TwainAgents

Privacy Policy

Effective date: 27 September 2026
Version: 1.1

This Privacy Policy explains how Twain - F.Z.E, an entity established in Ajman Free Zone, United Arab Emirates ("Twain", "we", "us" or "our"), collects, uses, stores, shares and protects personal information in connection with our websites, digital products, purchases, support interactions and related services.

1. Who controls your personal information

For the purposes of applicable data-protection law, the relevant controller is:

Twain - F.Z.E
B.C. 1301583
Ajman Free Zone C1 Building
Ajman, United Arab Emirates
Licensing authority: Ajman Free Zone Authority
Privacy and support contact: support@madebytwain.com

2. Scope

This Policy applies to personal information processed in connection with:

  • websites operated by Twain;
  • purchases of Twain digital products;
  • checkout and payment-related interactions;
  • secure product delivery and download activity;
  • customer support;
  • communications with Twain; and
  • analytics, security and website-operation data where such technologies are enabled.

This Policy does not govern third-party websites, platforms or services that operate under their own privacy policies.

3. Personal information we may collect

Depending on how you interact with Twain, we may collect the following categories of information.

3.1 Identity and contact information

This may include:

  • name;
  • email address;
  • telephone number where provided;
  • billing or business address;
  • company or business name where provided; and
  • country or region.

3.2 Order and transaction information

This may include:

  • product purchased;
  • amount and currency;
  • order or transaction identifiers;
  • purchase date and time;
  • payment status;
  • billing country;
  • refund or dispute status;
  • applicable product version;
  • licence or terms version associated with the purchase; and
  • tax-identification information where voluntarily provided or required.

3.3 Payment information

Payments are processed by third-party payment providers, including Stripe where applicable.

Twain does not intend to directly store complete payment-card numbers or card security codes. We may receive payment-related information from the payment provider, such as payment status, card type or limited masked card information, transaction identifiers and billing information.

3.4 Product-delivery and access information

For digital products, we may process:

  • entitlement status;
  • secure download identifiers;
  • download timestamps;
  • download counts;
  • link-expiry information;
  • product version; and
  • technical records required to prevent misuse or troubleshoot delivery.

3.5 Technical and usage information

When you use a Twain website, our systems or service providers may process information such as:

  • IP address;
  • browser type and version;
  • device type;
  • operating system;
  • approximate geographic region derived from technical information;
  • referring page;
  • pages viewed;
  • date and time of access;
  • security logs; and
  • cookie or similar identifiers where enabled.

3.6 Communications and support information

If you contact us, we may process:

  • the content of your message;
  • attachments you choose to provide;
  • support history; and
  • information needed to investigate or resolve your request.

3.7 Marketing preferences

Where Twain offers marketing communications, we may record whether you have opted in, opted out or otherwise expressed a communications preference.

We do not require marketing consent as a condition of purchasing a product.

4. How we collect information

We may collect information:

  • directly from you;
  • when you complete a purchase or checkout;
  • when you communicate with us;
  • automatically through website and security technologies;
  • from payment, hosting, delivery and infrastructure providers involved in providing the service; and
  • where lawful, from publicly available or business sources relevant to a transaction or enquiry.

5. Why we process personal information

We process personal information only where there is a lawful basis for doing so.

Depending on the circumstances, processing may be necessary to:

  • take steps requested by you before entering into a transaction;
  • perform a contract with you;
  • process and reconcile payment;
  • deliver a purchased product;
  • administer licences and product entitlements;
  • provide customer support;
  • detect, investigate or prevent fraud, misuse or security incidents;
  • maintain business, accounting, tax and transaction records;
  • comply with legal or regulatory obligations;
  • establish, exercise or defend legal rights;
  • maintain and secure our websites and services;
  • measure and improve website or product performance where permitted; or
  • send marketing communications where you have provided any consent required by applicable law.

Where processing is based on your consent, you may withdraw that consent subject to applicable law. Withdrawal does not affect processing that was lawful before the withdrawal.

6. Data minimisation and accuracy

Twain aims to collect only personal information reasonably necessary for the stated purpose.

We take reasonable steps to keep personal information accurate and to correct or delete inaccurate information where required.

We do not intentionally request sensitive personal information through ordinary product checkout or support channels unless it is necessary for a specific lawful purpose.

Please do not send sensitive personal information through general support channels unless it is genuinely required.

7. How we share personal information

We do not sell personal information to advertisers.

We may share personal information where reasonably necessary with service providers acting on our behalf or supporting a transaction. Depending on the service used, these may include providers of:

  • payment processing, including Stripe;
  • website and application hosting, including Render;
  • infrastructure, security and secure digital delivery, including Cloudflare where enabled;
  • transactional email and customer communications, including providers such as Resend where enabled;
  • analytics or performance measurement where enabled;
  • accounting, tax or professional advisory services; and
  • fraud prevention, security or compliance services.

We may also disclose information:

  • where required by law, regulation, court order or competent authority;
  • to establish, exercise or defend legal rights;
  • to protect Twain, our customers or others against fraud, security threats or unlawful conduct;
  • in connection with a merger, reorganisation, financing, acquisition, sale of assets or similar corporate transaction, subject to applicable safeguards; or
  • with your consent or at your direction.

Service providers are expected to process personal information only for authorised purposes and subject to applicable contractual and legal requirements.

8. International and cross-border processing

Some of Twain's service providers operate infrastructure in multiple countries. Personal information may therefore be processed or stored outside the United Arab Emirates.

Where cross-border transfer rules apply, Twain will take steps intended to ensure that transfers are made on a lawful basis and subject to appropriate contractual, organisational or other safeguards required by applicable law.

9. Cookies and similar technologies

Twain websites may use cookies or similar technologies for purposes such as:

  • essential website functionality;
  • security;
  • session management;
  • payment or checkout integration;
  • remembering user preferences; and
  • analytics or performance measurement where enabled.

We do not introduce marketing consent as a condition of purchasing a product.

Where applicable law requires consent before non-essential cookies or similar technologies are used, Twain will seek that consent or provide the relevant controls.

You can also manage many cookie settings through your browser. Disabling some technologies may affect website functionality.

10. Data retention

Twain retains personal information only for as long as reasonably necessary for the purpose for which it was collected, including to:

  • complete and evidence transactions;
  • provide purchased products and support;
  • maintain licence and entitlement records;
  • meet accounting, tax, legal or regulatory requirements;
  • prevent fraud or misuse;
  • resolve disputes; and
  • establish, exercise or defend legal rights.

Retention periods differ according to the type of information and applicable legal requirements.

When information is no longer required, Twain will take reasonable steps to delete, anonymise or securely dispose of it, subject to lawful retention obligations.

11. Security

Twain uses reasonable technical and organisational measures intended to protect personal information against unauthorised access, loss, misuse, alteration or disclosure.

These measures may include access controls, restricted credentials, encryption in transit where supported, private storage, tokenised access mechanisms, security logging and use of established infrastructure providers.

No electronic system can guarantee absolute security. If you believe your information or a Twain service has been compromised, contact support@madebytwain.com promptly.

12. Your data-protection rights

Subject to applicable law and any lawful exceptions, you may have rights including the right to:

  • obtain information about how your personal data is processed;
  • request access to relevant personal information;
  • request correction of inaccurate or incomplete personal information;
  • request deletion where the legal conditions for deletion are met;
  • request restriction or cessation of certain processing;
  • receive or request transfer of qualifying personal information in a structured and machine-readable form where applicable;
  • object to direct-marketing processing;
  • object to certain qualifying decisions based solely on automated processing;
  • withdraw consent where processing is based on consent; and
  • submit a complaint to the competent data-protection authority where you believe applicable data-protection law has been breached.

To exercise a right, contact support@madebytwain.com.

We may need to verify your identity before fulfilling a request. Rights may be limited where an applicable legal exception permits or requires us to retain or continue processing particular information.

13. Direct marketing

Where Twain sends optional marketing communications, you can unsubscribe using the mechanism provided in the communication or by contacting support@madebytwain.com.

Transactional messages relating to an order, payment, security issue, product delivery, legal notice or support request are not marketing messages and may still be sent where necessary.

14. Children

Twain's commercial digital products and purchasing services are not intended to be directed primarily at children.

If you believe a child has provided personal information to Twain in circumstances where consent or other legal requirements have not been satisfied, contact support@madebytwain.com.

15. Third-party links and platforms

Twain websites or products may link to third-party websites, AI platforms, software, APIs or other services.

Those third parties control their own processing activities and privacy practices. You should review their policies before providing personal information to them.

16. Changes to this Privacy Policy

Twain may update this Privacy Policy as its products, technology, service providers or legal obligations change.

Material revisions will be identified by an updated effective date or version number.

The current version will be published on the relevant Twain website.

17. Language

This Privacy Policy is made available in English and Arabic.

Both versions are intended to communicate the same substantive policy. If there is any inconsistency between language versions, the effect and interpretation required by applicable mandatory law will prevail.

18. Contact

For privacy questions or requests relating to your personal information, contact:

Twain - F.Z.E
B.C. 1301583
Ajman Free Zone C1 Building
Ajman, United Arab Emirates
support@madebytwain.com