Effective date: 7 October 2026
Operator: Tsuin AI Sdn. Bhd. (Kuala Lumpur, Malaysia)
The Cognitive AI Twin is a personal digital clone that captures your thought process. The more you use and interact with the AI Twin, the more it will think and act like you. The Twin continuously learns your unique thought process and reasoning and works on tasks autonomously on your behalf. It can also be used for instant knowledge transfer to another person. This page explains exactly what the app collects, which companies process it, where it is stored, and how you delete it.
- Your selfie never leaves your iPhone. Your twin's look is created on the device.
- Voice recordings are sent to our servers to be transcribed, then deleted. We keep the transcript, not the audio.
- Your messages, transcripts, answers and commit summaries are processed by our AI model provider to generate your twin's replies and to train your twin. They are never used to train a shared model or anyone else's twin.
- Your twin's text replies are turned into speech by ElevenLabs when voice replies are on. ElevenLabs never receives your voice.
- You sign in with Apple. We never see a password.
- No ads, no tracking, no analytics code in the app, and we never sell your data.
- You must be 18 or older.
- Delete your account from Settings. It is removed from our systems when you confirm; backups and vendor copies clear within 30 days.
1. Who we are
Tsuin AI Sdn. Bhd. is a company registered in Malaysia.
- Registered address: Kuala Lumpur, Malaysia
- Company registration number: 202501031994 (1633406-K)
- Contact: hello@tsuin.ai
We are the data controller (in Malaysian law, the "data user") for the personal data described here.
2. What this policy covers
This policy covers:
- the tsuin app for iPhone, distributed through the Apple App Store ("the app")
- the website at tsuin.ai
Other tsuin products (the desktop app and Team plans) are not yet released. This policy will be updated before they launch.
3. What we collect
3.1 Your account
You sign in with Apple. From Apple we receive:
| Data | Notes |
|---|---|
| Apple user identifier | A code unique to you and tsuin. We use it as your account ID. |
| Name | Optional. Apple lets you edit or remove it before sharing. |
| Email address | Either your real address or an Apple private relay address, your choice. We use it only to identify your account and to answer support requests. |
We never see or store your Apple ID password.
3.2 What your twin learns from
| Data | How it is collected | Why |
|---|---|---|
| Voice recordings | When you hold the mic button. The recording is sent to our servers, transcribed, and then deleted. | To understand what you said. |
| Messages and replies | Everything you type or say to your twin, and everything it replies. | To hold the conversation and to train your twin. |
| Commit data | Only from repositories you approve in the Inbox. For each commit: the commit message, a summary, and the diff (full or trimmed, your choice in Settings), plus your twin's guess about why you made the change and your correction. | To teach your twin how you work. |
| Questionnaire answers | The profile questions you answer in Teach. | To shape how your twin thinks. |
| Skills | Procedures you write down in Teach. | Same. |
| Feedback | Your corrections, skips and ratings of your twin's output. | Same. |
| Reports | When you report a reply: the prompt, the reply, the reason you chose and any note you add. | For human safety review. |
3.3 What stays on your iPhone
- Your selfie. The photo you take or choose is cropped, resized and stored only in the app's private storage on your iPhone. It is never uploaded. Your twin's look is rendered on the device. Remove it any time from Settings, or by deleting the app.
- Your preferences. The look you chose, whether voice replies are on, and the dates you confirmed your age and consent.
- Your sign-in token, stored in the iPhone Keychain.
3.4 Technical data
- Our servers keep standard request logs: IP address, time, and the endpoint called.
- The app contains no analytics, crash-reporting, advertising or tracking code. We do not show the App Tracking Transparency prompt because we do not track you.
- The website at tsuin.ai uses PostHog and Google Analytics. See section 10.
3.5 What we do not collect
- Your contacts, photo library (beyond the one selfie you pick), calendar, or precise location.
- Any repository data before you approve that repository.
- Any data from anyone under 18. See section 11.
4. How we use your data
| Purpose | Data used | Legal basis (PDPA / GDPR) |
|---|---|---|
| Run your twin: transcribe, reply, speak | Voice recordings, messages, replies | Performance of our contract with you, plus your explicit consent given in the app before the first recording |
| Train your twin | Messages, commit data, answers, skills, feedback | Contract |
| Keep you and others safe | Message content (checked for crisis language on the device and on our servers), reports | Legitimate interests, legal obligation |
| Operate your account, let you delete it | Account data | Contract |
| Answer support requests | Account data, whatever you send us | Contract, legitimate interests |
| Security, abuse prevention, rate limiting | Technical data, account data | Legitimate interests |
| Marketing emails, if you opt in on the website | Email address | Consent. Every email has an unsubscribe link. |
Your data trains your twin only. We never use it to train a shared model, another user's twin, or any vendor's model.
5. Who processes your data
Each company below is bound by a contract that limits what it can do with your data.
5.1 AI vendors
| Vendor | What it receives | What it does |
|---|---|---|
| Google LLC (Gemini API, United States) | Your messages, transcripts, answers, skills and commit data | Generates your twin's replies and processes your data during training. We use Google's paid API tier, under which Google does not use your data to train its models. |
| ElevenLabs, Inc. (United States) | The text of your twin's replies, only when voice replies are on | Converts that text to speech. ElevenLabs never receives your voice or your messages. |
5.2 Infrastructure
| Vendor | Role |
|---|---|
| Amazon Web Services | Hosts tsuin's servers, transcription, database and storage. Region: Southeast Asia (Singapore) |
| Google Cloud | Cloud infrastructure and hosting. Region: Southeast Asia (Singapore) |
| Supabase, Inc. | Database and storage services. Region: Southeast Asia (Singapore) |
| Apple Inc. | Distributes the app and provides Sign in with Apple |
| Vercel, Inc. | Hosts the website |
| PostHog, Inc. and Google Analytics | Website analytics only. Not present in the app. |
5.3 Other disclosures
We will disclose data when the law requires it, to protect someone's safety, or to a buyer if tsuin is sold or merged (you will be notified first). Otherwise we do not share your data with anyone.
We do not sell personal data. We do not share it with advertisers.
6. Where your data lives
- On your iPhone: your selfie, your preferences and your sign-in token.
- On tsuin servers (Amazon Web Services): your account, messages, transcripts, answers, skills, commit data, feedback, reports and your trained twin.
- With our AI vendors, transiently: Google and ElevenLabs process each request and do not retain your data beyond their standard abuse-monitoring windows.
Our vendors are in the United States. If you are in Malaysia, the EU or the UK, your data leaves your country. We rely on the vendors' standard contractual clauses and equivalent safeguards for these transfers.
7. How long we keep it
| Data | Kept until |
|---|---|
| Voice recordings | Deleted as soon as transcription finishes |
| Messages, transcripts, answers, skills, feedback, trained twin | You delete your account |
| Commit data from a repository | You revoke that repository in Settings, or delete your account |
| Reports | 12 months after review |
| Account data | You delete your account. Backups clear within 30 days. |
| Support emails | 2 years |
| Server logs | 90 days |
| Website analytics | 12 months (PostHog), 14 months (Google Analytics) |
When you delete your account we remove your data from our systems before confirming, revoke your Sign in with Apple token, and instruct our vendors to clear any copies within 30 days.
8. Your rights
Wherever you are, you can:
- Access a copy of your data
- Correct it
- Delete your selfie (Settings > Remove selfie), a repository's data (Settings > Shared repos > Revoke), or your whole account (Settings > Delete account)
- Export your transcripts and answers. Email us and we send them in a usable format. In-app export is coming.
- Withdraw consent by revoking a repository, turning off voice replies, or deleting your account
- Object to processing based on legitimate interests
- Complain to a regulator. In Malaysia that is the Personal Data Protection Department (JPDP). In the EU it is your national data protection authority. In the UK it is the ICO.
Email hello@tsuin.ai for anything you cannot do in the app. We respond within 21 days (the PDPA limit) and usually much faster.
If you are in California, the rights above cover your rights under the CCPA. We do not sell or share personal information as those terms are defined there.
9. Security
- Data is encrypted in transit (TLS) and at rest.
- Your sign-in token is stored in the iPhone Keychain and sent as a bearer token with each request.
- Every request is checked against your account. You can only ever read your own data.
- Voice recordings are deleted from your iPhone once uploaded and from our servers once transcribed.
- Access to production data inside tsuin is limited to engineers who need it and is logged.
No system is perfectly secure. If we discover a breach that affects you, we will tell you within 72 hours of confirming it.
10. Cookies, app tracking, and App Store privacy
- Website cookies: The website at tsuin.ai uses essential cookies and analytics tools (PostHog and Google Analytics). You can accept or decline analytics cookies via the cookie notice on the site.
- iOS App cookies: The tsuin iOS app does not use cookies. All session authentication is managed securely via the iPhone Keychain.
- iOS App tracking (ATT): The app contains no advertising SDKs, ad networks, or cross-site trackers. Because we do not track you across third-party apps or websites, the app does not display Apple's App Tracking Transparency (ATT) prompt.
- App Store Privacy Labels: Data collected by the app (such as account details, voice recordings for transcription, and conversations) is linked to your account to power your AI Twin, but is never used to track you across third-party apps or sold to advertisers.
11. Age
tsuin is for adults. You must be 18 or older to create an account, and the app is rated 18+ on the App Store. We do not knowingly collect data from anyone under 18. If you believe we have, email hello@tsuin.ai and we will delete it.
12. Your selfie and likeness
The selfie you take or choose must be of your own face. It is used only to render your twin's look on your own iPhone and is never uploaded or shared. You may not use anyone else's photo. See the Terms of Use.
13. Changes to this policy
When we change this policy we will update the date at the top and, for material changes, notify you in the app or by email at least 14 days before they take effect.
14. Contact
Tsuin AI Sdn. Bhd.
Kuala Lumpur, Malaysia.
hello@tsuin.ai