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BioTwin

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. For a change of mind, a kit that has already shipped cannot 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.

These rules concern a change of mind. A defective kit or unusable sample may be replaced free of kit charges; any shipping charge is disclosed before your agreement, subject to your statutory warranties.

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 and data protection at BioTwin

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 update this Policy when our practices, services or legal requirements change. Each version is dated and the previous version remains accessible. For a material change, we notify you by email and in the portal at least 30 days before it takes effect, or earlier where required by law, explaining what changes and your choices.

A minor correction may take effect on publication. A legal requirement or immediate security risk may justify a shorter period where permitted by law; we notify you as soon as possible. If your consent is required for a new use or disclosure, we ask for it before making that change. Your silence or continued use of the service alone does not replace that consent.

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

These Terms of Use (the “Agreement”) govern your use of TwinMe and BioTwin, including their portals and services (the “Platform”). Your contract is with the entity providing the service to you (the “Operating Company”):

  • Canada: BioTwin Canada Inc.
  • United States: BioTwin Canada Inc. A U.S. company is planned; it will only become your contracting party once its incorporation is confirmed and its identity and applicable terms have been provided to you.
  • United Arab Emirates: BIOTWIN LIMITED.
  • For another country, ask go@biotwin.ai to confirm which entity will provide your service before purchasing.

The contracting entity is identified above for your market. A change of entity does not reduce your rights and is subject to notice and, where required, your agreement. TwinMe is a BioTwin group brand. In these Terms, “we” means the Operating Company; other group entities act only in the roles described in the policies or offer applicable to you.

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 at least 30 days' notice before the new price takes effect, subject to more protective local rules and section 9. 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 the rights you hold in the content you provide. These Terms do not transfer ownership of your personal information to BioTwin or reduce your rights in it.

You authorize us to host, reproduce, process, analyze and display your content to the extent needed to provide, secure and support the service. When another group entity or service provider assists us, its access is limited to its role and governed by applicable obligations. This authorization does not permit that provider to use your data independently.

Other uses, including service improvement, validation, research and model development, are those described in the Privacy Policy, within the limits of applicable law and required consents. This clause does not grant blanket or unlimited permission and does not replace separate consent. The Policy governs aggregated, de-identified or anonymized data, retention and AI providers.

You may provide information about another person only if you have the right and necessary authorizations to do so. You are responsible for providing lawful content and information that is accurate to your knowledge.

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.

Availability: we work to keep the Platform operating properly, but interruptions, maintenance or errors may occur. We do not promise uninterrupted or error-free service.

Your statutory warranties: nothing in these Terms excludes any warranty, refund, remedy or liability that the law does not allow us to exclude. Limitations of liability apply only to the extent permitted by law and do not allow BioTwin to set aside its legal obligations to you.

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

To the extent permitted by law, you are responsible for direct losses resulting from unlawful or wrongful use of the Platform attributable to you. This clause does not require you to cover BioTwin's own fault, claims arising from normal use of the service or liability that the law does not allow us to transfer to you.

9. Changes to Terms

We may amend provisions about service operation, subscriptions and prices, use of the Platform or our contact details to reflect changes in our services or legal requirements, within the limits allowed by law. We notify you by email and a notice in the portal at least 30 days before a material change, or earlier where required by law. The notice identifies the provisions being changed, the previous and new wording, the effective date and your options to refuse or terminate. Dated versions remain available.

You may refuse a change that increases your obligations or reduces ours and end the affected service without penalty where the law provides that right. The notice explains the procedure and applicable deadlines. Any refunds and other remedies provided by law remain available. We obtain your express acceptance where required.

A correction without a material effect on your rights may take effect on publication. An urgent change needed to comply with a legal obligation or address an immediate security risk may take effect sooner, only to the extent permitted by law; we explain the reason and notify you as soon as possible. A change to the Terms does not constitute consent to a new purpose for processing your information.

Previous version dated October 1, 2026.

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

If your contract is with BioTwin Canada Inc., the laws of Quebec and applicable federal laws of Canada govern these Terms. For BIOTWIN LIMITED, the governing law is that of the jurisdiction where the company is established, subject to applicable mandatory provisions. For any other entity, the governing law is stated in the offer before you commit.

These choices do not deprive you of mandatory consumer protections in your place of residence. You retain access to the competent courts and authorities provided by law, including a court where you reside when the law permits. These Terms do not impose mandatory arbitration or waive any class action or other remedy protected by law.

To raise a dispute with us, email go@biotwin.ai. We will work with you to find a solution. This support process is not a prerequisite to exercising your legal remedies.

12. Contact Information

For questions about your account, an order, a subscription, a refund, a kit or a complaint, contact go@biotwin.ai. To exercise your information rights or ask a privacy question, use dpo@biotwin.ai; the privacy officer's details are in the Privacy Policy.

  • 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.

Returns, cancellations & refunds

Cancellation rules effective August 29, 2026; prepaid plans clarified September 30, 2026; warranties and support clarified October 4, 2026. This policy applies to orders, kits and prepaid plans sold by BioTwin and TwinMe. The change-of-mind rules below do not limit your rights for defects, non-conformity or a service not provided, or any other mandatory legal rights.

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

For a change of mind, a kit that has already shipped is not refundable. Prepaid plans follow their dedicated section. A defective kit, unusable sample or service not provided is covered by the support described below and your statutory warranties.

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.

  • Until the first kit ships, sections 1 and 2 apply to the whole formula.
  • Once the first kit has shipped, kits already shipped are not refundable and are counted at the regular price of a single kit, without the prepaid discount. The rest of the amount paid, if any, is refunded, less the costs described in section 2.

4A. Defective kit or unusable sample

Contact go@biotwin.ai if your kit is defective, you have a collection problem or your sample is insufficient or unusable. We help you find a solution and replace a defective kit, or the kit needed for recollection when a sample is unusable, free of kit charges. Shipping charges may apply case by case; we tell you the amount before asking for your agreement. No charge is imposed where the law requires a remedy at no cost.

If the service cannot be provided, we explain the available solutions and apply any refunds and remedies required by law. This support does not reduce your statutory warranties.

5. Refund requests

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

  • responding within 5 business days
  • processing approved refunds within 10 business days, on the original payment method used

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

  • 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.

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 us

Customer service, orders and commercial policies: go@biotwin.ai.

Personal information and privacy: dpo@biotwin.ai. Our person responsible for the protection of personal information is Louis-Philippe Noel, Chief Executive Officer. Mailing address: BioTwin Canada Inc., 1405, boulevard du Parc-Technologique, Québec (Québec) G1P 4P5, Canada.

For a privacy complaint in Quebec, you may also contact the Commission d'accès à l'information du Québec.

Last updated: October 4, 2026

October 4, 2026 clarifications: contracting entities, advance notice, data rights, warranties and support. The prices, billing frequency and renewal terms described in section 4.7 are unchanged. Previous version dated October 1, 2026.