Policies

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.).

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 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 use identifiable personal health information or identifiable genetic data for targeted advertising. We do not sell personal information as that term is commonly understood. Where a law defines “sale” or “sharing” more broadly, we will provide required notices, rights, and opt-out mechanisms.

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.

How We Disclose Information

We may disclose personal information as described below:

• Within the BioTwin Group for administration, service delivery, support, security, compliance, research and development, business operations, and governance.
• To service providers and processors, including cloud hosting, security, analytics, AI infrastructure, LLM infrastructure, customer support, payment, logistics, laboratory, communications, identity verification, and technical providers.
• To laboratories, logistics partners, sample collection partners, healthcare providers, wellness professionals, clinics, and medical-adjacent providers when needed to deliver a service, process a sample, validate a result, manage a program, or comply with applicable requirements.
• To provider programs, employer programs, research programs, partner programs, or authorized recipients when you consent, direct us to share data, or participate in a program that includes data sharing.
• To research and development partners using aggregated, anonymized, or de-identified data where permitted by law, or identifiable data where you consent or another legal basis applies.
• To professional advisors, insurers, auditors, banks, legal counsel, and consultants where necessary for business, legal, compliance, audit, insurance, or risk-management purposes.
• To authorities, courts, regulators, law enforcement, or private parties when required or permitted by law, or when necessary to protect rights, safety, security, users, services, or property.
• In connection with an actual or proposed business transaction, financing, merger, acquisition, reorganization, sale of assets, bankruptcy, due diligence, investment, transfer, or corporate change, subject to appropriate safeguards.

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.

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 information it determines is legally required or appropriate under the circumstances. Where legally permitted, BioTwin will attempt to notify affected users before or after disclosure so they may seek legal protection.

Nothing in this section limits BioTwin's ability to disclose information where BioTwin believes in good faith that disclosure is necessary to protect users, prevent harm, respond to emergencies, protect rights or property, detect fraud or security incidents, or comply with applicable law.

International Transfers and Data Localization

Your information may be processed and stored in Canada, the UAE, the United States, and other countries where BioTwin Group or our service providers operate. 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; delete information (subject to legal exceptions); withdraw consent (which may limit certain features); object to or restrict certain processing; data portability. 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. 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.

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.

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. When information is no longer required, BioTwin may delete it, anonymize it, de-identify it, aggregate it, archive it, or isolate it from active processing, where permitted by law.

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.

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 use identifiable health data or identifiable genetic data for targeted advertising and does not sell such data. 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").

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.

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. 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, with or without notice, for any reason. Upon termination, your license to use the Platform ceases.

11. Governing Law

This Agreement is governed by the laws of the Operating Company providing the Services to you:

• BioTwin Canada Inc.: Laws of the Province of Québec and the federal laws of Canada; courts located in Montréal, Québec.
• BioTwin Limited (UAE): Laws of the United Arab Emirates as applied in the Emirate where the Operating Company is established.
• BioTwin USA (when established): Laws and forum specified at the time the Services are offered.

12. Contact Information

For questions about these Terms of Use, please contact:

Email: dpo @ biotwin.ai

Registered Addresses:

• BioTwin Canada Inc.: 1405, boulevard du Parc Technologique, Québec (Québec) G1P 4P5 Canada
• BioTwin Limited (UAE): Al Khatem Tower - 15 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

Effective April 2026. BioTwin (and the TwinMe brand) provides personalized health and well-being analyses based on biological samples and biomarkers. Because each kit, each sample and each analysis is generated specifically for you, our return and refund policy is adapted to this type of service. You can cancel an order as long as no sample, no analysis and no service has been initiated.

1. General principle

Our goal is to be transparent: kits and analyses are personalized, single-use services. They become non-refundable as soon as they are dispatched, used, or processed by the laboratory.

2. Kits (single purchase)

• Before shipment: you can cancel your order at no cost and receive a full refund.
• Once the kit has been shipped: the kit is no longer refundable, because it has been prepared, dispatched and is on its way to you.
• Once the kit has been used: no refund is possible if the kit has been opened, used, or if the sample has been received at the laboratory.

3. Analyses

Once the laboratory analysis has started, the service is considered rendered and is non-refundable.

If a technical issue prevents the laboratory analysis (insufficient sample, contamination, equipment failure), we will offer either a free replacement of the kit, or a refund of the amount paid for the analysis, at your choice.

4. Prepaid plans (monthly, quarterly, annual)

• Cancellation: you can cancel your plan at any time by contacting our support team at go@biotwin.ai. Your plan then stops at the end of the current period (no automatic renewal).
• Already-used services: services already rendered (kits sent, kits used, analyses started, reports delivered) are not refundable.
• Unused services: within an annual prepaid plan, services that have not yet started (kits not yet shipped, analyses not yet started) can either be refunded prorata, or kept as credit on your account for a future purchase.

5. If you request a refund

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 refunds within 10 business days after agreement, on the original payment method used

6. Timeframes

• Cancellation of an unshipped kit: full refund within 5 to 10 business days
• Refund following a confirmed technical issue: same timeframe
• Cancellation of a prepaid plan: applied at the end of the current period

7. 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 campaigns and provide non-sensitive marketing where permitted by law.

BioTwin does not use identifiable health data or identifiable genetic data for targeted advertising. BioTwin does not knowingly allow advertising partners to use sensitive health information collected through the Services for cross-context behavioral advertising.

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.

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

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).