Privacy Policy

1. Introduction

TWYN ("we", "us", or "our"), operated by Fabian Brown, is committed to protecting your privacy in accordance with the General Data Protection Regulation (GDPR) and Irish data protection law. This Privacy Policy explains how we collect, use, disclose, and safeguard your information when you use our platform at twyn.shop.

2. Information We Collect

Personal Information

When you create an account or use our services, we may collect:

• Name and email address
• Payment information (processed securely via Stripe)
• Profile information you choose to provide
• Communication preferences

Usage Information

• Log data (IP address, browser type, pages visited)
• Device information
• Feature usage and interaction data
• Content you create using our tools

3. Legal Basis for Processing (GDPR Article 6)

We process your personal data under the following legal bases:

4. How We Use Your Information

We use your information to:

• Provide and maintain our services
• Process payments and manage subscriptions
• Send service-related communications
• Improve and personalize your experience
• Respond to your inquiries and support requests
• Detect and prevent fraud or abuse
• Comply with legal obligations

5. AI Content Processing

When you use our AI tools, your prompts and generated content may be processed by third-party AI providers (such as OpenAI). We do not use your content to train AI models. Generated content is stored in your account for your convenience and can be deleted at any time.

6. Data Sharing

We may share your information with:

• Service Providers: Stripe (payments), AI providers, hosting services
• Legal Requirements: When required by law or to protect our rights
• Business Transfers: In connection with a merger, acquisition, or sale

We do not sell your personal information to third parties.

7. International Data Transfers

Your data may be transferred to and processed in countries outside the European Economic Area (EEA), including the United States (for AI processing and hosting services).

We ensure appropriate safeguards are in place for such transfers:

• EU-US Data Privacy Framework: For US-based processors certified under the DPF
• Standard Contractual Clauses (SCCs): EU-approved contractual safeguards
• Adequacy Decisions: Transfers to countries deemed adequate by the European Commission

You can request information about the specific safeguards in place by contacting us.

8. Data Security

We implement industry-standard security measures to protect your data, including:

• Encryption of data in transit (TLS/SSL) and at rest
• Secure password hashing (bcrypt)
• Regular security assessments
• Access controls and authentication
• Secure hosting infrastructure

9. Data Retention

We retain your data for specific periods depending on the type of data and purpose:

10. Your Rights (GDPR)

Under GDPR, you have the following rights:

• Access (Art. 15): Request a copy of your personal data
• Rectification (Art. 16): Correct inaccurate or incomplete data
• Erasure (Art. 17): Request deletion of your data ("right to be forgotten")
• Restriction (Art. 18): Limit how we process your data
• Portability (Art. 20): Receive your data in a portable format
• Objection (Art. 21): Object to processing based on legitimate interests
• Withdraw Consent (Art. 7): Withdraw previously given consent at any time
• Automated Decision-Making (Art. 22): Not be subject to solely automated decisions

To exercise these rights, contact us at hello@twyn.shop. We will respond within 30 days.

11. Right to Lodge a Complaint

If you believe your data protection rights have been violated, you have the right to lodge a complaint with the Irish Data Protection Commission:

We encourage you to contact us first so we can address your concerns directly.

12. Children's Data Protection

In accordance with Irish law (implementing GDPR Article 8), our services are not intended for children under 16 years of age. The digital age of consent in Ireland is 16.

• We do not knowingly collect personal information from children under 16
• If we discover we have collected data from a child under 16 without parental consent, we will delete it promptly
• If you believe a child has provided us with personal information, please contact us immediately

13. Cookies

We use cookies and similar technologies to enhance your experience. For detailed information about the cookies we use and how to manage them, please see our Cookie Policy.

14. Changes to This Policy

We may update this Privacy Policy from time to time. We will notify you of significant changes via email or platform notification. The "Last updated" date at the top indicates when the policy was last revised.

15. Contact Us

For privacy-related questions or to exercise your rights, contact us at: