Last updated: May 7, 2025

1. Data Controller

In accordance with Regulation (EU) 2016/679 (GDPR) and Organic Law 3/2018 (LOPDGDD), we inform you that the data controller is:

• 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

2. Purpose of Processing

We process your personal data for the following purposes:

• To properly provide and manage the services contracted through the Twinny platform.

• To send commercial communications related to our products and services.

• To comply with applicable legal and tax obligations.

Personal data will be retained as long as a contractual relationship exists, and thereafter for the legally required period.

3. Legal Basis

The legal bases for processing your data are:

• The performance of a contract in which you are a party.

• Your explicit consent for the sending of commercial communications (if granted).

• Compliance with legal obligations.

4. Recipients

No data will be transferred to third parties, except where legally required. Under no circumstances do we sell, rent, or share your data with other entities for commercial purposes.

Data may be processed by service providers contracted by Wason Digital, S.L., who comply with GDPR requirements and ensure the confidentiality and security of the information.

5. International Data Transfers

No international data transfers are planned. Should they occur, you will be duly informed and appropriate safeguards will be implemented in accordance with the GDPR.

6. User Rights

You may exercise your rights of access, rectification, erasure, objection, restriction of processing, and data portability by submitting a written request to clientes@twinny.es, providing proof of 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 violated.

7. Data Security

Wason Digital, S.L. applies appropriate technical and organizational measures to ensure a level of security appropriate to the risk and to prevent the loss, misuse, alteration, unauthorized access, or theft of the personal data provided.

8. Confidentiality

Your data will be treated with the utmost confidentiality. We are committed to maintaining professional secrecy and ensuring the duty of care, even after the contractual relationship ends.

9. Use of the Platform

By using the Twinny platform, the user acknowledges having read and accepted this Privacy Policy and authorizes the processing of their personal data under the terms described above.

10. Google User Data

If you choose to connect your Google account to the Twinny platform (for example, Gmail, Google Calendar, Google Ads, or Google Drive/Docs), the Platform may access certain Google user data, strictly for the purpose of providing the contracted services. This data may include:

• Basic profile information (name, email address).

• Gmail: email metadata and/or content (only if explicitly authorized by you) to manage interactions with your contacts or leads.

• Google Calendar: event and scheduling information to synchronize meetings, reminders, or automated actions.

• Google Ads: campaign, audience, and budget data to assist with agent management, conversational advertising, and reporting.

• Google Drive/Docs: selected files or documents explicitly authorized by you to configure or train agents.

This information is only used to enable the contracted functionalities and is never shared with third parties.

Retention and Deletion
Google user data accessed through the Platform is retained only while your Twinny account remains active.

• If you delete your Twinny account or terminate the service, all Google user data associated with your account is irreversibly deleted from our systems within a maximum of 30 days, unless a longer retention period is required by law.

• You may also request immediate deletion of your Google data by contacting clientes@twinny.es.

Revoking Access
You may revoke Twinny’s access to your Google data at any time from your Google Security Settings.