkhumanly.co
Anything else: contact@thinkhumanly.co

If you believe a child's privacy has been affected and we have not resolved it to your satisfaction, you can also contact your local data protection authority. We will never penalise a parent for asking, and we will never hide a data issue from you.