Last updated: May 7, 2025

1. Owner Information

In compliance with the duty of disclosure established in Law 34/2002 (LSSI-CE), the following information is provided:

• Owner: Wason Digital, S.L.

• Tax ID (CIF): B67770859

• Registered address: Parque Tecnológico, Av. Gregorio Peces Barba, 1, 28919 Leganés, Madrid

• Contact email: clientes@twinny.es

• Registered trademark: Twinny

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2. Purpose and Scope

These terms govern access to and use of the Twinny platform (hereinafter, “the Platform”), as well as the contracting of services offered by Wason Digital S.L. through it. By using the Platform, the user expressly agrees to these terms.

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3. Service Description

Twinny is a SaaS (Software as a Service) platform focused on conversational intelligence and automation of commercial interactions. Users can subscribe to monthly or annual plans based on their needs, whether they are companies or self-employed professionals.

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4. Registration and Access

To access the services, users must register by providing truthful and up-to-date information. Users are responsible for maintaining the confidentiality of their login credentials.

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5. Free Trial Period

All plans include a 14-day free trial. During this period, no charges will be made. At the end of the trial, if the service has not been canceled, the selected plan will automatically be activated and billed accordingly.

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6. Pricing and Payment Methods

Plan prices are available on the Platform and may be subject to change.
Payment is made exclusively online via Stripe, a third-party payment gateway that complies with PCI-DSS standards. Stripe ensures the security and confidentiality of banking data.
Wason Digital S.L. does not store payment information.

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7. Renewal, Cancellation, and Refunds

• Subscriptions are automatically renewed based on the selected plan (monthly or annual).

• Users may cancel their subscription at any time from their user dashboard. The cancellation will take effect at the end of the current billing period for annual plans or for discounted pricing. Therefore, early cancellation does not entitle the user to a partial refund.

• By the end of the free trial, the user agrees that the paid service will begin.

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8. User Obligations

Users agree to:

• Use the Platform appropriately.

• Not use it for unlawful purposes or in ways that may harm the reputation of Wason Digital S.L.

• Provide truthful and accurate information and keep it updated.

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9. Intellectual and Industrial Property

All intellectual property rights related to the Platform, content, designs, software, and the Twinny brand are owned by Wason Digital S.L. or its licensors. Any total or partial reproduction without express permission is prohibited.

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10. Data Protection

The processing of personal data is governed by our Privacy Policy, which the user acknowledges and accepts upon registration.

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11. Changes to the Terms

Wason Digital S.L. may modify these terms. In the event of significant changes, users will be notified by email or via the Platform. Continued use of the service implies acceptance of the new terms.

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12. Governing Law and Jurisdiction

These terms are governed by Spanish law. For any disputes, the parties submit to the Courts and Tribunals of Madrid, unless otherwise required by applicable mandatory legal provisions.

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13. Regulatory Compliance in Platform Use

Users agree to use the Platform in compliance with applicable laws and regulations, including but not limited to:

• The Organic Law on Data Protection and Guarantee of Digital Rights (LOPDGDD) and the General Data Protection Regulation (GDPR).

• Any applicable laws related to the use of artificial intelligence systems in their sector or country.

The user is solely responsible for the processing of personal data belonging to their own contacts, customers, or leads, as well as compliance with applicable laws in each case.

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14. WhatsApp Integration and Responsible Use

Twinny allows integration with messaging channels like standard WhatsApp, which may be subject to limitations, including the risk of account suspension or cancellation due to:

• Excessive use of unsolicited mass messages (spam).

• Fraudulent content or content not permitted under Meta’s policies.

As such, the user agrees to hold Twinny harmless against any third-party claims resulting from the misuse of any messaging channels used by the user.

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15. Use of Artificial Intelligence (AI) Agents

The Twinny Platform includes features powered by artificial intelligence (AI) agents that allow users to automate responses, generate content, make recommendations, or conduct automated conversations with their contacts or customers. These features are designed to provide a more agile, personalized, and efficient experience; however, several key considerations must be noted.

Training, configuring, and using these agents is the sole responsibility of the client, who can adapt their behavior according to commercial and operational goals. Therefore, responsibility for the content generated, responses provided, automated decisions made, and information collected through AI lies exclusively with the client using these features.

Wason Digital S.L. provides tools and technology to enable automation, but it does not intervene in or validate the specific content or actions generated by AI agents configured by each user. As such, any errors, misunderstandings, or consequences arising from the use of these tools are the sole responsibility of the client who configures and uses them.

We recommend regularly supervising and reviewing the behavior of implemented AI agents, reaching out to Twinny support if needed, and properly informing end users about the use of AI when applicable, always in compliance with current laws on transparency, data protection, and ethical use of artificial intelligence.

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16. Privacy and Data Handling

Wason Digital S.L. does not access, view, or share the data or interactions of users’ end customers. All information managed by the user through Twinny is securely stored in our systems and is never shared with third parties.

• Only the registered user has access to their data and interaction history.

• Upon service termination, all data associated with the account will be irreversibly deleted within a maximum of 30 days, unless legal obligations require otherwise.

• Our data processing practices are detailed in our Privacy Policy, which the user accepts upon registering on the Platform.