TwinOry Accessibility and Assistance Statement
1. Commitment
1.1 SMARTEDTECH SL designs twinory.net to be usable by as many people as possible. The target standard for the public pages, signup, Settings, Twin editor and Ask Cards is WCAG 2.2 level AA.
1.2 This statement describes the current conformance status as measured by the Operator. It is updated with each release that changes a covered journey.
2. Conformance status
2.1 Status: partially conformant with WCAG 2.2 AA. The journeys listed on this page under "Measured journeys" have been checked by the Operator with keyboard-only navigation and a screen reader; the known barriers are listed under "Known barriers" with a target release for each.
2.2 Third-party components (authentication provider, payment provider once enabled, embedded media placed by Twin owners) are the responsibility of their providers; the Operator links to their accessibility statements where available.
2.3 The page renders the measured journeys, known barriers and the measurement date from the Operator's accessibility register; this statement does not claim conformance for a journey that is not listed as measured.
3. Legal documents and acceptance controls
3.1 Every legal document is available as an HTML page with proper headings and as a downloadable copy on request from legal@twinory.net.
3.2 Acceptance checkboxes and the cookie banner are operable by keyboard and labelled for assistive technology. Where a barrier prevents you from completing an acceptance step, support@twinory.net records your acceptance by an alternative accessible route and issues the same durable copy.
4. Assistance and feedback
4.1 Report an accessibility barrier to support@twinory.net stating the page, the action you were trying to complete and the assistive technology used. Do not include passwords, payment details or health information in the message.
4.2 The Operator acknowledges within 2 business days and provides an accessible alternative for any essential service within 10 business days.
4.3 If you are not satisfied with the response, you may use the complaints route in PUB-04 clause 9 and, where applicable, the competent public accessibility authority of your country.
5. Change control
The Operator's accessibility owner records known issues, evidence and remediation priorities. A new release, theme, language or embedded provider triggers a re-check of the affected journeys before the statement is updated. Every version is archived at /legal/accessibility/v/.
Platform-specific terms
Persona, voice and likeness
1. You grant the Operator permission to create, store and operate a digital representation of you (text, voice, appearance) only to the extent you enable in settings. You may limit the audience, the topics and the actions of the representation, and the representation is labelled as AI in every interaction.
2. The representation does not act for you in legal, financial or medical matters and cannot enter contracts on your behalf unless a separate recorded delegation exists.
3. You may withdraw permission at any time; the representation is deactivated immediately and its training material is deleted within 30 days, subject to legal hold.
4. Professional representations state the professional's name, registration and a disclaimer that AI responses are not the professional's advice unless the professional has reviewed them.
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AI services: disclosure, limitations and human escalation
1. Disclosure. Where you interact with an AI system (chat, voice, agent, digital twin or generated content), the Operator tells you so at the start of the interaction and labels AI-generated or AI-manipulated content in accordance with Article 50 of Regulation (EU) 2024/1689. A voice or persona representing a real person is used only with that person's recorded permission.
2. Nature of outputs. AI outputs are generated from models and data that can be incomplete or wrong. They are information and assistance, not professional advice, and not a decision of the Operator. You remain responsible for decisions you take on the basis of an output. Where a decision has legal, financial, medical, educational or safety effect, the service routes it to a human reviewer or to you for decision, and the Operator does not make that decision automatically.
3. Human escalation. You may at any time request a human review of an AI interaction through «contacts.support.address» or the in-product escalation control; the Operator responds within 5 business days (consumer) or within the SLA (business).
4. Permitted use. You will not use AI features to impersonate a person without permission, to generate unlawful content, to circumvent safety controls, or to extract or reverse-engineer models. The Operator may suspend AI features for breach.
5. Recording and model use. Recordings, transcripts and uploads are used to provide the service to you. They are used to improve models only with your separate permission (purpose research_contribution), which you may withdraw at any time without affecting the service.
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Minors and guardians
1. The platform may be used by persons under 18 only where the specific service states so. In Spain, a person aged 14 or over may give their own consent to the processing of their personal data; for persons under 14, the holder of parental authority or guardianship must give consent and accept the terms. In the UK the corresponding age is 13.
2. The guardian's identity and capacity are verified before the minor's account is activated. The guardian may access, correct and delete the minor's data, and may close the account at any time.
3. Educators and other adults in contact with minors through the platform are vetted in accordance with the platform's safeguarding policy, and communications with minors are logged and may be reviewed. Recording of minors is permitted only with guardian consent.
4. Payment for a minor's service is made by the guardian; the minor's account cannot incur charges.
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