Privacy Policy

This Privacy Policy ("Privacy Policy") explains how Twinstake Limited (‘’Twinstake’’), a limited liability company registered in 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) to provide you with our products and services;
(ii) to perform a contract which we may have with you;
(iii) to communicate with you, including responding to inquiries and providing customer and technical support;
(iv) to personalise and improve your experience with our services;
(v) 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;
(vi) to comply with our legal and regulatory obligations; and
(vii) to enforce our terms and policies.

2.  Consent

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 choice to opt-out of certain data processing activities, as outlined in the "Access" section below.

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.

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 will ensure that the personal information that we hold is subject to appropriate security measures.

6. Access to and control of your personal information

You have the following rights in respect of the personal information about you that we process:

(i) the right to access and port personal information;
(ii) the right to rectify personal information;
(iii) the right to restrict the use of personal information;
(iv) the right to request that personal information is erased;
(v) the right to object to processing of personal information.

If you wish to exercise any of the rights set out above, please contact [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.

In the circumstances, where Twinstake shares information with third parties, we will ensure that the third party is contractually bound to only process personal information in accordance with applicable data protection laws and with Twinstake’s specific instructions and requirements, and at all times in a manner that protects your rights under applicable data protection laws. Our service providers and business partners will be required to meet our standards on processing information and security.

8. International transfers

It’s possible that Twinstake may need to share or process your personal data outside of the Cayman Islands. If we do so, Twinstake will ensure that any international transfers comply with the applicable local data protection laws, including by, where necessary, entering into standard contractual clauses with the recipient of your data. If you would like more information about this, please contact [email protected].

9. Security for Privacy

We recognise the importance of protecting and managing your personal data.
Any personal data we process will be treated with the utmost care and security.

We use a variety of organisational and technical measures to:
(i) maintain the confidentiality, availability and integrity of your personal
(ii) make sure your personal data is not improperly used or disclosed.

We have detailed information security and data protection policies which our
employees are required to follow when they handle your personal data.
Electronic data and databases are stored on secure computer systems with
access controls in place to limit physical, system and information access to only
authorised employees.

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

We monitor our privacy practices to ensure compliance with this Privacy Policy and applicable laws and we may update this notice from time to time. We will notify you in the event we make any material changes to this notice. If you have any questions or concerns about our privacy practices or this Privacy Policy, please contact us using the information provided below.

Contact Us

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