Privacy Policy

Last updated: March 21, 2026

1. Our Principles

  • ✓We don’t require personal information to play. Students can join and play with just a nickname.
  • ✓We don’t sell, rent, or share your data with advertisers.
  • ✓We don’t show ads. 100% of our revenue comes from optional subscriptions.
  • ✓We don’t use your prompts or images to train AI models.
  • ✓We collect only what we need to run the game and keep it safe.

2. Who Uses Twin Pics

Teachers

Teachers can create accounts with Google, Microsoft, Apple, or email and password. They create classrooms, invite students, and run live games.

Students

Students join classrooms using a word-based code and a nickname they choose. No account, email, or personal information is required to play.

Visitors

Anyone can browse the site. Browsing public pages does not create a gameplay session, but we may receive basic analytics and performance data about site visits.

3. What We Collect

Teachers (account holders)

Name, email address, and profile photo from your sign-in provider, or your email address and password hash if you sign up with email and password. Classroom names, join codes, and subscription status. Payment information is handled by our payment processor and is not stored on our servers.

Students (classroom players)

Chosen nickname, text prompts submitted during gameplay, AI-generated images, similarity scores, and a session cookie required for the game to function. We do not collect student names, emails, or other identifying information.

Technical data (all users)

Our infrastructure automatically collects standard request data such as IP addresses, browser type, and access timestamps for security and performance monitoring. Session cookies maintain your login state and are required for gameplay.

4. How We Use AI

Twin Pics uses AI services to power the core game experience:

  • Image generation: Your text prompt is sent to an AI image generation service to create your game image. We send the prompt text you submit for generation, and you should not include personal information in prompts.
  • Image scoring: Your generated image and the challenge image are sent to an AI scoring service to compute a similarity score. You should not include personal information in prompts submitted for gameplay.
  • Content safety: Prompts are screened by an AI classifier to filter inappropriate content before image generation. This protects students in classroom environments.
  • No model training: Your prompts, images, and game data are never used to train AI models. AI services process your data only to provide immediate game functionality.

5. Third-Party Services

We use the following categories of third-party services to operate Twin Pics:

  • Cloud hosting and infrastructure providers (website hosting, image storage, database)
  • AI image generation services (prompt-to-image, no personal data sent)
  • AI scoring and content safety services (image comparison, prompt moderation, no personal data sent)
  • Payment processing services (teacher subscriptions only, card data handled entirely by the processor)
  • Email communication services (teacher accounts only, for welcome and account emails)
  • Product analytics services (to understand how the game is used and improve the experience)
  • Authentication providers: Google, Microsoft, and Apple (for teacher sign-in)
  • Realtime infrastructure providers (for live game connections)

These services process data in accordance with their own privacy policies. We select providers that maintain industry-standard security practices and do not use your data for their own advertising or marketing purposes.

6. Classrooms

  • Teachers create classrooms with automatically generated word-based join codes.
  • Students join by entering the code and choosing a nickname. No account or personal information is required.
  • Teachers can view student nicknames, scores, and participation within their own classrooms only.
  • Classroom data (nicknames, scores, prompts, images) is scoped to each teacher and is not shared across classrooms or with other teachers.
  • Teachers can run live games where students compete in real time. Live game data (prompts, images, scores) is stored as part of the classroom record.

7. Children's Privacy & COPPA

Twin Pics is designed for use in K-12 classrooms and complies with the Children's Online Privacy Protection Act (COPPA). Here is how we protect children's privacy:

Anonymous play by default

Students play using only a self-chosen nickname. No email address, real name, or account creation is required. This minimizes the personal information collected from children.

Account creation is 13+

Creating an account (which requires a name, email, and sign-in with Google, Microsoft, Apple, or email and password) is intended for users aged 13 and older. We do not knowingly collect personal information from children under 13 through account registration.

School consent

When Twin Pics is used in a school or classroom setting, the teacher or school may act as the parent's agent and consent to the collection of student data for educational purposes, consistent with COPPA's school consent provision. The scope of this consent covers gameplay, scoring, and classroom participation tracking. Data collected under school consent is used solely for educational purposes and is not used for commercial purposes unrelated to the educational context.

Parental rights

Parents and guardians retain the right to: review the personal information collected from their child, request deletion of their child's data, and refuse further collection. To exercise these rights, contact us at the email address listed below.

Internal operations

We use session cookies and product analytics solely for internal operations: maintaining site functionality, monitoring performance, and improving the game experience. These tools do not track users across other websites and are not used for behavioral advertising.

8. Cookies & Analytics

  • Session cookies maintain your login state (anonymous or signed in) and are required for the game to function.
  • We use product analytics tools to understand how the game is used and to improve the experience. For authenticated teacher accounts, analytics may be linked to account information. For anonymous students, analytics uses session-level identifiers only.
  • Analytics tools do not track you across other websites.
  • Browser privacy settings may reduce some analytics signals, but Do Not Track is not treated as a universal opt-out for all analytics processing on Twin Pics.

If you clear your cookies without first signing in, your anonymous session and game history will no longer be accessible.

9. Data Retention

  • Active accounts: Data is retained while the account is active and for a reasonable period afterward to allow for reactivation.
  • Anonymous sessions: Anonymous gameplay data is tied to a browser-based session rather than a named account. Clearing your cookies makes that session inaccessible from your browser.
  • Deletion on request: You may request deletion of your data at any time by contacting us. We will process deletion requests promptly.
  • Classroom data: When a teacher deletes a classroom or their account, associated student data within that classroom is also deleted.

10. Your Rights

You have the following rights regarding your data:

  • Request a copy of any data associated with your account or session.
  • Request deletion of your account, images, prompts, and scores.
  • Use your browser privacy controls to limit some browser-based tracking tied to your device or session.
  • Clear your cookies to disassociate from an anonymous session.

To exercise any of these rights, contact us at privacy@twinpics.ai.

11. International Users

Twin Pics is operated from and data is stored in the United States. If you access Twin Pics from outside the US, your data will be transferred to and processed in the US. By using Twin Pics, you consent to this transfer.

For users in the EU/EEA: our legal basis for processing personal data is legitimate interest (providing the game experience) and consent (for optional marketing communications). You may withdraw consent for marketing at any time by unsubscribing from emails.

12. Changes to This Policy

We may update this Privacy Policy from time to time. When we make material changes, we will revise the “Last updated” date at the top of this page and notify registered users via email. We encourage you to review this policy periodically.

13. Contact Us

If you have questions about this Privacy Policy, want to exercise your data rights, or have concerns about children's privacy, contact us at: privacy@twinpics.ai

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