TwinOry Privacy Notice
1. Controller
1.1 The controller of personal data processed on twinory.net is SMARTEDTECH SL, B66970831, Carrer Agricultura, 16, 1º, 9ª, 08320 El Masnou, Barcelona, Spain (the Operator). Privacy contact: privacy@twinory.net. Rights form: /legal/privacy-rights.
1.2 Data-protection roles are allocated as follows.
1.3 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.
1.4 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. On twinory.net this paragraph applies only where a third-party supply is enabled and identified on the order summary.
1.5 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.
1.6 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.
1.7 International transfers. Personal data is stored in the European Economic Area. Where a processor outside the EEA is used, the transfer is covered by Standard Contractual Clauses, listed in the subprocessor annex (DAT-02).
2. What we process, why and on what basis
| Data class | Purpose | Legal basis (GDPR) | Retention |
|---|---|---|---|
| Account data: email, display name, date of birth or age band, password hash, language, settings | Create and operate your account; age gate; security | Art. 6(1)(b) contract | Life of account + 90 days (clause 6) |
| Acceptance records: document id, version, hash, time, method, hashed IP and user agent | Prove which terms you accepted | Art. 6(1)(c) and 6(1)(f) evidence of compliance | 5 years after end of relationship |
| Twin content: published fields, Ask Card questions and answers, follows, visibility settings | Operate your Twin and the social discovery service | Art. 6(1)(b) contract | Life of account + 90 days |
| Private Twin configuration: Never-Do rules, private memory, protected identity settings | Enforce the limits you set on your Twin | Art. 6(1)(b) contract; clause 4 confidentiality | Life of account + 90 days; never published or indexed |
| Voice, image and likeness material (only if you enable it) | Create the voice or visual representation of your Twin | Art. 6(1)(a) consent, purpose recording_voice / likeness_persona (ACC-02) | Until withdrawal + 30 days (C25.3) |
| Guardian data for members aged 16–17 where guardian involvement is required by clause 3 | Verify guardian identity and capacity | Art. 6(1)(c) and 6(1)(f) | Life of the minor's account + 90 days |
| Payment data: plan, PSP customer reference, invoice data (never full card numbers) | Billing of paid plans once enabled (CUS-01, feature-flagged) | Art. 6(1)(b) contract; Art. 6(1)(c) tax | 6 years (tax and accounting) |
| Support and complaint correspondence | Answer requests, handle complaints, human review of AI interactions | Art. 6(1)(b) and 6(1)(f) | 12 months after closure of the case |
| Security and audit logs | Prevent abuse, investigate incidents, keep the append-only audit trail | Art. 6(1)(f) | 12 months; audit events per clause 6 |
| Optional analytics | Measure use of the site (only after you choose "Accept optional") | Art. 6(1)(a) consent, purpose analytics_optional (PUB-03) | Per PUB-03 inventory |
| Marketing email (only if you opt in) | Send product news | Art. 6(1)(a) consent, purpose marketing_email | Until unsubscribe |
| Recommendation profiling (only if you opt in) | Suggest Twins and Ask Cards relevant to you | Art. 6(1)(a) consent, purpose profiling_recommendation | Until withdrawal |
2.2 Mandatory fields are marked on each collection screen. Accepting the Member Account Terms is not consent to any optional purpose; each optional purpose has its own unticked control and can be withdrawn in Settings.
2.3 No AI decision on this platform produces legal or similarly significant effects for you without human review (ACC-02 clause 2; C07.2).
3. Age and guardians
3.1 TwinOry accounts are available to persons aged 16 or over. Accounts for persons under 16 are refused at signup and, where discovered later, closed.
3.2 Members aged 16 or 17 may use the service with the following limits: they 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. These limits are enforced by the age gate and cannot be removed by self-declaration.
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. On twinory.net the service minimum age is 16; accordingly a member aged 16 or 17 gives their own data-protection consent, and clauses 3.4 to 3.6 apply where a guardian is involved.
3.4 Where a guardian acts for a member aged 16 or 17 (for example to close the account or to exercise rights), the guardian's identity and capacity are verified before the 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 subject to the Acceptable Use rules in ACC-01; communications with minors through Ask Cards are logged and may be reviewed. Recording of a minor's voice or likeness for a Twin requires guardian consent in addition to the minor's own enabling action.
3.6 Payment for a minor's service is made by the guardian; the minor's account cannot incur charges.
4. Confidentiality of private Twin rules (Never-Do rules)
4.1 The Never-Do rules, private memory and protected identity settings you configure for your Twin (Private Rules) are confidential information of the member. The Operator treats Private Rules as follows:
(a) Private Rules are stored separately from published Twin fields and are never included in public pages, search indexes, sitemaps, API responses to other members, exports to other platforms or marketing material;
(b) Private Rules are not written into acceptance records, audit event payloads, proof records or any append-only ledger; only a minimised reference (rule set id, version, hash) is recorded;
(c) Private Rules are accessible to Operator staff only through the audited privileged-access function under INT-01, for a stated reason, for a limited time, and never for another member's benefit;
(d) Private Rules are not used to train models and are not disclosed to any processor beyond the hosting and inference services necessary to enforce them, each bound by DAT-01 confidentiality;
(e) a Twin does not reveal, paraphrase or confirm the existence of a specific Private Rule to any person other than its owner.
4.2 This clause survives closure of the account for as long as any copy of the Private Rules exists, and the Operator deletes Private Rules within the period in clause 6.1.
5. Recipients
5.1 Personal data is disclosed only to: (a) processors listed in the subprocessor annex (DAT-02) for hosting, authentication, email delivery, AI inference, payment processing (once paid plans are enabled) and support tooling, each under a data-processing agreement; (b) other members, limited to the Twin fields you have published and to the audience you selected; (c) public authorities where a legal obligation applies; (d) a successor in a merger or acquisition, under the same obligations.
5.2 The Operator does not sell personal data and does not share it with advertisers.
5.3 Cross-platform sharing with other SET platforms is OFF by default and is controlled per destination in Settings (clause 1.6).
6. Retention and deletion
6.1 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).
6.2 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.
6.3 Backups are rotated on a cycle not exceeding 35 days; data deleted from production is removed from backups at the end of the cycle.
6.4 Where a provider is an independent controller, its own retention rules apply to its records.
7. Your rights
7.1 You may request access, rectification, erasure, restriction, portability and object to processing, and you may withdraw any consent at any time with effect for the future, through /legal/privacy-rights or privacy@twinory.net.
7.2 The Operator verifies identity proportionately (normally by confirmation from the account email) and answers within one month; where an extension is lawfully required, the Operator informs you of the reason within the first month.
7.3 Erasure may be limited for the records listed in clause 6.1; the Operator tells you the scope and duration of any such limit.
7.4 You may complain to the Agencia Española de Protección de Datos (www.aepd.es) or to the supervisory authority of your habitual residence.
7.5 Data-protection contact: privacy@twinory.net. The Operator has not appointed a Data Protection Officer; the privacy contact is the Operator's data-protection contact.
8. Security
The Operator applies tenant isolation with row-level security, least-privilege and multi-factor access for privileged roles, encryption in transit and at rest for stored content, separate storage of Private Rules, append-only audit events, and tested restore procedures, as documented in the technical and organisational measures annex of DAT-01. Personal-data breaches are assessed and, where required, notified to the AEPD within 72 hours and to affected persons without undue delay (DAT-03).
9. Changes
9.1 The Operator may amend this notice 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).
9.2 A new purpose or a new category of recipient is enabled only after notice and, where consent is the legal basis, after your separate opt-in.
9.3 Every version is archived with its date and content hash at /legal/privacy/v/.