Legal
Privacy Policy
Last updated: [Insert Date] • Effective date: [Insert Date]
⚠ Template Notice — Read Before Publishing
This document is a professionally structured starting template, not a finished, legally reviewed policy. Claude is not a lawyer, and this is not legal advice. Before publishing this page live, have it reviewed by a lawyer qualified in UAE law (and in any other jurisdiction where TwinSpan collects data from users), to confirm it meets UAE Federal Decree-Law No. 45 of 2021 (Personal Data Protection Law), any applicable free zone data protection rules, and any other laws that apply to your actual data practices. Placeholders like [Insert Date] and [Insert Address] still need to be completed accurately — an inaccurate policy can create more legal exposure than none at all.
1. Introduction
This Privacy Policy explains how TwinSpan ("TwinSpan," "we," "us," or "our"), operated by TwinSpan LLC, a company registered in the United Arab Emirates with its registered address at [Insert Registered Address], collects, uses, discloses, and safeguards information when you visit our website, use our platform, or otherwise interact with our services (collectively, the "Services"). By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with this Policy, please do not use the Services.
2. Data We Collect
2.1 Information you provide directly
- Contact details (name, company name, email address, phone number, job title) submitted through forms such as "Request Pricing" or "Book a Demo."
- Information provided during onboarding, including building/portfolio details, site access arrangements, and communications with our team.
- Any other information you choose to submit via email, phone, or in-person meetings.
2.2 Information collected automatically
- Usage data (pages visited, time on page, referring URLs, device and browser type, approximate location derived from IP address).
- Cookies and similar tracking technologies (see Section 6).
2.3 Building and asset data
As part of delivering our digital twin services, we capture and process data about physical buildings and assets (3D scans, BIM models, sensor data, maintenance records). This data is processed on behalf of our clients under separate service agreements and is treated as confidential client data, distinct from personal data covered by this Policy, except where it incidentally contains personal information (e.g., a maintenance log referencing a technician's name).
3. How We Use Data
- To provide, operate, and maintain the Services, including responding to demo requests and pricing inquiries.
- To communicate with you about your account, service updates, and support requests.
- To improve our website, platform, and service offerings.
- To comply with legal obligations, resolve disputes, and enforce our agreements.
- To send marketing communications where permitted by law, from which you may opt out at any time.
4. Legal Basis for Processing
Where required by applicable law, we process personal data on one or more of the following bases: your consent; performance of a contract with you; compliance with a legal obligation; or our legitimate business interests (such as operating and improving the Services), provided those interests are not overridden by your data protection interests or fundamental rights.
5. Sharing & Disclosure
We do not sell personal data. We may share information with:
- Service providers who perform functions on our behalf (e.g., cloud hosting, email delivery, analytics, customer relationship management), under contractual confidentiality obligations.
- Professional advisors such as lawyers, auditors, and insurers, where necessary.
- Government or regulatory authorities where required by applicable law, court order, or governmental request.
- A successor entity in the event of a merger, acquisition, financing, or sale of assets, subject to standard confidentiality arrangements.
6. Cookies & Tracking Technologies
We use cookies and similar technologies to operate the website, remember preferences, and understand how visitors use our Services. You can control cookies through your browser settings; disabling cookies may affect site functionality. [Insert details of specific cookies/analytics tools used, e.g., Google Analytics, once finalized, and link a separate Cookie Policy if required by your jurisdiction.]
7. Data Security
We implement administrative, technical, and physical safeguards designed to protect personal data against unauthorized access, alteration, disclosure, or destruction, including role-based access controls and encryption in transit. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security. You transmit information to us at your own risk.
8. Data Retention
We retain personal data only for as long as necessary to fulfill the purposes described in this Policy, comply with legal obligations, resolve disputes, and enforce agreements. Retention periods vary depending on the type of data and the nature of our relationship with you. [Insert specific retention schedule once defined, e.g., "client data is retained for the duration of the service agreement plus 7 years thereafter for accounting and legal purposes."]
9. International Transfers
TwinSpan is based in the United Arab Emirates. If we transfer personal data outside the UAE (for example, to cloud service providers hosting data in other regions), we take steps intended to ensure the data remains protected consistent with this Policy and applicable law, such as contractual safeguards with service providers.
10. Your Rights
Depending on applicable law, you may have rights to: access the personal data we hold about you; request correction of inaccurate data; request deletion of your data; object to or restrict certain processing; and request a copy of your data in a portable format. To exercise these rights, contact us using the details in Section 15. We may need to verify your identity before fulfilling a request, and some rights may be subject to exceptions under applicable law.
11. Children's Privacy
Our Services are intended for business use by adults and are not directed at individuals under the age of 18. We do not knowingly collect personal data from children. If you believe a child has provided us with personal data, please contact us so we can delete it.
12. Third-Party Links
Our website may contain links to third-party websites or services not operated by us. We are not responsible for the privacy practices or content of any third-party sites. We encourage you to review the privacy policies of any third-party site you visit.
13. Disclaimers & Limitation of Liability
To the maximum extent permitted by applicable law:
- The Services and this website are provided "as is" and "as available," without warranties of any kind, whether express, implied, or statutory, including implied warranties of merchantability, fitness for a particular purpose, and non-infringement.
- TwinSpan, its founders, officers, employees, and affiliates shall not be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, including but not limited to loss of profits, data, goodwill, or business opportunity, arising out of or related to your use of, or inability to use, the Services or this website, even if advised of the possibility of such damages.
- Where liability cannot be excluded under applicable law, TwinSpan's total aggregate liability arising from or related to this Policy or your personal data shall not exceed the amount (if any) paid by you to TwinSpan in the twelve (12) months preceding the event giving rise to the claim, or [Insert nominal cap amount, e.g., AED 1,000] if no amount was paid.
- Nothing in this Policy excludes or limits liability that cannot be excluded or limited under applicable UAE law, including in cases of fraud or willful misconduct.
14. Changes to This Policy
We may update this Privacy Policy from time to time to reflect changes in our practices or for legal, operational, or regulatory reasons. We will post the updated Policy on this page with a revised "Last updated" date. Your continued use of the Services after changes take effect constitutes acceptance of the revised Policy.