Chat privacy

You are chatting on Telegram with a content creator who uses Twinyx to answer some messages with an artificial intelligence (AI) assistant. Here is what happens to your data, briefly and with no small print.

1. Who processes your data

• The creator you are talking to is the controller of your data in that conversation: they decide to use the assistant, and what for.
• Twinyx (BAIXOSAMA INVERSIONES, SL, NIF B27854181, Rua Condesa Casa Barcenas, 11, 36204 Vigo, Pontevedra, Spain, admin@twinyx.app) provides the service on behalf of the creator, as processor (Article 28 of the GDPR). It does not use your messages for anything else.
• Twinyx decides on its own about only one thing: it keeps proof that it told you an AI is replying, because the law requires it (Article 50 of the European Artificial Intelligence Act).

2. What data is processed

• Your Telegram ID and username, and the name you display.
• What you write in the conversation with the creator and the replies you receive. It may include intimate information or information about your sex life, which the law gives special protection.
• If you send photos, voice notes or other files, only the fact that you sent them is stored, not the file. Screenshots from a promotion swap are analyzed on the spot and not stored.
• Data generated as you chat: the date and time of the messages, whether the conversation is handed over to the creator, an estimate of the commercial interest of the conversation, your answer to the consent request and, if there is one, a flag indicating that you may be a minor.

3. What for

• To reply to you with AI on behalf of the creator and to alert them when they should take over.
• To tell you that an AI is replying to you and to ask for your consent.
• To protect the service against spam and abuse.
• Your data is not used for advertising, to train AI models or to build a profile of you.

4. On what legal basis

• Your explicit consent (Articles 6.1.a and 9.2.a of the GDPR). Nothing you write is processed with AI until you answer YES to the request you receive in the chat or tap the Yes, I agree button below it. By accepting you also declare that you are 18 or older.
• You can withdraw it whenever you want by writing STOP in the chat. From that moment the AI stops processing your messages, and the creator replies to you if they wish. Withdrawing does not affect what was processed before.
• Until you answer, your messages are only stored so that the creator can read them, as in any chat.
• The proof of the AI notice is based on a legal obligation (Article 6.1.c of the GDPR and Article 50 of Regulation (EU) 2024/1689).
• If you are another creator who uses Twinyx, or a channel with which the creator has already agreed a promotion swap or that is among the creator's trusted partners, we do not ask for your consent: the basis is the creator's legitimate interest in managing that commercial arrangement (Article 6.1.f of the GDPR). If you propose a swap for the first time without being one of them, you receive the same request as any other contact. You can object by writing to admin@twinyx.app.

5. Only for people aged 18 or over

This service is for adults only. If you say you are a minor, the AI stops replying to you and we alert the creator. We will never ask you for an identity document.

6. Who else receives your data

Only providers that work for Twinyx under a data processing agreement:

Telegram is the messaging platform you use, and it processes your messages under its own privacy policy.

7. How long it is kept

• Messages: at most 365 days and, in addition, only the last 50 or 200 messages of each conversation, depending on the creator's plan.
• Technical logs of the service: 30 days.
• Proof of the AI notice and of your answer to the consent request: 3 years from the last time the AI processed your messages. If you write again after that, you will be notified and asked again.
• If the creator deletes their Twinyx account or removes the Telegram account you are talking to from Twinyx, your data is deleted. The proof of the notice and of consent and, if there is one, the flag indicating that you may be a minor are kept, blocked, for up to 3 years to deal with claims (Article 32 of the LOPDGDD, the Spanish data protection act). Pending technical tasks are deleted within 7 days at most, and the notifications the creator received about your messages within 30 days at most. Google erases what it has already received within 55 days at most.
• Backups: overwritten every day.

8. Your rights

You can exercise your rights of access, rectification, erasure, objection, restriction and portability, and withdraw your consent:

• by writing STOP in the chat, which withdraws your consent immediately, or
• by writing to admin@twinyx.app with your Telegram username. To check that it is you, we will ask you to type a code in that same chat. We reply on behalf of the creator within one month at most.

If you ask us to delete your data, we keep the flag indicating that you may be a minor, if there is one, so that the AI does not reply to you again, and, if the creator had excluded you from the assistant or banned you from promotion swaps, that decision of theirs. The proof of the notice and of consent is kept, blocked, for up to 3 years to deal with claims.

If you think we have not handled your request properly, you can complain to the Spanish Data Protection Agency (Agencia Española de Protección de Datos, www.aepd.es) or to the data protection authority of your country.

9. Automated decisions

The assistant decides what to reply, but none of its decisions has legal effects on you or affects you in a similar way: when it cannot or should not reply, the conversation passes to the creator.

More information in our Privacy Policy.