TwinFlow

TwinFlow (“TwinFlow”, “we”, “us”, or “our”) is a business based in British Columbia, Canada. This Privacy Policy explains how we collect, use, disclose, and protect personal information when you visit twinflow.co, create an account, or use our prospecting and outreach platform (the “Service”).

We handle personal information in accordance with British Columbia’s Personal Information Protection Act (“PIPA”) and, where it applies, Canada’s Personal Information Protection and Electronic Documents Act (“PIPEDA”).

By using the Service, you consent to the practices described here. If you do not agree, please do not use TwinFlow.

1. Who we are

TwinFlow provides software that helps businesses discover companies and contacts, research public information, and draft outreach. We are the organization responsible for personal information collected through the Service.

Privacy inquiries: hello@twinflow.co

2. Information we collect

We collect personal information in the following categories.

Account and profile information

When you register or manage your account we may collect your first name, last name, company name, email address, password, plan selection, and related account settings. If you sign in with a third-party provider (such as Google), we receive the identifiers that provider shares with us.

Customer content

You may store campaign details, search criteria, notes, drafts, contact lists, email copy, headlines, and other material you submit to the Service (“Customer Content”). Customer Content may include personal information about your prospects or other third parties that you choose to process through TwinFlow.

Connected services

If you connect Gmail, GoHighLevel, Buttondown, a sending domain, GitHub, or another integration, we collect the tokens, addresses, and configuration data needed to operate that connection on your behalf.

Communications

If you contact us (including through our website form), we collect your name, email address, subject, message, and any other information you provide.

Usage, device, and technical data

We automatically collect information such as IP address, browser type, device information, pages viewed, referring URLs, timestamps, and diagnostic logs. We use Google Analytics and similar tools to understand how the Service is used.

Cookies and similar technologies

We use cookies and similar technologies that are necessary to operate the Service (including authentication and security cookies), to remember preferences, and to measure usage. Google reCAPTCHA may collect device and interaction data to distinguish humans from bots. Google Fonts may be loaded from Google’s servers.

3. How we use personal information

We use personal information to:

• create and administer accounts, authenticate users, and provide the Service;
• process campaigns, research, contact discovery, drafting, and related features you request;
• operate connected sending, CRM, newsletter, and publishing integrations you enable;
• provide customer support and respond to inquiries;
• improve, secure, and troubleshoot the Service;
• measure usage and product performance;
• send service, security, and (where permitted) product communications;
• enforce our Terms of Service and protect TwinFlow, our users, and the public; and
• comply with legal obligations.

We may use artificial intelligence and machine-learning providers (including OpenAI) to classify, summarize, research, and draft content based on information you submit or that is retrieved to fulfill your request.

4. Consent

Under PIPA, we collect, use, and disclose personal information with your consent, except where the law allows or requires otherwise. Consent may be express (for example, creating an account or connecting Gmail) or implied where the purpose would be obvious to a reasonable person.

You may withdraw consent, subject to legal or contractual restrictions and reasonable notice, by emailing hello@twinflow.co or using available account controls. If you withdraw consent, some features may no longer function.

5. Customer Content and prospect data

You are responsible for the personal information you upload or instruct TwinFlow to collect about third parties (such as business contacts). You must have a lawful basis to process that information, including compliance with applicable privacy, anti-spam, and marketing laws.

We process Customer Content to provide the Service to you. We do not sell your Customer Content. We do not use Customer Content to train public third-party models except as needed to operate a feature you request through our providers, or as otherwise disclosed in this Policy.

6. When we share information

We may disclose personal information:

• Service providers. Vendors that help us host, operate, secure, analyze, and improve TwinFlow, including cloud hosting, email delivery, analytics, CAPTCHA, AI, and lead-data providers. These parties may only use the information to perform services for us or as required by law.
• Integrations you connect. If you authorize a connection (for example Gmail, GoHighLevel, Apollo-powered lookups, Buttondown, or GitHub), we share the information needed to complete the action you requested.
• Legal and safety reasons. To comply with law, enforce our terms, or protect rights, property, or safety.
• Business transfers. In connection with a merger, financing, acquisition, or sale of assets, subject to appropriate confidentiality protections.

We do not sell personal information.

7. Cross-border transfers

TwinFlow is based in British Columbia, Canada. Some service providers (including analytics, AI, email, and lead-data vendors) are located in the United States or other countries. Personal information processed by those providers may be subject to the laws of those jurisdictions, including lawful access by foreign authorities.

By using the Service, you consent to this transfer and processing.

8. Retention

We keep personal information only as long as needed for the purposes described in this Policy, to provide the Service, to resolve disputes, to enforce agreements, and as required by law. Account information is generally retained for the life of the account. After deletion or inactivity, we may retain limited records for backup, security, and legal compliance, then delete or de-identify them.

9. Security

We use administrative, technical, and physical safeguards appropriate to the sensitivity of the information, including encrypted connections, access controls, and authentication cookies. No method of transmission or storage is completely secure. You are responsible for keeping your credentials confidential.

10. Your rights

Subject to exceptions in PIPA and PIPEDA, you may:

• request access to personal information we hold about you;
• request correction of inaccurate or incomplete information;
• withdraw consent where applicable;
• ask us to delete your account and associated personal information, subject to legal retention needs; and
• manage some information directly in your account settings, including personal data download and deletion tools where available.

To make a request, email hello@twinflow.co. We may need to verify your identity before responding. We will respond within the time required by applicable law.

11. Commercial electronic messages

If we send you commercial electronic messages, we do so in accordance with Canada’s Anti-Spam Legislation (“CASL”). You may unsubscribe using the link in those messages or by contacting us. Transactional and service messages related to your account may still be sent.

Messages you send to third parties through TwinFlow are your responsibility. You must comply with CASL, CAN-SPAM, and any other applicable anti-spam or marketing laws.

12. Children

The Service is intended for business users who are at least 19 years of age (the age of majority in British Columbia). We do not knowingly collect personal information from children.

13. Changes to this Policy

We may update this Privacy Policy from time to time. The “Last updated” date at the top will change when we do. Material changes will be posted on this page and, where required, notified to account holders. Continued use of the Service after the update means you accept the revised Policy.

14. Contact and complaints

Questions, access requests, or privacy complaints:

TwinFlow
British Columbia, Canada
Email: hello@twinflow.co

If we cannot resolve your concern, you may contact the Office of the Information and Privacy Commissioner for British Columbia at oipc.bc.ca, or the Office of the Privacy Commissioner of Canada at priv.gc.ca.

See also our Terms of Service.