Privacy Policy

This Privacy Policy ("Privacy Policy") explains how Twinstake Ltd. ("Twinstake"), a limited liability company registered in the Cayman Islands, ("we," "us," or "our") collects, uses, shares, and protects personal information obtained from customers ("you" or "your") in connection with your use of our products and services.

1. Purpose for Collecting Personal Information

We may hold and process your personal data on the following lawful grounds:
(i) Contractual necessity: To provide you with our products and services and to perform a contract which we may have with you.
(ii) Legal obligation: To comply with our Customer Due Diligence ("CDD") processes and our anti-money laundering and countering the financing of terrorism/proliferation financing ("AML/CFT/PF") obligations, and to satisfy other legal and regulatory obligations.
(iii) Legitimate interests: To communicate with you, including responding to inquiries and providing customer and technical support, and to improve your experience with our services.
(iv) Consent: In cases where we process your personal data for specific purposes, such as marketing, we will request your explicit consent, which you can withdraw at any time as outlined in the "Consent and Opt-Out" section below.

2. Consent and Opt-Out

By using our services, you consent to the collection, use, and sharing of your personal information as described in this Privacy Policy. You have the right to withdraw your consent at any time by contacting us at [email protected] or by following the instructions provided in communications we send. Additionally, you can opt out of certain types of data processing, such as direct marketing, by adjusting your preferences in your account settings or contacting us directly.

3. Types of Personal Information Collected

We may collect the following types of personal information from customers:
(i) Onboarding and contact information: Such as names, addresses, email addresses, date of birth, and source of wealth.
(ii) Account information: Usernames, passwords, and other credentials used to access our services.
(iii) Usage data: Information about how you interact with our services, including log data and device information.
(iv) Other information: Any other information you voluntarily provide to us or that we collect in connection with your use of our products and services.

4. Methods of Collection

We may collect personal information through various methods, including:
(i) Directly from you when you provide it to us, such as when you become a customer of our services.
(ii) Automatically through the use of our website and cookies. You can control the use of cookies through your browser settings. Please find our cookies policy here.

5. Use, Retention, and Disposal

Your personal information will be retained for as long as required:
(i) For the purposes for which the personal information was collected.
(ii) To establish or defend legal rights or obligations or to satisfy any reporting or accounting obligations.
(iii) As required by data protection laws and any other applicable laws or regulatory requirements.
We retain your personal information for as long as necessary to fulfil the purposes for which it was collected, including satisfying legal, accounting, or regulatory requirements. The specific retention period will vary depending on the type of data, the legal basis for processing, and any legal or regulatory obligations. If you would like more details on specific retention periods, please contact us.
We will ensure that the personal information we hold is subject to appropriate security measures and disposed of securely when no longer required.

6. Access to and Control of Your Personal Information

Under the Cayman Islands Data Protection Act 2017, you have the following rights in respect of the personal information we process about you:
(i) Right to Access: You can request a copy of the personal data we hold about you.
(ii) Right to Rectification: You can ask us to correct any inaccuracies in the data.
(iii) Right to Restrict Processing: You may ask us to limit the way we use your personal data. Please note that if you exercise your right to restrict processing, this may impact the availability or functionality of certain services we provide. For example, we may be unable to fulfill specific requests or provide certain features that rely on the unrestricted processing of your personal data. In cases where processing limitations affect our ability to offer core services, we may need to suspend or modify access to those services until the restriction is lifted.
(iv) Right to Erasure: You have the right to request that your personal data is deleted (subject to laws and regulatory requirements that apply to Twinstake).
(v) Right to Object: You can object to the processing of your data under certain circumstances.
(vi) Right to Data Portability: You may request a copy of your data in a structured, commonly used format.
(vii) Right to Withdraw Consent: You can withdraw your consent to data processing at any time, where consent was the basis for processing.
(viii) Right to Lodge a Complaint: You can lodge a complaint with the Cayman Islands Ombudsman if you feel that your data has been mishandled, however, before you do so, please contact us at [email protected] so that we can address your concern.
If you wish to exercise any of the above rights, please contact us at [email protected].

7. Disclosure to Third Parties

We may share your personal information with third parties for the purposes stated in this Privacy Policy, including:
(i) Service Providers: Third-party vendors and service providers who assist us in operating our business and providing our services.
(ii) Business Partners: Affiliates and business partners we work with for the provision of our services and products.
(iii) Legal Authorities: As required by law or to comply with legal obligations, enforce our terms and policies, or protect our rights.
When Twinstake shares information with third parties, we will ensure that the third party is contractually bound to process personal information in accordance with applicable data protection laws, including the Cayman Islands Data Protection Act 2017, and with Twinstake’s specific instructions and requirements, ensuring that your rights are protected.

8. International Transfers

Twinstake may need to share or process your personal data outside of the Cayman Islands. In such cases, Twinstake will ensure that appropriate safeguards are in place to protect your personal data. These safeguards may include entering into standard contractual clauses with the recipient of your data, in compliance with the Cayman Islands DPA 2017.
If you would like more information on international data transfers, please contact us at [email protected].

9. Security for Privacy

We recognize the importance of protecting and managing your personal data. We use a variety of organizational and technical measures to:
(i) Maintain the confidentiality, availability, and integrity of your personal data.
(ii) Ensure your personal data is not improperly used or disclosed.
These measures include encryption of data in transit and at rest, regular third-party security audits, and strict access controls ensuring only authorized personnel have access to your personal data.

10. Quality

We strive to maintain the accuracy and integrity of your personal information and rely on you to ensure its quality. Please notify us of any changes or inaccuracies in your personal information so that we can update our records accordingly.

11. Monitoring and Updates

We regularly monitor our privacy practices to ensure compliance with this Privacy Policy and applicable laws, including the Cayman Islands Data Protection Act 2017. This Privacy Policy will be reviewed and updated at least annually or as required by changes in legal or regulatory requirements. If we make any material changes to this Privacy Policy, we will notify you via email or through an in-app notification.

Contact Us

If you have any questions or concerns about our privacy practices or this Privacy Policy, please contact us at [email protected].