Privacy Policy

1. Who We Are

TwinBasis AI (“TwinBasis”, “we”, “us”) operates the website twinbasis.com and the TwinBasis AI platform. We are committed to protecting your personal data and complying with the EU General Data Protection Regulation (GDPR). Our company is registered in Estonia.

2. Data We Collect

Early Access form. When you submit our Early Access form, we collect:

• Your name and work email address
• Property type and number of properties managed
• Optional: your biggest operational challenge

Operational data. When property managers use the live Service, TwinBasis processes guest communication data (messages sent via WhatsApp, SMS, and email) solely to deliver the AI response functionality. In this context, TwinBasis acts as a data processor on behalf of the property manager, who is the data controller for their guests’ data.

Server logs. We collect standard server logs (IP address, browser type, pages visited) for security and performance monitoring purposes.

3. How We Use Your Data

We use the information you provide solely to:

• Contact you about your Early Access request
• Send you updates about TwinBasis (you can unsubscribe at any time)

We do not sell, rent, or share your personal data with third parties for marketing purposes.

4. Automated Processing & AI

The TwinBasis Service uses artificial intelligence to automatically read, classify, and respond to guest messages on behalf of property managers. This constitutes automated processing under GDPR Article 22. Property managers retain full control and can review, override, or disable any automated response at any time through their dashboard. No automated decisions are made solely on the basis of profiling without human oversight capability.

5. Data Retention

We retain your Early Access contact information for as long as necessary to fulfil the purpose for which it was collected, or until you request deletion. Operational guest communication data processed through the Service is retained only for as long as required to deliver the Service and is deleted upon account termination or earlier upon request.

6. International Data Transfers

TwinBasis is based in Estonia (EU) and primarily processes data within the European Economic Area. Some AI processing components may involve infrastructure or models outside the EEA. Where this occurs, we ensure appropriate safeguards are in place in accordance with GDPR Chapter V, including Standard Contractual Clauses where required.

7. Your Rights

Under GDPR, you have the right to:

• Access — request a copy of the personal data we hold about you
• Rectification — request correction of inaccurate data
• Erasure — request deletion of your personal data
• Restriction — request that we limit how we use your data
• Portability — receive your data in a structured, machine-readable format
• Object — object to processing based on legitimate interests
• Withdraw consent — where processing is based on consent, withdraw it at any time

To exercise any of these rights, contact us at privacy@twinbasis.com.

You also have the right to lodge a complaint with a supervisory authority. As an Estonian company, our lead supervisory authority is the Estonian Data Protection Inspectorate (Andmekaitse Inspektsioon, www.aki.ee).

8. Cookies

This website does not use tracking or advertising cookies. We use only essential cookies required for the site to function (such as storing your cookie consent preference).

9. Third-Party Services

We use the following third-party processors:

• Resend (resend.com) — transactional email delivery
• Vercel (vercel.com) — website hosting
• Twilio (twilio.com) — WhatsApp and SMS message delivery
• AI model providers — for processing guest communications on behalf of property managers

All processors are bound by appropriate data processing agreements.