Privacy & Security Policy

MLtwist, Inc. (“MLtwist,” “we,” “us,” or “our”) respects your privacy and is committed to protecting personal data.

This Privacy & Security Policy explains how we collect, use, store, share, and protect personal data when you visit our websites, use our services, or interact with us.

MLtwist provides software and services that help organizations prepare, process, label, evaluate, and manage data for artificial intelligence and machine learning applications.

We do not sell personal data. We collect limited personal data necessary to operate our business, provide our services, communicate with customers, and maintain the security and functionality of our systems.

Customer-provided data is processed in accordance with the customer’s instructions and applicable agreements.

1. Scope of This Policy

This policy applies to:

MLtwist.com and other websites operated by MLtwist (collectively, the “Websites”).
MLtwist’s software platform, applications, and associated services (collectively, the “Services”).
Communications with MLtwist, including sales inquiries, customer support, and business correspondence.
Personal data processed by MLtwist in connection with its business operations.

This policy distinguishes between personal data that MLtwist processes for its own business purposes and data processed on behalf of customers.

Third-party applications and services integrated with MLtwist may have separate privacy policies.

2. Data Controller and Data Processor

Data protection laws distinguish between organizations that determine how and why personal data is processed (“controllers”) and organizations that process data on behalf of others (“processors”).

MLtwist as a Data Processor

When customers upload, submit, or otherwise provide datasets, files, images, videos, audio, text, or other content to the Services (“Customer Content”), the customer generally determines the purposes and means of processing.

In these circumstances, the customer generally acts as the data controller, and MLtwist acts as the data processor.

MLtwist processes Customer Content according to:

The customer’s instructions and configurations.
Applicable customer agreements.
Authorized use of the Services.
Applicable legal requirements.

Customers are responsible for determining the appropriate legal basis for processing personal data contained within Customer Content.

Individuals seeking to exercise privacy rights concerning Customer Content should generally contact the organization responsible for that content.

MLtwist assists customers with applicable data protection obligations as required by law and contractual agreements.

MLtwist as a Data Controller

MLtwist acts as a controller when it determines the purposes and means of processing personal data associated with its own business operations.

This may include:

Customer and prospective customer contact information.
Platform user account information.
Website analytics.
Customer support communications.
Billing and administrative records.
Security logs and operational information.

For questions about personal data controlled by MLtwist, contact [email protected].

3. Personal Data We Collect

We collect personal data necessary to provide, maintain, secure, and improve our Websites and Services.

Depending on your interactions with MLtwist, this may include the following categories.

Account and Organization Information

When an organization or individual creates an account, we may collect:

Names and business email addresses.
Organization names and business contact details.
Authentication and account information.
Account permissions and user roles.
Billing and administrative information.

Website and Usage Information

When you access our Websites or Services, certain technical information may be collected, including:

IP addresses.
Browser and operating system information.
Device type and technical configuration.
Pages visited and interactions with our Websites.
Referring websites.
Dates and times of access.
Application logs and error information.

Some information is collected automatically to operate and protect our Websites and Services.

Optional website analytics that use cookies, such as Google Analytics, are subject to the cookie consent choices described below.

Communications and Business Information

When you communicate with MLtwist, we may collect:

Your name and contact information.
Your organization and professional role.
Information included in correspondence or support requests.
Information voluntarily submitted through website forms.

We may also receive business contact information from partners, customers, and publicly available professional sources.

We may collect information about how recipients interact with our emails, such as whether an email was opened or a link was clicked. To do this, we may include a small transparent image (sometimes called a “clear GIF” or tracking pixel) in our emails. Much of this information is aggregated. You can prevent this tracking by turning off images in your email program.

We may record video or telephone calls with customers, for example for training and quality assurance. We record a call only with the participants’ consent, and we tell you when a recording is made. You can ask us not to record.

Customer Content

Customers may submit datasets and other content through the Services.

Customer Content may include personal data depending on the nature of the customer’s project.

MLtwist processes this content on behalf of the customer and according to the applicable agreements and instructions.

Third-Party Integrations

Customers may configure integrations with external software, cloud services, AI providers, and other third-party systems.

When these integrations are enabled, MLtwist may transmit or receive data as necessary to perform the customer’s requested operations.

Such processing is governed by the applicable agreements, customer configurations, and third-party service terms.

4. How We Use Personal Data

MLtwist processes personal data for legitimate business and operational purposes, including:

Providing our Services: Creating accounts, authenticating users, processing customer requests, and delivering contracted services.
Operating and securing our systems: Maintaining infrastructure, detecting abuse, preventing fraud, investigating security incidents, and troubleshooting technical issues.
Customer support: Responding to questions, resolving issues, and providing technical assistance.
Business administration: Managing contracts, billing, payments, and customer relationships.
Service improvement: Understanding product performance, identifying technical problems, and improving the functionality and reliability of our Services.
Website analytics: Understanding how visitors interact with our Websites when the necessary consent has been obtained.
Advertising: If we advertise in the future, we may use Google Analytics audiences to show MLtwist ads on other websites to people who have visited our Websites, subject to your cookie choices.
Business communications: Providing service announcements, responding to inquiries, and sending permitted business communications.
Legal compliance: Meeting applicable legal, regulatory, and contractual obligations.

We do not sell personal data.

Where required by law, we obtain consent before processing personal data for particular purposes.

5. Cookies and Website Analytics

MLtwist uses cookies and similar technologies to operate, secure, and understand the use of its Websites.

We distinguish between essential technologies and optional analytics technologies.

Essential Technologies

Essential technologies support the operation and security of our Websites.

These may include technologies used for:

Website security and protection against automated abuse.
Maintaining essential website functionality.
Remembering privacy preferences.
Protecting website forms and preventing spam.

We use Cloudflare services, including Cloudflare Turnstile where applicable, to help protect our Websites.

Essential technologies are not controlled by the optional analytics consent setting.

We also use Cloudflare Web Analytics to understand website traffic and performance. It does not set cookies on your device, so it is not controlled by the cookie consent setting. It collects limited technical and usage information, such as pages viewed and page performance.

Optional Analytics

MLtwist uses Google Analytics to understand website traffic and usage patterns.

Google Analytics may collect information such as pages visited, approximate geographic location, device characteristics, and interactions with our Websites.

We use Cloudflare Zaraz to manage the loading and operation of Google Analytics.

Analytics tracking is optional. Where consent is required, we do not activate optional analytics until you provide consent.

You may accept or reject analytics cookies through our cookie consent banner.

Your choice is stored so that you do not need to make the same selection on every visit.

Google Analytics Advertising Features

We have turned on these Google Analytics Advertising Features:

Google signals. For visitors who are signed in to a Google account and have turned on Ads Personalization, Google Analytics can add aggregated information such as demographics and interests, and connect activity across their devices and browsers.
Google Analytics audiences. We can group visitors based on how they use our Websites. We do not currently advertise with Google, but we may use these audiences in the future to show MLtwist ads on other websites through Google’s advertising services.

These features use first-party cookies, such as the Google Analytics cookie, together with third-party cookies, such as Google advertising cookies. They are part of our optional analytics, so they follow your cookie consent choice.

You can opt out of these features at any time by rejecting analytics cookies through our cookie banner or the Cookie settings link, by managing ad personalization in Google’s Ads Settings, or through the Network Advertising Initiative’s consumer opt-out. To learn how Google uses information from sites that use its services, see How Google uses information from sites or apps that use our services.

You may change or withdraw your analytics consent at any time using the Cookie settings link in the footer of our Websites.

Withdrawing consent prevents further optional analytics collection that relies on that consent. It does not automatically delete information lawfully collected before withdrawal.

Browser settings may also allow you to manage or delete cookies.

For more information about Google’s privacy practices, visit: https://policies.google.com/privacy

For information about Cloudflare’s privacy practices, visit: https://www.cloudflare.com/privacypolicy/

6. Customer Data and AI Processing

MLtwist provides infrastructure and services for processing data used in artificial intelligence and machine learning workflows.

Customers control the datasets they submit, the processing workflows they configure, and the third-party integrations they authorize.

Customer Content is processed for the purpose of providing the Services requested by the customer, in accordance with applicable agreements.

MLtwist may use automated processing, AI models, human review, quality assurance procedures, and third-party tools to perform authorized customer workflows.

Where customers enable third-party AI providers, Customer Content may be transmitted to those providers as necessary to perform the requested processing.

The handling, retention, and use of Customer Content by third-party providers are subject to the applicable contractual terms and service configurations.

MLtwist does not claim ownership of Customer Content merely because it is submitted to or processed through the Services.

MLtwist does not sell personal data.

We may disclose limited personal data to third parties when necessary to operate our business, provide the Services, or comply with applicable legal obligations.

These recipients may include:

Service Providers

Companies that provide hosting, cloud infrastructure, analytics, authentication, security, communications, payment processing, and other operational services.

Such providers process data in accordance with applicable agreements and legal requirements.

Customer-Authorized Third Parties

When customers enable integrations, MLtwist may transmit Customer Content or related information to the selected providers as necessary to complete authorized workflows.

Business and Professional Advisers

We may share information with legal advisers, accountants, auditors, and other professional advisers where reasonably necessary.

Legal and Security Requirements

We may disclose information when reasonably necessary to comply with applicable law, respond to lawful requests, enforce agreements, investigate fraud, or protect the security and rights of MLtwist, its customers, or others.

Business Transactions

If MLtwist participates in a merger, acquisition, financing, restructuring, or sale of assets, relevant information may be disclosed as permitted by applicable law and subject to appropriate protections.

8. Data Retention

MLtwist retains personal data only for as long as reasonably necessary for the purposes described in this policy, unless a longer retention period is required or permitted by law.

Retention depends on the type of information and the purpose for which it is processed.

Customer Content is retained according to customer instructions, applicable agreements, and configured retention or deletion procedures.

Account and business records may be retained while an account or business relationship remains active and for an appropriate period afterward to meet contractual, accounting, legal, and security obligations.

Website analytics information is retained according to the applicable Google Analytics configuration and consent settings.

Security and operational logs are retained as reasonably necessary to protect our systems, investigate incidents, and maintain service reliability.

When information is no longer required, MLtwist deletes, anonymizes, or otherwise securely disposes of it as appropriate.

9. Data Security

MLtwist implements technical and organizational measures designed to protect personal data against unauthorized access, disclosure, alteration, destruction, and loss.

These measures may include:

Access controls and authentication.
Encryption and secure communications.
Monitoring and logging.
Infrastructure and application security controls.
Restricted access to customer environments.
Security review and incident response procedures.

No system can guarantee absolute security. MLtwist continuously evaluates and improves its security practices in accordance with operational requirements.

If you discover a potential security vulnerability, please contact: [email protected]

10. International Data Transfers

MLtwist operates in the United States and may use service providers located in other jurisdictions.

As a result, personal data may be processed or stored outside the country in which it was originally collected.

Where required by applicable data protection law, MLtwist implements appropriate safeguards for international transfers.

These may include contractual protections such as the European Commission’s Standard Contractual Clauses and other legally recognized transfer mechanisms.

Customers with specific data residency or processing requirements should refer to their applicable agreements with MLtwist.

11. Your Privacy Rights

Depending on your location and applicable law, you may have rights concerning your personal data.

These may include the right to:

Request access to personal data.
Request correction of inaccurate information.
Request deletion of personal data.
Request restriction of certain processing activities.
Object to certain processing.
Request data portability where applicable.
Withdraw consent where processing is based on consent.
Submit a complaint to an appropriate data protection authority.

These rights may be subject to applicable legal exceptions.

To exercise your rights concerning personal data controlled by MLtwist, contact: [email protected]

If your request concerns Customer Content that MLtwist processes on behalf of another organization, we may direct you to that organization or assist it in responding to your request.

12. European Economic Area and United Kingdom

If you are located in the European Economic Area or United Kingdom, additional protections may apply under the GDPR or UK GDPR.

Legal Bases for Processing

Where MLtwist acts as a controller, we process personal data under one or more applicable legal bases.

These may include:

Contractual necessity: Processing required to provide Services or fulfill agreements with individuals.
Legitimate interests: Processing necessary to operate and secure our business, maintain customer relationships, and improve our Services, provided those interests are not overridden by individuals’ rights and freedoms.
Consent: Processing optional website analytics and other activities for which consent is required.
Legal obligations: Processing necessary to comply with applicable laws and regulations.

Exercising Your Rights

You may submit a request concerning your personal data by contacting [email protected].

We will respond within the periods required by applicable law, generally within one month under GDPR, subject to permitted extensions.

You may also lodge a complaint with an appropriate data protection supervisory authority.

Where MLtwist processes Customer Content as a processor, the customer generally remains responsible for determining the legal basis for processing and responding to data subject requests.

13. California Privacy Rights

California residents may have additional privacy rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, the “CCPA”), where that law applies.

Categories of Personal Information

Depending on your interactions with MLtwist, we may collect:

Identifiers, such as names, email addresses, IP addresses, and account identifiers.
Professional or employment-related information.
Internet or electronic network activity information.
Approximate geolocation information.
Commercial information associated with customer relationships.
Other information voluntarily provided in communications or through the Services.

These categories are collected for the business and operational purposes described in this policy.

MLtwist does not sell personal information.

You can decline analytics cookies at any time through our cookie banner or the Cookie settings link in the footer of our Websites. Declining prevents optional analytics from running.

California Consumer Rights

Subject to applicable legal requirements and exceptions, California residents may have the right to:

Know and Access: Request information about the personal information we collect, use, and disclose.
Delete: Request deletion of personal information.
Correct: Request correction of inaccurate personal information.
Opt Out: Opt out of the sale or sharing of personal information where applicable.
Limit Certain Uses: Request limitations on certain uses or disclosures of sensitive personal information where the law provides that right.
Non-Discrimination: Exercise applicable privacy rights without unlawful discrimination or retaliation.

To submit a request, contact [email protected].

We may take reasonable steps to verify your identity before fulfilling certain requests.

Authorized agents may submit requests where permitted by law.

We respond within the timeframes required by applicable California law.

14. Children’s Privacy

MLtwist’s Websites and Services are intended primarily for business and professional use.

They are not directed toward children under 16.

MLtwist does not knowingly collect personal data directly from children under 16 through its Websites for its own business purposes.

Customer Content may be subject to separate customer agreements and instructions, including where customers are legally authorized to process data involving minors.

If you believe MLtwist has collected personal data from a child inappropriately, contact [email protected].

15. Third-Party Websites and Services

Our Websites and Services may contain links to external websites or integrate with third-party services.

These services operate under their own privacy policies and terms.

MLtwist is not responsible for the independent privacy practices of third parties that it does not control.

We encourage users to review the privacy policies of third-party services before providing information to them.

16. Changes to This Policy

We may update this Privacy & Security Policy to reflect changes in our Services, business practices, or legal obligations.

The updated policy will be published on our Website with a revised effective date.

Where required by law, we will provide additional notice of material changes.

17. Contact Information

For questions about this Privacy & Security Policy or to exercise applicable privacy rights, contact:

MLtwist, Inc.
2010 El Camino Real #2058
Santa Clara, CA 95050
United States

Privacy inquiries: [email protected]
Security inquiries: [email protected]
General inquiries: [email protected]
Website: https://mltwist.com

18. AI Content Policy

MLtwist creates and processes AI-generated content for our customers, including synthetic images, video, audio, and text used to train, test, and evaluate AI systems. This section describes the standards we follow when we do that work. Where a customer agreement sets stricter requirements for a project, we follow them.

Personal Information in AI-Generated Content

We design synthetic content to minimize the inclusion of personal information unless its use is specifically authorized and necessary for a legitimate customer project.

We do not include real people’s names, contact details, government identifiers, financial information, or other personal information in generated content unless a customer has the legal right to provide it and has instructed us to use it.
We take steps to keep personal information out of the prompts, reference material, and outputs we create.
If we find personal information in generated content that should not be there, we remove it or regenerate the content.

Likeness of Real People

We do not knowingly create content that depicts an identifiable real person, including their face, voice, or other distinguishing features, without that person’s consent or another clear legal right to do so.

We do not create content that impersonates a real person or presents them as doing or saying something they did not.

Sensitive and Edge-Case Scenarios

Some customers need AI systems that can recognize rare, dangerous, or harmful situations, such as accidents, hazards, security threats, or prohibited items. Training and testing those systems can require realistic examples of difficult scenarios.

We create this kind of content only:

For a legitimate safety, security, research, or testing purpose defined by a customer project.
To the extent the project requires, without gratuitous detail.
In compliance with applicable law, including U.S. federal and state law.

We do not create content intended to promote, glorify, or incite violence, or to harass, threaten, or intimidate anyone.

Content We Never Create

Regardless of the project, we do not create:

Sexual content involving minors.
Sexual or intimate content depicting a real person without their consent.
Content designed to deceive people into believing it is real, such as fake documents or fraudulent media.
Content that infringes the intellectual property or other rights of others.
Content that is otherwise illegal under applicable law.

Review and Labeling

Human review and approval are incorporated into synthetic content workflows according to customer requirements and project configurations. For managed synthetic video production, MLtwist performs human review before final delivery.

We keep track of what is synthetic. Each synthetic file we deliver is recorded as synthetic on its Data ID Card, along with the information used to create it, so that real and generated data can be told apart.

Third-Party AI Providers

We use AI models and services from third-party providers to generate content. We follow the usage policies of the providers we use, in addition to this policy.

Customer Responsibilities

Customers are responsible for having the rights and consents needed for any data, reference material, or likeness they provide to us, and for using the content we deliver in compliance with applicable law.

Raising a Concern

If you believe content created by MLtwist violates this section, or depicts you without your consent, contact us at [email protected]. We will review the concern and respond.