Privacy Notice

Notice version 2026-09-22.v1  ·  Effective 22 September 2026  ·  Jurisdiction: India  ·  Data Fiduciary: Future18

Who we are

SG Twin is a product of Future18 ("we", "us"). The SG Twin companion app (Brain Merge) captures and preserves your voice, memories and manner as a private digital twin. For the personal data described here, Future18 is the Data Fiduciary and you, the subscriber, are the Data Principal. This notice is provided under the Digital Personal Data Protection Act, 2023 (DPDP) and is available in English here and in Hindi within the app.

What we collect, and why

We collect only what you switch on. Inside the app, consent is itemised — you grant or withdraw each of the following on its own, and nothing in a category is collected until you allow it:

• Persona & voice learning — to learn how you speak and think and build your twin.
• Ambient audio — spoken audio around you while collection is on, for context.
• Call audio — your side of phone calls, when you enable it.
• Messages — your outgoing messages, for context.
• App usage — context from apps you select, to enrich memory.
• Location — coarse location attached to memories.
• Voice recognition (biometric) — a voiceprint to tell your voice apart from others. Sensitive personal data — collected only with your explicit consent.
• Face recognition (biometric) — a faceprint for people you enrol. Sensitive personal data — collected only with your explicit consent.

We do not use your data for advertising, we do not sell it, and we do not share it with third parties for their own purposes.

The lawful basis is your consent

Every category above is processed on the basis of your free, specific, informed and unambiguous consent, given through the itemised controls in the app against the version of this notice shown at the time. When the wording of this notice changes materially, we raise its version and ask you to review and consent again. Withdrawing consent is as easy as giving it — one tap per category, at any time. When you withdraw, we stop that use going forward and you can delete what was already collected.

How your information is used

Consented material is turned into your private persona model on hardware close to you. Only your own consented voice trains your twin; other people's voices are kept out of training unless that person's consent is recorded. Everything is used solely to build, preserve and serve your twin — for you, and for the people you later choose.

How long we keep it, and erasure

We keep your data only while your consent stands and for as long as it is needed to provide your twin. You can export or erase your entire twin from the app in a single action. One record we retain even after erasure is the log of your consents and withdrawals — kept as the legal proof, required by law, of what you agreed to and when. It is never used to rebuild deleted content.

How we protect it

Your vault is sealed with AES-256-GCM encryption using keys only you hold. We store ciphertext we cannot read — there is no master key and no back door. Privacy here is the architecture, not merely a policy.

Children

SG Twin is for adults aged 18 and over. We do not knowingly build a twin for a child. Where a person you enrol is a minor, their data is kept out of training unless verifiable consent from a parent or lawful guardian has been recorded.

Your rights

Under the DPDP Act you have the right to:

• Access — a summary of the personal data we hold and how it is processed.
• Correction & erasure — correct, update or delete your data.
• Withdraw consent — for any category, at any time, from the app.
• Grievance redressal — a readily available means to raise a complaint (below).
• Nominate — name another person to exercise your rights in the event of death or incapacity.

Withdrawal, export and erasure are built into the app. For access, correction, nomination or any other request, write to us at privacy​[at]​sgtwin​.com.

Grievance Officer

If you have a concern about how your personal data is handled, you can reach our Grievance Officer at grievance​[at]​sgtwin​.com. We will acknowledge your grievance and respond within the timelines required under the DPDP Act. If you remain unsatisfied, you may escalate to the Data Protection Board of India.

Changes to this notice

We may update this notice as the product and the law evolve. Each version carries a version number and effective date at the top. Where a change materially affects what we collect or why, we will raise the version and ask for your consent again before the change applies to you.

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