Privacy Policy

Introduction

This is the privacy policy (“Privacy Policy”) of TwinTerra, Inc. and its affiliated companies (“TwinTerra,” or “we,” “us,” and “our”). If you have any questions about this Privacy Policy, please contact us at info@twinterra.ai.

We have adopted this Privacy Policy to explain what Personal Information we collect on our website at twinterra.ai (the “Website”), how we use that Personal Information, and the circumstances under which we may disclose it to third parties. This Privacy Policy applies only to Personal Information we collect through the Website, or that you otherwise provide to us, and does not apply to Personal Information we collect from other sources.

“Personal Information” means any information that identifies, relates to, describes, or is reasonably capable of being associated with a particular individual. Personal Information does not include information that is (i) lawfully made available to the general public from federal, state, or local government records, (ii) de-identified or aggregated, or (iii) otherwise excluded from the scope of applicable privacy law.

Collection of Personal Information

The amount and type of Personal Information we collect depends on the nature of your interaction with us. Over the past 12 months, we may have collected the following categories of Personal Information about you:

• Identifiers, such as your name, email address, Internet Protocol (IP) address, or other similar identifiers.
• Records information, such as your title or role and the name of your organization, provided when you contact us or request a demonstration of our products.
• Internet or other electronic network activity information, such as your IP address, device and browser information, and information about your interaction with the Website.
• Geolocation data, limited to the approximate region (for example, country or city) derived from your IP address.
• Professional or employment-related information, such as your resume, work history, and links to prior work, when you apply for a role with us.

We collect Personal Information from the following categories of sources:

• directly from you, such as when you request a demo, apply for a role, or otherwise communicate with us; and
• automatically, through the analytics technology we deploy on the Website.

How We Use Your Personal Information

We generally use your Personal Information to respond to your requests, to comply with our legal obligations, and to operate and improve our business. This includes, for example:

• communicating with you, including responding to demo requests, job applications, and other inquiries;
• complying with our legal obligations, including satisfying any regulatory or reporting requirements;
• protecting against fraud and security incidents, including detecting and protecting against illegal activity and testing, debugging, and securing the Website;
• performing research and analytics, such as analyzing Website traffic and reporting on that analysis in aggregate form;
• maintaining and improving our services, including operating and administering the Website; and
• any other purpose we disclose to you at the time we collect your Personal Information.

How We Disclose Your Personal Information

We may disclose your Personal Information to:

• service providers, such as hosting, email, and analytics providers, that process Personal Information in the course of providing services to us;
• professional advisors and business partners, such as auditors, law firms, and consultants, where reasonably necessary;
• legal or governmental authorities, as required by applicable law;
• other entities in connection with a potential business transfer, corporate reorganization, restructuring, asset or stock sale, or bankruptcy; and
• other third parties to whom you authorize us to disclose such information.

Links to External Sites

The Website may contain links to external sites that we do not operate. If you follow a third-party link, you will be directed to that third party's site. We encourage you to review the privacy policy and terms of every website you visit. We have no control over, and assume no responsibility for, the content, privacy policies, or practices of any third-party websites, products, or services.

Security and Retention of Personal Information

We use commercially reasonable and appropriate measures to protect your Personal Information. However, no method of transmitting data over the Internet or storing it electronically is completely secure, and we cannot guarantee its absolute security.

We retain your Personal Information only for as long as necessary to fulfill the purposes for which we collected it, including to satisfy any legal, accounting, regulatory, or reporting requirements.

Cookies and Other Tracking

We use analytics services to understand how visitors use the Website and to help us improve it. These services collect information such as the number of visitors, the websites or campaigns visitors came from, and the pages they viewed, and we review this information in aggregate form. These services may set first-party cookies to distinguish visitors and measure usage. We do not use analytics data for personalized or interest-based advertising.

You may configure your browser to refuse some or all cookies; for more information, including how to manage cookies, you can visit www.allaboutcookies.org. Please note that disabling cookies may affect the Website's functionality.

Automated Information Collection

We use automated technologies for aggregate reporting and analysis only. We do not use automated collection to identify you individually, to build a profile about you, or to link your activity across devices or applications, and we do not engage in personalized or interest-based advertising.

Do Not Track

Some browsers offer a “Do Not Track” setting that lets you signal that you do not want your online activity tracked. Because we use our analytics in aggregate form and we do not serve interest-based advertising, we do not track you across websites and therefore do not alter our practices in response to Do Not Track signals.

Transferring Personal Data

Your Personal Information may be transferred to, processed, and stored in a country other than the one in which it was collected. The Personal Information we collect from you is currently held within the United States. If you access the Website from outside the United States, you agree that your Personal Information may be transferred to, stored, and processed in the United States, which may not offer the same level of data protection as your country. Where we transfer Personal Information, we do so only through a legally permitted method and with appropriate safeguards in place to protect it. In connection with the sale or transfer of some or all of our business assets, we may transfer the corresponding Personal Information and may retain a copy of it.

California Privacy Disclosures

This notice to California residents is provided under California law, including the disclosures required by the California Consumer Privacy Act, as amended by the California Privacy Rights Act (together, the “CCPA”). It supplements this Privacy Policy by describing the California privacy rights of California residents and providing certain mandated disclosures about our collection and use of California residents' Personal Information. If you have a disability and would like to access this notice in an alternative format, please contact us at info@twinterra.ai.

The sources from which we collect Personal Information, the manner in which we collect it, and how we use it are described above. Over the past 12 months, we have not sold your Personal Information or shared it for targeted (cross-context behavioral) advertising purposes, and we have not used your Personal Information to make automated decisions that produce legal or similarly significant effects. The table below describes how we have disclosed Personal Information for a business purpose over the last 12 months.

For an explanation of the rights you may have as a California resident, please see the “Your Privacy Rights” section below.

California “Shine the Light”

If you are a California resident, you may opt out of our sharing your Personal Information with third parties for those third parties' direct marketing purposes by emailing us at info@twinterra.ai.

Your Privacy Rights

Depending on where you live, you may have the following rights, subject to applicable exemptions and limitations:

• Right to access / know. You may request the categories and specific pieces of Personal Information we have collected about you, the categories of sources from which we collected it, our business or commercial purposes for collecting it, and the categories of third parties to whom we have disclosed it.
• Right to correct. You may request that we correct inaccurate Personal Information we maintain about you.
• Right to delete. You may request that we delete Personal Information we have collected from you, subject to applicable legal exceptions.
• Right to opt out of sale / sharing. You may opt out of the “sale” of your Personal Information or its “sharing” for cross-context behavioral advertising. As stated above, TwinTerra does not sell or share Personal Information as those terms are defined under the CCPA.

You may submit a request to exercise your rights by emailing us at info@twinterra.ai. We may take steps to verify your identity before responding, including by asking you to provide information we can match against our records; if we cannot verify your identity, we may need to deny your request. You may designate an authorized agent to make a request on your behalf, and we may take steps to confirm the agent's authority. We will respond to a verifiable request within the timeframe required by applicable law (generally 45 days), and will inform you if we require additional time. You have the right not to receive discriminatory treatment for exercising your privacy rights.

Children's Privacy

The Website is intended for a professional audience and is not directed to children. We do not knowingly collect Personal Information from children under 13 without verifiable parental consent. If we learn that a child under 13 has provided us Personal Information without such consent, we will take reasonable measures to delete it. If you believe a child under 13 has provided us with Personal Information, please contact us at info@twinterra.ai.

Changes to This Privacy Policy

We may update this Privacy Policy from time to time, in our discretion or to reflect changes in applicable law. When we make material changes, we will revise the “Last updated” date at the top of this page. We encourage you to review this page periodically. Your continued use of the Website after any change takes effect constitutes your acceptance of the revised Privacy Policy.

Contact Us

If you have any questions about this Privacy Policy, you can contact us by email at info@twinterra.ai.