Privacy policy
This Privacy Policy ("Policy") explains how the BioTwin Group collects, uses, discloses, protects, and retains personal information when you use our websites, applications, portals, products, and services (collectively, the "Services"), including TwinMe, the BioTwin Portal, provider programs, research programs, sample collection and analysis, laboratory-related services, questionnaires, device and app connections, medical record imports, file uploads, photos, voice features, AI-powered features, large language model-powered features, simulations, conversational assistants, and customer support.
Health data is highly sensitive. BioTwin applies privacy, security, and data-minimization safeguards appropriate to the sensitivity of the information. BioTwin does not permit third-party large language model providers to use identifiable personal information or health data to train their general-purpose models, unless you provide explicit consent or the data has been de-identified or anonymized in accordance with applicable law.
This Policy does not apply to third-party websites, apps, devices, services, healthcare providers, laboratories, partners, employers, insurers, or other organizations that you choose to connect to or share data with, except where BioTwin acts as their processor or service provider under a separate agreement. Their privacy practices are governed by their own policies.
By using our Services, creating an account, submitting data, ordering a kit, uploading documents, connecting a third-party service, interacting with AI-powered features, or receiving communications from us, you acknowledge this Policy. Where required by law, we will request your consent for specific uses of personal information, sensitive information, health data, genetic data, biometric data, research participation, or data sharing.
Scope
This Policy explains how we collect, use, disclose, protect, and retain your personal information when you use TwinMe (wellness brand), the BioTwin portal (including "provider", "portal", "research" programs or related services), or interact with our features (questionnaires, document imports, device integrations, sample tracking, AI simulations, conversational assistant, support, etc.). It also applies to the TwinMe partner program and its portal, TwinMe Partners (partners.twinme.ai), including people we are considering inviting to join it (see "TwinMe partner program").
Who We Are (BioTwin + TwinMe)
BioTwin Holding International ("BioTwin Holding") is the parent company of the group. It owns BioTwin Canada Inc. and BioTwin Limited (UAE), and may operate through other entities (e.g., BioTwin USA). TwinMe is a non-medical brand owned by BioTwin Holding and licensed to the group’s operating entities. Unless otherwise indicated in a contract or program notice, the group entity providing the service to you (depending on your country, program, and journey) acts as the data controller, and BioTwin Holding may act as a joint controller or as a group support/administration entity.
Information We Collect
We collect information in different ways: when you create an account, complete your profile, answer questionnaires, import data, connect devices or third-party services, order or activate services, submit samples, upload documents, interact with AI-powered features, contact support, or participate in a provider, employer, wellness, research, or partner program.
Categories may include:
- Account and identity information: name, email, credentials, language, preferences, account identifiers, billing and transaction information.
- Profile, questionnaires, and check-ins: lifestyle habits, symptoms, goals, medical history, medications, supplements, family history, wellness information, and program responses.
- Biological samples and derived results: sample metadata, collection status, laboratory processing information, biomarkers, analytical outputs, and related quality-control information.
- Genetic, biometric, health, and wellness information: genetic data, lab results, physiological indicators, biometric characteristics, health records, imaging, reports, photos, voice information, nutrition information, activity, sleep, and other wellness metrics.
- Connected devices and third-party apps: data you authorize us to receive from wearables, health apps, devices, platforms, or other integrations.
- Medical records and uploaded documents: files, reports, prescriptions, lab reports, imaging reports, clinical notes, and other documents you choose to upload or import.
- Photos, visual information, and voice information: images of face, body, hands, skin, eyes, meals, and voice samples or recordings when a feature requires or permits them.
- AI interactions and content: prompts, questions, responses, feedback, conversation history, metadata, safety signals, and content generated by or submitted to AI-powered features.
- Communications and support: messages, requests, call or chat records, customer service history, and related metadata.
- Technical, security, and usage data: IP address, device information, browser information, logs, diagnostics, identifiers, approximate location, session activity, fraud-prevention signals, and security events.
Some of this information may be considered sensitive personal information, health data, consumer health data, genetic data, biometric data, or special-category data under applicable law.
How We Use Information
We use personal information for the following purposes:
- To provide, operate, personalize, maintain, and secure the Services.
- To create, update, test, validate, and operate your virtual twin and related insights.
- To process samples, coordinate laboratory work, perform quality control, generate analytical outputs, and deliver reports.
- To manage accounts, orders, billing, subscriptions, cancellations, refunds, support, and service communications.
- To enable medical record management, document uploads, data imports, third-party integrations, and controlled sharing with recipients you authorize.
- To provide, operate, secure, evaluate, test, improve, and develop AI-powered features, LLM-powered features, simulations, conversational assistants, recommendations, visualizations, and related safety systems.
- To improve service quality, user experience, reliability, accuracy, security, fraud prevention, and technical performance.
- To conduct internal analytics, product improvement, validation, research and development, and model development where permitted by law.
- To create, use, and share aggregated, anonymized, or de-identified data for lawful business, research, validation, publication, development, security, and commercial purposes, where permitted by law.
- To invite you to voluntary research projects and process research data when you consent or when another legal basis applies.
- To communicate about service updates, policy updates, security, product information, and marketing where permitted by law.
- To measure the audience of our websites and the effectiveness of our advertising, and to provide Meta with the data it uses to deliver and measure that advertising, as described in "Audience measurement, advertising and cookies".
- To comply with legal, regulatory, contractual, tax, accounting, clinical, laboratory, safety, and compliance obligations.
- To establish, exercise, defend, or protect BioTwin's legal rights, property, safety, users, partners, and services.
We do not send your questionnaire answers, your results, your genetic data, or the contents of your record to any advertising platform. Our websites do, however, use audience measurement tools and the Meta advertising pixel by default: the address of the pages you view and your purchases, which can reveal the program you are interested in, are sent to Meta, as described in "Audience measurement, advertising and cookies". BioTwin does not sell personal information. BioTwin may disclose personal information to service providers, partners, processors, and subprocessors where necessary to provide the Services, to Google, Hotjar, and Meta for audience measurement and advertising, or where disclosure is required by law, as described in this Policy.
De-Identified, Aggregated, and Anonymized Data
BioTwin may create de-identified, aggregated, or anonymized data from personal information. BioTwin may use and disclose such data for lawful business, research, validation, publication, analytics, security, commercial, product development, AI development, model development, benchmarking, and scientific purposes, where permitted by law.
BioTwin applies technical, contractual, and organizational measures designed to reduce re-identification risk. BioTwin will not attempt to re-identify anonymized data except where permitted by law for security, compliance, validation of de-identification methods, or legal obligations.
Research, Samples, and Laboratory Data
BioTwin may invite users to participate in research, validation, pilot, clinical, wellness, or scientific programs. Participation is voluntary unless a separate program agreement states otherwise. Where required, BioTwin will provide a separate consent form, research notice, ethics-board documentation, institutional-review documentation, or program notice.
Biological samples, laboratory data, biomarkers, genetic information, and derived results may be subject to specific consent, retention, destruction, quality-control, regulatory, accreditation, or laboratory requirements. BioTwin may retain information where necessary to provide Services, comply with legal or regulatory requirements, maintain quality records, support audit trails, resolve disputes, enforce agreements, protect safety, or preserve scientific integrity.
If you withdraw from a research program, BioTwin will stop future processing where required by law or the applicable consent. Withdrawal may not affect data already used, de-identified, aggregated, anonymized, included in completed analyses, submitted to regulators, included in audit records, or required to be retained by law.
Legal Bases
Depending on where you live and the feature, we process information based on: your consent (especially for health-related data, integrations, AI features, and sharing); performance of a contract (to provide requested Services); legitimate interests (security, fraud prevention, service improvement) where permitted; and legal obligations. The audience measurement and advertising described in "Audience measurement, advertising and cookies" are active by default; you can refuse them at any time.
How We Disclose Information
BioTwin does not sell personal information. We may disclose personal information only as described below:
- Within the BioTwin Group where necessary for service delivery, administration, support, security, compliance, and operation of the Services.
- To service providers, processors, and subprocessors, including cloud hosting, security, analytics, AI and LLM infrastructure, customer support, payment, logistics, laboratory, communications, identity verification, and technical providers, where necessary to provide the Services.
- To Google (Google Analytics), Hotjar, and Meta (Facebook, Instagram), for audience measurement of our websites and for measuring and delivering our advertising. These tools are active by default on biotwin.ai and twinme.ai; what they receive and how to refuse them are described in "Audience measurement, advertising and cookies".
- To laboratories, logistics and sample-collection partners, healthcare providers, wellness professionals, clinics, provider programs, employer programs, research programs, partner programs, and recipients you authorize, where necessary to provide a Service you request or a program in which you participate.
- For the TwinMe partner program, as described in "TwinMe partner program": to the agency or organization a person posts for, and to the public, for what a partner authorizes us to publish, such as their name and image on our partner pages.
- To professional advisors, insurers, auditors, banks, legal counsel, and consultants where necessary to provide, secure, administer, or support the Services or to meet applicable legal and compliance obligations.
- To authorities, courts, regulators, or law enforcement where disclosure is required by law.
We require service providers to use personal information only for authorized purposes and to apply safeguards appropriate to the sensitivity of the information. If you direct BioTwin to share information with a third party, that third party's own privacy practices may apply after it receives the information. Data received from Garmin is never disclosed to these recipients: see "Garmin data".
Government, Legal, and Law-Enforcement Requests
BioTwin reviews government, law-enforcement, regulatory, court, subpoena, and other legal requests for personal information on a case-by-case basis. Where permitted by law, BioTwin will oppose, challenge, seek to narrow, or reject requests that BioTwin considers overly broad, insufficiently supported, disproportionate, legally deficient, or inappropriate, particularly where sensitive health data, genetic data, biometric data, minors' data, or AI interaction data is involved.
BioTwin will disclose only the personal information required by law. Where legally permitted, BioTwin will attempt to notify affected users before or after disclosure so they may seek legal protection.
International Transfers and Data Localization
Your information may be processed and stored outside Quebec: elsewhere in Canada (for example in Microsoft Azure's Canada Central region, in Toronto), in the UAE, the United States, and other countries where BioTwin Group or our service providers operate. Authorities in those places may access it under their laws. Where cross-border transfers occur, we apply contractual and organizational safeguards appropriate to the sensitivity of the information. In some jurisdictions (including the UAE for certain health data contexts), additional localization or transfer restrictions may apply; we implement additional controls where required.
Your Rights and Choices
Depending on your jurisdiction, you may have rights to: access and obtain a copy of your information; correct inaccurate information; request deletion of your account and personal information; withdraw consent (which may limit certain features); object to or restrict certain processing; and data portability. Deletion requests remain subject to applicable legal, regulatory, scientific, laboratory, security, and data-integrity requirements. You may disconnect third-party apps/devices or adjust permissions. Where offered, you may manage document sharing and revoke access. You may opt out of marketing emails at any time. You can refuse audience measurement and advertising on our websites at any time with the cookies link at the bottom of our pages (see "Audience measurement, advertising and cookies"). To exercise rights, contact our Privacy Officer at dpo @ biotwin.ai.
AI, LLMs, Automation, and Simulations
Some BioTwin and TwinMe features use artificial intelligence, machine learning, automated processing, simulations, and large language model-powered tools to generate insights, recommendations, summaries, explanations, visualizations, conversational responses, support responses, or program-support outputs.
These outputs are provided for informational, educational, wellness, research, operational, or program-support purposes. They do not replace professional medical judgment. BioTwin does not provide medical diagnosis, treatment, cure, prevention, or emergency medical services through consumer-facing Services. Always consult a qualified healthcare professional for medical decisions.
BioTwin may use AI interaction data, prompts, responses, feedback, metadata, usage signals, safety signals, and related information to operate, secure, monitor, test, evaluate, improve, and develop AI-powered features and BioTwin proprietary systems, where permitted by applicable law and subject to appropriate safeguards.
BioTwin may use third-party AI infrastructure, cloud providers, model providers, or technical service providers to support AI-powered features. BioTwin requires service providers to process personal information only for authorized purposes, to apply appropriate safeguards, and not to use identifiable personal information or health data to train their general-purpose models unless you provide explicit consent or the data has been de-identified or anonymized in accordance with applicable law. Data received from Garmin is never sent to, or processed by, any third-party AI infrastructure or model provider: see "Garmin data".
BioTwin may use aggregated, anonymized, or de-identified data to improve services, conduct validation, perform research and development, develop models, create benchmarks, publish findings, and support commercial and scientific purposes, where permitted by law. BioTwin will not attempt to re-identify anonymized data except where permitted by law for security, compliance, validation of de-identification methods, or legal obligations.
AI outputs may be incomplete, inaccurate, biased, outdated, or unsuitable for your circumstances. You are responsible for reviewing outputs carefully and seeking professional advice before making health, medical, legal, financial, or safety decisions. If you believe an output is incorrect, unsafe, or harmful, contact BioTwin support.
Garmin data
When you connect your Garmin account, we receive your Garmin Connect™ data, such as sleep, daily activity, stress, heart rate variability, body composition and workouts. Notwithstanding anything else in this Policy, this data is handled as follows:
- It is used only to show you your own data in your private TwinMe dashboard and in the services you request.
- It stays linked to your account alone, and it is never sold.
- It is not shared with, processed by, or otherwise made available to any third party, including external AI providers, large language model providers, and other external AI or data processing services. It is never used to train an AI model.
- You can disconnect Garmin at any time from the Devices page. We delete your Garmin data on request: write to our Privacy Officer at dpo @ biotwin.ai.
Data Retention
BioTwin retains personal information for as long as necessary to provide the Services, maintain accounts, operate programs, process samples, deliver reports, comply with legal, regulatory, tax, accounting, laboratory, clinical, quality, audit, research, and contractual obligations, resolve disputes, enforce agreements, protect safety and security, prevent fraud, and preserve BioTwin's legal rights.
Retention periods vary depending on the type of information, the sensitivity of the data, the service used, the jurisdiction, the program, the consent, the laboratory or research requirements, and applicable law. BioTwin deletes or de-identifies personal information that no longer needs to be retained, subject to applicable legal, regulatory, scientific, laboratory, security, and data-integrity requirements.
Minors
Our Services are intended only for individuals who meet the minimum age, legal capacity, consent, and eligibility requirements that apply in their jurisdiction and to the specific Service, program, feature, contract, sample collection, laboratory activity, research activity, or data processing involved.
Some Services may be available only to individuals who are legally considered adults in their jurisdiction. Some Services may be available to minors only where permitted by law and only with the required consent, authorization, supervision, or program approval from a parent, legal guardian, tutor, healthcare provider, institution, or other authorized person.
BioTwin may require age verification, identity verification, parental or guardian consent, tutor consent, additional consent, or program-specific eligibility confirmation at any time. BioTwin may restrict, suspend, or refuse access to any Service where BioTwin determines that the user does not meet the applicable age, consent, identity, capacity, program, or legal requirements.
If we learn that we collected personal information from a minor without the required legal basis, BioTwin will take reasonable steps to delete, restrict, or regularize the information as required or permitted by law.
TwinMe partner program
Section added on October 1, 2026.
This section describes how BioTwin Canada Inc. handles personal information related to the TwinMe partner program and its portal, TwinMe Partners (partners.twinme.ai). BioTwin Canada Inc. is responsible for this information. This section details section 10 of the TwinMe Partner Commitment.
Who this covers:
- program partners (influencers, creators, ambassadors, agencies and other organizations) and the people who accept the commitment on their behalf;
- creators, employees or subcontractors that a partner agency or organization registers in the portal because they post for it, as well as members of an ambassador's team and collaborators a partner invites;
- prospective partners, that is, people whose public profile we note because we are considering inviting them, or because a partner or an agency suggested them to us.
What we collect, and where it comes from:
- From you, in the portal or by email: your name, contact details, social media accounts, organization and position; your GST and QST numbers, if applicable, the details where you receive your payments (for example the email address or phone number for your Interac e-Transfers) and your invoices; your regulated professional declaration, with the name of your professional order and your licence number if applicable; the photo and biography you give us for your partner page; your exchanges with us.
- When you accept the commitment: the version accepted and the digital fingerprint (SHA-256) of its text, the identifier of the portal release then in service, the commercial agreement then in force, the language chosen, the date and time, the name you type, your position, your organization, your account email, your answer on professional orders, your choice in the box on copies of your posts, your IP address and your browser.
- When you use the portal: your sign-ins (email, account identifier, date and time, sign-in method, IP address and browser) and your activity, for example the training modules you complete.
- From our sales systems: the sales attributed to you through your link, your code or your page, and your commissions. Each order is shown to you as an opaque number and an amount, never with a customer's name, contact details or results.
- From twinme.ai audience measurement: totals calculated by landing page and promo code from Google Analytics 4, for your live report.
- From public sources: your public posts about TwinMe, which we review to check their compliance and of which we keep a copy only if you consent, through an optional box at acceptance; for a prospective partner, what their public profile shows (platform, username, link, number of followers, content topic).
- From a partner or an agency: the name, public profile link and number of followers of a person they suggest to us, and the name of who suggested them; for a person attached to an agency, a member of an ambassador's team or a collaborator, the name, accounts and regulated professional declaration the partner registers after informing that person of this section and obtaining their consent.
We do not ask for any health information as part of the program and we do not note any in a prospective partner's record. If you use TwinMe yourself, your results remain governed by the rest of this Policy: we never use them for the program, and we never make them public, including by sharing a post in which you show them, without your express and separate consent.
Why we use it:
- to manage your participation: your account, your commercial agreement, your links and codes, your level, training and materials;
- to attribute sales, calculate and pay your commissions, and keep our books;
- to check that posts about TwinMe comply with the commitment, the partner guide and the law, and to prevent fraud, such as purchases made only to earn a commission;
- to present you as a partner on our pages and accounts, with your authorization, under sections 9.2 and 9.3 of the commitment;
- to keep evidence of your commitment and protect the security of the portal and of your accounts;
- for a prospective partner: to decide whether to invite them, and to contact them a first time;
- to meet our legal obligations, including tax obligations, and to assert our rights in a dispute.
Sales attribution is calculated automatically, under the rules of the partner guide. On request, we tell you what information was used, and the reasons and main factors behind the calculation. You can have that information corrected and submit your observations to a member of our team who can review the result.
When we contact a prospective partner, we identify ourselves, tell them where the information comes from (their public profile, or the name of the person who suggested them) and how to ask us to stop using their information to approach them.
Who can see it, and who we share it with: only BioTwin staff who need it for their duties can access it. We share it, to the extent necessary:
- with our service providers: Microsoft Azure, which hosts the portal application and its database in Canada; Google, which handles sign-in to the portal (Firebase Authentication, in the United States), delivery of its pages (Firebase Hosting, worldwide network) and twinme.ai audience measurement (Google Analytics, in the United States); Microsoft 365, for our email; Stripe, our order payment provider, which receives the partner code used for an order; and our Canadian bank, for Interac e-Transfers;
- with our professional advisers, such as our accountants and lawyers, and with authorities that require it, such as tax authorities;
- with the agency or organization that registered you, if you post for it: it sees in the portal the information in its portfolio, such as the sales and commissions attributed to it; with the ambassador or partner who invited you to their team or to collaborate: they see your attributed sales and your share, with your consent obtained at that time;
- with the public, only what you authorize us to publish: your name, username, image and biography on our partner pages and in our announcements, and your content about TwinMe, under the commitment.
We do not sell your information. We use your name, image or content in paid advertising only with your separate written agreement. Your partner page on twinme.ai is measured like the other pages of the site: its address, which may contain your name, is sent to the tools described in "Audience measurement, advertising and cookies". The TwinMe Partners portal itself uses only the storage needed for your sign-in: it loads no audience measurement tool and no advertising pixel.
Outside Quebec: the portal application and its database are hosted by Microsoft Azure in the Canada Central region, in Toronto, so in Canada but outside Quebec. Google processes your sign-in data in the United States, and the portal's pages go through its worldwide network of servers; other providers, such as Stripe, may also process information outside Canada. In those places, authorities may access the information under local laws. Before entrusting your information to a service provider outside Quebec, we assess the protection it will receive there and set it out in a written agreement.
How long: we keep your information for the duration of your commitment. After it ends, we keep only the following, then destroy or anonymize it securely:
- your tax and payment information, invoices, attributed sales, commissions, and the commitment and its acceptance data: 6 years after the end of the fiscal year of the last payment, as tax laws require, or, if no payment was made, 3 years after the commitment ends;
- other information: no more than 3 years after the commitment ends, the period during which legal action remains possible;
- information used to make a decision about you, such as a refused commission or the end of the commitment: at least one year after the decision;
- what is needed to settle a dispute: until it is settled.
Shorter periods apply:
- your sign-ins to the portal: 12 months;
- your presentation on our partner pages: removed within 30 days after the commitment ends or you withdraw your authorization;
- notes about a prospective partner who does not join the program: 12 months after the last exchange. If they ask us not to contact them again, we keep only their username, to respect that choice.
Your rights: you may ask to see your information and receive a copy of it, including, for the information you provided, in a structured, commonly used technological format; have it corrected if it is inaccurate, incomplete or ambiguous; withdraw a consent, for example your authorization to be presented on our partner pages or your consent to copies of your posts (if you withdraw information needed for your payment, however, we will no longer be able to pay you); and ask us to stop disseminating information about you or to de-index a link that leads to it, in the cases provided by law. A prospective partner may also find out where the information we hold about them comes from, ask us not to contact them again and have our notes deleted. We reply in writing within 30 days.
Person in charge: to exercise these rights or ask a question, write to our Privacy Officer, Louis-Philippe Noel, General Manager, at dpo @ biotwin.ai, or by mail at the address shown in "Contact". If you reside in Québec, you may also contact the Commission d'accès à l'information du Québec (cai.gouv.qc.ca); elsewhere in Canada, the Office of the Privacy Commissioner of Canada (priv.gc.ca).
Changes to This Policy
We may update this Policy from time to time to reflect changes in our Services, practices, or legal requirements. The updated Policy becomes effective when posted, unless otherwise stated. Where required, we may provide additional notice.
Regional Addenda
Canada and Quebec: Users may have rights to access, correct, withdraw consent, request deletion, obtain information about automated processing, and ask questions about the governance of personal information. Quebec privacy rules may impose additional transparency, consent, retention, cross-border transfer, incident, and privacy-impact-assessment obligations.
United States: Depending on your state, you may have rights to access, delete, correct, port, appeal, withdraw consent, restrict certain processing, or opt out of certain uses or disclosures. Health-related data may be regulated under consumer health data laws, genetic privacy laws, biometric privacy laws, and state privacy laws. BioTwin does not send your questionnaire answers, your results, your genetic data, or the contents of your record to any advertising platform, and does not sell such data. You can object at any time to the transfer of data to Meta for advertising, described in "Audience measurement, advertising and cookies", with the cookies link at the bottom of our pages or the Global Privacy Control signal, which biotwin.ai and twinme.ai honor. BioTwin will provide additional notices or consent flows where required.
Washington and other consumer health data jurisdictions: If applicable, users may have rights relating to consumer health data, including access, deletion, withdrawal of consent, and information about categories of third parties or affiliates with whom consumer health data is shared. BioTwin will honor applicable consumer health data rights as required by law.
United Arab Emirates: UAE health-data laws and localization rules may restrict processing and cross-border transfers. For UAE users or UAE programs, BioTwin may apply UAE-based infrastructure, local hosting, additional transfer controls, or other safeguards where required.
EEA, UK, and Switzerland: GDPR, UK GDPR, and Swiss data protection rights may apply where relevant, including rights of access, correction, deletion, restriction, objection, portability, withdrawal of consent, and complaint to a supervisory authority. Sensitive data, including health and genetic data, receives enhanced protection.
Other jurisdictions: Local privacy, consumer protection, health, research, laboratory, medical device, AI, and data-transfer laws may apply depending on the user, program, feature, entity, and country.
Contact
Privacy Officer: Louis-Philippe Noel, General Manager.
Email: dpo @ biotwin.ai
Postal address: BioTwin Canada Inc., 1405, boulevard du Parc-Technologique, Québec (Québec) G1P 4P5 Canada.
If you reside in Québec, you may also file a complaint with the Commission d'accès à l'information du Québec (cai.gouv.qc.ca).
Terms of Use
Welcome to TwinMe and BioTwin (including the BioTwin Portal and provider programs) (collectively, the "Platform"). These Terms of Use (the "Agreement") form a binding agreement between you ("User") and the BioTwin entity that provides the Platform and related services to you (the "Operating Company").
Corporate Structure and Branding:
- BioTwin Holding International ("BioTwin Holding") is the parent company of BioTwin operating entities.
- BioTwin Holding owns BioTwin Canada Inc. (Canada) and BioTwin Limited (UAE), and may establish additional operating entities in the future (for example, BioTwin USA).
- TwinMe is a non-medical brand owned by BioTwin Holding and licensed to BioTwin operating entities for use in connection with the Platform.
- When we say "BioTwin", "we", "us" or "our" in this Agreement, we mean the Operating Company and, where relevant, BioTwin Holding and its affiliates (the "BioTwin Group").
By creating a User Account or using our Platform, you acknowledge you have read and accept this Agreement and all policies referenced herein. If you do not agree, do not use our Platform.
1. Acceptance and Eligibility
Acceptance: By registering for an account, ordering a Sample Collection Kit, uploading data, using any Service or clicking an acceptance checkbox, you agree to be bound by this Agreement and our Privacy Policy.
Age, Capacity, and Location: You may use the Platform only if you meet the minimum age, legal capacity, consent, identity, and eligibility requirements that apply to you, your jurisdiction, and the specific Service you use. Some Services may be available only to individuals who are legally considered adults in their jurisdiction. Some Services may be available to minors only where permitted by law and only with the required consent, authorization, supervision, or program approval from a parent, legal guardian, tutor, healthcare provider, institution, or other authorized person. BioTwin may require age verification, identity verification, parental or guardian consent, tutor consent, additional consent, or program-specific eligibility confirmation at any time.
IMPORTANT: The Platform provides lifestyle, wellness and health-related information but does not provide medical advice and is not a medical device or substitute for care. The Services are offered for informational and educational purposes only and are not intended to diagnose, treat or cure any disease.
2. Permitted and Prohibited Use
You may use the Platform solely for lawful, personal, non-commercial purposes in accordance with this Agreement. You may not: use the Platform to harass, threaten, defame, violate privacy or otherwise harm others; upload or transmit unlawful or harmful material; attempt to gain unauthorized access to BioTwin's systems; or use the Platform to provide medical diagnosis or treatment to another person.
You may not use the Platform or AI features to make medical, emergency, legal, financial, employment, insurance, eligibility, or similarly significant decisions about another person. You may not use the Platform to reverse engineer BioTwin systems, extract model outputs at scale, train competing models, scrape data, bypass safety controls, generate harmful content, or attempt to identify individuals from aggregated, anonymized, or de-identified data.
3. User Accounts and Security
To access most Services, you must create a User Account and provide accurate, current and complete information. You are responsible for maintaining the confidentiality of your credentials and for any activities under your account.
4. Services
4.1 Virtual Twin Creation: You may create a Virtual Twin by completing online questionnaires about your health history, lifestyle and habits. The resulting scores are for informational purposes only.
4.2 Sample Collection and Analysis: BioTwin may offer Sample Collection Kits for collecting biological samples. By submitting a sample, you authorize BioTwin to process your sample and acknowledge that results are intended for wellness monitoring and are not diagnostic.
4.3 Third-Party Devices: You may link third-party health and wellness devices to your account. BioTwin is not responsible for the devices' functionality.
4.4 AI Tools, LLM Features, and Simulations: BioTwin's Platform may include artificial-intelligence tools, machine-learning tools, large language model-powered features, chatbots, conversational assistants, simulations, visualizations, aging metrics, recommendations, summaries, and other automated features. These tools are experimental, may change over time, and are provided for informational, educational, wellness, research, operational, or program-support purposes only. They are not medical devices, do not provide medical diagnosis or treatment, and do not replace professional medical judgment. You must not rely on AI outputs for emergency, medical, legal, financial, or safety-critical decisions. Always consult a qualified healthcare professional for health or medical decisions.
4.5 Research Projects: BioTwin may invite you to participate in research projects. Participation is voluntary. You may withdraw at any time.
4.6 Portal and Provider Programs: BioTwin may provide a portal, dashboards, reports, and other features intended for use by healthcare providers, clinics, wellness professionals, employers, or other partner organizations.
4.7 TwinMe Monthly Subscription: The TwinMe subscription costs CA$9.95 per month, plus applicable taxes. It renews automatically each month until cancelled. You may cancel at any time. After cancellation, paid access remains active until the end of the period already paid, and no new payment will be charged.
BioTwin may change the subscription price by giving reasonable advance notice before the new price takes effect. BioTwin may suspend or terminate paid TwinMe access for non-payment, fraud, abuse, or breach of this Agreement.
When the subscription ends, access to paid TwinMe features ends. Ending the subscription does not by itself delete your account or personal information. Your account and personal information continue to be handled under the Privacy Policy, and you may request deletion of your account and personal information as described in that Policy. BioTwin deletes or de-identifies personal information that no longer needs to be retained, subject to applicable legal, regulatory, scientific, laboratory, security, and data-integrity requirements.
If a BioTwin program includes a period of TwinMe access, that included period applies first. No paid TwinMe subscription is required before the included period ends.
4.8 TwinMe Partner Program: The TwinMe partner program and the TwinMe Partners portal are governed by the TwinMe Partner Commitment, which each partner accepts in the portal. For that program, the commitment prevails over this Agreement in case of conflict, including as to the commercial use of the portal and of the materials provided.
5. Privacy and Data Use
BioTwin is committed to protecting your privacy. Personal information collected through the Platform is handled in compliance with applicable privacy and health-data laws. Key principles include: consent, purpose specification, data security, disclosure and cross-border transfer protections, data retention and disposal, accuracy and access rights, breach notification, and responsible AI data use.
5A. User Content, Data Rights, and AI Inputs
You retain ownership of personal information and content you submit to the Platform, subject to BioTwin's rights under this Agreement, the Privacy Policy, applicable consents, and applicable law.
You grant BioTwin and the BioTwin Group a worldwide, non-exclusive, transferable, sublicensable, royalty-free license to host, store, process, reproduce, modify, analyze, translate, create derivative technical outputs from, display, transmit, and otherwise use your submitted content, personal information, samples, results, prompts, feedback, uploaded files, and related data as necessary or appropriate to provide, operate, secure, support, maintain, improve, test, validate, develop, and enforce the Platform and Services, to comply with law, and to protect BioTwin's rights, users, partners, and systems.
Where permitted by law, BioTwin may use aggregated, anonymized, or de-identified data for research, validation, publication, analytics, product development, AI development, model development, benchmarking, commercial, scientific, security, and business purposes. BioTwin may retain and use such data even after your account is closed, where permitted by law.
You must not submit information about another person unless you have the legal right and required consent to do so. You must not submit unlawful, harmful, misleading, infringing, or unsafe content. You are responsible for the accuracy and legality of information you provide.
6. Intellectual Property
The Platform and its content are owned by BioTwin or our licensors and are protected by copyright and other intellectual-property laws. You receive a limited, revocable license to access and use the Platform for personal, non-commercial purposes.
7. Disclaimers
No Medical Advice: The Platform is provided for informational purposes only. BioTwin does not provide medical advice. Always consult a licensed healthcare professional.
No Warranties: The Platform is provided "as is" and "as available." We do not warrant that the Platform will be uninterrupted, error-free or free of viruses.
Limitations of Liability: To the maximum extent permitted by law, BioTwin will not be liable for any indirect, special, incidental, consequential or punitive damages.
7A. AI Output Disclaimer
AI outputs may be inaccurate, incomplete, biased, outdated, unsafe, or unsuitable for your personal circumstances. BioTwin does not guarantee that AI outputs are correct, complete, current, or appropriate. You are responsible for reviewing and verifying outputs before using them. BioTwin is not responsible for decisions you make based on AI outputs, except where liability cannot be excluded under applicable law.
8. Indemnification
You agree to indemnify and hold harmless BioTwin and its affiliates from any claims, damages or expenses arising out of your use of the Platform or your violation of this Agreement.
9. Changes to Terms
BioTwin may update this Agreement at any time. Except for TwinMe subscription price changes governed by Section 4.7, changes are effective upon posting on the Platform. Your continued use constitutes acceptance of the updated Agreement.
10. Termination
BioTwin may terminate or suspend your access to the Platform for non-payment, fraud, abuse, breach of this Agreement, or where required by law. Upon termination, your license to use the Platform ceases.
11. Governing Law
This Agreement is governed by the laws of the Operating Company providing the Services to you:
- BioTwin Canada Inc.: Laws of the Province of Québec and the federal laws of Canada; courts located in Montréal, Québec.
- BioTwin Limited (UAE): Laws of the United Arab Emirates as applied in the Emirate where the Operating Company is established.
- BioTwin USA (when established): Laws and forum specified at the time the Services are offered.
12. Contact Information
For questions about these Terms of Use, please contact:
Email: dpo @ biotwin.ai
Registered Addresses:
- BioTwin Canada Inc.: 1405, boulevard du Parc-Technologique, Québec (Québec) G1P 4P5 Canada
- BioTwin Limited (UAE): Al Khatem Tower - 15th Floor - Al Maryah Island - Abu Dhabi Global Market Square - Abu Dhabi - United Arab Emirates
- BioTwin Holding International: 1405, boulevard du Parc-Technologique, Québec (Québec) G1P 4P5 Canada
13. Jurisdiction-Specific Terms
13.1 Users in the United States: Certain U.S. state laws regulate consumer health data. BioTwin will provide clear disclosures and obtain appropriate consent. BioTwin is not a healthcare provider.
13.2 Users in the United Arab Emirates: UAE health-data laws may restrict cross-border transfers. For UAE Users, BioTwin will store and process health data in UAE-based infrastructure by default.
13.3 Users in Other Jurisdictions: You are responsible for complying with local laws. Nothing in this Agreement limits any non-waivable consumer rights you may have under applicable law.
Cookie Policy
BioTwin and TwinMe use cookies, pixels, SDKs, local storage, tags, analytics tools, and similar technologies to operate our websites, applications, portals, and Services.
Types of Technologies We Use
- Strictly necessary technologies: required for login, security, fraud prevention, account management, cart functionality, consent management, and service operation.
- Functional technologies: used to remember preferences, language, session settings, and user choices.
- Analytics technologies: used to understand usage, performance, errors, navigation, and service quality.
- Security technologies: used to detect abuse, protect accounts, prevent fraud, investigate incidents, and maintain service integrity.
- Marketing technologies: used to measure our campaigns and deliver our advertising, including the Meta pixel described in "Audience measurement, advertising and cookies" below.
BioTwin does not send your questionnaire answers, your results, your genetic data, or the contents of your record to any advertising platform: no advertising tool loads on the pages that collect or display them. Our websites do, however, use the Meta advertising pixel by default: it can send Meta the address of the pages you view, and a paid purchase is reported to Meta with your hashed order details. The "Audience measurement, advertising and cookies" section below describes these transfers and how to refuse them.
You can manage cookies through browser settings, device settings, consent tools, and opt-out mechanisms we provide where required. Disabling certain technologies may prevent some Services from working correctly.
Audience measurement, advertising and cookies
Section updated on September 29, 2026.
In short: on biotwin.ai and twinme.ai (TwinMe, powered by BioTwin), four tools measure visits and our advertising: Google Analytics 4, Hotjar, the Meta pixel and Meta Conversions API, and our own journey measurement. They are active by default from your first visit; no banner asks for your agreement first. None of them receives your questionnaire answers or your results. You can refuse them at any time with the cookies link at the bottom of our pages, as explained below.
- Google Analytics 4 (Google LLC, United States) counts page views and purchase steps. It receives the page address, from which we remove every parameter except campaign (utm) parameters, the site you came from, the products and amount of an order, information about your device, and an approximate location that Google derives from your IP address. It sets the _ga cookie, which holds a random measurement identifier. That identifier can follow your visit from one of our websites to another, and it is sent to our server with an order so that the visit can be linked to the purchase. Our code tells Google not to use these measurements for advertising.
- Hotjar (Hotjar Ltd, Malta; data hosted in the European Union) produces click and scroll maps and visit recordings: pages viewed, clicks, mouse movements, scrolling, and device type, with a random identifier kept in a cookie. What you type into form fields is masked. Hotjar never runs on the cart or the checkout.
- Meta pixel and Meta Conversions API (Meta Platforms, Inc., United States): they tell Meta (Facebook, Instagram) which visits and purchases came from our ads, and Meta uses them to deliver and measure those ads. The events sent are page view, product view, add to cart, information request, checkout start, purchase, subscription, and account creation. Their parameters are limited to the amount, currency, content type, and number of items, never a program name. Because the pixel runs in your browser, Meta also receives the address of the page you visit, which can reveal the program or topic you are viewing, the address of the previous page, your IP address, information about your browser, and its _fbp and _fbc cookies. Meta may link this data to your Facebook or Instagram account. The pixel also uses Meta's automatic advanced matching: on the pages where it runs, including the cart and checkout, it may read the contact details you enter in a form (email, phone, first and last name, city, province, postal code, country and, when requested, date of birth and gender), convert them into hashed values in your browser, and send them to Meta to link the visit to an account. Our server also receives each event and forwards it to Meta with its identifier, the amount, the currency, your IP address, your browser, the _fbp and _fbc cookies, and only the site's domain name, never the page address.
- Purchases, account creation, and Meta forms: if you had not refused Meta advertising when you went through checkout, our server reports your paid order to Meta (purchase, and subscription where applicable) with the amount paid and your hashed (SHA-256) order details: email, phone, first name, last name, city, province, postal code, and country. If you then create your TwinMe account, it reports the account creation with your email, your country, and your account identifier, also hashed. Meta does not receive these details in readable form, but it can compare them with those of its own users to learn which ads led to a purchase. If you fill in a TwinMe form on Facebook or Instagram, Meta sends us your answers, and we may tell Meta, using your request identifier and your hashed email and phone, that the request was qualified or led to a purchase.
- Our own journey measurement (BioTwin) records each page view: the page address without its parameters, where you came from (campaign parameters, whether a Facebook or Google click identifier is present, without its value, and the site you came from), device, operating system, and browser type, screen size, language, clicks (position, element clicked, text of our own links and buttons, link address and product chosen), scrolling, active time, and checkout steps with their amount. It sets no cookie: a random visit identifier stays in the browser tab and is renewed after 30 minutes of inactivity. Your IP address is not kept: it is used only on the same day to filter out bots, in the form of a fingerprint whose key changes every day and is never recorded. This data is hosted for BioTwin by Microsoft Azure in Canada (Canada Central region) and deleted after 395 days; it is not sent to any advertising platform. Since September 24, 2026, it also measures the time spent on each part of the page, how fast the page displays, a few gestures (scrolling back up, zooming, copying text, switching to another app and coming back) and, in a form, the name of the fields you touch, the time spent and the number of corrections, never their content. It also records a replay of the visit: what is shown on screen, scrolling, and taps. Everything you type is replaced with dots in your browser before anything is sent, as are email addresses, phone numbers, and postal codes shown on the page. This replay never runs on the cart or the checkout, and it is deleted after 30 days. On twinme.ai analysis pages, a question may appear ("What makes you hesitate today?"): you answer with one tap among the proposed choices, or close it. The answer is recorded without your name or address.
What is never measured: the Meta pixel, Hotjar, and our own measurement never load on questionnaire and quiz pages, results pages, sign-in, registration, and account pages, private pages, or the checkout embedded in a partner's website. Google Analytics may measure the visit there (page address and title and, in a checkout, the purchase steps), never your answers or your results. Hotjar masks what you type and our own measurement never reads the content of a field. The Meta pixel reads only the contact details described above, as hashed values, never your questionnaire answers or your results.
Refusing, at any time: the cookies link at the bottom of biotwin.ai and twinme.ai pages ("Cookies" or "Manage my cookies") opens your settings, as does the "Privacy preferences" button shown at the bottom right of the screen on your first visit. Uncheck Google Analytics, Hotjar, or Meta advertising, then choose "Save choices": the refused tool stops at once and its cookies are deleted. Our own measurement stops when you refuse both Google Analytics and Hotjar. The visit replay stops as soon as you refuse Hotjar, or with the Global Privacy Control signal. Your choice is stored in your browser, for that website only: make it on biotwin.ai and on twinme.ai, and on each device you use. It remains in effect until the site's data is cleared from your browser; some browsers clear it on their own after a period without a visit. A refusal recorded before Meta advertising was added, on September 22, 2026, covers Google Analytics and Hotjar but not Meta advertising: to refuse it, open your settings again. Your browser's Global Privacy Control signal is honored: it blocks Google Analytics, Hotjar, and the Meta pixel with no further step, but not our own measurement, which does not leave BioTwin. On this page, you can open your settings for biotwin.ai.
Where this data goes and for how long: Google and Meta process what they receive under their own privacy policies, including in the United States, and therefore outside Quebec and Canada. Hotjar hosts its data in the European Union. Our own measurement, the server that relays events to Meta, and the copy of those events it keeps are hosted for BioTwin by Microsoft Azure in Canada. In your browser: _ga cookie, up to 2 years; _fbp and _fbc cookies, 90 days; Hotjar cookies, up to 1 year; our measurement's visit identifier, up to 30 minutes of inactivity. A note that the question "What makes you hesitate today?" was already asked: 30 days. Our own measurement data: 395 days; visit replays: 30 days.
The portal.twinme.ai portal: Google Analytics and Hotjar load there only after you agree, in the portal's cookie settings ("Manage cookies" link at the bottom of its pages). The portal loads no advertising pixel, and our own journey measurement does not run there. If you accept Hotjar there, it may record the portal pages you view, including those that display your results.
Strictly necessary storage, without consent: language, cart, payment attempt identifier (7 days), portal sign-in session, and a record of your cookie choices.
Arrival parameters: when you submit a form, create an account, or place an order, we attach to that request the parameters you arrived with on our sites: source, medium and campaign name, advertising click identifier, referring site, entry page, partner or referral code, language, and device type. These parameters stay in your browser's local storage for at most 90 days. They are used to handle your order, to measure our campaigns, and to calculate our partners' commissions. For an order, they are also written into the transaction metadata at Stripe, our payment provider. Meta's advertising click identifier may also accompany the events sent to Meta described above.
Partner websites: when you reach us from a partner's website, that website measures its own page with our tool and passes us the measurement identifier, so that your visit and your purchase form a single journey rather than two. The privacy notice and the consent choice of that partner then govern its page, as our integration guide provides.
Partners and influencers: they receive only totals and opaque order numbers, never your name, your email, or your results.
Other retention periods: campaign parameters in your browser, 90 days; unpaid order attempts, 90 days then anonymisation; contact requests that did not convert, 12 months after the last exchange; consent evidence, 3 years after it is withdrawn.
To exercise your rights, withdraw your agreement, or ask a question about this measurement: dpo@biotwin.ai.