TwinOry Member Account Terms
1. Parties and scope
1.1 These terms are a contract between you and SMARTEDTECH SL, B66970831, Carrer Agricultura, 16, 1º, 9ª, 08320 El Masnou, Barcelona, Spain (the Operator) for a TwinOry member account.
1.2 The account gives you access to the free member functions: creating and configuring one Twin, publishing selected fields to a selected audience, following other Twins, and asking and answering Ask Cards. Paid plans (Standard, Premium, VIP) are governed by CUS-01 and CUS-02 and become available only when the price page shows a price and the order flow is enabled.
1.3 The AI and Identity Use Policy (ACC-02) and the Persona Owner Publication and Identity Licence (TWN-01) form part of these terms. The Privacy Notice (PUB-02) is information, not a contract term.
2. Formation
2.1 A contract for the platform service is formed when the Operator records your acceptance of the applicable terms through the acceptance control shown to you (an unticked checkbox, an order button labelled with an obligation to pay, or an electronic signature) and, for paid services, when the payment provider confirms payment.
2.2 The Operator keeps an append-only record of the document identifier, version, content hash, date, time and acceptance method. You may request a copy of the record and of the accepted version at any time at legal@twinory.net. Each version is archived at /legal/account-terms/v/«version».
2.3 Acceptance by a person acting for an organisation is a representation that the person is authorised to bind that organisation. Where the Operator requires verification of that authority, the service for the organisation is not activated until verification is complete.
2.4 The Operator may rely on an electronic signature produced through its signature provider as the signature of the signatory under Regulation (EU) No 910/2014 and, for the UK, the UK eIDAS regulation.
2.5 The signup screen shows this exact version with direct links. Marketing email, recommendation profiling, voice and likeness use, and sharing to another SET platform are separate unticked choices; none is required to open an account.
3. Eligibility and age
3.1 You must be at least 16 years old. The Operator refuses accounts for persons under 16 and closes any such account discovered later, returning any data to the guardian on request.
3.2 Members aged 16 or 17 use the service with the limits in clause 3.4 to 3.7 and in PUB-02 clause 3.
3.3 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. The TwinOry minimum age is 16.
3.4 Where a guardian acts for a member aged 16 or 17, the guardian's identity and capacity are verified before the guardian's request is executed. The guardian may access, correct and delete the minor's data, and may close the account at any time.
3.5 Adults in contact with minors through the platform are bound by clause 9; communications with minors through Ask Cards are logged and may be reviewed. Recording of a minor's voice or likeness for a Twin is permitted only with guardian consent.
3.6 Payment for a minor's service is made by the guardian; the minor's account cannot incur charges.
3.7 A member aged 16 or 17 may not monetise a Twin, may not enter a paid plan and may publish a Twin only after the additional publication review shown in Settings.
4. Your account
4.1 Keep your registration details accurate, protect your credentials, and tell support@twinory.net immediately if you suspect compromise. Do not share your account.
4.2 One person, one account. An account is personal and cannot be transferred.
4.3 An account does not make you a provider, a licensed professional or a signatory for an organisation; those roles require the corresponding verification and agreement.
5. Your Twin
5.1 You own your Twin. A Twin exists only while it has an identified owner; there is no unowned Twin.
5.2 You decide which fields are published and to which audience (private, followers, members, public). Nothing is published without your explicit publication action after preview (TWN-01).
5.3 Your Never-Do rules, private memory and protected identity settings are confidential and are never published, indexed or shared (PUB-02 clause 4). Your Twin does not disclose them.
5.4 Your Twin is labelled as AI in every interaction and never starts a conversation; it answers only Ask Cards addressed to it within the audience you selected.
5.5 Your Twin does not act for you in legal, financial or medical matters and cannot enter contracts on your behalf (ACC-02 clause 2).
6. Ask Cards and follows
6.1 An Ask Card is a question addressed by one member to another member's Twin. The asking member is responsible for the question; the owning member is responsible for the Twin configuration that produces the answer; the Operator provides the AI service under ACC-02.
6.2 Follows have no monetary weight and confer no right against the followed member or the Operator. Notifications are off by default and are controlled in Settings.
6.3 Answers are visible only to the asking member and to any audience the owner has explicitly enabled for that Ask Card.
7. Fees
7.1 Prices are those shown on the price page or order summary at the time of order. Prices for consumers are shown including applicable VAT; prices for business customers are shown excluding VAT unless stated. The Operator may change prices for future periods with at least 30 days' notice; a price change does not affect a period already paid.
7.2 Payments are processed by the payment service provider identified at checkout. The Operator does not store full card numbers. Bank transfer is available only where the order summary states so and only to the account stated on the invoice issued by the payee.
7.3 Where a provider is the seller, the provider's price, taxes, fees and refund rule apply to that supply; the Operator's platform fee, if any, is shown separately.
7.4 Invoices are issued electronically to the billing email on the account. Business customers agree to receive electronic invoices.
7.5 Overdue business invoices accrue interest at the statutory commercial late-payment rate and reasonable recovery costs; the Operator may suspend the service for a business customer on 7 days' written notice of non-payment.
7.6 The member account is free. No payment obligation arises until you place an order under CUS-01 through an order button labelled "Order with obligation to pay".
8. Advertising
8.1 The free member tier may show advertising labelled as such. Members on a paid plan that states "no advertising" see no advertising anywhere on the service while the plan is active.
8.2 Advertising is never inserted into a Twin's answers and never uses Private Rules.
9. Acceptable use
9.1 You will not: impersonate a person or a Twin owner; create a Twin of another person; publish a third person's messages, images or data without their permission; attempt to extract another Twin's Private Rules; harass, threaten or exploit any member, in particular a member aged under 18; manipulate follows or Ask Cards; upload unlawful, infringing or malicious content; bypass audience limits; or use automated means to query Twins at scale.
9.2 The Operator may warn, restrict, suspend or close an account for breach, giving reasons and a review route under MKT-02 except where urgent safety action is required.
10. Content and intellectual property
10.1 You retain ownership of content you upload. You grant the Operator a worldwide, non-exclusive, royalty-free licence to host, store, reproduce, adapt, display, distribute and create derivative works of your content for the purpose of operating, promoting (listing content only) and improving the service, for the term of your account plus the period required for backup and legal retention.
10.2 You warrant that your content does not infringe third-party rights and is not unlawful.
10.3 The Operator may remove or restrict content that it reasonably believes is unlawful, infringes these terms or creates a risk to users, and will inform you of the reason and the review route.
10.4 All platform software, designs, models, trade marks and data compilations are owned by the Operator or its licensors. No licence is granted except as stated.
10.5 The licence in clause 10.1 does not cover publicity, model training, synthetic voice or publication beyond the audience you selected; each of those requires the separate permission described in ACC-02 and TWN-01.
11. Data roles
11.1 Platform data. The Operator is the controller of personal data processed to operate the platform: account, identity verification, acceptance records, payments, security, support, communications and analytics.
11.2 Provider supply data. Where a provider supplies services to a customer through the platform, the provider is an independent controller of the data it needs for that supply (booking, order, clinical, educational or professional records), and the Operator is a controller of the platform-level record of the transaction. Each party complies with its own obligations; neither acts for the other.
11.3 Processor services. Where the Operator processes personal data on behalf of a business customer under the customer's instructions (for example an enterprise tenant's employee data), the Data Processing Agreement (DAT-01) applies and governs; it is signed as part of the order.
11.4 Sharing between SET platforms. Personal data is not shared with any other platform operated by the Operator or its group unless you enable the specific destination in your settings. Enabling one destination does not enable others, and you may disable it at any time.
11.5 International transfers. Personal data is stored in the European Economic Area (or, for wellbridge.uk, the United Kingdom). Where a processor outside those areas is used, the transfer is covered by Standard Contractual Clauses or the UK Addendum/IDTA, listed in the subprocessor annex.
12. Closure and retention
12.1 You may close your account at any time in Settings or by email to support@twinory.net. Closure unpublishes your Twin immediately.
12.2 Closure does not cancel a separately formed paid order, an unpaid invoice or a statutory record; the Operator tells you which obligations remain and keeps receipts available.
12.3 You may export your Twin content and Ask Card history in a machine-readable format before closure and for 30 days after.
12.4 Account data is kept for the life of the account and deleted or anonymised within 90 days after closure, except where a longer period is required by law (tax and accounting records: 6 years; acceptance and consent records: 5 years after the end of the relationship, as evidence of compliance; records subject to a legal hold: until the hold ends).
12.5 Conversation logs, recordings and uploads not linked to an active contract are deleted no later than 12 months after the last interaction, and earlier on your request, unless a legal hold applies.
12.6 Backups are rotated on a cycle not exceeding 35 days; data deleted from production is removed from backups at the end of the cycle.
12.7 Where a provider is an independent controller, its own retention rules apply to its records.
13. Changes
13.1 The Operator may amend these terms for legitimate reasons: changes in law, in the service, in security or fraud prevention, in the payment provider, or to clarify wording. The Operator notifies you of material changes by email and in-product at least 30 days before they take effect (immediately where required by law or security).
13.2 If you do not accept a material change, you may terminate before it takes effect and receive a pro-rata refund of any prepaid period affected. Continued use after the effective date is acceptance; for major changes the service asks you to confirm acceptance at your next sign-in.
13.3 Every version is archived with its date and content hash at /legal/account-terms/v/.
14. Liability
14.1 The Operator is liable for damage caused by its breach of these terms, by its negligence, or under mandatory law. The Operator is not liable for loss that was not foreseeable at the time of contracting, for loss caused by a provider's supply where the provider is the contracting party, for your breach of these terms, or for events outside its reasonable control.
14.2 Nothing in these terms excludes or limits liability for death or personal injury caused by negligence, for fraud, for wilful misconduct or gross negligence, or for any liability that cannot be limited by law.
15. Complaints and out-of-court resolution
15.1 Complaints may be sent to support@twinory.net or submitted through /legal/complaints. The Operator acknowledges within 2 business days and answers within 15 business days (one calendar month maximum under Spanish customer-service rules).
15.2 Consumers resident in Spain may use the consumer arbitration system (Sistema Arbitral de Consumo) or the consumer mediation services of their autonomous community. Consumers resident in the UK may use a certified ADR provider named in the complaints page; the Operator states on that page whether it has agreed to use that provider. The The The EU Online Dispute Resolution platform has been discontinued and is not used.
15.3 Nothing in this clause prevents you from bringing a claim in court.
16. Governing law and forum
These terms are governed by Spanish law. You also benefit from any mandatory consumer protection provisions of the law of the country where you reside. Disputes are heard by the courts of your domicile; the Operator may bring proceedings in your domicile.
17. Features not yet in force
Echo, Arena and digital legacy release are described in schedules that are not in force. They are activated only by their feature flags (echo.enabled, arena.enabled, legacy.enabled) after separate notice and, where they change your obligations, separate acceptance. Nothing in these terms enables them.
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.
---
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.
---