Legal

Privacy Policy

Last revised July 2026

This privacy notice has two parts: Website and Twinsity Platform.

Website Privacy Policy

1. An overview of data protection 

GENERAL INFORMATION 

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you visit this website. The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy. 

DATA RECORDING ON THIS WEBSITE 

HOW DO WE RECORD YOUR DATA? 

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter into our contact form. 

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access this website. 

WHAT ARE THE PURPOSES WE USE YOUR DATA FOR? 

A portion of the information is generated to guarantee the error free provision of the website. Other data may be used to analyze your user patterns. 

WHAT RIGHTS DO YOU HAVE AS FAR AS YOUR INFORMATION IS CONCERNED? 

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency. 

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues. 

2. Hosting 

EXTERNAL HOSTING 

This website is hosted by an external service provider (host). Personal data collected on this website are stored on the servers of the host. These may include, but are not limited to, IP addresses, contact requests, metadata and communications, contract information, contact information, names, web page access, and other data generated through a web site. 

The host is used for the purpose of fulfilling the contract with our potential and existing customers (Art. 6 para. 1 lit. b GDPR) and in the interest of secure, fast, and efficient provision of our online services by a professional provider (Art. 6 para. 1 lit. f GDPR). 

Our host will only process your data to the extent necessary to fulfil its performance obligations and to follow our instructions with respect to such data. 

We are using the following host: 

1&1 IONOS SE, Elgendorfer Str. 57, 56410 Montabaur 

In order to guarantee processing in compliance with data protection regulations, we have concluded an order processing contract with our host. 

3. General information and mandatory information 

DATA PROTECTION 

The operators of this website and its pages take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. 

Whenever you use this website, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. 

We herewith advise you that the transmission of data via the Internet (i.e., through email communications) may be prone to security gaps. It is not possible to completely protect data against third-party access. 

INFORMATION ABOUT THE RESPONSIBLE PARTY (REFERRED TO AS THE “CONTROLLER” IN THE GDPR) 

The data processing controller on this website is: 

Twinsity Technologies GmbH 
An der Tränke 4
34479 Breuna
Germany 
Email: info@twinsity.com 

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, email addresses, etc.). 

GENERAL INFORMATION ON THE LEGAL BASIS FOR THE DATA PROCESSING ON THIS WEBSITE 

If you have consented to data processing, we process your personal data on the basis of Art. 6(1)(a) GDPR or Art. 9 (2)(a) GDPR, if special categories of data are processed according to Art. 9 (1) GDPR. In the case of explicit consent to the transfer of personal data to third countries, the data processing is also based on Art. 49 (1)(a) GDPR. If you have consented to the storage of cookies or to the access to information in your end device (e.g., via device fingerprinting), the data processing is additionally based on § 25 (1) TDDDG. The consent can be revoked at any time. If your data is required for the fulfillment of a contract or for the implementation of pre-contractual measures, we process your data on the basis of Art. 6(1)(b) GDPR. Furthermore, if your data is required for the fulfillment of a legal obligation, we process it on the basis of Art. 6(1)(c) GDPR. Furthermore, the data processing may be carried out on the basis of our legitimate interest according to Art. 6(1)(f) GDPR. Information on the relevant legal basis in each individual case is provided in the following paragraphs of this privacy policy. 

STORAGE DURATION 

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply. 

INFORMATION ON DATA TRANSFER TO THE USA 

Our website uses, in particular, tools from companies based in the USA. When these tools are active, your personal information may be transferred to the US servers of these companies. We must point out that the USA is not a safe third country within the meaning of EU data protection law. US companies are required to release personal data to security authorities without you as the data subject being able to take legal action against this. The possibility cannot therefore be excluded that US authorities (e.g. secret services) may process, evaluate, and permanently store your data on US servers for monitoring purposes. We have no influence over these processing activities. 

REVOCATION OF YOUR CONSENT TO THE PROCESSING OF DATA 

A wide range of data processing transactions are possible only subject to your express consent. You can also revoke at any time any consent you have already given us. This shall be without prejudice to the lawfulness of any data collection that occurred prior to your revocation. 

RIGHT TO OBJECT TO THE COLLECTION OF DATA IN SPECIAL CASES; RIGHT TO OBJECT TO DIRECT ADVERTISING (ART. 21 GDPR) 

In the event that data are processed on the basis of Art. 6 Sect. 1 lit. E or F GDPR, you have the right to at any time object to the processing of your personal data based on grounds arising from your unique situation. This also applies to any profiling based on these provisions. To determine the legal basis, on which any processing of data is based, please consult this data protection declaration. If you log an objection, we will no longer process your affected personal data, unless we are in a position to present compelling protection worthy grounds for the processing of your data, that outweigh your interests, rights and freedoms or if the purpose of the processing is the claiming, exercising or defence of legal entitlements (objection pursuant to Art. 21 Sect. 1 GDPR). 

If your personal data is being processed in order to engage in direct advertising, you have the right to at any time object to the processing of your affected personal data for the purposes of such advertising. This also applies to profiling to the extent that it is affiliated with such direct advertising. If you object, your personal data will subsequently no longer be used for direct advertising purposes (objection pursuant to Art. 21 Sect. 2 GDPR). 

RIGHT TO LOG A COMPLAINT WITH THE COMPETENT SUPERVISORY AGENCY 

In the event of violations of the GDPR, data subjects are entitled to log a complaint with a supervisory agency, in particular in the member state where they usually maintain their domicile, place of work or at the place where the alleged violation occurred. The right to log a complaint is in effect regardless of any other administrative or court proceedings available as legal recourses. 

RIGHT TO DATA PORTABILITY 

You have the right to demand that we hand over any data we automatically process on the basis of your consent or in order to fulfil a contract be handed over to you or a third party in a commonly used, machine readable format. If you should demand the direct transfer of the data to another controller, this will be done only if it is technically feasible. 

SSL AND/OR TLS ENCRYPTION 

For security reasons and to protect the transmission of confidential content, such as purchase orders or inquiries you submit to us as the website operator, this website uses either an SSL or a TLS encryption program. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. 

If the SSL or TLS encryption is activated, data you transmit to us cannot be read by third parties. 

ENCRYPTED PAYMENT TRANSACTIONS ON THIS WEBSITE 

If you are under an obligation to share your payment information (e.g. account number if you give us the authority to debit your bank account) with us after you have entered into a fee-based contract with us, this information is required to process payments. 

Payment transactions using common modes of paying (Visa/MasterCard, debit to your bank account) are processed exclusively via encrypted SSL or TLS connections. You can recognize an encrypted connection by checking whether the address line of the browser switches from “http://” to “https://” and also by the appearance of the lock icon in the browser line. 

If the communication with us is encrypted, third parties will not be able to read the payment information you share with us. 

INFORMATION ABOUT, RECTIFICATION AND ERADICATION OF DATA 

Within the scope of the applicable statutory provisions, you have the right to at any time demand information about your archived personal data, their source and recipients as well as the purpose of the processing of your data. You may also have a right to have your data rectified or eradicated. If you have questions about this subject matter or any other questions about personal data, please do not hesitate to contact us at any time. 

RIGHT TO DEMAND PROCESSING RESTRICTIONS 

You have the right to demand the imposition of restrictions as far as the processing of your personal data is concerned. To do so, you may contact us at any time. The right to demand restriction of processing applies in the following cases: 

In the event that you should dispute the correctness of your data archived by us, we will usually need some time to verify this claim. During the time that this investigation is ongoing, you have the right to demand that we restrict the processing of your personal data. If the processing of your personal data was/is conducted in an unlawful manner, you have the option to demand the restriction of the processing of your data in lieu of demanding the eradication of this data. 
If we do not need your personal data any longer and you need it to exercise, defend or claim legal entitlements, you have the right to demand the restriction of the processing of your personal data instead of its eradication. 
If you have raised an objection pursuant to Art. 21 Sect. 1 GDPR, your rights and our rights will have to be weighed against each other. As long as it has not been determined whose interests prevail, you have the right to demand a restriction of the processing of your personal data. 

If you have restricted the processing of your personal data, these data – with the exception of their archiving – may be processed only subject to your consent or to claim, exercise or defend legal entitlements or to protect the rights of other natural persons or legal entities or for important public interest reasons cited by the European Union or a member state of the EU. 

REJECTION OF UNSOLICITED EMAILS 

We herewith object to the use of contact information published in conjunction with the mandatory information to be provided in our Site Notice to send us promotional and information material that we have not expressly requested. The operators of this website and its pages reserve the express right to take legal action in the event of the unsolicited sending of promotional information, for instance via SPAM messages. 

4. Recording of data on this website 

COOKIES 

Our websites and pages use what the industry refers to as “cookies.” Cookies are small data packages that do not cause any damage to your device. They are either stored temporarily for the duration of a session (session cookies) or they are permanently archived on your device (permanent cookies). Session cookies are automatically deleted once you terminate your visit. Permanent cookies remain archived on your device until you actively delete them, or they are automatically eradicated by your web browser. 

Cookies can be issued by us (first-party cookies) or by third-party companies (so-called third-party cookies). Third-party cookies enable the integration of certain services of third-party companies into websites (e.g., cookies for handling payment services). 

Cookies have a variety of functions. Many cookies are technically essential since certain website functions would not work in the absence of these cookies (e.g., the shopping cart function or the display of videos). Other cookies may be used to analyze user behavior or for promotional purposes. 

Cookies, which are required for the performance of electronic communication transactions, for the provision of certain functions you want to use (e.g., for the shopping cart function) or those that are necessary for the optimization (required cookies) of the website (e.g., cookies that provide measurable insights into the web audience), shall be stored on the basis of Art. 6(1)(f) GDPR, unless a different legal basis is cited. The operator of the website has a legitimate interest in the storage of required cookies to ensure the technically error-free and optimized provision of the operator’s services. If your consent to the storage of the cookies and similar recognition technologies has been requested, the processing occurs exclusively on the basis of the consent obtained (Art. 6(1)(a) GDPR and § 25 (1) TDDDG); this consent may be revoked at any time. 

You have the option to set up your browser in such a manner that you will be notified any time cookies are placed and to permit the acceptance of cookies only in specific cases. You may also exclude the acceptance of cookies in certain cases or in general or activate the delete-function for the automatic eradication of cookies when the browser closes. If cookies are deactivated, the functions of this website may be limited. 

You can see which cookies are used on this website, and change your choice at any time, through the cookie settings on this website. 

CONSENT MANAGEMENT WITH COOKIEYES

We use CookieYes to ask for and record your choices about cookies. When you first visit our website, CookieYes displays a banner that lets you accept or reject categories of cookies. Cookies that are not strictly necessary are only set once you have given your consent. Your choice is stored in a cookie on your device so that it can be respected on later visits, and a record of your consent is kept by CookieYes. You can change or withdraw your choice at any time through the cookie settings on this website. The legal basis for this processing is our legal obligation to obtain and document consent pursuant to Art. 6(1)(c) GDPR.

COOKIES USED ON THIS WEBSITE 

The cookies and similar browser storage used on this website are listed below by category, with how long each one lasts and what it is used for. This list was last reviewed on 11 August 2026. The current list is always available, and your choice can be changed at any time, through the cookie settings on this website.

NECESSARY 

cookieyes-* · 1 year · CookieYes sets this cookie for consent solution management.

FUNCTIONAL 

portal7691-_zldp · 1 year 1 month 4 days · Zoho SalesIQ sets this cookie for the visitor live chat, to recognise a returning visitor across sessions.

portal7691-_zldt · 1 day · Zoho SalesIQ sets this cookie for the visitor live chat, to identify the current chat session.

uesign · 1 month · Zoho sets this cookie for the visitor live chat.

ANALYTICS 

LS_CSRF_TOKEN · session · Zoho SalesIQ sets this cookie as a security token to prevent cross site request forgery.

zalb_* · session · Zoho SalesIQ sets this cookie for load balancing, so that requests during a session reach the same server.

_ga · 1 year 1 month 4 days · Google Analytics sets this cookie to calculate visitor, session and campaign data and to track site usage for the analytics report. It stores information anonymously and assigns a randomly generated number to recognise unique visitors.

_ga_* · 1 year 1 month 4 days · Google Analytics sets this cookie to store and count page views.

utsdb · local storage, does not expire · Zoho SalesIQ uses this browser storage entry to record data on visitor behaviour on the website.

siqlsdb · local storage, does not expire · Zoho uses this browser storage entry to generate a unique session identifier, which allows data on visitor behaviour to be obtained for statistical purposes.

PERFORMANCE 

No cookies are used in this category.

ADVERTISEMENT 

_gcl_au · 3 months · Google Tag Manager sets this cookie to measure the effectiveness of advertising on websites that use its services.

test_cookie · 15 minutes · doubleclick.net sets this cookie to determine whether your browser supports cookies.

SERVER LOG FILES 

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises: 

  • The type and version of browser used 
  • The used operating system 
  • Referrer URL 
  • The hostname of the accessing computer The time of the server inquiry 
  • The IP address 

This data is not merged with other data sources. 

This data is recorded on the basis of Art. 6 Sect. 1 lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded. 

REQUEST BY EMAIL, TELEPHONE, FAX OR VIA OUR CONTACT FORM 

If you contact us by email, telephone, fax or via our contact form your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent. 

These data are processed on the basis of Art. 6 Sect. 1 lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 Sect. 1 lit. f GDPR) or on the basis of your consent (Art. 6 Sect. 1 lit. a GDPR) if it has been obtained. 

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected. 

REGISTRATION ON THIS WEBSITE 

You have the option to register on this website to be able to use additional website functions. We shall use the data you enter only for the purpose of using the respective offer or service you have registered for. The required information we request at the time of registration must be entered in full. Otherwise, we shall reject the registration. 

To notify you of any important changes to the scope of our portfolio or in the event of technical modifications, we shall use the email address provided during the registration process. 

We shall process the data entered during the registration process on the basis of your consent (Art. 6(1)(a) GDPR). 

The data recorded during the registration process shall be stored by us as long as you are registered on this website. Subsequently, such data shall be deleted. This shall be without prejudice to mandatory statutory retention obligations. 

5. Analysis tools and advertising 

Google Analytics 

This website uses functions of the web analysis service Google Analytics. The provider of this service is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. 

Google Analytics enables the website operator to analyze the behavior patterns of website visitors. To that end, the website operator receives a variety of user data, such as pages accessed, time spent on the page, the utilized operating system and the user’s origin. This data is assigned to the respective end device of the user. An assignment to a user-ID does not take place. 

Furthermore, Google Analytics allows us to record your mouse and scroll movements and clicks, among other things. Google Analytics uses various modeling approaches to augment the collected data sets and uses machine learning technologies in data analysis. 

Google Analytics uses technologies that make the recognition of the user for the purpose of analyzing the user behavior patterns (e.g., cookies or device fingerprinting). The website use information recorded by Google is, as a rule transferred to a Google server in the United States, where it is stored. 

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time. 

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://privacy.google.com/businesses/controllerterms/mccs/ 

Google Ads 

The website operator uses Google Ads. Google Ads is an online promotional program of Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. 

Google Ads enables us to display ads in the Google search engine or on third-party websites, if the user enters certain search terms into Google (keyword targeting). It is also possible to place targeted ads based on the user data Google has in its possession (e.g., location data and interests; target group targeting). As the website operator, we can analyze these data quantitatively, for instance by analyzing which search terms resulted in the display of our ads and how many ads led to respective clicks. 

The use of these services occurs on the basis of your consent pursuant to Art. 6(1)(a) GDPR and § 25(1) TDDDG. You may revoke your consent at any time. 

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://policies.google.com/privacy/frameworks and https://privacy.google.com/businesses/controllerterms/mccs/ 

Google Fonts

This website uses fonts provided by Google to display text consistently across browsers. When you open one of our pages, your browser loads the fonts it needs directly from Google’s servers, which means your IP address is transmitted to Google. We have no influence over this transfer. The provider is Google Ireland Limited (“Google”), Gordon House, Barrow Street, Dublin 4, Ireland. The use of these fonts is based on our legitimate interest in a consistent presentation of our website pursuant to Art. 6(1)(f) GDPR. Further information is available in Google’s privacy policy.

6. Newsletter 

NEWSLETTER DATA 

If you would like to subscribe to the newsletter offered on this website, we will need from you an email address as well as information that allow us to verify that you are the owner of the email address provided and consent to the receipt of the newsletter. For the handling of the newsletter, we use Zoho Campaigns, as described in section 7 below. 

7. Zoho

We use Zoho One, the business software suite provided by Zoho, across our website and our business operations. The following Zoho services process personal data in connection with this website: Zoho Forms for our contact form, distributor enquiry form, newsletter signup and free trial registration; Zoho Bookings for scheduling demonstrations; Zoho CRM to manage enquiries and customer relationships; Zoho Campaigns to send our newsletter; Zoho Billing and Zoho Books to issue and account for invoices; Zoho Contracts and Zoho Sign to prepare and sign agreements; and Zoho Desk to handle customer support requests.

The forms on this website (contact, distributor enquiry, newsletter signup and free trial) and the demo booking tool are provided by Zoho. When you submit a form or book a demo, the details you enter, such as your name, email address, company and message, are processed by Zoho and stored in our Zoho CRM so we can respond and manage the enquiry. These Zoho forms run on Zoho’s European infrastructure (zohopublic.eu), operated by Zoho Corporation B.V., Beneluxlaan 4B, 3527 HT Utrecht, Netherlands. The legal basis is Art. 6 Sect. 1 lit. b GDPR for enquiries and pre-contract steps, and Art. 6 Sect. 1 lit. a GDPR (consent) for the newsletter. We keep the data for as long as needed for the purpose, or until you ask us to delete it or withdraw consent. For more information, see Zoho’s privacy policy.

ZOHO SALESIQ

We also use Zoho SalesIQ to analyse how visitors use our website. SalesIQ stores information on your device and records your visit. This happens only where you have given consent, and you can withdraw that consent at any time through the cookie settings on this website.

8. eCommerce and payment service providers 

PROCESSING OF DATA (CUSTOMER AND CONTRACT DATA) 

We collect, process, and use personal data only to the extent necessary for the establishment, content organization or change of the legal relationship (data inventory). These actions are taken on the basis of Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or pre-contractual actions. We collect, process and use personal data concerning the use of this website (usage data) only to the extent that this is necessary to make it possible for users to utilize the services and to bill for them. 

The collected customer data shall be eradicated upon completion of the order or the termination of the business relationship. This shall be without prejudice to any statutory retention mandates. 

DATA TRANSFER UPON CLOSING OF CONTRACTS FOR SERVICES AND DIGITAL CONTENT 

We share personal data with third parties only if this is necessary in conjunction with the handling of the contract; for instance, with the financial institution tasked with the processing of payments. 

Any further transfer of data shall not occur or shall only occur if you have expressly consented to the transfer. Any sharing of your data with third parties in the absence of your express consent, for instance for advertising purposes, shall not occur. 

The basis for the processing of data is Art. 6 Sect. 1 lit. b GDPR, which permits the processing of data for the fulfilment of a contract or for pre-contractual actions. 

PAYMENT SERVICES 

We do not take payments on this website. Invoices are issued separately and can be settled by bank transfer or through a payment link. Where you use a payment link, your payment data (for example name, payment amount and bank or card details) is processed by the payment service provider named below for the purpose of processing that payment. For these transactions, the respective contractual and data protection provisions of the respective providers apply. The use of the payment service providers is based on Art. 6(1)(b) GDPR (contract processing) and in the interest of a smooth, convenient, and secure payment transaction (Art. 6(1)(f) GDPR). Insofar as your consent is requested for certain actions, Art. 6(1)(a) GDPR is the legal basis for data processing; consent may be revoked at any time for the future. 

We use the following payment services / payment service providers within the scope of this website: 

STRIPE

We use Stripe to collect payment when you settle an invoice through a payment link we send you. Payments are not taken on this website itself. When you pay an invoice, your payment details are processed by Stripe Payments Europe, Limited, an Irish company. The legal basis is Art. 6 Sect. 1 lit. b GDPR (performance of a contract). For more information, see Stripe’s privacy policy.

9. Conference tools used 

We employ the following conference tools: 

MICROSOFT TEAMS 

We use Microsoft Teams. The provider is Microsoft Corporation, One Microsoft Way, Redmond, WA 98052-6399, USA. For details on data processing, please refer to the Microsoft Teams privacy policy: https://privacy.microsoft.com/en-us/privacystatement

AVOMA

We use Avoma, a meeting assistant that joins our video calls to produce notes and transcripts. Avoma announces itself at the start of every call it attends, and participants can decline. If you decline, the call continues without recording or transcription. We use the resulting notes and transcripts internally to record what was discussed and to follow up on your enquiry. Avoma is provided by Avoma, Inc. Personal data may be transferred outside the European Economic Area, including to the United States. Avoma incorporates the EU standard contractual clauses for these transfers.

PURPOSE AND LEGAL BASES 

The conference tools are used to communicate with prospective or existing contractual partners or to offer certain services to our customers (Art. 6 para. 1 sentence 1 lit. b GDPR). Furthermore, the use of the tools serves to generally simplify and accelerate communication with us or our company (legitimate interest in the meaning of Art. 6 para. 1 lit. f GDPR). Insofar as consent has been requested, the tools in question will be used on the basis of this consent; the consent may be revoked at any time with effect from that date. 

DURATION OF STORAGE 

Data collected directly by us via the video and conference tools will be deleted from our systems immediately after you request us to delete it, revoke your consent to storage, or the reason for storing the data no longer applies. Stored cookies remain on your end device until you delete them. Mandatory legal retention periods remain unaffected. 

We have no influence on the duration of storage of your data that is stored by the operators of the conference tools for their own purposes. For details, please directly contact the operators of the conference tools. 

10. Social media 

DATA PROCESSING THROUGH SOCIAL NETWORKS 

We maintain publicly available profiles in social networks. The individual social networks we use can be found below. 

Social networks such as Facebook, Twitter etc. can generally analyze your user behavior comprehensively if you visit their website or a website with integrated social media content (e.g., like buttons or banner ads). When you visit our social media pages, numerous data protection-relevant processing operations are triggered. In detail: 

If you are logged in to your social media account and visit our social media page, the operator of the social media portal can assign this visit to your user account. Under certain circumstances, your personal data may also be recorded if you are not logged in or do not have an account with the respective social media portal. In this case, this data is collected, for example, via cookies stored on your device or by recording your IP address. 

Using the data collected in this way, the operators of the social media portals can create user profiles in which their preferences and interests are stored. This way you can see interest-based advertising inside and outside of your social media presence. If you have an account with the social network, interest-based advertising can be displayed on any device you are logged in to or have logged in to. 

Please also note that we cannot retrace all processing operations on the social media portals. Depending on the provider, additional processing operations may therefore be carried out by the operators of the social media portals. Details can be found in the terms of use and privacy policy of the respective social media portals. 

LEGAL BASIS 

Our social media appearances should ensure the widest possible presence on the Internet. This is a legitimate interest within the meaning of Art. 6 (1) lit. f GDPR. The analysis processes initiated by the social networks may be based on divergent legal bases to be specified by the operators of the social networks (e.g., consent within the meaning of Art. 6 (1) (a) GDPR). 

RESPONSIBILITY AND ASSERTION OF RIGHTS 

If you visit one of our social media sites (e.g., Facebook), we, together with the operator of the social media platform, are responsible for the data processing operations triggered during this visit. You can in principle protect your rights (information, correction, deletion, limitation of processing, data portability and complaint) vis-à-vis us as well as vis-à-vis the operator of the respective social media portal (e.g., Facebook). 

Please note that despite the shared responsibility with the social media portal operators, we do not have full influence on the data processing operations of the social media portals. Our options are determined by the company policy of the respective provider. 

STORAGE TIME 

The data collected directly from us via the social media presence will be deleted from our systems as soon as you ask us to delete it, you revoke your consent to the storage or the purpose for the data storage lapses. Stored cookies remain on your device until you delete them. Mandatory statutory provisions – in particular, retention periods – remain unaffected. 

We have no control over the storage duration of your data that are stored by the social network operators for their own purposes. For details, please contact the social network operators directly (e.g., in their privacy policy, see below). 

YOUR RIGHTS 

You have the right to receive information about the origin, recipient and purpose of your stored personal data at any time and free of charge. You also have the right to object, the right to data portability and the right to file a complaint with the responsible regulatory agency. Furthermore, you can request the correction, blocking, deletion and, under certain circumstances, the restriction of the processing of your personal data. 

INDIVIDUAL SOCIAL NETWORKS 

INSTAGRAM 

We have a profile on Instagram. The provider of this service is Meta Platforms Ireland Limited, 4 Grand Canal Square, Grand Canal Harbour, Dublin 2, Ireland. 

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.facebook.com/legal/EU_data_transfer_addendum, https://help.instagram.com/519522125107875 and https://de-de.facebook.com/help/566994660333381

For details on how they handle your personal information, see the Instagram Privacy Policy: https://help.instagram.com/519522125107875

LINKEDIN 

We have a LinkedIn profile. The provider is the LinkedIn Ireland Unlimited Company, Wilton Plaza, Wilton Place, Dublin 2, Ireland. LinkedIn uses advertising cookies. 

If you want to disable LinkedIn advertising cookies, please use the following link: https://www.linkedin.com/psettings/guest-controls/retargeting-opt-out

Data transmission to the US is based on the Standard Contractual Clauses (SCC) of the European Commission. Details can be found here: https://www.linkedin.com/legal/l/dpa and https://www.linkedin.com/legal/l/eu-sccs

For details on how they handle your personal information, please refer to LinkedIn’s privacy policy: https://www.linkedin.com/legal/privacy-policy

YOUTUBE 

We have a profile on YouTube. The provider is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Details on how they handle your personal data can be found in the YouTube privacy policy: https://policies.google.com/privacy?hl=en

Twinsity Platform Privacy Policy

1. An Overview of Data Protection 

General Information 

The following information will provide you with an easy to navigate overview of what will happen with your personal data when you use our online platform Twinsity (hereinafter referred to as “platform” or “website”). The term “personal data” comprises all data that can be used to personally identify you. For detailed information about the subject matter of data protection, please consult our Data Protection Declaration, which we have included beneath this copy. 

Data Recording on our Platform 

Who is the responsible party for the recording of data on the platform (i.e., the “controller”)? 

The data on the platform is processed by the operator of the website, whose contact information is available under section “Information about the responsible party (referred to as the “controller” in the GDPR)” in this Privacy Notice. 

How do we record your data? 

We collect your data as a result of your sharing of your data with us. This may, for instance be information you enter for signing up on our platform. 

Other data shall be recorded by our IT systems automatically or after you consent to its recording during your website visit. This data comprises primarily technical information (e.g., web browser, operating system, or time the site was accessed). This information is recorded automatically when you access our platform. 

What are the purposes we use your data for? 

A portion of the information is generated to guarantee the error free provision of the platform. Other data may be used to analyze your user patterns. 

What rights do you have as far as your information is concerned? 

You have the right to receive information about the source, recipients, and purposes of your archived personal data at any time without having to pay a fee for such disclosures. You also have the right to demand that your data are rectified or eradicated. If you have consented to data processing, you have the option to revoke this consent at any time, which shall affect all future data processing. Moreover, you have the right to demand that the processing of your data be restricted under certain circumstances. Furthermore, you have the right to log a complaint with the competent supervising agency. 

Please do not hesitate to contact us at any time if you have questions about this or any other data protection related issues. 

2. General Information and Mandatory Information 

Data Protection Declaration 

The operators of our platform take the protection of your personal data very seriously. Hence, we handle your personal data as confidential information and in compliance with the statutory data protection regulations and this Data Protection Declaration. 

Whenever you use this platform, a variety of personal information will be collected. Personal data comprises data that can be used to personally identify you. This Data Protection Declaration explains which data we collect as well as the purposes we use this data for. It also explains how, and for which purpose the information is collected. 

We herewith advise you that the transmission of data via the Internet (i.e., through email communications) may be prone to security gaps. It is not possible to completely protect data against third-party access. 

Information about the responsible party (referred to as the “controller” in the GDPR) 

The data processing controller on this website is: 

Twinsity Technologies GmbH
An der Tränke 4
34479 Breuna
Germany 
Email: info@twinsity.com 
 
(hereinafter “Twinsity”, “we”, “our”, “us”, etc.). 

The controller is the natural person or legal entity that single-handedly or jointly with others makes decisions as to the purposes of and resources for the processing of personal data (e.g., names, email addresses, etc.). 

Storage duration 

Unless a more specific storage period has been specified in this privacy policy, your personal data will remain with us until the purpose for which it was collected no longer applies. If you assert a justified request for deletion or revoke your consent to data processing, your data will be deleted, unless we have other legally permissible reasons for storing your personal data (e.g., tax or commercial law retention periods); in the latter case, the deletion will take place after these reasons cease to apply. 

3. Recording of Data on our Platform 

Server Log Files 

The provider of this website and its pages automatically collects and stores information in so-called server log files, which your browser communicates to us automatically. The information comprises: 

  • The type and version of browser used 
  • The used operating system 
  • Referrer URL 
  • The hostname of the accessing computer 
  • The time of the server inquiry 
  • The IP address 

This data is not merged with other data sources. 

This data is recorded on the basis of Art. 6 (1) lit. f GDPR. The operator of the website has a legitimate interest in the technically error free depiction and the optimization of the operator’s website. In order to achieve this, server log files must be recorded. 

Personal data that you provide to us in the course of using the Twinsity Services 

We also collect personal data from you if you have voluntarily provided it to us in order to provide, operate and administer the platform and provide the Twinsity Services to you in accordance with our GTC (available at https://twinsity.com/terms-of-use/), to provide, operate and administer the platform and to provide the platform and the Twinsity Services to you. 

In particular, we collect (i) your name, email address, telephone number, position with the Company, industry in which the Company operates, language you choose, and payment information; and (ii) -optional- your profile picture, if you register a customer account on the platform as our contractual partner and thereby specify yourself as the contact person of the customer account. The legal basis for this is the fulfilment of our contractual obligations (Art. 6 (1) lit. b GDPR). 

Furthermore we collect in particular (i) your name, email address, telephone number, position with the Company, industry in which the Company operates and the language you choose; and (ii) – optionally – your profile picture, if you register a user account assigned to the customer account as a person authorized to use the service (hereinafter “user“) or if you are registered as a user by the owner of the corresponding customer account or by Twinsity with your consent. The legal basis for this is our legitimate interests (Art. 6 (1) lit. f GDPR), which are to provide you with the Platform and Twinsity Services in accordance with our GTC (available at https://twinsity.com/terms-of-use/). 

In this context, the email address of the user can also be provided to us by the owner of the customer account, with the request to send the user an invitation to the platform. 

When we collect your personal data, we will inform you whether the provision of the respective personal data is required or merely optional, as well as the possible consequences if you do not provide the corresponding information. 

Contact Form 

If you submit inquiries to us via our contact form, the information provided in the contact form as well as any contact information provided therein will be stored by us in order to handle your inquiry and in the event that we have further questions. We will not share this information without your consent. 

The processing of these data is based on Art. 6 (1) lit. b GDPR, if your request is related to the execution of a contract or if it is necessary to carry out pre-contractual measures. In all other cases the processing is based on our legitimate interest in the effective processing of the requests addressed to us (Art. 6 (1) lit. f GDPR) or on your agreement (Art. 6 (1) lit. a GDPR) if this has been requested. 

The information you have entered into the contact form shall remain with us until you ask us to eradicate the data, revoke your consent to the archiving of data or if the purpose for which the information is being archived no longer exists (e.g., after we have concluded our response to your inquiry). This shall be without prejudice to any mandatory legal provisions – in particular retention periods. 

Request by Email, Telephone, or Fax 

If you contact us by email, telephone or fax, your request, including all resulting personal data (name, request) will be stored and processed by us for the purpose of processing your request. We do not pass these data on without your consent. 

These data are processed on the basis of Art. 6 (1) lit. b GDPR if your inquiry is related to the fulfillment of a contract or is required for the performance of pre-contractual measures. In all other cases, the data are processed on the basis of our legitimate interest in the effective handling of inquiries submitted to us (Art. 6 (1) lit. f GDPR) or on the basis of your consent (Art. 6 (1) lit. a GDPR) if it has been obtained. 

The data sent by you to us via contact requests remain with us until you request us to delete, revoke your consent to the storage or the purpose for the data storage lapses (e.g. after completion of your request). Mandatory statutory provisions – in particular statutory retention periods – remain unaffected. 

Newsletter 

If you have given us your consent, we will also collect your name, email address and the language you have selected when you register for our newsletter. We process this personal data in order to send you our newsletter. The legal basis for this is your consent (Art. 6 (1) lit. a GDPR). 

4. Disclosure of Personal Data 

We do not pass on any personal data to third parties unless this is necessary for the performance of the contract, is otherwise permitted by relevant statutory provisions or you have given us your consent. 

To this extent, in order to provide the Twinsity Services, we must provide certain information for processing purposes to (a) other involved users of the platform (i.e., users also involved in the activities and operations); and; (b) integrated service providers (i.e. payment service providers). This information is shared with these individuals solely for the purpose of providing Twinsity services on the Platform, and in no event for marketing purposes. The legal basis for this is the fulfilment of our contractual obligations (Art. 6(1)(b) GDPR) and our legitimate interests (Art. 6(1)(f) GDPR), which are to provide you with the Platform and the Twinsity Services in accordance with our GTC (available at https://twinsity.com/terms-of-use/). 

Furthermore, we are entitled to outsource the processing of personal data in whole or in part to external service providers who act for us as processors (Art. 4 No. 8 GDPR) within the framework of the data protection regulations. If these service providers are located outside the European Union (EU) or the European Economic Area (EEA) Treaty Area, we will take appropriate security measures in accordance with legal and regulatory requirements to ensure the security of your personal data. 

5. Web Analysis, Cookies, and Local Storage 

5.1 Cookies and local storage are used on the platform in order to (a) better understand how the platform is used; (b) to provide and maintain, so far as is technically possible and reasonable, a stable, secure, functional and accurate platform; and (c) provide and enable you to have an optimal and meaningful user experience. 

Cookies and local storage help us to make your visit to the platform and use of Twinsity’s services more enjoyable, efficient and meaningful. 

  1. Cookies 
    Cookies are text information files that are sent from our web server to your computer and stored there when you visit the Platform. Most browsers automatically accept cookies, but they can be configured not to use them via the browser’s settings function. You can refuse the use of cookies or delete the correspondingly collected data at a later time. It is not necessary that you allow cookies to be set in order to use the platform in general. However, there are certain areas and features on the Platform that you will not be able to use without cookies. 
  1. Local Storage 
    The use of local storage cannot be deactivated for the reasons stated there, because it is required for authentication and security purposes in connection with your customer account or user account. 

5.2 The following types of cookies and local storage are used on the Platform 

  1. Local Storage 
    Local Storage is a technology that allows your browser to store data on your computer or mobile device in order to recognize multiple uses by the same user; the data collected remains stored for this purpose even after you close the browser or exit the program. For example, Local Storage records whether you are logged in to the platform. This serves authentication and security purposes and is necessary to enable you to navigate and use the platform when logged in (allocation to your customer account or user account). The legal basis for this is the fulfilment of our contractual obligations (Art. 6 (1) lit.b GDPR) or our legitimate interests (Art. 6 (1) lit. f GDPR), which consist in providing you with the Platform and the Twinsity Services in accordance with our GTC (available at https://twinsity.com/terms-of-use/). 
  1. Technically necessary cookies 
    Technically necessary cookies are cookies that are required for navigation on the Platform and for the use of different options of Twinsity services provided there, in particular the necessary data communication, identification of your user account, access to restricted areas of the Platform or storage of content in order to share it. The legal basis for this is our legitimate interests (Article 6 (1) lit. f GDPR), which are to provide you with the Platform and Twinsity Services in accordance with our Terms and Conditions (available at https://twinsity.com/terms-of-use/). 
  1. Personalizing cookies or customization cookies 
    Customization cookies are cookies that allow access to the platform with certain general default settings according to different specifications of your end device, such as language settings, browser type and regional settings, etc. The legal basis for this is our legitimate interests (Art. 6 (1) lit. f GDPR). The legal basis for this is our legitimate interests (Art. 6 (1) lit. f GDPR), which consist of providing you with a personalized service in accordance with our GTC (available at https://twinsity.com/terms-of-use/) to provide a user-friendly and meaningful platform and Twinsity services that meet your expectations and needs. 

6. Safety 

We take appropriate and reasonable technical measures to secure your personal data against loss, destruction, manipulation and unauthorized access. The platform uses transport encryption (TLS) to protect the transmission. All our employees as well as external service providers working for us (order processors in the sense of Art. 4 No. 8 GDPR) are obliged to comply with the applicable data protection laws. 

Our security measures are subject to a continuous improvement and optimisation process. Please always use the latest version of the Google Chrome web browser to ensure that your personal data is protected in the best possible way. 

7. Your Rights as a Data Subject 

In accordance with the applicable data protection law, you are entitled to the following rights in particular.
(a) Right to information: You have the right to request information about your personal data stored by us at any time.  

(b) Right to rectification: When we process your personal data, we will endeavour to take reasonable steps to ensure that your personal data is accurate and up to date for the purposes for which it was collected. In the event that your personal data is inaccurate or incomplete, you may request that it be corrected.  

(c) Right to erasure and restriction: You may have the right to request the erasure or restriction of the processing of your personal data if, for example, there is no longer a legitimate business purpose for such processing under this Privacy Notice  or applicable law and legal retention obligations do not prevent further storage. 
(d) Right to data portability: You may have the right to obtain the personal data concerning you that you have provided to us in a structured, commonly used and machine-readable format, or to transfer this data to another controller. 
(e) Right to object: You may have the right to object to the processing of your personal data on specific grounds relating to your particular situation. 
(f) Right to revoke your consent: If you have consented to the collection and processing of your personal data, you may revoke your consent at any time with effect for the future, but without affecting the lawfulness of the processing carried out on the basis of the consent until revocation. You can also object to the use of your personal data for the purposes of market and opinion research and advertising.  

(g) Supervisory authority responsible for possible complaints: You can appeal to a supervisory authority at any time, e.g. the relevant supervisory authority in the state of your residence, or to the supervisory authority applicable to us. A list of supervisory authorities (for the non-public sector) with addresses can be found at:  
https://www.bfdi.bund.de/DE/Infothek/Anschriften_Links/anschriften_links-node.html 

8. Links to other Websites 

Our platform may contain external links to other websites which may not be owned or funded by us. Generally, these links are identified as such. We cannot control to what extent linked websites comply with the applicable data protection provisions. We therefore recommend that for other providers’ data protection statements, you refer to the information given on their respective websites. 

9. Amendments to this Privacy Notice 

Any revision of this Privacy Notice is identified by the date specified (see below). We reserve the right to amend this Privacy Statement at any time with effect for the future. Amendments will be made, among other things, in case of technical adjustments of the online offering or changes of the data protection laws. The Privacy Notice as amended from time to time is always made available directly through our online offering. We recommend to read about amendments of this Privacy Notice in a regular basis. 

10. Contact Us 

If you have any questions or complaints about this Privacy Policy, please send an email to info@twinsity.com or send physical mail to: 

Twinsity Technologies GmbH 
An der Tränke 4
34479 Breuna
Germany 
Email: info@twinsity.com 

 
This Privacy Notice was last revised in: July 2026