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Privacy Policy

Last updated: April 4, 2025

Introduction

This Privacy Notice for Twintual Inc. ("we," "us," or "our") describes how and why we might access, collect, store, use, and/or share ("process") your personal information when you use our services ("Services"), including when you visit our website at twintual.com, download and use our mobile application (Twintual), or engage with us in other related ways including sales, marketing, or events.

If you do not agree with our policies and practices, please do not use our Services. If you still have any questions or concerns, please contact us at info@twintual.com.

1. What Information Do We Collect?

Personal Information You Provide

We collect personal information that you voluntarily provide when you register on the Services, express interest in our products, participate in activities, or contact us. This may include:

  • Names, phone numbers, and email addresses
  • Usernames and passwords
  • Billing addresses and debit/credit card numbers
  • Job titles, contact preferences, and authentication data

Sensitive Information: We do not process sensitive personal information.

Payment Data: All payment data is handled and stored by Stripe. You may review their privacy notice at stripe.com/privacy.

Information Automatically Collected

We automatically collect certain information when you visit, use, or navigate the Services, including:

  • Log and usage data (IP address, browser type, activity in Services, date/time stamps)
  • Device data (device ID, model, operating system, hardware information)
  • Location data (precise or imprecise, based on device settings and GPS)

Application Data

If you use our application, we may collect information including mobile device access permissions (calendar, camera, contacts, social media accounts), mobile device data, and push notification preferences. You may adjust these permissions in your device's settings.

2. How Do We Process Your Information?

We process your personal information for a variety of reasons, including:

  • To facilitate account creation, authentication, and account management
  • To deliver and facilitate delivery of services to you
  • To respond to user inquiries and offer support
  • To send administrative information about our products, services, and policy changes
  • To fulfill and manage your orders, payments, returns, and exchanges
  • To enable user-to-user communications
  • To save or protect an individual's vital interest

3. When and With Whom Do We Share Your Information?

We may share your data with third-party vendors, service providers, contractors, or agents who perform services for us. We have contracts in place designed to safeguard your personal information. Third parties we work with include:

  • AI Service Providers: Google Cloud AI
  • Cloud Computing: Google Cloud Platform
  • Payments: Stripe
  • Authentication: Google Sign-In and Google OAuth 2.0
  • Analytics: Google Analytics, Google Analytics for Firebase, Google Tag Manager
  • Performance Monitoring: Firebase Performance Monitoring and Firebase Crash Reporting
  • Testing: Google Play Console and TestFlight

We may also share your information in connection with business transfers, with affiliates, or with your consent. We do not sell your personal information to third parties for marketing purposes.

4. AI-Based Products

Our Services use artificial intelligence technologies. We use Google Cloud AI for cloud-based AI services. AI-generated content may be inaccurate or incomplete. Users should not rely on AI output as a sole source of truth or factual information, and should independently verify any AI-generated content.

5. Cookies and Tracking Technologies

We may use cookies and similar tracking technologies to access or store information. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. If you disable or refuse cookies, some parts of our Services may become inaccessible or not function properly.

6. Data Security and Retention

We have implemented adequate organizational and technical processes to protect your personal information. However, no electronic transmission over the internet or information storage technology can be guaranteed to be 100% secure. We will retain your personal information only for as long as necessary for the purposes set out in this notice, unless a longer retention period is required by law.

7. Your Privacy Rights

Depending on where you are located, you may have certain rights regarding your personal information, including:

  • Access: Request a copy of the personal information we hold about you
  • Correction: Update or correct inaccurate information
  • Deletion: Request deletion of your personal information
  • Withdraw Consent: Withdraw consent for data processing at any time
  • Opt-out: Opt out of certain data processing activities including targeted advertising

If you are a resident in the European Economic Area or Switzerland, Mathieu Bertrandy has been appointed as our representative. You can contact them at mat@twintual.com.

8. International Data Transfers

Our servers are located in the United States. If you access our Services from outside the United States, your information may be transferred to, stored, and processed in the United States. We ensure appropriate safeguards are in place, including adherence to the EU-US Data Privacy Framework and Swiss-US Data Privacy Framework Principles.

9. Children's Privacy

We do not knowingly collect data from or market to children under 18 years of age. By using the Services, you represent that you are at least 18 or that you are a parent or guardian providing consent for a minor dependent's use of the Services. If we learn that personal information has been collected from users under age 18, we will take reasonable measures to promptly delete such data.

10. Updates to This Notice

We may update this Privacy Notice from time to time. The updated version will be indicated by an updated "Revised" date. If we make material changes, we may notify you by prominently posting a notice or directly sending you a notification. We encourage you to review this Privacy Notice frequently.

11. Contact Us

If you have questions or comments about this notice, you may contact us at:

Twintual Inc.
131 Continental Drive, Suite 305
Newark, DE 19713, United States
Email: info@twintual.com

EEA/Switzerland Representative:
Mathieu Bertrandy
Email: mat@twintual.com
Phone: +34 622272074
Rambla Ribatallada 31, blq 6, 1-3, Sant Cugat del Valles, Barcelona 08172, Spain

12. Review, Update, or Delete Your Data

Based on the applicable laws of your country or state of residence, you may have the right to request access to the personal information we collect from you, details about how we have processed it, correct inaccuracies, or delete your personal information. To request to review, update, or delete your personal information, please submit a data subject access request by contacting us at info@twintual.com.