TwinOry Legal Notice

1. Operator identity

1.1 Operator. This website and the services described in it are operated by SMARTEDTECH SL, a company incorporated in Spain with tax identification number B66970831, registered office at Carrer Agricultura, 16, 1º, 9ª, 08320 El Masnou, Barcelona, Spain, and contact address at Carrer Agricultura, 16, 1º, 9ª, 08320 El Masnou, Barcelona, Spain (the Operator). Electronic contact: legal@twinory.net. Telephone: +34 687 66 64 99.

1.2 Registry data. Registro Mercantil de Barcelona, Hoja B-501172.

1.3 Role. Unless a page or contract states otherwise, the Operator provides an information-society service as an intermediary platform. Where a third party (a provider, venue, professional, institution or seller) supplies goods or services to you, that third party is identified before you commit to any order, and that third party is the contracting party for that supply.

1.4 Precedence. Where a signed agreement exists between you and the Operator, the signed agreement prevails over this notice to the extent of any conflict.

2. The TwinOry service

2.1 TwinOry is a brand of SMARTEDTECH SL. The service on twinory.net is structured social discovery and owner-backed AI Twins: a member creates a digital representation of themselves (a Twin), decides which fields are published and to which audience, and other members interact with the published Twin through Ask Cards. Every Twin is owned by one identified member; there is no Twin without an owner.

2.2 The Operator is the provider of the platform service and the controller of platform data (Privacy Notice, PUB-02). Members are the authors of their own Twin content and are responsible for it under the Member Account Terms (ACC-01) and the Persona Owner Publication and Identity Licence (TWN-01).

2.3 A Twin, an Ask Card answer or any other AI output is labelled as AI-generated. It is information, not professional advice, and it does not bind its owner or the Operator (ACC-02).

3. Contact routes

Do not send passwords, full payment details, identity documents or health records through a public enquiry form.

4. Website content and intellectual property

4.1 The Operator and its licensors own the platform software, designs, models, trade marks and data compilations. You may read, link to and quote public pages within the limits of applicable law. No licence is granted to copy the platform, to scrape member content or Twins, to impersonate the TwinOry brand or to extract records.

4.2 Members retain ownership of their own content under ACC-01 clause 10.

4.3 Third-party marks and data remain subject to their owners' rights and attribution.

5. Complaints and competent authorities

5.1 Complaints are handled under clause 15 of the Member Account Terms (ACC-01) and the Notice, Action and Appeal Policy (MKT-02).

5.2 Data-protection complaints may be brought before the Agencia Española de Protección de Datos (AEPD) or the supervisory authority of your habitual residence.

5.3 Nothing in this notice limits a consumer's mandatory rights or the jurisdiction of the courts of the consumer's domicile.

6. Versions

Every version of this notice is archived with its date and content hash at /legal/legal-notice/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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