Policies

In plain language

Our policies, in a few lines

Your health data is the most personal information there is. Here is what our policies say, in simple words: what you share with us, what we do with it, and the choices you keep.

What you share with us

What you choose to give us: your account details, your questionnaire answers, your kit and its results, and the apps or documents you decide to connect. Plus the technical information every website needs to work. For the TwinMe partner program, we also note information taken from public profiles or provided by a partner or an agency.

Full text: Privacy policy

What we use it for

To build your virtual twin, analyze your sample, deliver your results and support you along the way. Where the law allows, also to improve our services, with the safeguards the policy describes.

Full text: Privacy policy

What we never do

We do not sell your personal information. Your answers, your results, your genetic data and the contents of your record are never sent to an advertising platform. Outside AI providers may not use your identifiable health data to train their general models without your explicit consent. Data from your Garmin account is never shared with a third party or an outside AI provider.

Full text: Privacy policy

Who else sees it

The partners who help us provide the service (for example the laboratory, hosting, payment and delivery), the people you choose to share with, and the authorities when the law requires it. Our websites also use audience measurement and advertising tools from Google, Hotjar and Meta, which you can refuse at any time.

Full text: Audience measurement, advertising and cookies

Your choices

Depending on where you live, you can access, correct, download or delete your information, withdraw your consent and unsubscribe from our emails. The cookies link at the bottom of every page opens your settings, where you can refuse measurement and advertising. Questions: dpo@biotwin.ai.

Full text: Privacy policy

How we protect it

Encryption, restricted access, monitoring and strict contracts with our partners. For research, we use de-identified or aggregated data whenever appropriate.

Full text: Data & Security

Your order

Changed your mind? Cancel within 24 hours for a full refund. After that and before shipping, we refund what you paid minus the costs already incurred. Once a kit has shipped, it can no longer be refunded; if you stop a prepaid formula, the kits already shipped are counted at the regular price and the rest is refunded, minus those costs. Write to go@biotwin.ai.

Full text: Returns, cancellations & refunds

What TwinMe is, and is not

TwinMe helps you understand your biology and take care of your well-being. It is not a diagnosis, not medical advice and not a substitute for your healthcare professional. Your subscription can be cancelled at any time.

Full text: Terms of Use

This summary is here to help you find your way. It does not replace the full policies below, which remain the reference: we encourage you to read them.

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:

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:

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:

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:

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:

What we collect, and where it comes from:

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:

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:

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:

Shorter periods apply:

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:

12. Contact Information

For questions about these Terms of Use, please contact:

Email: dpo @ biotwin.ai

Registered Addresses:

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.

Returns, cancellations & refunds

Effective August 29, 2026. Section 4 (prepaid formulas) added on September 30, 2026. This policy applies to orders and kits sold by BioTwin and TwinMe.

1. Within 24 hours after the order

You may cancel an order within 24 hours after placing it and receive a full refund.

2. After 24 hours and before shipment

After 24 hours and before the order or kit is shipped, any refund equals the amount paid less costs already incurred and non-recoverable, including credit-card fees, payment-processing fees, handling fees, preparation costs, and other reasonable costs incurred to process the order.

3. Once the order or kit has shipped

Once the order or kit has shipped, no refund is available for it. Prepaid formulas follow section 4.

4. Prepaid formulas

A prepaid formula, such as 4 or 12 kits paid upfront, is paid in full when you order, and its kits are shipped over time.

5. Refund requests

Send your request to go@biotwin.ai, with your order number and the reason for your request. We commit to:

6. How to reach us

BioTwin / TwinMe Customer Service
Email: go@biotwin.ai

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

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.

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.

Data & Security

BioTwin applies technical, organizational, contractual, and administrative safeguards designed to protect personal information, especially health data, genetic data, biometric data, samples, AI interaction data, and other sensitive information.

Safeguards may include encryption in transit, encryption at rest where appropriate, access controls, role-based permissions, authentication, logging, monitoring, network security, vulnerability management, vendor review, contractual restrictions, personnel training, privacy-by-design practices, data minimization, pseudonymization, de-identification, anonymization, backup controls, and incident response processes.

BioTwin limits access to sensitive information to personnel, affiliates, providers, contractors, laboratories, and service providers who need access for authorized purposes. BioTwin requires service providers to apply safeguards appropriate to the sensitivity of the information and to process personal information only for authorized purposes.

No system can be guaranteed to be completely secure. Users are responsible for protecting their credentials, using secure devices, and promptly notifying BioTwin of suspected unauthorized access.

BioTwin may update security measures as threats, technologies, legal requirements, and Services evolve.

Data philosophy & ethics

BioTwin understands the power of AI and the significance of health data. We consider health data to be the most personal type of data there is, and hold ourselves accountable to very strict data management policies.

Privacy-protective data design

We believe health data deserves strong protection. Some Services require identifiable information to operate, including account management, sample processing, support, billing, personalization, provider programs, research programs, and report delivery. Where appropriate and permitted by law, BioTwin uses minimization, pseudonymization, de-identification, aggregation, anonymization, access controls, and contractual safeguards to reduce privacy risk.

Our business model and collaborations are designed to limit unnecessary identification and unnecessary disclosure. When BioTwin uses data for research, validation, analytics, AI development, or model development, BioTwin uses aggregated, anonymized, or de-identified data where appropriate and legally permitted.

Key principles

Fully accountable

We are responsible for our platform, solutions and your data. If we use third party solutions or services, or collaborate with partners, we make sure there are no grey areas so we always know who is in charge.

Security-first

Our platform is built and tested to prevent possible misuse and to ensure the highest level of security.

Transparent for all

We aim for transparency by making our processes and operations clear and easy to understand for partners, customers, end-users and other stakeholders, following industry best practices.

Fairness

We believe in fairness in gender diversity and racial equality. Fairness is applied through the selection of dataset and algorithms, and biases are corrected as soon as detected.

Contact

If you have any questions regarding our policies, we encourage you to reach out to our Privacy Officer.

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).

Last updated: October 1, 2026