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 (consumer-facing, wellness-oriented experience), BioTwin Portal and Provider Programs (programs or portals used with healthcare providers, clinics, wellness professionals, employers, or other partners), and services related to questionnaires, sample collection and analysis, device/app connections, file uploads (including medical records), photos, voice features, AI chat and simulations, and customer support.

This Policy does not apply to third-party websites, apps, devices, or services you connect to the Services. Their privacy practices are governed by their own policies.

By using our Services, contacting us, or receiving communications from us, you acknowledge and accept this Policy.

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 various ways: when you create an account, complete your profile, import data, connect services, order/activate services, or interact with our features. Categories may include:

• Account and identity information: name, email, credentials, language, preferences, billing
• Profile, questionnaires, check-ins: personal info, lifestyle habits, symptoms, medical history, medications
• Biological samples and derived results: sample data, metadata, tracking
• Connected devices and third-party apps: activity, sleep, wellness metrics you authorize
• Medical records and uploaded documents: genetic data, lab results, imaging, reports
• Photos and visual information: face, body, hands, skin, eyes
• Voice information: voice samples for personalization or vocal indicators
• Food intake logging and media: meal photos, nutrition data
• AI interactions and content: chat prompts, responses, feedback
• Communications and support: messages, requests, metadata
• Technical, security, and usage data: IP, device info, logs, diagnostics

How We Use Information

We use personal information to: provide, operate, and maintain the Services; create and update your virtual twin and generate insights; process samples and generate analytical outputs; enable medical record management and controlled sharing; provide AI features and improve their quality; provide customer support; communicate about service updates and security; conduct internal analytics and product improvement; conduct research projects (with appropriate consent); protect the Services (fraud prevention, security); and comply with legal obligations.

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: within the BioTwin Group (for administration, support, security, compliance); to service providers/processors (cloud hosting, security, analytics, AI infrastructure, customer support, payment, logistics); to labs and logistics partners (for sample processing and fulfillment); to Provider Programs and authorized recipients (with your authorization, to healthcare providers or partner organizations); to research and development partners (aggregated/de-identified data, or identifiable with consent); for legal and safety reasons (to comply with law, protect rights, prevent fraud); and in business transactions (mergers, acquisitions, with safeguards).

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 us at legal@biotwin.ai or privacy@biotwin.ai.

AI, Automation, and Simulations

Some features use automated processing and AI to generate insights, recommendations, simulations, or visualizations. These outputs are for informational and wellness/program-support purposes and do not replace professional medical judgment. If you believe an output is incorrect or harmful, contact support. We may use AI interaction data to operate, secure, and improve AI features, consistent with this Policy and applicable law.

Children

Our Services are not intended for individuals under 18 unless expressly offered under a specific, legally compliant program. If we learn we collected personal information from a child without the required legal basis, we will take reasonable steps to delete it.

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/Québec: You may have rights to access and correct personal information, and additional requirements may apply under Québec privacy rules. UAE: Additional requirements may apply for cross-border transfers and health data contexts. United States: Depending on your state, you may have rights to access, delete, correct, and opt out of certain processing; health-related data may be regulated under state “consumer health data” laws. EEA/UK: GDPR/UK GDPR rights may apply where relevant, including enhanced protections for health data.

Contact

To ask questions, make a request, or raise a concern, contact our Privacy Team: Email: legal@biotwin.ai and/or privacy@biotwin.ai. BioTwin Canada Inc.: 1405, boulevard du Parc Technologique, Québec (Québec) G1P 4P5 Canada.

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.

Always anonymous

We believe not knowing who the health data belongs to is the best form of privacy. Our business model and collaborations are designed so health data always remains anonymous. We treat the data internally using proprietary methodologies and only the insights coming from the transformed data reach service providers.

Key principles

Contact

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

Email: legal@biotwin.ai and/or privacy@biotwin.ai