Privacy policy

TwinsAI, Inc. Privacy Policy

TwinsAI is committed to protecting your privacy. This Privacy Policy applies to the personal data we collect and process in the course of our business. TwinsAI acts in different ways when processing data:

• TwinsAI acts as a controller of your personal data when you sign up for our products and services, visit our websites or interact with us through other channels (for example in person events). We use this data for a variety of purposes, including to provide our products and services to you, contact you about relevant content, and improve and promote our products and services.
• TwinsAI acts as a processor when our customers use our products and services to collect and process personal data in connection with their sales, marketing, and other business activities. In this case, we act as a processor (or service provider) on behalf of our customers (who are controllers of personal data) under the TwinsAI Data Processing Agreement included in the Customer Terms of Service.
• TwinsAI also acts as a controller when we collect and process personal data about individuals in their professional capacity, and make that information available to customers for their own sales, marketing, and other business activities. This includes personal data we may collect indirectly about you, such as from publicly available sources, our customers, or other third parties. For more information see the “What Information We Collect and Process” section.

For the purposes of this Privacy Policy "Personal Data" means any information relating to an identified or identifiable individual. This Privacy Policy describes your choices and rights with respect to your Personal Data, including your rights of access and correction.  

• For information about how to exercise your privacy rights when TwinsAI acts as a controller of personal data, please see the “Your Privacy Rights and Choices” section.
• To opt out and delete your personal data from our commercial dataset of professionals, please email us at contact@twinsai.net
• If you wish to exercise your privacy rights regarding Personal Data we process on behalf of a customer, please refer to the customer policies and contact the customer directly.

We update this Privacy Policy from time to time and encourage you to review this Privacy Policy periodically. We will post any Privacy Policy changes on this page and, if the changes are material, notify you directly (for example, by sending you an email notification). Terms not otherwise defined in this Privacy Policy have the meaning given to them in the TwinsAI Customer Terms of Service.

1. Important information

1.1. General terms

At TwinsAI, Inc. (“TwinsAI,” “we,” “us” or “our”), putting our users (“you” or “your”) first means exceeding global privacy and data protection standards in order to keep important contacts and sensitive data and communications private, safe and secure.We set up our infrastructure, applications, and tools in a way that enables you to strengthen and leverage your important relationships when they matter the most, without having to worry about data security or privacy concerns.Our Privacy Promise:No one will access, read, or delete your emails.When TwinsAI connects to your email server, we pull only the minimum amount of information required for our service to function.Our server only stores emails you have sent via TwinsAI and any responses you received to those emails, so we can detect replies and you can have access to them from the application.You own your data.Your personal data will be kept private according to this policy and to the greatest extent allowed by the law.Additional questions? Don’t hesitate to send us an email at contact@twinsai.net. TwinsAI is committed to maintaining the privacy and security of any of your personal information on the website or in our applications or information received in any other manner. This Privacy Policy (“Agreement” or “Policy”) defines how TwinsAI uses and protects any personal information that it collects and stores.For the purpose of this Policy, “Personal Information” means information about an identifiable individual but does not include aggregated information that cannot be associated with a specific individual.For the purpose of this Agreement, “Services” refers to the Company’s website which can be viewed or accessed at www.twinsai.net (“Website”), our applications or any other services that we may supply to you which are further described in our Terms of Service.By accepting our Policy and our Terms of Service, you expressly consent to our collection, storage, processing, use and disclosure of your Personal information as described in this Policy.In case your organization acts as a data controller under ‘General Data Protection Regulation (EU) 2016/679’ of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data you will need to sign or agree to an additional Data Processing Agreement with TwinsAI in order to process data in our Services.

1.2. Revision of the Privacy Policy

TwinsAI reserves the right to revise, modify or update this Policy at any time. Your continued use of the Services after any such revisions, modifications or updates constitutes your acceptance of any such change.If we make any material changes we will notify you by posting the revised Privacy Policy on our Website or conspicuously in the Services and, if you subscribe to our Subscription Service, providing notice through the in-app Notifications.

2. Use of our services

2.1. Our customers use

You can use the Services to create communication campaigns in order to reach out to or nurture prospects with sales, marketing or customer success purposes.TwinsAI does not control the content of campaigns (text, email or other communications templates) or the types of information that our customers may choose to collect or manage using the Services.That information belongs to you and is used, disclosed and protected by them according to their privacy policies and is not subject to this Privacy Policy.TwinsAI processes our customers’ information as they direct and in accordance with our agreements with our customers, and we store it on our service providers’ servers, but we do not have control over its collection or management.Our agreements with your customers prohibit us from using that information, except as necessary to provide and improve the Services, as permitted by this Privacy Policy, and as required by law.We have no direct relationship with individuals who provide Personal Information to our customers.TwinsAI acknowledges that you have the right to access your Personal Information.You control and are responsible for correcting, deleting or updating the information they have collected from you using the Services.If requested to remove data we will respond within a reasonable timeframe.We may work with you to help them provide notice to their visitors about their data collection, processing, and usage.Our agreements with your customers prohibit usage of the Services to collect, manage, or process Sensitive Information.We are not responsible for your customers’ use of information on the Services.TwinsAI collects information under the direction of its customers and has no direct relationship with the individuals whose Personal Information it processes.If you are a customer of one of our customers and would no longer like to be contacted by one of our customers that use our Services, please contact the customer that you interact with directly or leave a request on our Trust page.We may transfer Personal Information to companies that help us provide our Services. Transfers to subsequent third parties are covered by the processing agreements with our customers.

2.2. “Sensitive Information

”This refers to credit or debit card numbers, personal financial account information, Social Security numbers, passport numbers, driver’s license numbers or similar personal identifiers, racial or ethnic origin, physical or mental health condition or information, or other employment, financial or health information.Also, sensitive information includes credentials to TwinsAI application services or email accounts (Google or other providers) that are connected to TwinsAI application.

3. Information We Collect

When you provide TwinsAI with your Personal Information you consent to our providing your information to any third parties that are necessary to offer, support and improve the Services.TwinsAI also collects Personal Information from you when you place an order including your name, physical address, email address. TwinsAI only uses this data for the purpose of fulfilling orders or communicating with you and TwinsAI’s partners regarding the Services.

3.1. When You Visit our Website

You are free to explore our Website without providing any Personal Information about yourself. TwinsAI collects your Personal Information when you register and open an account with TwinsAI to help us operate and support the Services and to contact you in connection with your use of the Services. Also, we collect navigational Information.

3.2. “Personal Information”

This refers to any information that you voluntarily submit to us and that identifies you personally, including contact information, such as your name, e-mail address, company name, address, phone number, and other information about yourself or your business.Personal Information can also include information about any transactions, both free and paid, that you enter into on the Websites, and information about you that is available on the internet, such as from Facebook, LinkedIn, Twitter and Google, or publicly available information that we acquire from service providers.

3.3. “Navigational Information

”This refers to information about your computer and your visits to and use of the Services such as your IP address, geographical location, browser type, referral source, length of visit and pages viewed.We use this information for the above purposes and to monitor and analyze use of the Services, for the Services’ technical administration, to increase our Services’ functionality and user-friendliness, to verify users have the authorization needed for the Services to process their requests, and for advertising purposes.For more details please see the “Navigation Information” section below.

3.4. Payment Information

We collect and process payment information from you when you subscribe to the Service, including credit card numbers and billing information, using third party PCI-compliant service providers. Except for this, we do not collect Sensitive Information from you.

3.5. Information About Children

The Websites and our Services are not intended for or targeted at children under 13, and we do not knowingly or intentionally collect information about children under 13. If you believe that we have collected information about a child under 13, please contact us at contact@twinsai.net, so that we may delete the information.

3.6. Information You Provide

You may also provide us with information that you post to the Services. Your questions, answers, and other contributions on the Services, and metadata about them (such as when you posted them), are publicly viewable on the Services. This information may be found by search engines and be published elsewhere on the web in accordance with our Terms of Service and this Policy.

3.7. Disclosure regarding information received from Google APIs

‍twinsai.net use and transfer to any other app of information received from Google APIs will adhere to Google API Services User Data Policy, including the Limited Use requirements.

3.8. Google User Data‍

If you choose to connect a Gmail account to TwinsAI, we will ask you to grant TwinsAI application permissions to access your Gmail account. These permissions are necessary to sustain the functionality of our Services, as intended and described in the Terms of Service. In particular, we will need to access your inbox folder to detect replies to emails that have been sent via TwinsAI.Our servers only store emails that you have sent via TwinsAI and any responses you have received to those emails so we can detect replies, classify them, and provide access to them in your TwinsAI account. All data obtained via Gmail API is available in your TwinsAI account.Also, we will store your authentication token and account email address. This data will be securely stored to be used by TwinsAI to provide you with the Services (including but not limited to logging into your account, sending emails via the TwinsAI platform, accessing emails you sent, and viewing replies you received to these emails). Under no circumstances will this data be voluntarily shared with any third parties; TwinsAI could only provide this information to legal authorities upon their lawful request. Should you choose to disconnect your Gmail account or decide to close your account, any information from Google that is stored on our servers will be removed permanently. At TwinsAI, we do not use data obtained from our customers (from their Google accounts) for advertising purposes; this includes personalized, re-targeted, and interest-based advertising.Our employees, contractors, and any human, in general, are not allowed to access your personal information, including the data obtained via Google API. We could access user data only after obtaining the user’s affirmative agreement. We may need access to the user data to resolve a support issue, provide advice on service usage or provide any other help, requested by the user. Also, we can access such information when/if necessary for a security investigation or comply with applicable laws.To obtain more information, please reach out to our Data Protection Officer (contact@twinsai.net).

3.9 Web beacons

We may also collect information using web beacons (also known as “tracking pixels”).

4. Use of Information We Collect

4.1 Navigational data, cookies and web beacons

A cookie is a string of information that a website stores on a visitor’s computer, and that the visitor’s browser provides to the website each time the visitor returns. TwinsAI uses cookies to identify and track visitors, and your website access preferences.You have the ability to accept or decline cookies. Most web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer. If you choose to decline cookies, you may not be able to fully experience the interactive features of the TwinsAI Services.Web beacons are electronic images (also called “gifs”) that may be used in the TwinsAI Services or in emails that help us to deliver cookies, count visits, understand usage and campaign effectiveness and determine whether an email has been opened and acted upon.You can decline to show gifs or pictures in your email clients to avoid being tracked by email web beacons.Also we use Navigational Information to operate and improve the Services.

4.2 Use of Personal Information

In addition to the uses identified elsewhere in this Privacy Policy, we may use your Personal Information to:(a) improve your browsing experience by personalizing and improving the Services;(b) send information to you which we think may be of interest to you by post, email, or other means;(c) send you marketing communications relating to our business or the businesses of carefully-selected third parties which we think may be of interest to you, and(d) provide other companies with aggregated and Non-Personal Information about our users — but this information will not be used to identify any individual user,We may, from time to time, contact you on behalf of external business partners about a particular offering that may be of interest to you. In those cases, we do not transfer your unique Personal Information to the third party.In addition, we may share data with trusted partners to contact you based on your request to receive such communications, help us perform statistical analysis, or provide customer support. Such third parties are prohibited from using your Personal Information except for these purposes, and they are required to maintain the confidentiality of your information. If you do not want us to share your personal information with these companies, contact us at contact@twinsai.net.We use the information collected/stored via our Services by our customers for the following purposes:(a) to provide the Services (which may include the detection, prevention, and resolution of security and technical issues);(b) to respond to customer support requests;(c) otherwise to fulfill the obligations under the TwinsAI Terms of Service.

4.3. Customer Testimonials and Comments

We post customer testimonials and comments in our Services, which may contain Personal Information. We obtain each customer’s consent via email prior to posting the customer’s name and testimonial.

4.4. Use of Credit Card Information

If you give us credit card information, we use it solely to check your financial qualifications and collect payment from you. We use a third-party service provider to manage credit card processing. This service provider is not permitted to store, retain, or use information you provide except for the sole purpose of credit card processing on our behalf.

4.5. Service Providers

We employ other companies and people to provide services to the visitors and users of the Services and we may need to share your information with them to provide information, products or services to you. Examples may include removing repetitive or invalid information from prospect lists, analyzing data, providing marketing assistance, processing credit card payments, supplementing the information you provide us in order to provide you with better service, and providing customer service. In all cases where we share your information with such third parties, we explicitly require the agent to acknowledge and adhere to our privacy and customer data handling policies.

4.6. Confidentiality and Security of personal information

We use a variety of security technologies and procedures to help protect your Personal Information from unauthorized access, use or disclosure. We secure the Personal Information you provide on computer servers in a controlled, secure environment, protected from unauthorized access, use or disclosure.All the Personal Information we have where TwinsAI acts as a processor for a customer’s data (e.g., use of the TwinsAI Services) is encrypted via database encryption. All connections to our Website or Services are protected via the use of encrypted connections, such as the Secure Socket Layer (SSL) protocol.Also we do store all email accounts or email accounts passwords we use to provide our services via your email servers encrypted.Do not forget that your account in TwinsAI service is protected by your account password and we urge you to take steps to keep your personal information safe by not disclosing your password and keep it long and complicated enough and by logging out of your account after each use.If you have any questions about the security of your Personal Information, you can contact us at dpo@TwinsAI.io.

4.7. Social Media

Our Websites include Social Media Features, such as the Facebook Like button and Widgets, such as the Share This button or interactive mini-programs that run on our sites. These features may collect your IP address, which page you are visiting on our sites, and may set a cookie to enable the feature to function properly. Social Media Features and Widgets are either hosted by a third party or hosted directly on our Websites. This Privacy Policy does not apply to these features. Your interactions with these features are governed by the privacy policy and other policies of the companies providing them.

4.8. External Websites

Our Websites provide links to other websites. We do not control and are not responsible for the content or practices of these other websites. Our provision of such links does not constitute our endorsement of these other websites, their content, their owners, or their practices. This Privacy Policy does not apply to these other websites, which are subject to any privacy and other policies they may have.

4.9. Retention of Personal Information

We retain Personal Information that you provide us as long as we consider it potentially useful in contacting you about the Service or our other services, or as needed to comply with our legal obligations, resolve disputes and enforce our agreements, and then we securely delete the information.If you provide information to our customers as part of their use of the TwinsAI Service, our customers decide how long to retain the personal information they collect from you. If a customer terminates its use of the Service, then we will provide a customer with access to all information stored for the customer by the Service, including any Personal Information provided by you, for export by the customer according to our agreement with our customer. After termination, we may, unless legally prohibited, delete all customer information, including your Personal Information, from the TwinsAI Service.

4.10. International Transfer of Information

If you are located outside the United States, the information that we collect from you may be transferred to and stored and processed at a destination in the United States. By submitting information, you agree to this transfer, storing or processing. We will take all steps necessary to ensure that your information is treated securely and in accordance with this Privacy Policy.All our employees and contractors related to working with personal data as part of their duties are signed agreements that cover TwinsAI and their responsibility regarding the transfer of data to remote working locations other than the United States.This Privacy Policy shall apply even if we transfer Personal Information to other countries.

4.11. Sharing with Third-party applications

Certain aspects of the TwinsAI Service allow or require you to connect with third-party applications or services. In connection with your use of any such third-party applications or services, such third parties may receive information about you including your username and any Content you choose to use in connection with those applications and services, and such third parties may contact you directly as necessary.The TwinsAI Service may automatically collect and upload certain data from such applications via direct integrations or proxy services.This Privacy Policy does not apply to your use of such third party applications and services, and we are not responsible for how those third parties collect, use and disclose your information and Content. We encourage you to review the privacy policies of those third parties before connecting to or using their applications or services to learn more about their information and privacy practices.

4.12. Compelled Disclosure

TwinsAI reserve the right to use or disclose your Personal Information if required by law or if we reasonably believe that use or disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud and security breaches, or comply with a law, court order, or legal process.

4.13. Data retention

After TwinsAI account cancellation all the data within this account are due to be deleted after a 60 days period time has elapsed. At the same time, personal data of customers could be retained longer as it needed for providing a legal and financial trace of past operations up to the time required by US law.

4.14. TwinsAI Database

TwinsAI gathers current and historic business contact data. The data collected about individuals on the TwinsAI Database comprises: Name; Employer Company & Company Details; Office Location (Country & City); Business Telephone Number; Business Email Address; Job Title. We also hold data in respect of your employer company such as its name, size, industry, website and industry. In order to provide certain aspects of its services, TwinsAI requires a business email address to be recorded against profiles in its database. Where TwinsAI does not have the business email address of a profile, it may generate a business email address based on the email address structure understood to be implemented by the employer company. The majority of the personal data we collect about you comes from publicly available sources such as from business and employment-oriented social networks, recruitment websites and company websites. Information is also gathered from correspondence with you (by email or phone), from our clients, recruiters and other premium data providers. TwinsAI does not seek to collect any non-business-related data such as date of birth or home address and TwinsAI does not collect sensitive personal data. TwinsAI obtains the data for its Business Profiles in several ways, including: Our search technology scans the web and gathers publicly-available information. We license information from other companies. Our users and customers contribute information about themselves or other people and companies. Through market research surveys, phone interviews, and other research conducted by our in-house research team.

4.15. Anti-Spam Policy

We at TwinsAI committed to providing customers with tools and expertise to curate highly targeted and relevant communications via our platform. We monitor and prohibits the use of the TwinsAI Service to send unsolicited commercial email in violation of applicable laws as stated in our Terms of service, and requires the inclusion in every email sent using the Service of an “opt-out” mechanism and other required information. We require all of our customers to agree to adhere to the Terms of Service Policy at all times, and any violations of the Terms of Service Policy by a customer can result in suspension or termination of the TwinsAI Service. We also provide customers with the tools to manage their sending reputation and customer success team work closely to monitor all customer metrics and best-practices to ensure high quality and targeted campaigns.

4.16. To Unsubscribe From Our Communications

You may unsubscribe from our marketing communications by clicking on the “unsubscribe” link located on the bottom of our e-mails, or by sending us an email at contact@twinsai.net. Customers cannot opt-out of receiving transactional emails or notifications related to their account with us or the TwinsAI Service.

4.17. To Unsubscribe from Our Customers’ Communications

Our customers are solely responsible for their own sales or marketing emails and other communications;We make sure that all emails sent using TwinsAI service have proper unsubscribe mechanics (links or text + AI sorting + Auto opt-out).You can unsubscribe from our customers’ communications by clicking on the “unsubscribe” link located on the bottom of their emails, responding to unsubscribe via email or by contacting them directly.Any questions about this Privacy Policy should be addressed to contact@twinsai.net

5. How We Transfer Personal Data Internationally

5.1 International Transfers within the TwinsAI Group

To facilitate our global operations, we may transfer information that may include Personal Data to other TwinsAI Affiliates who act as subprocessors, where we have operations for the purposes described in this policy. Please see Annex 3 of our Customer Data Processing Agreement for a list of impacted TwinsAI Affiliates and their locations.

This Privacy Policy will apply even if we transfer Personal Data to other countries. We have taken appropriate safeguards to require that your Personal Data will remain protected wherever it is transferred. When we share Personal Data of individuals in the European Economic Area ("EEA"), Switzerland or the United Kingdom ("UK") within and among TwinsAI’s Affiliates, we rely upon the the Standard Contractual Clauses (approved by the European Commission and Swiss authorities) and UK Addendum to the Standard Contractual Clauses (approved by the UK authorities) where required.  We also have additional safeguards where appropriate (such as commercial industry standard secure encryption methods to protect customer data at rest and in transit, TLS for TwinsAI hosted sites, web application firewall protection, and other appropriate contractual and organizational measures), as described more in detail in the TwinsAI Trust Center.

5.2 International Transfers to Third Parties

Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may not have equivalent privacy and data protection laws to the country in which you reside. When we share Personal Data of individuals in the EEA, Switzerland or UK with third parties, we use a variety of legal mechanisms to safeguard the transfer including the European Commission-approved Data Privacy Framework Standard Contractual Clauses, as well as additional safeguards where appropriate. For transfers to or from the United Kingdom, we make use of the UK Addendum. For transfers to or from Canada, we make use of the standard contractual clauses. With respect to personal data received from or transferred to Canada, TwinsAI is subject to the regulatory enforcement powers of the Office of the Privacy Commissioner of Canada. Please contact us if you need more information about the legal mechanisms we rely on to transfer personal data outside the EEA, Switzerland, Canada, and UK.

5.3 Data Privacy Framework Notice

TwinsAI complies with the EU-U.S. Data Privacy Framework (“EU-U.S. DPF”), the UK Extension to the EU-U.S. DPF, and the Swiss-U.S. Data Privacy Framework (“Swiss-U.S. DPF”) as set forth by the U.S. Department of Commerce (collectively “the Data Privacy Framework”).

TwinsAI has certified to the U.S. Department of Commerce that it adheres to the EU-US DPF Principles with regard to the processing of Personal Data received from the European Union, and the United Kingdom (and Gibraltar) and to the Swiss-US DPF Principles with regard to the processing of Personal Data received from Switzerland. If there is any conflict between this Privacy Policy and the DPF Principles, the DPF Principles will govern. To learn more about the Data Privacy Framework, and to view our certification, please visit https://www.dataprivacyframework.gov/.

If you are located in the EU, UK or Switzerland, you have the right to request access to the Personal Data that we hold about you and request that we correct, amend or delete your Personal Data if it is inaccurate or processed in violation of the DPF Principles. We will give you an opportunity to opt out where Personal Data we control about you is to be disclosed to an independent third party or used for a purpose that is materially different from those set out in this Privacy Policy. If you would like to exercise any of your rights, please contact us via the details provided below.

In compliance with the DPF Principles, TwinsAI commits to resolve DPF Principles-related complaints about our collection and use of your Personal Data. We will investigate and attempt to resolve any DPF Principles-related complaints within sixty (60) days. EU, UK and Swiss individuals with inquiries or complaints regarding our handling of Personal Data received in reliance on the DPF Principles should first contact TwinsAI here.  

In compliance with the Data Privacy Framework, TwinsAI commits to refer unresolved complaints concerning our handling of personal data received in reliance on the Data Privacy Framework to an alternative dispute resolution provider based in the United States. If you do not receive timely acknowledgment of your DPF Principles-related complaint from us, or if we have not addressed your DPF Principles-related complaint to your satisfaction, please visit https://feedback-form.truste.com/watchdog/request for more information or to file a complaint. The services of TRUSTe Dispute Resolution, are provided at no cost to you.

Under certain conditions, more fully described on the DPF website, you may be entitled to invoke binding arbitration when other dispute resolution procedures have been exhausted. The Federal Trade Commission has jurisdiction over TwinsAI’s compliance with the DPF Principles.

In the context of an onward transfer, TwinsAI is responsible for the processing of Personal Data it receives under the DPF Principles and subsequently transfers to a third party acting as an agent on our behalf. TwinsAI will remain liable under the DPF Principles if our agent processes your Personal Data in a manner inconsistent with the DPF Principles, unless TwinsAI is not responsible for the event giving rise to the damage.

Please note that under certain circumstances, we may be required to disclose your Personal Data in response to lawful requests by public authorities, including to meet national security or law enforcement requirements.

6. California Privacy Rights

6.1 Applicability

This section applies only to California consumers. For purposes of this section "Personal Information" has the meaning given in the California Consumer Privacy Act (“CCPA”). It describes how we collect, use, and share California consumers' Personal Information in our role as a business, and the rights applicable to such residents.

If you are unable to access this Privacy Policy due to a disability or any physical or mental impairment, please contact us and we will arrange to supply you with the information you need in an alternative format that you can access.

6.2 How We Collect, Use, and Disclose your Personal Information

We have collected the following statutory categories of Personal Information in the past twelve (12) months:

• Identifiers, such as name, e-mail address, mailing address, and phone number. We collect this information directly from you or from third party sources.
• Commercial information, such as subscription records. We collect this information directly from you.
• Internet or network information, such as browsing and search history. We collect this information directly from your device.
• Geolocation data, such as IP address. We collect this information from your device.
• Financial information, such as Payment Information or financial account numbers in the process of providing you with a subscription. We collect this information from you.
• Professional data, such as your job title and company.
• Other Personal Data, in instances when you interact with us online, by phone or mail in the context of receiving help through our help desks or other support channels; participation in customer surveys or contests; or in providing the Subscription Service.
• Inferences drawn from any of the above categories, alone or in combination.

The business and commercial purposes for which we collect this information are described in this Privacy Policy. The categories of third parties to whom we "disclose" this information for a business purpose are described in the “How We Share Personal Data” section of this Privacy Policy. The period of time for which we retain this information is described in the “How We Store and Secure Personal Data” section of this Privacy Policy.

In the preceding 12 months, we have “sold” or “shared” (as defined under the CCPA) certain information, including identifiers, to our advertising partners. We have also “sold” or “shared” certain information, including identifiers, approximate location data, and professional data to our customers.

6.3 Your California Rights

You have certain rights regarding the Personal Information we collect or maintain about you. Please note these rights are not absolute, and there may be cases when we decline your request as permitted by law. These rights include:

• The right of access means that you have the right to request that we disclose what Personal Data we have collected and maintained about you in the past 12 months.
• The right of deletion means that you have the right to request that we delete Personal Data collected or maintained by us, subject to certain exceptions.
• The right of correction means that you have the right to request that we correct any inaccurate Personal Data that we maintain about you.
• The right to request information concerning the categories of Personal Data (if any) that we disclose to third parties or affiliates for their direct marketing purposes.
• The right to limit the use of sensitive personal information means that you have the right to direct businesses to only use your sensitive personal information for limited purposes. We only collect sensitive personal information (such as your payment information), as defined by applicable laws for the purposes allowed by law or with your consent. We do not collect or process sensitive personal information for the purpose of inferring characteristics about you.
• The right to appeal means that you can appeal any decision by us to deny your privacy rights under applicable laws.
• The right to non-discrimination means that you will not receive any discriminatory treatment when you exercise one of your privacy rights.

We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

6.4 How to Exercise your California Rights

You can exercise your rights yourself or you can alternatively designate an authorized agent to exercise these rights on your behalf. Please note that to protect your Personal Data, we will verify your identity by a method appropriate to the type of request you are making. Depending on your request, we will ask for information such as your name and your email address. We may also request that your authorized agent have written permission from you to make requests on your behalf, and we may also need to verify your authorized agent's identity to protect your Personal Data. We may deny a request from an agent that does not submit proof that they have been authorized to act on your behalf.

We will respond within the time frame permitted by applicable law. Please note that we may charge a reasonable fee for multiple requests in the same 12-month period, as permitted by law.

Please use the contact details below, or see the  "Your Privacy Rights and Choices" section above, if you would like to:

• Access this policy in an alternative format;
• Exercise any of your rights described above;
• Learn more about your rights or our privacy practices; or
• Designate an authorized agent to make a request on your behalf.

6.5 Right to Opt Out of "Sale" or "Sharing"

TwinsAI collects data from publicly available sources or other third-party sources and discloses that information to our customers who purchase our enrichment products. This may be considered a “sale” or “sharing” under certain state privacy laws, such as the CCPA. Please see the "Information We Collect and Process in connection with our enrichment products” section for more information.

We may also "share" your Personal Data, as defined under the CCPA , with third party advertising partners to deliver personalized ads on TwinsAI's behalf on other companies' sites or mobile apps. Please see the  "Advertising Partners" section for more information.

If you’d like your information to be removed from our commercial dataset, or would like to opt out from the "sharing" of your Personal Data for our advertising and marketing activities, please fill out this form.

You can also control the personalized advertising you see by using these services: https://optout.networkadvertising.org/ or https://optout.aboutads.info/ (or if located in the European Union, by clicking here: http://www.youronlinechoices.eu/). Please note this does not opt you out of being served advertising and you will continue to receive generic ads.

We do not knowingly “sell” or “share” Personal Data of children under 16 years of age.

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