1. Data controller
In accordance with the provisions of Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD), we inform you that the controller of your data is:
- Wason Digital, S.L.
- Tax ID (CIF): B67770859
- Registered office: Parque Tecnológico, Av. Gregorio Peces Barba, 1, 28919 Leganés, Madrid (Spain)
- Contact email: clientes@twinny.es
2. Purpose of the processing
We process your personal data for the following purposes:
- To correctly provide and manage the services contracted through the Twinny platform.
- To send commercial communications related to our products and services.
- To comply with the applicable legal and tax obligations. The personal data provided will be kept for as long as a contractual relationship exists and, thereafter, for the periods required by law.
3. Legal basis
The legal basis for processing your data is:
- The performance of a contract to which you are a party.
- Your explicit consent for sending commercial communications (where it has been given).
- Compliance with legal obligations.
4. Recipients
Data will not be disclosed to third parties, except where required by law or where you consent to it, as explained in section 11. Under no circumstances do we sell or rent your data. Data may be processed by providers that deliver services under contract with Wason Digital, S.L., and that guarantee compliance with the GDPR and the maintenance of the confidentiality and security of the information.
5. International transfers
As a general rule, we do not carry out international data transfers. The only exception is the advertising campaign measurement described in section 11: OpenAI may process that data outside the European Economic Area, in particular in the United States, with the appropriate safeguards provided for in the GDPR, such as the standard contractual clauses approved by the European Commission.
6. Users' rights
You may exercise your rights of access, rectification, erasure, objection, restriction of processing and portability by means of a written request addressed to the email address clientes@twinny.es, duly proving your identity. You also have the right to lodge a complaint with the Spanish Data Protection Agency (www.aepd.es) if you believe your rights have been infringed.
7. Data security
At Wason Digital, S.L. we apply the appropriate technical and organisational measures to guarantee an adequate level of security and to prevent the loss, misuse, alteration, unauthorised access or theft of the personal data provided.
8. Confidentiality
Data will be processed with absolute confidentiality, and we undertake to maintain professional secrecy in respect of it and to guarantee the duty of safekeeping, even after the contractual relationship has ended.
9. Use of the Platform
By using the Twinny platform, the user acknowledges having read and accepted this Privacy Policy and authorises the processing of their personal data under the terms set out herein.
10. Google User Data
If the user connects their Google account with the Twinny Platform, we may access only the data they expressly authorise, for the sole purpose of providing the contracted services. This data may include:
- Basic profile information (name and email address).
- Gmail: email metadata and/or content (only if the user authorises it) for managing interactions with contacts or customers.
- Google Calendar: events and calendar data for synchronising meetings, reminders or automated actions.
- Google Ads: campaign, audience and budget information for managing agents, conversational advertising and report generation.
- Google Drive/Docs: files or documents expressly selected by the user to configure or train agents.
Retention and Deletion
Google user data will be kept only while the user's Twinny account remains active.
- If the account is closed or the service ends, that data will be irreversibly deleted within a maximum of 30 days, unless there is a legal obligation to retain it for longer.
- The user may request the immediate deletion of their data by writing to clientes@twinny.es.
Revoking Access
The user may revoke the permissions granted to Twinny at any time from the security settings of their Google account, available at: Google Security Settings.
11. Advertising campaign measurement
We advertise Twinny on ChatGPT, OpenAI's service. To know which visits and meeting requests come from those ads we use OpenAI's measurement pixel, only if you accept advertising cookies in our cookie notice.
With your consent, the pixel records the pages you visit on our website and whether you request a meeting, and sets the cookies described in our cookie policy. In addition, when you request a meeting, we share with OpenAI an encrypted identifier of your email address: an irreversible code (SHA-256 hash) generated in your browser. We never send your email address in plain text, nor your name, company or the content of your request.
- Purpose: to measure the effectiveness of our advertising campaigns on ChatGPT and attribute conversions to them.
- Legal basis: your consent (Art. 6(1)(a) GDPR and Art. 22.2 of the Spanish LSSI).
- Recipient: OpenAI, as the provider of the advertising platform.
- Retention: as indicated for each cookie in the cookie policy; OpenAI retains measurement data under its own advertiser terms.
- How to withdraw it: at any time, from the Cookie preferences link at the bottom of every page. When you withdraw it we stop sending data and the measurement cookies are deleted. Withdrawal does not affect the lawfulness of prior processing.
If you do not accept advertising cookies, you can browse and request a meeting as normal: we do not share any data with OpenAI.