1. Introduction

Agentic Labs Sdn. Bhd. ("we", "us", "our"), the owner and operator of the TwinGiG AI ("Platform"), is committed to protecting your personal data and respecting your privacy.

This Privacy Policy explains how we collect, use, disclose and protect personal data you provide when you access or use our Platform (the "Services"), whether as a Creator or User, and how your rights are managed under Malaysian law including the Personal Data Protection Act 2010 (PDPA).

2. Scope

This policy applies to all personal data collected by us via our website, Platform, mobile apps (if any), and other services, whether you are a creator publishing an agent, a user purchasing/using an agent, or a visitor to our site.

3. Data We Collect

We may collect the following categories of personal data:

• Registration & account data: name, email address, telephone/mobile number, password hash, company name (if applicable), billing address, payment details (via payment provider).
• Usage data: logs of access to the Platform, agent usage history, IP address, device type, browser type, timestamps.
• Agent content/metadata: if you are a Creator you may upload documents, agent persona descriptions, knowledge base, and behaviour settings.
• Payment & transaction data: transaction amount, currency, commission, payout account.
• Communications: support queries, feedback, chat transcripts (where relevant).

4. How We Use Your Data

We use your data to:

• Provide and maintain the Platform and services (registration, account management, agent submission, publishing, search, and transaction processing).
• Process payments and issue payouts.
• Enable you to build, publish, search for, and use agents.
• Analyse usage to improve our Platform, monitor performance, and detect fraud or security issues.
• Communicate with you (notifications, updates, and marketing communications if you have opted in).
• Comply with legal, regulatory, or tax obligations.

5. Legal Basis & Consent

Under Malaysian PDPA and relevant laws, we process your personal data where you have given consent, or where such processing is necessary for our legitimate business interests (providing and operating the Platform), the performance of a contract with you, or compliance with legal obligations.

By registering or using the Platform, you consent to our collection, use and processing of your personal data as described in this Privacy Policy.

6. Disclosure of Data

We may disclose your personal data:

• To third-party service providers (such as payment processors, hosting/cloud providers, and email/communications providers) under contract and with confidentiality obligations.
• To Creators or Users when necessary for a transaction with your consent or as otherwise permitted.
• To law enforcement agencies, regulatory bodies, or other authorities for compliance with legal obligations or court orders.
• In connection with business transactions (including merger, acquisition, or asset sale).

We will not sell your personal data for marketing or advertising purposes without your explicit consent.

7. International Transfers

Your data may be transferred, processed, and stored in jurisdictions outside Malaysia (for example, where our cloud hosting providers are located). Where we do so, we implement appropriate safeguards in accordance with applicable law.

8. Data Retention

We retain your personal data for as long as necessary to fulfil the purposes listed in this policy (including service delivery, payment support, and legal compliance). After that, we will securely delete or anonymise the data.

9. Security

We implement reasonable technical and organisational measures (such as encryption in transit, access controls, and regular audits) to protect your personal data. However, no system is completely secure and you use the Platform at your own risk.

10. Your Rights

Under the PDPA and other applicable laws, you may have the right to:

• Access your personal data held by us, and request corrections or updates.
• Withdraw your consent to processing (where consent is the basis for processing).
• Request deletion of your personal data (subject to our legal or regulatory retention obligations).
• Object to certain data processing activities (for example, processing for direct marketing).

To exercise your rights, contact us at [email protected]. We will respond in accordance with applicable law.

11. Cookies & Tracking

We use cookies, web beacons, and similar technologies to manage your session, remember your preferences, analyse usage, and deliver targeted (opt-in) communications. We only set non-essential cookies after you accept them in our consent banner. You may adjust your browser settings to block or limit cookies, but this may affect certain features or degrade your experience on the Platform.

12. Third-Party Links & Services

Our Platform may contain links to third-party websites or services. We are not responsible for the privacy practices or content of those third parties. We encourage you to review their respective privacy policies.

13. Changes to this Policy

We may update this Privacy Policy from time to time. We will notify you of material changes (for example, via email or a notice on our site). Your continued use of the Platform after such changes constitutes your acceptance of the updated policy.

14. International Users & GDPR/UK GDPR/US Rights

If you access the Platform from outside Malaysia (including the EEA, UK, or the United States), additional rights and disclosures may apply.

EEA/UK users: We process personal data under the legal bases of performance of a contract, legitimate interests, consent, and compliance with legal obligations. You may have the right to access, correct, delete, restrict processing, object to processing, and data portability, and to withdraw consent at any time where consent is the basis. You may also lodge a complaint with your local supervisory authority.

California users (CCPA/CPRA): You may have the right to know, delete, correct, and opt out of the sale or sharing of personal information (if applicable), and to limit the use of sensitive personal information. We do not sell personal information. You may exercise your rights by contacting us.

15. International Transfers & Safeguards

Where we transfer personal data internationally, we use appropriate safeguards such as standard contractual clauses (SCCs) or equivalent measures, and we limit access to authorized personnel only.

16. Children's Privacy

The Platform is not intended for children under 18 (or the age of majority in your jurisdiction). We do not knowingly collect personal data from children. If you believe a child has provided personal data to us, please contact us and we will take appropriate steps to delete it.

17. Data Protection Contact

For privacy questions or to exercise your rights, contact us at [email protected]. If you are in the EEA/UK and need an EU/UK representative, please contact us and we will provide the relevant details.

18. Contact Us

TwinGiG AI

Agentic Labs Sdn. Bhd. (1643912-P)

Level 19, BO1-D, Menara 2,
KL Eco City, No 3, Jalan Bangsar,
Kg Haji Abdullah Hukum,
59200, Kuala Lumpur
Malaysia

Email: [email protected]

Section Navigation

• 1. Introduction
• 2. Scope
• 3. Data We Collect
• 4. How We Use Your Data
• 5. Legal Basis & Consent
• 6. Disclosure of Data
• 7. International Transfers
• 8. Data Retention
• 9. Security
• 10. Your Rights
• 11. Cookies & Tracking
• 12. Third-Party Links & Services
• 13. Changes to this Policy
• 18. Contact Us