Privacy Policy

1. 1.1
   This privacy policy (“Policy”) explains how WisdomLabs AI India Private Limited (“We”, “Us” and “Our”) collects, processes, stores, and/or shares any Personal Data (as defined below) and/or other information from or about the users (“You” or “Your” or “User” or “Users”) via Your access and registration on the web based TwinCafe platform (“Platform”) to use the Platform and the services we provide through it, including the creation, training and operation of a digital twin, being an artificial intelligence persona which responds to other Users on a User's behalf (“Digital Twin” or “Twin”) (together, the “Services”).
2. 1.2
   This Policy and Our Terms of Service together constitute the basis on which You engage with the Platform, and they form part of the understanding between You and Us. They are to be read together, and Your registration on and use of the Platform signifies that You have read, understood and accepted both.
3. 1.3
   Any word or expression used but not defined in this Policy shall have the meaning given to it in Our Terms of Service. Our Terms of Service and this Policy are together referred to as the “Policies”. This Policy is nonetheless presented so that it may be read and understood on its own.
4. 1.4
   We may update this Policy from time to time by publishing a revised version on the Platform and shall notify the same in order to comply with all laws, rules, regulations, orders and directions in force in India or the region from which You access the Platform (“Applicable Law”), and You agree to be legally bound by the Policy. Please check this Policy each time before You share Personal Data (defined below) with Us. If You object to any update to this Policy, You may write to Us and discontinue Your Use of the Platform.
5. 1.5
   This Policy, and any request for Your consent, is presented in clear and plain language. You may access this Policy and any such request in English or in any language specified in the Eighth Schedule to the Constitution of India, and You may ask Us for it in writing.
6. 1.6
   Where a User who has created a Twin (a “Twin Creator”) uses that Twin for purposes of its own then that Twin Creator decides why and how the Personal Data You give to that Twin is used for those purposes, and is an independent Data Fiduciary in respect of that use. We only process that Personal Data on the Twin Creator's behalf for those purposes.
7. 1.7
   Subject to clause 1.6, We process Your Personal Data on the basis of Your consent, given by a clear affirmative action at the point at which We ask for it (including at registration, before You create a Twin, and before any optional cookie is set), or for a legitimate use permitted under the Applicable Laws, including where processing is needed as per the Applicable Law. Each request for consent is accompanied or preceded by a notice which may be read independently of any other information We give You, which itemises the Personal Data sought and the specified purpose for which it is sought, and which tells You how to withdraw consent, how to exercise Your rights and how to complain to the Data Protection Board of India. Your consent is limited to the Personal Data necessary for the specified purpose. You may also give, manage, review and withdraw Your consent through a Consent Manager registered with the Board, once one is available to You.
8. 1.8
   This Policy also applies where You interact with a Twin which a Twin Creator has embedded on its own website (a “Website Twin”). In that case We collect only the conversation, the technical information described in clause 2.4 and anything else You choose to give, and clause 1.6 applies.

For the purpose of providing the Services and Your use of the Platform, We collect the following information about You, which, to the extent it relates to and is capable of identifying You, is Your personal data (“Personal Data”):

1. 2.1
   Information you give us: Your name, email address, mobile number, account details and anything you choose to put on a public profile. This is collected to create and administer your account, to confirm who you are, to communicate with you about the Service, and to display your public profile where you choose to have one. The accuracy of the information You give Us, and the liability attaching to it and to anything else You put onto the Platform, are governed by the Policies.
2. 2.2
   What You do on the Platform: The questions You put to a Twin, the conversations You have with it, the items You save, the edits You make, any correction or approval You give to a response, and Your notification preferences. This is collected to generate responses through the Twin, to keep Your conversation history and saved content available to You, to record any correction or approval You give to a response, and to send You only the notifications You have chosen. A Twin generates its response only from the Material supplied by the User to whom that Twin belongs. Where the User to whom a Twin belongs has left switched on the automated response feature described in the Terms of Service, a response may also draw on the underlying artificial intelligence model.
3. 2.3
   Booking and payment information: The meeting you booked, the price, the date and time, the status of your checkout, receipt and refund status, and any dispute or chargeback. We do not store your full card, bank account or Unified Payments Interface credentials, which are collected directly by our payment partners. This is collected to take and fulfil your booking, to process payment and payouts, to issue receipts, to make refunds, to handle disputes and chargebacks, and to keep the records that tax and company law require.
4. 2.4
   Technical information: Device and browser data, IP address, and logs of your use of the Service, collected for security, fraud prevention and to keep the Service working. We also retain Your conversation history with a Twin for security purposes, including to detect, investigate and prevent misuse of the Platform, to enforce the Policies, and to respond to a complaint or to a lawful request, and We retain it in accordance with Applicable Law and clause 7.3.
5. 2.5
   User Material: The documents, text, recordings, images, responses and other content You supply to create, train and operate Your Twin, which may include recordings of Your voice and images of Your face (the “Material”). The Material is collected to create, train, operate and improve Your own Twin, and may also be used to train and improve the Platform. You may opt out of the use of Your Material to train and improve the Platform at any time by writing to Us, and opting out does not affect Your use of the Platform.
6. 2.6
   A User below eighteen (18) years of age may use the Platform only with the consent of a parent or lawful guardian, and We shall process that User's Personal Data only with such consent. Where we process the personal data of a person with a disability who has a lawful guardian, we shall do so only with that guardian's consent. We do not track or behaviorally monitor a child, and we do not direct advertising at a child. Where We become aware that an account has been created by, or that We hold information about, a person under eighteen (18) years of age without the consent of a parent or lawful guardian, we shall forthwith delete the account. If You believe We hold such information, please tell Us.
7. 2.7
   We collect only such information as is necessary for the purposes set out in clause 4 and for providing the Service, and no more. Where any information is optional, we tell you so at the point at which we ask for it, and declining to give it does not stop you using the rest of the Service.
8. 2.8
   Some of the information We collect, such as any voiceprint or facial template derived from the Material, is dealt with in accordance with Applicable Law and, wherever applicable, the Policies.
9. 2.9
   Please do not put information into a conversation which You would not want processed in accordance with the Policies, including anything about Your health, Your finances or another person. If You do include information about another person, You confirm that You are entitled to share it with Us for the purposes set out in clause 4. Where the Material or a conversation contains the personal data of another person, We process it only where there is a lawful basis to do so under Applicable Law. A Twin Creator who includes the personal data of another person in the Material is the Data Fiduciary in respect of it, and confirms that the other person has been given notice and has consented, or that another lawful basis under Applicable Law applies.
10. 2.10
    Your obligations are expressly mentioned in the Policies, and the same shall be binding on You.

1. 3.1
   We use cookies and similar technologies to keep you signed in, to remember your preferences, to keep the Service secure and to understand how it is used. Some are necessary for the Service to work at all. Others are optional. The optional cookies are not loaded until You consent, save to the extent strictly necessary for the security and working of the Service.
2. 3.2
   We ask for your consent before we set any optional cookie, and you may change or withdraw that consent at any time through the cookie controls on the Service or in your browser. Refusing an optional cookie does not stop you using the Service.

The information collected under clause 2 is used only for the following purposes:

1. 4.1
   To provide the Services, including generating responses, creating, training and operating Twins, and running Your account.
2. 4.2
   To take and fulfil bookings, take payment, issue receipts, make refunds and handle disputes and chargebacks.
3. 4.3
   To keep the Service safe, to prevent fraud and abuse, and to moderate content.
4. 4.4
   To meet our legal obligations.
5. 4.5
   To improve the Service, which means analysing use of the Service in aggregated or de-identified form, fixing faults and developing features, and does not include training any general purpose artificial intelligence model on Your Personal Data, save that the Material is used as set out in clause 2.5.
6. 4.6
   Your conversations never form part of the Material of a Twin belonging to any other User and are not used for training another User's Twin or the Platform, and We do not sell Your information to any third party for any purpose. A correction, edit, note or approval which a Twin Creator gives to a response of its own Twin forms part of that Twin Creator's own Material. The other User's side of the conversation does not.
7. 4.7
   To send You communications about Your account and the Service and, only with Your separate consent, which You may withdraw at any time without losing access to the Service, marketing and promotional communications and research surveys.

1. 5.1
   Service providers who work for us under contract and under obligations of confidentiality and security, including cloud hosting, email and message delivery, artificial intelligence model providers, payment processors and payout providers. We share your information with them only so that they may provide those services to us, which include providing customer support, improving the functionality of the Services, analysing how the Services are used, conducting research and surveys, and marketing and promoting the Services. Where a response is generated, Your question, the context retrieved from the Material and the response may be sent to Our artificial intelligence inference and embedding providers so that the response can be produced, and they process it on Our behalf and under Our instructions.
2. 5.2
   The User to whom a Twin belongs, to the extent that a conversation with that Twin is shown to them. You should assume that what You write to a Twin may be read by the User to whom that Twin belongs.
3. 5.3
   A Government agency lawfully authorised to obtain it, or where disclosure is required by law or by an order of a court or authority.
4. 5.4
   A buyer or successor, if our business or a part of it is transferred, on terms which protect your information at least as well as this Policy.
5. 5.5
   A twin generates its response automatically, and We make no decision about You that produces a legal or similarly significant effect solely by automated means. Where an automated system flags your account for a safety or fraud concern, a person reviews it before we suspend or terminate your access, except where the law or an immediate risk of harm requires us to act at once. This clause is to be read in accordance with the Policies.
6. 5.6
   We remain responsible for Your information in accordance with the Policies while a service provider processes it on Our behalf. We engage each provider under a contract or under the terms applicable to that provider's services, which require the provider to apply reasonable security safeguards, and We require each provider to erase Your information on Our instruction, in each case to the extent applicable to that provider.

1. 6.1
   We use third party hosting and infrastructure providers, and Your information may be stored and processed by them outside India. We do not transfer Your Personal Data to any country which the Central Government restricts for that purpose under Applicable Law. We shall comply with the Applicable Laws as they apply on us.

1. 7.1
   We keep information only for as long as is needed for the purpose for which it was collected, or for as long as the law requires.
2. 7.2
   Your conversations with a Twin are retained by Us, and remain available to the User to whom that Twin belongs, for so long as that User's Twin remains active on the Platform, subject to clauses 7.1, 7.3 and 7.6 and to Your right to ask for erasure under clause 9.1.
3. 7.3
   We retain personal data, associated traffic data and other logs of the processing for a minimum period of one (1) year from the date of such processing, in accordance with Applicable Law, after which We cause them to be erased unless further retention is required under any other law for the time being in force or is notified by the Government. Any erasure You ask for under this Policy takes effect subject to that minimum period.
4. 7.4
   Where We erase information, We do so category by category rather than in general terms and erasure reaches Your account and profile data, the Material and any voiceprint or facial template derived from it, the embeddings, indices and other artefacts derived from the Material, Your conversations with a Twin and any saved, cached or derived copy of them, the retrieval records described in clause 7.5, and the logs described in clause 8.1, in each case subject to clause 7.3 and to any retention required by Applicable Law. Deleting a file does not by itself delete what has been derived from it, and Our erasure reaches the derived copies and not only the file.
5. 7.5
   Where We keep a record of which of the Material was used to generate a particular response, that record identifies the source and the class of the source and does not store the passage itself. It is retained in accordance with clauses 7.3 and 8.1 and is erased with the Material to which it relates.
6. 7.6
   Where a Twin is unpublished, paused or removed, or where the User to whom it belongs withdraws consent to the operation of that Twin, dies or becomes incapacitated, and We are informed of it by You or Your representative, We shall stop generating responses from that Twin, stop making it publicly accessible, and disable any cloned voice, avatar or facial template associated with it. The Material and the artefacts derived from it are then erased in accordance with clause 7.4, subject to clause 7.3.

1. 8.1
   We follow reasonable security practices and procedures, comprising managerial, technical, operational and physical controls proportionate to the information we hold, in accordance with applicable law. Those controls include the guardrails and disclaimers applied to what a Twin may generate, encryption of information in transit and at rest, obfuscation, masking or tokenisation where appropriate, control of access to our computer resources, logging and monitoring with logs retained for one (1) year, and backup and business continuity measures. We also maintain visibility over access to Personal Data through logs, monitoring and review so as to detect, investigate and remedy unauthorised access, synchronise Our system clocks and maintain the logs of Our information and communication technology systems for a rolling period of not less than one hundred and eighty (180) days in accordance with Applicable Laws and furnish them to the Indian Computer Emergency Response Team on a lawful request.
2. 8.2
   If a cyber security incident of a kind specified by the Indian Computer Emergency Response Team occurs, we shall report it to that team within six (6) hours of noticing it or being told of it.
3. 8.3
   Where a personal data breach affects your information, we shall tell you about it without delay, whether or not we consider it likely to cause you harm, describe the nature, extent and timing of the breach and what information was involved, tell you the consequences relevant to you that are likely to arise from it, what we are doing about it and what you can do to protect yourself, and give you the business contact information of a person who is able to respond to your queries about it. We give that intimation through your user account or through a mode of communication you have registered with us.
4. 8.4
   In case you come across some information or have reasonable apprehension of a cyber security incident, We would appreciate it if You bring it to Our attention promptly.
5. 8.5
   Where a personal data breach occurs, we shall also intimate the Data Protection Board of India without delay of the nature, extent, timing and location of the breach and its likely impact, and shall furnish the further particulars the law requires within seventy two (72) hours of becoming aware of the breach or within such longer period as the Board allows on request.
6. 8.6
   Any dispute or difference arising out of or in connection with this Policy shall be dealt with in accordance with the Policies.

1. 9.1
   You may ask us for a summary of the personal data we hold about you and of the processing we carry out on it, and for the identities of the data fiduciaries and data processors with whom we have shared it together with a description of what was shared. You may ask us to correct, complete or update anything that is inaccurate, incomplete or out of date, and you may ask us to erase your personal data or to delete your account.
2. 9.2
   You may withdraw at any time any consent You have given Us. Where You withdraw consent to a particular feature, such as optional cookies, account messages, or the use of Your voice or image, We disable that feature and You may continue to use the rest of the Platform. Withdrawal of consent to the processing of the Personal Data needed to operate Your account disables Your access to the Platform and can be given effect only by deletion of Your account. On deletion, we shall erase your personal data in accordance with clause 7, save for information we are required by law to retain. We shall nevertheless retain Your conversation history for security purposes in accordance with clause 7.3 and Applicable Law. Withdrawal of consent does not affect the lawfulness of processing carried out before the withdrawal, and the consequences of withdrawal, such as the loss of a feature or of access, are borne by You. On withdrawal We shall, within a reasonable time, stop processing the Personal Data concerned and cause Our data processors to stop, unless processing without consent is required or authorised under Applicable Law.
3. 9.3
   We send You a one-time passcode by short message service where You enter Your mobile number and request a sign-in or verification code, and We send You other alerts by short message service only if You consent to receive them. You may withdraw your consent at any time by replying STOP to any account notification message, by disabling the option in Your account settings, or by removing Your verified mobile number, and You will continue to receive sign-in codes when You request them.
4. 9.4
   You may nominate another individual to exercise your rights under this Policy on your behalf in the event of your death or incapacity, by writing to Us.
5. 9.5
   You may withdraw Your consent and exercise Your rights under this Policy through the Platform at www.twincafe.com, through the controls in Your account settings, or by writing to Us, and withdrawing Your consent is made no more difficult for You than giving it was.
6. 9.6
   We shall respond to a request under this clause 9 within thirty (30) days of receiving it. We may ask you for information reasonably needed to verify your identity before we do so. To enable Us to identify You, a request should be made from the email address or mobile number registered with Your account and should give Your username or other account identifier.
7. 9.7
   In exercising Your rights under this clause 9, You are required to comply with Applicable Law, not to impersonate another person, not to suppress any material information when providing Personal Data for a document or proof of identity or address, not to register a false or frivolous grievance or complaint, and to furnish only verifiably authentic information when asking for correction or erasure.