TwinOry International Transfer Schedule
1. Map the actual transfer
Identify exporter, importer, controller/processor role, country, recipient function, categories/subjects, frequency, onward access and hosting/support access. No default assumption is made that a Spanish domain stays in the EEA or that a UK domain uses a UK-established operator. If no restricted transfer occurs, record that fact and maintain a change trigger rather than attaching irrelevant SCCs.
2. Select and execute the instrument
Use a current applicable adequacy decision only within its scope and validity. Otherwise select the correct EU SCC module and complete its parties, annexes, technical/organizational measures and subprocessor details; keep the Commission's mandatory clauses intact. For a UK restricted transfer use the appropriate current UK IDTA or approved UK Addendum and complete its tables. This explanatory schedule is not itself a signed SCC/IDTA and does not replace their operative text.
3. Assessment and controls
Assess actual destination law, government access, data sensitivity and practical safeguards. Document access controls, encryption/key control, minimization, pseudonymization, complaint/redress and onward-transfer limits where relevant. Reassess material vendor, country or legal changes. If an instruction cannot be lawfully fulfilled, pause that transfer and seek a compliant alternative; do not paper over it with generic consent.
4. Release condition
No transfer is marked approved until the data map, importer identity, executed instrument, annexes, impact/risk assessment and supplementary measures are recorded. Data subjects retain the instrument's enforceable rights; disclose a lawful way to obtain relevant safeguards without disclosing others' secrets.
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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