TWINThinkingWealth. inclusion

Trust, privacy, and how it actually works

Built so no one has to take our word for it.

Privacy here isn’t a policy bolted on at the end — it’s the architecture. Here is exactly how each product handles a child’s data, and why, in the places that matter most, there’s nothing to handle.

Why we built it this way

Sending words to a server used to be the only way to make AI useful.

Once a child’s data sits on servers, the incentives change — profiles, personalisation, monetisation.

So we waited. Until useful AI could run on the device itself.

Now the learning conversation happens locally.

That’s not a privacy policy. It’s architecture.
A policy is a promise. Architecture is a constraint.

Three modes, one principle

Honest about where the AI runs.

Local-first for children
In Alpha and Z the AI runs on the device. The child’s learning conversation is processed there, not sent to our servers.
Cloud-first for the classroom
Class uses frontier AI in the cloud for the teacher — but it never holds a student identity, because none exists.
Hybrid lessons
Class lesson content caches locally so a wifi drop never drops the class, and updates when there’s a connection.

The connections an unlinked device makes

The app connects only for limited operational reasons.

Download the app
From the app store, like any other app.
Download the AI model
A one-time fetch of the on-device model and its updates.
Update local content
Region packs and lesson content, carrying no user data.
Check compliance
A check for the latest privacy and policy version.

None of these is designed to carry a child’s conversation. When a device isn’t linked to a classroom, this is the shape of everything it sends.

The principles, stated plainly

01

No server-side student.

In Class and in the national Index there is, by construction, no student record on any server. There’s no child’s learning conversation sitting on our servers — nothing from it to sell, nothing from it to breach.

02

No trackers. No advertising. No data brokers.

The apps carry no third-party tracking, no advertising and no data brokers. There’s no behavioural profile being built, and nothing being sold.

03

No real money in a child’s hands.

Through launch, every market and every transaction is a simulation. No child moves real money inside TWin.

04

Designed against the frameworks that matter.

We build to be defensible to the people who answer for children — DPDP, KHDA, ADEK, COPPA, GDPR-K, FERPA. The test we set ourselves: could we show any screen to a thoughtful regulator without apologising for it?

05

The Index — privacy as a public good.

Anonymised, aggregated classroom scores become a public instrument for financial literacy — designed so an aggregate can’t be resolved back to a single child.

The safest child data is the data we never collect.