Twelver – Terms of Service & Privacy Policy

Applies to the “Twelver” mobile and web platform, published by The Mainstay Foundation (UK Charity No. 1166017)
Office 11, 211 Kingsbury Rd, London NW9 8AQ
Phone: +44 7507 899044
Email: info@mainstay.uk
Last updated: 25 June 2025

Summary

• Twelver is a free educational platform.

• You must use it respectfully, for lawful personal learning only.

• AI answers are machine-generated and not guaranteed to be accurate. Always verify religious rulings with qualified scholars.

• Children’s use is sandboxed and parent-supervised (age 6+).

• We only keep the data we need and you can request deletion/export.

• Users can report inappropriate AI or user content directly in the app or online.

Part A — Terms of Service

T1. Acceptance of Terms

By installing, accessing, or using Twelver you agree to these Terms of Service and the Privacy Policy in Part B. If you do not agree, do not use Twelver. Users must accept these Terms before uploading or submitting user-generated content.

T2. Eligibility & Age Gates

• Twelver is intended for users aged 6 or older.

• Children under 6 must use Twelver only with parental supervision, after the parent or guardian has created the child’s profile.

T3. Registration & Accounts

• Provide accurate information (name, email, age bracket).

• You are responsible for all activity under your account.

• Keep credentials secure; notify us immediately of unauthorised use.

T4. Content & Intellectual Property

• All original text, graphics, audio, video, and code are © The Mainstay Foundation or its licensors.

• Permitted use: personal, non-commercial study.

• Prohibited use: copying, scraping, redistributing, training external AI models on, or creating derivative works from Twelver content without permission.

T5. Permitted & Prohibited Use

You may not:

• Violate UK law, EU law, Google Play policies, or App Store policies.

• Upload illegal, hateful, extremist, defamatory, or sexually explicit material.

• Upload or distribute child sexual exploitation or abuse material (strictly prohibited).

• Attempt to reverse engineer, hack, or overload the service.

• Use Twelver for commercial tutoring without a separate licence.

T6. Community Guidelines & Moderation

• Users may upload content (text, audio, video) only if lawful, respectful, and educational.

• Prohibited content includes hate speech, harassment, extremist views, misinformation, or sexually explicit material.

• All user-generated content (UGC) is subject to ongoing moderation. We may remove violating content, suspend accounts, or block users.

• Users can report or block content and accounts through in-app tools or at twelver.ai/content_report. Reports are reviewed promptly by moderators.

• We act promptly on reports and strive to maintain a safe community environment.

T7. AI-Generated Content Disclaimer

• Twelver includes AI-generated responses (“Twelver AI”).

• AI responses are automated and may contain inaccuracies.

• Disclaimer: These do not replace human scholarship. Always verify with qualified religious authorities.

• AI outputs are filtered for harmful or sensitive content. Users can flag inappropriate responses.

• Human oversight exists to monitor and improve AI performance.

• We conduct rigorous testing of AI outputs using industry best practices (e.g., filters, human review, frameworks such as Google SAIF or OWASP GenAI red-teaming).

T8. Donations & Payments

• The core app is free.

• Optional donations or purchases are processed via Google Play Billing only.

• No card details are stored on Twelver servers.

T9. Disclaimer of Warranties

Twelver is provided “as is”. We do not guarantee AI responses or translations are error-free.

T10. Limitation of Liability

The Mainstay Foundation will not be liable for indirect or consequential losses, or for any amount exceeding £100 arising from use of Twelver.

T11. Indemnity

You agree to indemnify us against claims from your misuse or breach of these Terms.

T12. Suspension & Termination

We may restrict, suspend, or terminate access if you violate these Terms, applicable law, or platform policies. Where possible, we will notify you of the reason for such action. You may delete your account at any time (§ B7).

T13. Appeals Process

If your account or content is restricted, removed, or suspended, you may appeal by contacting us at info@mainstay.uk. Appeals will be reviewed promptly and fairly.

T14. EU Digital Services Act Rights

For users in the European Union, the Digital Services Act (DSA) provides additional rights:

• You may appeal moderation decisions using the process in § T13.

• You may refer eligible disputes to an independent out-of-court dispute settlement body certified by an EU Member State. A list of such bodies is published by the European Commission at ec.europa.eu.

• Twelver will cooperate in good faith with any DSA out-of-court dispute settlement proceedings as required by law, but is not bound by decisions of such bodies.

• You also retain the right to bring claims before competent courts.

T15. Governing Law & Disputes

These Terms are governed by the laws of England & Wales. Disputes are subject to the jurisdiction of the English courts, without prejudice to rights granted under the EU DSA.

T16. Changes to These Terms

We may update these Terms. Material changes will be announced in-app or by email 30 days before taking effect.

Part B — Privacy & Data Protection Policy

B1. Who We Are

Controller: The Mainstay Foundation, UK Charity No. 1166017.
Contact (privacy): info@mainstay.uk
Address: Office 11, 211 Kingsbury Rd, London NW9 8AQ

B2. Legal Framework

We comply with the UK GDPR, Data Protection Act 2018, EU GDPR, and the EU Digital Services Act (DSA). Our lawful bases are consent, contract (providing the service), and legitimate interest (service improvement).

B3. Data We Collect

B4. Sensitive Data

We do not request or store biometric/health data. Religious queries you submit voluntarily may be stored as conversation logs.

B5. Cookies & Similar Tech

We use first-party cookies/local storage for session tokens and Plausible analytics. No third-party advertising cookies.

B6. How We Use Your Data

• Provide and personalise the Twelver experience.

• Deliver AI answers and track learning.

• Improve moderation, AI safety, and app security.

• Protect against misuse and detect bugs.

• Fulfil charity audit/legal obligations.

B7. Your Rights

• Access, correct, export, or delete your data.

• In-app deletion/export options are provided.

• You can also request deletion online at twelver.ai/delete_account.

• Alternatively, email info@mainstay.uk from your registered address.

• Deletion timeline: live records erased within 30 days, backups within 90 days.

• Parents may delete child profiles anytime.

B8. Children’s Privacy

• Parents create and manage child profiles.

• No targeted ads.

• No sharing of children’s data with third parties.

• Children’s data can be deleted at any time.

B9. Sharing & International Transfers

We share data only with service providers (e.g., Supabase, AWS, Plausible). Transfers outside the UK/EU use ICO-approved Standard Contractual Clauses.

B10. Security Measures

• TLS encryption in transit.

• AES-256 encryption at rest.

• Role-based access control.

• Annual penetration testing.

• Conversation logs pseudonymised.

B11. Data Breach Procedure

We notify the UK ICO and affected users within 72 hours of any breach, per UK GDPR Art. 34.

B12. Permissions Use

• Camera/Microphone: only when you choose to upload/record content.

• Storage/Photos: only to let you upload selected files.

• Location (approximate): for analytics (city-level only).

• Permissions are never used without consent.

B13. User Reporting & Moderation

• Users may report AI or user-generated content in-app or online at twelver.ai/content_report.

• Reports are reviewed by moderators.

• We may remove content and suspend or block accounts that violate our policies.

B14. Child Safety

• We explicitly prohibit child sexual exploitation or abuse content.

• Dedicated contact: Child Safety Officer — info@mainstay.uk (Subject: “Child Safety”).

• Reports of child safety concerns are prioritised and acted upon immediately.

B15. Changes to This Policy

We will post updates in-app and change the “Last updated” date. Significant changes are emailed at least 30 days in advance.