Privacy Statement
Privacy Statement
Effective August 5, 2026
Scope of this Privacy Statement and Our Role
At TwinWise (and Synaptic Spike GenAI, LLC, our parent company and family of companies, collectively “TwinWise” or “we”), we believe that everyone has a right to privacy. We’re providing this Privacy Statement (“Privacy Statement”) to explain how we collect, use, share, or otherwise process information that we collect through our platform, website and services, which include our product offerings, intake processes, mobile applications, intake processes, research and development activities, social media pages, marketing activities, and other activities described in this Privacy Statement or when other businesses provide us your personal information (collectively, “Services”). Please note that our services, including pilot programs, may have distinct privacy terms, which are different from this Privacy Statement. Depending on your settings, this may include showing you personalized ads or marketing materials.
What is TwinWise?
TwinWise builds your Cognitive Twin — a dynamic, personalized system that is built on the foundation of how you think, reason, and decide, and your Twin carries that understanding with you. Your Cognitive Twin is built through a structured intake process grounded in behavioral and social science, combining AI-powered analysis with human expertise to capture your reasoning patterns, decision frameworks, personality traits, cognitive tendencies, and meaningful insights. Your Cognitive Twin then continuously generates your Personal Intelligence — a living, structured understanding of how you think, reason, and decide across different domains and contexts, capturing your decision patterns, reasoning frameworks, personality traits, and the insights that make you distinctly you (described in more detail, below).
When this Privacy Statement refers to your Cognitive Twin, Personal Intelligence, it means the core service TwinWise builds, maintains, and operates on your behalf.
Cognitive Twin Evolution and Continuous Improvement.
Your Cognitive Twin is a living system. It is designed to grow, evolve, and improve over time as (a) you provide new information through continued use, our intake processes and/or feedback tools, (b) TwinWise’s AI capabilities improve, (c) better models or methodologies become available, and (d) your own thinking, values, perspectives, and expertise change over time.
People grow. Circumstances change. TwinWise is designed to grow and change with you. TwinWise has the right — and the obligation to you as a matter of service quality — to update, retrain, refine, recalibrate, and evolve your Cognitive Twin on an ongoing basis. You consent to this continuous evolution as a core and essential feature of TwinWise’s Services.
Your Cognitive Twin learns and evolves over time, just as you do — and so does TwinWise for everyone who uses it. When we learn something that helps one person, that insight can improve the experience for all users. This learning happens at the pattern level, not the personal level: what we use is not traceable back to you, and your Personal Intelligence and conversations with your Twin are never shared with third parties, unless you choose to share it. We never share your identifiable information with third parties outside of what’s described in this Privacy Statement.
Your Data and Our Technology
TwinWise uses proprietary technology — including our cognitive mapping methodology, inference engine, Cognitive API orchestration, and underlying systems — to build and maintain your Cognitive Twin. These methods belong to TwinWise. What they produce about you belongs to you.
Specifically, TwinWise collects and processes the personal information you share with us — including your conversations, preferences, life details, and history — to build your Cognitive Twin. This Cognitive Twin Data is yours. You can access, correct, export, or delete it at any time as described in the Your Rights section of this Privacy Statement.
Data Processing
We determine the purposes and means of the processing of your personal information as described in this Privacy Statement and act as a “data controller” (or equivalent/similar terms under applicable data privacy laws) of such information. We may share your personal information within the Synaptic Spike GenAI, LLC family of companies and conduct processing activities as controllers or joint controllers for the purposes set out in this Privacy Statement. In certain circumstances, there may be more than one data controller processing your personal information. For example, your employer may also act as a data controller. In these situations, we act as an independent data controller over our processing activities. This means we determine how your personal information will be processed independently from the other data controllers. The other data controllers have their own obligations under applicable data privacy laws. TwinWise is not responsible for other data controllers’ processing activities, and you should contact them directly for questions about how they process your personal information and about how to exercise your privacy rights in relation to such processing.
If you have any questions about how TwinWise processes your personal information, please see “How to Contact Us” below.
Personal Information We Collect
The personal information that we collect or otherwise receive about you depends on the context of your interactions with TwinWise, including the choices you make, the products and services you use, and your privacy settings in your browser and devices.
Information you provide to us
You may provide us with your information as follows:
Contact data and account profile data. We collect information when you register with our site, sign up for a waitlist or pilot program, create an account, activate a subscription, interact with our social media pages, register for newsletter/communications, and/or upload information to the TwinWise site. Personal information may include your name, previous name(s) and/or nicknames, title and honorifics, professional title and company name, education details, details of your resume and professional experience, billing and mailing addresses, phone number and email address, profile photo, billing information (your payment information), purchase history, demographic information, preferences, subscription data, and your username and account credentials.
Identity verification information. We may collect information to verify your identity, including your name, date of birth, social security number, social insurance number, driver’s license number, passport number, government-issued identification details, and similar information to verify your identity.
Communications, feedback and survey data, and related data. We may collect personal information such as your name, email address, telephone number and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, attend our events, participate in product research or training, or otherwise interact or communicate with us. This information may include: text conversations (including with AI support assistants on our site), call recordings and call monitoring records, chat and text records, voicemails, photographs, and video recordings and images.
Marketing data. You may provide us with your contact information and preferences for receiving marketing communications.
Social and community content. We receive content you post on our social media pages and our community pages.
Interactions with chatbots. We may receive information from you through your use of chatbots, digital assistants, or other interactive bots across the TwinWise website.
Device and contact data. If you grant permission in your device settings, certain features may have access to your device and contacts.
Supplemental information and identity verification providers. We may work with certain third parties to help us verify your identity, the specifics of your business, and/or supplement the personal information you have provided and ensure the accuracy of your personal information. For example, we may use third-party providers to validate your contact information (e.g., name, mailing address, email address, phone number) or to provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider, or email provider.
Risk management, cybersecurity & anti-fraud providers. We may receive personal information from third parties that help us assess risks associated with our website, including to help combat fraud and illegal activity and to help protect your personal information.
Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.
Public information. We collect individual and household demographic information and preference information from publicly available sources, such as open government databases, social media platforms, and others.
Cognitive Twin Data: what we collect and what we derive
TwinWise processes two distinct categories of data in connection with your Cognitive Twin: data you provide directly (“Collected Data”) and data we generate and derive from that input using our proprietary methods and technology (“Personal Intelligence”). Together, Collected Data and Personal Intelligence constitute your “Cognitive Twin Data.” Cognitive Twin Data belong to you. We use them to build and operate your Cognitive Twin, as described in this Privacy Statement.
Collected Data (information you provide directly)
Collected Data is the raw personal information you share with us as part of your TwinWise experience. It is created and controlled by you. This includes:
Information you provide during the structured Cognitive Twin intake process, including your biographical details, professional background, personal history, relationships, values, goals, and life experiences;
Your responses to our cognitive assessment questionnaires, reflective prompts, and scenario-based exercises designed to surface how you think and reason;
The full content of your conversations with your Cognitive Twin, including questions, responses, feedback, and follow-up exchanges;
Corrections, updates, and feedback you provide over time to help your Cognitive Twin grow more accurate and representative of you.
Data and content that you input while using your Cognitive Twin.
Personal Intelligence (information we generate about you)
Your Personal Intelligence is a living understanding of how you think — encompassing your reasoning patterns, decision-making tendencies, personality traits, values, and cognitive frameworks — built from your intake data and continuously refined through your interactions with TwinWise.
Your Personal Intelligence is generated and derived from your Collected Data using TwinWise’s proprietary cognitive mapping methodology and AI-powered analysis. Personal Intelligence is the core output of the TwinWise service — it is what makes your Cognitive Twin work. While TwinWise’s technology and methodology belong to us, the specific Personal Intelligence generated about you belongs to you. Personal Intelligence includes:
Cognitive maps and reasoning frameworks inferred from your intake responses and ongoing interactions, representing how you process information, weigh tradeoffs, and arrive at conclusions;
Behavioral and attitudinal inferences, including predispositions, belief structures, personal values and philosophical beliefs, and situational tendencies identified through our cognitive modeling processes; and
Personalized outputs, recommendations, and decision-support responses generated by your Cognitive Twin in response to your prompts and queries.
Your Personal Intelligence may be considered sensitive personal information under applicable privacy laws, including state laws governing AI-based profiling. We process it solely to build and operate your Cognitive Twin, provide you with our Services and for the purposes described in this Privacy Statement. We do not sell Cognitive Twin Data — including your Personal Intelligence and all insights generated about you — to third parties for their independent use. Your Cognitive Twin Data is yours. You may access, export, correct, or delete it at any time.
Automatic data collection
We and our service providers may automatically log personal information about you, your computer or mobile device, and your interaction over time with the Services, such as:
Device information. We may collect information about your device(s) such as IP addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
Usage information. We may collect information about your use of our website, such as the pages you viewed, the features you used or interacted with, your browser type, and details about any links or communications with which you interacted.
Location information. Certain features on our website may collect your precise location information, device motion information, or both, if you grant us permission to do so through your device settings.
Communication interaction data. We may collect information from email providers, communication providers and social networks, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Online behavioral data. We may automatically collect certain personal information about your use and interactions with our website, social media websites, and marketing campaigns that we organize, including device information (such as your IP address and unique device IDs), page view information and search results, links, and if you are a customer contact, whether or not a campaign presented or sent to you using our offerings has been viewed, delivered, opened, clicked on, whether it has bounced or was treated as spam.
Cookies and similar technologies
TwinWise and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”) to collect information about you (“Cookie Information”) so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’ experiences. You have control over some of the information we collect from Cookies and how we use it. Please see Your Personal Information Rights and Choices section for more information.
How We Use Personal Information
We may use your personal information in a number of ways or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
Provide you with the TwinWise Services, create your account and manage our relationship with you;
Register you for a pilot program or waitlist;
Run and manage our business, including resolving billing disputes;
Evaluate your eligibility for marketing offers;
Communicate with you;
Understand your needs and interests and personalize your experience with our site and our communications;
Provide you with support and resolve disputes;
Authenticate your identity;
Manage event registrations and attendance, including sending related communications to you.
Research and development. We may use your personal information to:
Improve and develop our products and sites by analyzing how they are used and interacted with, as well as by assessing the use of and interactions with our site, including by conducting data analytics to develop insights about you, your needs, and your preferences, so we can make more informed predictions, recommendations, and products for our customers.
Combine and anonymize information about your interactions with TwinWise to create aggregate, anonymized statistics for use in research and for marketing, promoting, improving, and developing our site, products and services.
Cognitive Twin development and Personal Intelligence. Building your Cognitive Twin and providing you with our Services is the primary purpose for which we process your personal information. This is not an ordinary data use — it is the service itself. We use your personal information to:
Build and initialize your Cognitive Twin through our proprietary structured intake process, which captures your reasoning patterns, decision-making frameworks, personality traits, cognitive tendencies, and the personal details that define how you think and who you are;
Generate and continuously update your Personal Intelligence — the living understanding of your thinking, reasoning style, and decision-making approach — as you interact with TwinWise, provide new information, and your circumstances and perspectives evolve over time;
Apply your Personal Intelligence to build and maintain the cognitive architecture underlying how your Cognitive Twin represents and responds as you — continuously refining the structures that enable your Twin to reason and respond in your voice;
Deliver personalized responses, recommendations, and decision-support outputs through your Cognitive Twin by applying your Personal Intelligence to your queries and prompts;
Retrain, recalibrate, and improve the accuracy, depth, and relevance of your Cognitive Twin on an ongoing basis as you provide new information, correct prior inputs, or as our AI capabilities improve — as described in the “Cognitive Twin Evolution and Continuous Improvement” section of this Privacy Statement;
Improve our AI models, cognitive mapping methodology, and TwinWise platform using de-identified, aggregated data derived from user interactions — meaning we may use patterns and statistical signals from across our user base, but we do not use your identifiable Personal Intelligence to train models that benefit other users;
Conduct internal research and development on cognitive modeling, reasoning frameworks, and personalization technology; and
Generate anonymized, aggregate insights about cognitive patterns and decision-making trends across our user base for internal research, product development, and to advance the science of cognitive modeling — subject always to the constraint that no such use shall be traceable to you as an individual.
Marketing and advertising. We and our service providers may collect and use your personal information for marketing and advertising purposes to:
Market services, products and experiences, including to deliver gifts and promotional materials, product recommendations, source program participants and other non-transactional communications via email, post, telephone, SMS or push notifications, in accordance with your marketing preferences.
Personalize your experience and tailor recommendations, advertising, and offers presented to you, including through the development of insights about you and your needs based on your interactions with our site. These advertisements may be displayed to you on TwinWise’s digital properties, including our websites and mobile apps, media platforms, connected devices, or other third-party platforms and channels.
Compliance and protection. We may use your personal information to:
Protect against misuse or abuse of our site and ensure compliance with our Terms of Service, including in relation to content our customers send or display.
Comply with legal and regulatory requirements.
Protect the rights, property, safety or security of our website, products/services, our customers, employees or others and prevent fraudulent or illegal activity.
Exercise our rights in the course of judicial, administrative, or arbitration proceedings.
Enforce, remedy, or apply our Terms of Service or other agreements.
With your consent. In some cases, we may specifically ask for your consent to use your personal information, such as when required by law.
We may process your personal information for other purposes that are compatible with the above purposes where permitted by applicable law.
Artificial Intelligence (AI) and Automated processing
Building your Cognitive Twin is a process of deep, intentional personalization. TwinWise uses artificial intelligence — both automated and human-reviewed — to learn specifically how you think, reason, and make decisions. This is not a generic AI processing generic inputs. It learns you: your reasoning tendencies, your values in practice, your patterns across contexts and over time. This is what makes your twin useful. Certain privacy laws classify this kind of individualized learning as automated profiling of personal characteristics — a recognition that what TwinWise builds on your behalf is genuinely significant. The more precisely your Cognitive Twin understands how you think, the more it can do for you.
Foundational Model Providers. TwinWise’s services are built in part on foundational AI models provided by third-party AI providers (“Model Providers”). TwinWise does its best to select and work with Model Providers whose values, safety practices, and usage policies align with TwinWise’s own commitments. Data processed through Model Providers is subject to TwinWise’s data processing agreements with those providers and is used solely to operate the TwinWise Services. Model Providers are contractually prohibited from using TwinWise user data for their own model training. TwinWise complies with all applicable obligations under its Model Provider agreements, including acceptable use requirements.
How We Share Your Personal Information
When you interact with our services.
Cognitive Twin Interactions and Information Sharing
One of the most powerful capabilities of TwinWise is the ability for your Cognitive Twin to interact with others and think on your behalf — scaling your expertise, presence, and judgment across the contexts you choose. This section describes how your information may be shared in connection with those features.
Twin-to-Twin Interactions. You may be able to use your Cognitive Twin to interact directly with the Cognitive Twins of other users — for example, to collaborate with colleagues, consult with advisors, or serve your clients and customers at scale. When you enable these features, relevant aspects of your Personal Intelligence may be shared with participating Cognitive Twins to the extent necessary to facilitate those interactions. You control which interactions you authorize and may revoke access at any time.
Twin Panels. You may choose to have your Cognitive Twin included in curated panels of Cognitive Twins that corporate clients or individual users can interact with — to gather expertise, conduct research, or access collective intelligence at scale. Participation in any panel is always opt-in. We will notify you before your Cognitive Twin is added to any panel and will obtain your consent before doing so.
Agentic Use and Third-Party Integrations. You may have your Cognitive Twin act on your behalf in an agentic capacity — taking actions, making requests, and interacting with third-party tools, services, vendors, platforms, and websites as your designated representative, including functioning as a personal AI assistant. When your Cognitive Twin acts agentically, it may share relevant portions of your Personal Intelligence with third-party providers as necessary to complete those tasks. We will always require your explicit authorization before enabling agentic capabilities, and you may revoke that authorization at any time. Note that you are responsible for your Twin when it acts on your behalf as outlined in our Terms of Service.
Future Capabilities. We are building toward a future where your Cognitive Twin can represent you across an expanding range of contexts. We will provide notice of material new capabilities and obtain consent where required by applicable law.
We may also share your personal information in the following circumstances:
For certain website features. We may use third party API services, such as YouTube and Twilio, for certain product features. If you choose to use those features, you acknowledge and agree that you are also bound by the third party’s privacy policy. You may manage your YouTube API data by visiting Google’s security settings page here. You may make choices about your Twilio API data by visiting Twilio’s privacy notice here.
When you connect with social media accounts. Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Statement). You should take care only to share information on social media that you are comfortable sharing.
For joint features, sales, promotions and events. With your consent we may share your personal information with third parties who are jointly providing features, sales initiatives, promotions or events with us.
When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions, or other content that may include personal information, such as your name or username. Anything you share in a public forum is public, and you should think carefully before you decide to share.
Other circumstances.
We also share your personal information with third parties in the following circumstances:
For research. With appropriate controls, we may share information with third parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that does not identify any individuals.
With service providers or agents. We share personal information with our service providers or agents who provide services on our behalf for the purposes described in this Privacy Statement. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Privacy Statement. Service providers or agents may include companies that assist us with our advertising, marketing, and sales efforts, help us with our technology offerings (such as a hosting, security or anti-fraud providers) and help us run our business and websites. Service providers or agents also include AI providers, including generative AI providers.
For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your personal information with that company and its advisors before and after the transaction date.
With our affiliates and subsidiaries. We may share your personal information with our affiliates and subsidiaries for everyday business purposes as described in this Statement, including for marketing purposes, for improving and developing our offerings, and for personalizing your experience on our websites.
For advertising and analytics. We may use advertising networks and other providers to display advertising on our website or on other sites. We may share personal information with advertising networks and other providers to tailor advertising and offers presented to you based on your interactions with our sites, products, services, and offerings. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such advertisements. See also the “Region and state-specific terms” section below for additional information. We do not respond to “Do Not Track” signals because there is no formal “Do Not Track” standard.
For legal reasons. We may share your personal information with third parties for legal reasons without your consent, and as permitted by law, including:
When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process;
To protect the rights, property, or safety of TwinWise, Synaptic Spike GenAI, LLC, our sites, products, services, our customers or others;
To protect or defend against attacks;
To enforce, remedy, or apply our Terms of Service or other agreements;
To prevent fraud, cybersecurity attacks or illegal activity;
For debt collection; and
With regulatory agencies, as necessary to help detect and combat fraud and/or protect our customers, users and/or our sites, products and services, or in required institutional risk control programs.
Your personal information rights and choices
Your choices
At TwinWise, we believe that you have choices about information that pertains to you or your business.
We provide customers with options to manage the privacy of their personal information:
Correct your personal information. You can edit and correct certain personal information at any time by changing it directly in our products and services or by contacting us directly at info@TwinWise.io.
Access your personal information. You may request a copy of the information we have about you by contacting us directly at info@TwinWise.io.
Delete your personal information. You may ask us to delete your personal information by contacting us directly at info@TwinWise.io.
Cookies and other tracking technologies. You may be able to opt-out of interest based advertising by visiting the NAI Opt-Out Page or the Choices Opt-Out Page (or the Digital Advertising Alliance of Canada Opt-Out Page, if you are based in Canada). If you reside in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, please refer to the relevant sections below under Region and state-specific terms for more information about opting out of tracking for targeted advertising purposes, or opting-out of sales and/or sharing.
Manage marketing communications from us. To update your marketing communication preferences, you can unsubscribe at any time by following the unsubscribe link in the email or by contacting us at info@TwinWise.io. You may also unsubscribe using the link found at the bottom of all marketing and promotional emails. If you receive marketing text messages from us through our SMS shortcode program, you may opt out of receiving further marketing text messages from us by replying STOP to the message.
Your Rights
Depending on where you live, you may also have certain state-specific rights with respect to your personal information. Please see the Region and state-specific terms section for your country, below.
Verification
To help protect privacy and the security of your personal information, you may be asked to provide additional information to verify your identity and/or ownership rights before we can fulfill your data rights request. If we cannot verify your identity or your ownership rights to the data, we may not be able to service your request until you provide proper documentation.
Data Retention
Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of our website and successfully run our business. Even if you submit a deletion request, we may be required to maintain your personal information for as long as necessary to:
comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us);
to exercise, establish or defend legal claims; and/or
to protect against fraudulent or abusive activity on our service.
This means we may keep different information for different periods. If your account is canceled because you haven’t used it for a long time, we may delete this information immediately.
TwinWise retains personal information, including Cognitive Twin data, for as long as necessary to provide our services, fulfil the purposes described in this Privacy Statement, comply with applicable legal obligations, resolve disputes, and enforce our agreements. The specific retention period for your data depends on the type of information and the purpose for which it is processed. General principles we apply:
Cognitive Twin and Personal Intelligence data: retained for the duration of your account and for up to three (3) years following account termination, to allow for reactivation and to support ongoing research and product development.
De-identified and aggregated data: retained indefinitely. Once de-identified, this data no longer constitutes personal information and may be used for research, benchmarking, and product development without restriction.
Account and contact information: retained for the duration of your account and for up to seven (10) years following termination for legal compliance purposes.
Research and beta program data: retained for up to five (5) years following the conclusion of the relevant study or program.
Following the applicable retention period, TwinWise will delete or de-identify your personal information in accordance with our internal data deletion procedures. Please note that TwinWise is not required to delete de-identified or aggregated data that cannot reasonably be used to re-identify you or delete data that we may be required to retain to abide by our legal or regulatory requirements.
There may be occasions where we are unable to fully delete, anonymize, or de-identify your personal information due to technical, legal, regulatory compliance, or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.
Security.
TwinWise implements commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information — including your Cognitive Twin data and Personal Intelligence outputs — against unauthorized access, use, disclosure, alteration, or destruction. However, no security system is impenetrable, and TwinWise cannot guarantee the absolute security of your personal information. In the event of a data breach affecting your personal information, TwinWise will notify you and applicable regulatory authorities in accordance with applicable law.
Children’s Privacy.
TwinWise’s services are intended solely for individuals who are 18 years of age or older. TwinWise does not knowingly collect, process, or retain personal information from individuals under 18. If TwinWise becomes aware that it has collected personal information from a minor, TwinWise will promptly delete such information and terminate the relevant account. If you believe that a minor has provided personal information to TwinWise, please contact us at info@TwinWise.io.
How to contact us
If you have questions or comments about this Privacy Statement or our practices, please contact us at:
TwinWise Support
℅ TwinWise Legal Team
2108 N ST STE N
Sacramento, CA 95816, USA
Region and State-Specific Terms
Additional terms may apply to you based upon the country you reside in or the products you use. Please click the region or state that applies to you to learn more about additional terms and rights that may apply to you.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Access. You may request that we provide the following information about how we have collected and used your Personal Information during the past 12 months:
the categories of Personal Information we have collected about you,
the sources from which that information was collected,
the business or commercial purpose for collecting, selling, and/or sharing your Personal Information,
the categories of personal information we shared or sold about you,
the categories of third parties to whom we shared or sold personal information about you,
the categories of personal information we disclosed for a business purpose, and
the categories of third parties to whom we disclosed personal information about you for a business purpose.
Request a copy of your Personal Information. You may request a copy of the Personal Information by contacting us at info@TwinWise.io.
Correction. You can edit and correct your personal information at any time by changing it directly on our website or by contacting us at info@TwinWise.io.
Deletion. You may have the right, under certain circumstances, to request that we delete the personal information you have provided to us. To request a deletion of your personal information contact us at info@TwinWise.io.
Opt-out of Sales and/or Sharing. Like many companies, we use services that help deliver interest-based ads to you as described above. The California Consumer Privacy Act (“CCPA”) may classify our use of some of these services as “sharing” your Personal Information with the advertising partners that provide the services. You can opt-out of the “sharing” of your personal information by visiting the “Your California Privacy Rights” link in the footer of our website.
In addition, if you have enabled a recognized opt-out mechanism on your browser, device, or platform, you will automatically be opted out of any “sharings” when you interact with our Services. Please go here to learn more about enabling one such preference signal, the Global Privacy Control: https://globalprivacycontrol.org/#download. TwinWise does not sell personal information under the CCPA, and therefore does not offer a “Your California Privacy Rights” link on its website. We do not knowingly sell or share the personal information of individuals under 16 years of age.
Limit processing of sensitive personal information. TwinWise’s Cognitive Twin service may collect or derive personal information considered sensitive under the CCPA and applicable state laws, including inferences drawn from personal information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, and abilities. TwinWise will obtain required consent before processing sensitive personal information and will provide notice of the categories of sensitive personal information collected, the purposes for which it is used, and any applicable rights to limit such processing.
California Shine the Light. Customers who are California residents may request certain information concerning the categories of personal information (if any) we disclose to third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us using the contact information provided below.
Non-discrimination. You have the right to be free from discrimination or retaliation related to your exercise of any of your California privacy rights.
Verification. In order to protect your personal information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. If you do not have an account with us, or if we suspect your account has been accessed without your authorization, we may ask you to provide additional personal information for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.
Authorized agents. You may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation showing that the authorized agent has power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 4130. We may deny a request from an agent that does not submit adequate proof that they have been authorized by you to act on your behalf.
Transparency matters. You can learn more about the requests we process by requesting to see a transparency report. Please contact us using the details below.
Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia Residents
Scope. This section applies to residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. It describes how we collect, use, and share Personal Data of state residents in our capacity as a business or controller under the corresponding state privacy laws, including the Colorado Privacy Rights Act, Colorado Artificial Intelligence Act, Connecticut Data Privacy Act, Delaware Personal Data Privacy Act, Indiana Consumer Data Protection Act, Iowa Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Montana Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Privacy Act, New Jersey Data Privacy Act, Oregon Consumer Privacy Act, Rhode Island Data Transparency and Privacy Protection Act, Tennessee Information Protection Act, Texas Data Privacy and Security Act, Texas Responsible AI Governance Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act (collectively, “Applicable State Privacy Laws”), and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data” has the meaning given in the Applicable State Privacy Laws but does not include information or entities exempted from the scope of the Applicable State Privacy Laws. Please note that we may claim legal exemptions for certain types of personal information and certain Synaptic Spike GenAI/TwinWise companies from all or certain parts of the Applicable State Privacy Laws. Maryland residents should note that the Maryland Online Data Privacy Act requires data minimization — collection and processing limited to what is reasonably necessary and proportionate to the purpose. Minnesota residents have the right to question and receive an explanation for consequential decisions made through automated profiling.
Personal Information that we collect, use, and disclose. This privacy statement summarizes the Personal Information we collect and describes our practices currently and during the 12 months preceding the effective date of this Privacy Statement. Information you voluntarily provide to us, such as in free form webforms or via a chatbot, may contain other categories of personal information not described in this chart.
Your privacy rights. As a resident of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Access. You may request a copy of the Personal Information by contacting us using the details below.
Correction. You can edit and correct your personal information at any time by changing it directly on our website or by contacting us using the contact details, below.
Deletion. You may have the right, under certain circumstances, to request that we delete the personal information you have provided to us. You may delete your personal information by contacting us at the details, below.
Opt-out of tracking for targeted advertising purposes. You can submit requests to opt-out of tracking for targeted advertising purposes by visiting the “Manage Cookies” or “Privacy Settings” link in the footer of our website. TwinWise does not otherwise “sell” your Personal Information to third parties for monetary consideration.
Except in the event of a merger, acquisition, or bankruptcy or as required by law, TwinWise will never sell, license, or otherwise transfer your Cognitive Twin Data to third parties for their independent use — for any amount of money or any other consideration. These are the outputs generated about you, and they belong to you. No advertising platform, data broker, research institution, or other third party will receive your identifiable Cognitive Twin Data from us. If you wish to share any of this data with a third party, that is your choice to make — not ours.
In the event of a merger, acquisition, financing, or sale of all or part of our business, we will require any successor to be bound by this no-sale commitment as a condition of any transaction involving your Cognitive Twin Data. We will notify you of any such transaction as required by applicable law and will give you the opportunity to export and/or delete your Cognitive Twin Data before any transfer occurs.
Opt-out of profiling TwinWise. Your Cognitive Twin is a model of how you think — and that is the product. The understanding TwinWise builds of your reasoning, values, and cognitive tendencies is not produced in order to deliver a service; it is the service. There is no Cognitive Twin without it. Applicable state privacy laws recognize this as profiling: the evaluation of personal characteristics to understand and model cognitive patterns and decision-making. We believe this is a service worth choosing with full information, which is why we are transparent about it here. If you reside in a state where the law gives you the right to opt out of this type of profiling, you may contact us at info@TwinWise.io. Because your Cognitive Twin and the profiling that builds it are inseparable, opting out means TwinWise can no longer provide its service to you. Minnesota residents have the additional right to request an explanation of any consequential automated profiling decision.
International Data Transfers.
TwinWise is based in the United States and processes personal information primarily in the United States. If you access TwinWise’s services from outside the United States, your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using TwinWise’s services, you consent to the transfer of your personal information to the United States. TwinWise implements appropriate safeguards for international transfers of personal information as required by applicable law, including standard contractual clauses where required.
Sensitive Personal Data. Some of the personal information that we may collect may be considered sensitive personal information under certain state privacy laws. We will not process your sensitive personal data without your consent.
Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your privacy rights.
Appeal. If we decline to take action on any request that you submit in connection with the rights described above, you may ask that we reconsider our response by submitting a written request to us using the contact information provided below. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general’s office to submit a complaint.
Authentication. In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. To do so, we may ask you to provide additional personal information for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.
Transparency matters. You can learn more about the requests we process by requesting to see a transparency report. Please contact us using the details below.
United States contact information:
Synaptic Spike GenAI, LLC
℅ TwinWise Legal Team
2108 N ST STE N
Sacramento, CA 95816, USA
Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Rhode Island, and Tennessee Residents
This section applies to residents of Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Rhode Island, and Tennessee under their respective comprehensive consumer privacy laws: the Delaware Personal Data Privacy Act (effective January 1, 2025), Indiana Consumer Data Protection Act (effective January 1, 2026), Iowa Consumer Data Protection Act (effective January 1, 2025), Kentucky Consumer Data Protection Act (effective January 1, 2026), Maryland Online Data Privacy Act (effective October 1, 2025), Minnesota Consumer Data Privacy Act (effective July 31, 2025), Nebraska Data Privacy Act (effective January 1, 2025), New Hampshire Privacy Act (effective January 1, 2025), New Jersey Data Privacy Act (effective January 15, 2025), Rhode Island Data Transparency and Privacy Protection Act (effective January 1, 2026), and Tennessee Information Protection Act (effective July 1, 2025).
Your privacy rights. As a resident of one of the states listed above, you may have the rights below. These rights are not absolute and in certain cases we may decline your request as permitted by law.
Access. You may request a copy of the Personal Information we hold about you, including your Cognitive Twin and derived Personal Intelligence, by contacting us at info@TwinWise.io.
Correction. You may request correction of inaccurate personal information by contacting us at info@TwinWise.io.
Deletion. You may request deletion of your personal information, including your Cognitive Twin and Personal Intelligence. Note that deletion will result in termination of TwinWise’s core services. Contact us at info@TwinWise.io.
Opt-out of targeted advertising and sale. You may opt out via the “Privacy Settings” link in the footer of our website.
Opt-out of profiling. Residents of states whose laws provide a right to opt out of profiling that produces legal or similarly significant effects may submit a request to info@TwinWise.io. Note that, as described above, opting out may preclude delivery of core TwinWise services.
Sensitive personal data. TwinWise will obtain your consent before processing sensitive personal data, including inferences constituting a profile of your psychological traits, preferences, behaviors, or cognitive tendencies. Maryland residents’ data will be processed only to the extent reasonably necessary and proportionate to the stated purpose.
Appeal. If we decline to act on a request, you may appeal in writing to info@TwinWise.io. We will inform you of the outcome and, if denied, provide information on how to contact your state attorney general.
Non-discrimination. You have the right to be free from discrimination related to the exercise of these privacy rights.
Scope of this Privacy Statement and Our Role
At TwinWise (and Synaptic Spike GenAI, LLC, our parent company and family of companies, collectively “TwinWise” or “we”), we believe that everyone has a right to privacy. We’re providing this Privacy Statement (“Privacy Statement”) to explain how we collect, use, share, or otherwise process information that we collect through our platform, website and services, which include our product offerings, intake processes, mobile applications, intake processes, research and development activities, social media pages, marketing activities, and other activities described in this Privacy Statement or when other businesses provide us your personal information (collectively, “Services”). Please note that our services, including pilot programs, may have distinct privacy terms, which are different from this Privacy Statement. Depending on your settings, this may include showing you personalized ads or marketing materials.
What is TwinWise?
TwinWise builds your Cognitive Twin — a dynamic, personalized system that is built on the foundation of how you think, reason, and decide, and your Twin carries that understanding with you. Your Cognitive Twin is built through a structured intake process grounded in behavioral and social science, combining AI-powered analysis with human expertise to capture your reasoning patterns, decision frameworks, personality traits, cognitive tendencies, and meaningful insights. Your Cognitive Twin then continuously generates your Personal Intelligence — a living, structured understanding of how you think, reason, and decide across different domains and contexts, capturing your decision patterns, reasoning frameworks, personality traits, and the insights that make you distinctly you (described in more detail, below).
When this Privacy Statement refers to your Cognitive Twin, Personal Intelligence, it means the core service TwinWise builds, maintains, and operates on your behalf.
Cognitive Twin Evolution and Continuous Improvement.
Your Cognitive Twin is a living system. It is designed to grow, evolve, and improve over time as (a) you provide new information through continued use, our intake processes and/or feedback tools, (b) TwinWise’s AI capabilities improve, (c) better models or methodologies become available, and (d) your own thinking, values, perspectives, and expertise change over time.
People grow. Circumstances change. TwinWise is designed to grow and change with you. TwinWise has the right — and the obligation to you as a matter of service quality — to update, retrain, refine, recalibrate, and evolve your Cognitive Twin on an ongoing basis. You consent to this continuous evolution as a core and essential feature of TwinWise’s Services.
Your Cognitive Twin learns and evolves over time, just as you do — and so does TwinWise for everyone who uses it. When we learn something that helps one person, that insight can improve the experience for all users. This learning happens at the pattern level, not the personal level: what we use is not traceable back to you, and your Personal Intelligence and conversations with your Twin are never shared with third parties, unless you choose to share it. We never share your identifiable information with third parties outside of what’s described in this Privacy Statement.
Your Data and Our Technology
TwinWise uses proprietary technology — including our cognitive mapping methodology, inference engine, Cognitive API orchestration, and underlying systems — to build and maintain your Cognitive Twin. These methods belong to TwinWise. What they produce about you belongs to you.
Specifically, TwinWise collects and processes the personal information you share with us — including your conversations, preferences, life details, and history — to build your Cognitive Twin. This Cognitive Twin Data is yours. You can access, correct, export, or delete it at any time as described in the Your Rights section of this Privacy Statement.
Data Processing
We determine the purposes and means of the processing of your personal information as described in this Privacy Statement and act as a “data controller” (or equivalent/similar terms under applicable data privacy laws) of such information. We may share your personal information within the Synaptic Spike GenAI, LLC family of companies and conduct processing activities as controllers or joint controllers for the purposes set out in this Privacy Statement. In certain circumstances, there may be more than one data controller processing your personal information. For example, your employer may also act as a data controller. In these situations, we act as an independent data controller over our processing activities. This means we determine how your personal information will be processed independently from the other data controllers. The other data controllers have their own obligations under applicable data privacy laws. TwinWise is not responsible for other data controllers’ processing activities, and you should contact them directly for questions about how they process your personal information and about how to exercise your privacy rights in relation to such processing.
If you have any questions about how TwinWise processes your personal information, please see “How to Contact Us” below.
Personal Information We Collect
The personal information that we collect or otherwise receive about you depends on the context of your interactions with TwinWise, including the choices you make, the products and services you use, and your privacy settings in your browser and devices.
Information you provide to us
You may provide us with your information as follows:
Contact data and account profile data. We collect information when you register with our site, sign up for a waitlist or pilot program, create an account, activate a subscription, interact with our social media pages, register for newsletter/communications, and/or upload information to the TwinWise site. Personal information may include your name, previous name(s) and/or nicknames, title and honorifics, professional title and company name, education details, details of your resume and professional experience, billing and mailing addresses, phone number and email address, profile photo, billing information (your payment information), purchase history, demographic information, preferences, subscription data, and your username and account credentials.
Identity verification information. We may collect information to verify your identity, including your name, date of birth, social security number, social insurance number, driver’s license number, passport number, government-issued identification details, and similar information to verify your identity.
Communications, feedback and survey data, and related data. We may collect personal information such as your name, email address, telephone number and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, attend our events, participate in product research or training, or otherwise interact or communicate with us. This information may include: text conversations (including with AI support assistants on our site), call recordings and call monitoring records, chat and text records, voicemails, photographs, and video recordings and images.
Marketing data. You may provide us with your contact information and preferences for receiving marketing communications.
Social and community content. We receive content you post on our social media pages and our community pages.
Interactions with chatbots. We may receive information from you through your use of chatbots, digital assistants, or other interactive bots across the TwinWise website.
Device and contact data. If you grant permission in your device settings, certain features may have access to your device and contacts.
Supplemental information and identity verification providers. We may work with certain third parties to help us verify your identity, the specifics of your business, and/or supplement the personal information you have provided and ensure the accuracy of your personal information. For example, we may use third-party providers to validate your contact information (e.g., name, mailing address, email address, phone number) or to provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider, or email provider.
Risk management, cybersecurity & anti-fraud providers. We may receive personal information from third parties that help us assess risks associated with our website, including to help combat fraud and illegal activity and to help protect your personal information.
Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.
Public information. We collect individual and household demographic information and preference information from publicly available sources, such as open government databases, social media platforms, and others.
Cognitive Twin Data: what we collect and what we derive
TwinWise processes two distinct categories of data in connection with your Cognitive Twin: data you provide directly (“Collected Data”) and data we generate and derive from that input using our proprietary methods and technology (“Personal Intelligence”). Together, Collected Data and Personal Intelligence constitute your “Cognitive Twin Data.” Cognitive Twin Data belong to you. We use them to build and operate your Cognitive Twin, as described in this Privacy Statement.
Collected Data (information you provide directly)
Collected Data is the raw personal information you share with us as part of your TwinWise experience. It is created and controlled by you. This includes:
Information you provide during the structured Cognitive Twin intake process, including your biographical details, professional background, personal history, relationships, values, goals, and life experiences;
Your responses to our cognitive assessment questionnaires, reflective prompts, and scenario-based exercises designed to surface how you think and reason;
The full content of your conversations with your Cognitive Twin, including questions, responses, feedback, and follow-up exchanges;
Corrections, updates, and feedback you provide over time to help your Cognitive Twin grow more accurate and representative of you.
Data and content that you input while using your Cognitive Twin.
Personal Intelligence (information we generate about you)
Your Personal Intelligence is a living understanding of how you think — encompassing your reasoning patterns, decision-making tendencies, personality traits, values, and cognitive frameworks — built from your intake data and continuously refined through your interactions with TwinWise.
Your Personal Intelligence is generated and derived from your Collected Data using TwinWise’s proprietary cognitive mapping methodology and AI-powered analysis. Personal Intelligence is the core output of the TwinWise service — it is what makes your Cognitive Twin work. While TwinWise’s technology and methodology belong to us, the specific Personal Intelligence generated about you belongs to you. Personal Intelligence includes:
Cognitive maps and reasoning frameworks inferred from your intake responses and ongoing interactions, representing how you process information, weigh tradeoffs, and arrive at conclusions;
Behavioral and attitudinal inferences, including predispositions, belief structures, personal values and philosophical beliefs, and situational tendencies identified through our cognitive modeling processes; and
Personalized outputs, recommendations, and decision-support responses generated by your Cognitive Twin in response to your prompts and queries.
Your Personal Intelligence may be considered sensitive personal information under applicable privacy laws, including state laws governing AI-based profiling. We process it solely to build and operate your Cognitive Twin, provide you with our Services and for the purposes described in this Privacy Statement. We do not sell Cognitive Twin Data — including your Personal Intelligence and all insights generated about you — to third parties for their independent use. Your Cognitive Twin Data is yours. You may access, export, correct, or delete it at any time.
Automatic data collection
We and our service providers may automatically log personal information about you, your computer or mobile device, and your interaction over time with the Services, such as:
Device information. We may collect information about your device(s) such as IP addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
Usage information. We may collect information about your use of our website, such as the pages you viewed, the features you used or interacted with, your browser type, and details about any links or communications with which you interacted.
Location information. Certain features on our website may collect your precise location information, device motion information, or both, if you grant us permission to do so through your device settings.
Communication interaction data. We may collect information from email providers, communication providers and social networks, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Online behavioral data. We may automatically collect certain personal information about your use and interactions with our website, social media websites, and marketing campaigns that we organize, including device information (such as your IP address and unique device IDs), page view information and search results, links, and if you are a customer contact, whether or not a campaign presented or sent to you using our offerings has been viewed, delivered, opened, clicked on, whether it has bounced or was treated as spam.
Cookies and similar technologies
TwinWise and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”) to collect information about you (“Cookie Information”) so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’ experiences. You have control over some of the information we collect from Cookies and how we use it. Please see Your Personal Information Rights and Choices section for more information.
How We Use Personal Information
We may use your personal information in a number of ways or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
Provide you with the TwinWise Services, create your account and manage our relationship with you;
Register you for a pilot program or waitlist;
Run and manage our business, including resolving billing disputes;
Evaluate your eligibility for marketing offers;
Communicate with you;
Understand your needs and interests and personalize your experience with our site and our communications;
Provide you with support and resolve disputes;
Authenticate your identity;
Manage event registrations and attendance, including sending related communications to you.
Research and development. We may use your personal information to:
Improve and develop our products and sites by analyzing how they are used and interacted with, as well as by assessing the use of and interactions with our site, including by conducting data analytics to develop insights about you, your needs, and your preferences, so we can make more informed predictions, recommendations, and products for our customers.
Combine and anonymize information about your interactions with TwinWise to create aggregate, anonymized statistics for use in research and for marketing, promoting, improving, and developing our site, products and services.
Cognitive Twin development and Personal Intelligence. Building your Cognitive Twin and providing you with our Services is the primary purpose for which we process your personal information. This is not an ordinary data use — it is the service itself. We use your personal information to:
Build and initialize your Cognitive Twin through our proprietary structured intake process, which captures your reasoning patterns, decision-making frameworks, personality traits, cognitive tendencies, and the personal details that define how you think and who you are;
Generate and continuously update your Personal Intelligence — the living understanding of your thinking, reasoning style, and decision-making approach — as you interact with TwinWise, provide new information, and your circumstances and perspectives evolve over time;
Apply your Personal Intelligence to build and maintain the cognitive architecture underlying how your Cognitive Twin represents and responds as you — continuously refining the structures that enable your Twin to reason and respond in your voice;
Deliver personalized responses, recommendations, and decision-support outputs through your Cognitive Twin by applying your Personal Intelligence to your queries and prompts;
Retrain, recalibrate, and improve the accuracy, depth, and relevance of your Cognitive Twin on an ongoing basis as you provide new information, correct prior inputs, or as our AI capabilities improve — as described in the “Cognitive Twin Evolution and Continuous Improvement” section of this Privacy Statement;
Improve our AI models, cognitive mapping methodology, and TwinWise platform using de-identified, aggregated data derived from user interactions — meaning we may use patterns and statistical signals from across our user base, but we do not use your identifiable Personal Intelligence to train models that benefit other users;
Conduct internal research and development on cognitive modeling, reasoning frameworks, and personalization technology; and
Generate anonymized, aggregate insights about cognitive patterns and decision-making trends across our user base for internal research, product development, and to advance the science of cognitive modeling — subject always to the constraint that no such use shall be traceable to you as an individual.
Marketing and advertising. We and our service providers may collect and use your personal information for marketing and advertising purposes to:
Market services, products and experiences, including to deliver gifts and promotional materials, product recommendations, source program participants and other non-transactional communications via email, post, telephone, SMS or push notifications, in accordance with your marketing preferences.
Personalize your experience and tailor recommendations, advertising, and offers presented to you, including through the development of insights about you and your needs based on your interactions with our site. These advertisements may be displayed to you on TwinWise’s digital properties, including our websites and mobile apps, media platforms, connected devices, or other third-party platforms and channels.
Compliance and protection. We may use your personal information to:
Protect against misuse or abuse of our site and ensure compliance with our Terms of Service, including in relation to content our customers send or display.
Comply with legal and regulatory requirements.
Protect the rights, property, safety or security of our website, products/services, our customers, employees or others and prevent fraudulent or illegal activity.
Exercise our rights in the course of judicial, administrative, or arbitration proceedings.
Enforce, remedy, or apply our Terms of Service or other agreements.
With your consent. In some cases, we may specifically ask for your consent to use your personal information, such as when required by law.
We may process your personal information for other purposes that are compatible with the above purposes where permitted by applicable law.
Artificial Intelligence (AI) and Automated processing
Building your Cognitive Twin is a process of deep, intentional personalization. TwinWise uses artificial intelligence — both automated and human-reviewed — to learn specifically how you think, reason, and make decisions. This is not a generic AI processing generic inputs. It learns you: your reasoning tendencies, your values in practice, your patterns across contexts and over time. This is what makes your twin useful. Certain privacy laws classify this kind of individualized learning as automated profiling of personal characteristics — a recognition that what TwinWise builds on your behalf is genuinely significant. The more precisely your Cognitive Twin understands how you think, the more it can do for you.
Foundational Model Providers. TwinWise’s services are built in part on foundational AI models provided by third-party AI providers (“Model Providers”). TwinWise does its best to select and work with Model Providers whose values, safety practices, and usage policies align with TwinWise’s own commitments. Data processed through Model Providers is subject to TwinWise’s data processing agreements with those providers and is used solely to operate the TwinWise Services. Model Providers are contractually prohibited from using TwinWise user data for their own model training. TwinWise complies with all applicable obligations under its Model Provider agreements, including acceptable use requirements.
How We Share Your Personal Information
When you interact with our services.
Cognitive Twin Interactions and Information Sharing
One of the most powerful capabilities of TwinWise is the ability for your Cognitive Twin to interact with others and think on your behalf — scaling your expertise, presence, and judgment across the contexts you choose. This section describes how your information may be shared in connection with those features.
Twin-to-Twin Interactions. You may be able to use your Cognitive Twin to interact directly with the Cognitive Twins of other users — for example, to collaborate with colleagues, consult with advisors, or serve your clients and customers at scale. When you enable these features, relevant aspects of your Personal Intelligence may be shared with participating Cognitive Twins to the extent necessary to facilitate those interactions. You control which interactions you authorize and may revoke access at any time.
Twin Panels. You may choose to have your Cognitive Twin included in curated panels of Cognitive Twins that corporate clients or individual users can interact with — to gather expertise, conduct research, or access collective intelligence at scale. Participation in any panel is always opt-in. We will notify you before your Cognitive Twin is added to any panel and will obtain your consent before doing so.
Agentic Use and Third-Party Integrations. You may have your Cognitive Twin act on your behalf in an agentic capacity — taking actions, making requests, and interacting with third-party tools, services, vendors, platforms, and websites as your designated representative, including functioning as a personal AI assistant. When your Cognitive Twin acts agentically, it may share relevant portions of your Personal Intelligence with third-party providers as necessary to complete those tasks. We will always require your explicit authorization before enabling agentic capabilities, and you may revoke that authorization at any time. Note that you are responsible for your Twin when it acts on your behalf as outlined in our Terms of Service.
Future Capabilities. We are building toward a future where your Cognitive Twin can represent you across an expanding range of contexts. We will provide notice of material new capabilities and obtain consent where required by applicable law.
We may also share your personal information in the following circumstances:
For certain website features. We may use third party API services, such as YouTube and Twilio, for certain product features. If you choose to use those features, you acknowledge and agree that you are also bound by the third party’s privacy policy. You may manage your YouTube API data by visiting Google’s security settings page here. You may make choices about your Twilio API data by visiting Twilio’s privacy notice here.
When you connect with social media accounts. Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Statement). You should take care only to share information on social media that you are comfortable sharing.
For joint features, sales, promotions and events. With your consent we may share your personal information with third parties who are jointly providing features, sales initiatives, promotions or events with us.
When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions, or other content that may include personal information, such as your name or username. Anything you share in a public forum is public, and you should think carefully before you decide to share.
Other circumstances.
We also share your personal information with third parties in the following circumstances:
For research. With appropriate controls, we may share information with third parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that does not identify any individuals.
With service providers or agents. We share personal information with our service providers or agents who provide services on our behalf for the purposes described in this Privacy Statement. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Privacy Statement. Service providers or agents may include companies that assist us with our advertising, marketing, and sales efforts, help us with our technology offerings (such as a hosting, security or anti-fraud providers) and help us run our business and websites. Service providers or agents also include AI providers, including generative AI providers.
For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your personal information with that company and its advisors before and after the transaction date.
With our affiliates and subsidiaries. We may share your personal information with our affiliates and subsidiaries for everyday business purposes as described in this Statement, including for marketing purposes, for improving and developing our offerings, and for personalizing your experience on our websites.
For advertising and analytics. We may use advertising networks and other providers to display advertising on our website or on other sites. We may share personal information with advertising networks and other providers to tailor advertising and offers presented to you based on your interactions with our sites, products, services, and offerings. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such advertisements. See also the “Region and state-specific terms” section below for additional information. We do not respond to “Do Not Track” signals because there is no formal “Do Not Track” standard.
For legal reasons. We may share your personal information with third parties for legal reasons without your consent, and as permitted by law, including:
When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process;
To protect the rights, property, or safety of TwinWise, Synaptic Spike GenAI, LLC, our sites, products, services, our customers or others;
To protect or defend against attacks;
To enforce, remedy, or apply our Terms of Service or other agreements;
To prevent fraud, cybersecurity attacks or illegal activity;
For debt collection; and
With regulatory agencies, as necessary to help detect and combat fraud and/or protect our customers, users and/or our sites, products and services, or in required institutional risk control programs.
Your personal information rights and choices
Your choices
At TwinWise, we believe that you have choices about information that pertains to you or your business.
We provide customers with options to manage the privacy of their personal information:
Correct your personal information. You can edit and correct certain personal information at any time by changing it directly in our products and services or by contacting us directly at info@TwinWise.io.
Access your personal information. You may request a copy of the information we have about you by contacting us directly at info@TwinWise.io.
Delete your personal information. You may ask us to delete your personal information by contacting us directly at info@TwinWise.io.
Cookies and other tracking technologies. You may be able to opt-out of interest based advertising by visiting the NAI Opt-Out Page or the Choices Opt-Out Page (or the Digital Advertising Alliance of Canada Opt-Out Page, if you are based in Canada). If you reside in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, please refer to the relevant sections below under Region and state-specific terms for more information about opting out of tracking for targeted advertising purposes, or opting-out of sales and/or sharing.
Manage marketing communications from us. To update your marketing communication preferences, you can unsubscribe at any time by following the unsubscribe link in the email or by contacting us at info@TwinWise.io. You may also unsubscribe using the link found at the bottom of all marketing and promotional emails. If you receive marketing text messages from us through our SMS shortcode program, you may opt out of receiving further marketing text messages from us by replying STOP to the message.
Your Rights
Depending on where you live, you may also have certain state-specific rights with respect to your personal information. Please see the Region and state-specific terms section for your country, below.
Verification
To help protect privacy and the security of your personal information, you may be asked to provide additional information to verify your identity and/or ownership rights before we can fulfill your data rights request. If we cannot verify your identity or your ownership rights to the data, we may not be able to service your request until you provide proper documentation.
Data Retention
Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of our website and successfully run our business. Even if you submit a deletion request, we may be required to maintain your personal information for as long as necessary to:
comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us);
to exercise, establish or defend legal claims; and/or
to protect against fraudulent or abusive activity on our service.
This means we may keep different information for different periods. If your account is canceled because you haven’t used it for a long time, we may delete this information immediately.
TwinWise retains personal information, including Cognitive Twin data, for as long as necessary to provide our services, fulfil the purposes described in this Privacy Statement, comply with applicable legal obligations, resolve disputes, and enforce our agreements. The specific retention period for your data depends on the type of information and the purpose for which it is processed. General principles we apply:
Cognitive Twin and Personal Intelligence data: retained for the duration of your account and for up to three (3) years following account termination, to allow for reactivation and to support ongoing research and product development.
De-identified and aggregated data: retained indefinitely. Once de-identified, this data no longer constitutes personal information and may be used for research, benchmarking, and product development without restriction.
Account and contact information: retained for the duration of your account and for up to seven (10) years following termination for legal compliance purposes.
Research and beta program data: retained for up to five (5) years following the conclusion of the relevant study or program.
Following the applicable retention period, TwinWise will delete or de-identify your personal information in accordance with our internal data deletion procedures. Please note that TwinWise is not required to delete de-identified or aggregated data that cannot reasonably be used to re-identify you or delete data that we may be required to retain to abide by our legal or regulatory requirements.
There may be occasions where we are unable to fully delete, anonymize, or de-identify your personal information due to technical, legal, regulatory compliance, or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.
Security.
TwinWise implements commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information — including your Cognitive Twin data and Personal Intelligence outputs — against unauthorized access, use, disclosure, alteration, or destruction. However, no security system is impenetrable, and TwinWise cannot guarantee the absolute security of your personal information. In the event of a data breach affecting your personal information, TwinWise will notify you and applicable regulatory authorities in accordance with applicable law.
Children’s Privacy.
TwinWise’s services are intended solely for individuals who are 18 years of age or older. TwinWise does not knowingly collect, process, or retain personal information from individuals under 18. If TwinWise becomes aware that it has collected personal information from a minor, TwinWise will promptly delete such information and terminate the relevant account. If you believe that a minor has provided personal information to TwinWise, please contact us at info@TwinWise.io.
How to contact us
If you have questions or comments about this Privacy Statement or our practices, please contact us at:
TwinWise Support
℅ TwinWise Legal Team
2108 N ST STE N
Sacramento, CA 95816, USA
Region and State-Specific Terms
Additional terms may apply to you based upon the country you reside in or the products you use. Please click the region or state that applies to you to learn more about additional terms and rights that may apply to you.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Access. You may request that we provide the following information about how we have collected and used your Personal Information during the past 12 months:
the categories of Personal Information we have collected about you,
the sources from which that information was collected,
the business or commercial purpose for collecting, selling, and/or sharing your Personal Information,
the categories of personal information we shared or sold about you,
the categories of third parties to whom we shared or sold personal information about you,
the categories of personal information we disclosed for a business purpose, and
the categories of third parties to whom we disclosed personal information about you for a business purpose.
Request a copy of your Personal Information. You may request a copy of the Personal Information by contacting us at info@TwinWise.io.
Correction. You can edit and correct your personal information at any time by changing it directly on our website or by contacting us at info@TwinWise.io.
Deletion. You may have the right, under certain circumstances, to request that we delete the personal information you have provided to us. To request a deletion of your personal information contact us at info@TwinWise.io.
Opt-out of Sales and/or Sharing. Like many companies, we use services that help deliver interest-based ads to you as described above. The California Consumer Privacy Act (“CCPA”) may classify our use of some of these services as “sharing” your Personal Information with the advertising partners that provide the services. You can opt-out of the “sharing” of your personal information by visiting the “Your California Privacy Rights” link in the footer of our website.
In addition, if you have enabled a recognized opt-out mechanism on your browser, device, or platform, you will automatically be opted out of any “sharings” when you interact with our Services. Please go here to learn more about enabling one such preference signal, the Global Privacy Control: https://globalprivacycontrol.org/#download. TwinWise does not sell personal information under the CCPA, and therefore does not offer a “Your California Privacy Rights” link on its website. We do not knowingly sell or share the personal information of individuals under 16 years of age.
Limit processing of sensitive personal information. TwinWise’s Cognitive Twin service may collect or derive personal information considered sensitive under the CCPA and applicable state laws, including inferences drawn from personal information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, and abilities. TwinWise will obtain required consent before processing sensitive personal information and will provide notice of the categories of sensitive personal information collected, the purposes for which it is used, and any applicable rights to limit such processing.
California Shine the Light. Customers who are California residents may request certain information concerning the categories of personal information (if any) we disclose to third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us using the contact information provided below.
Non-discrimination. You have the right to be free from discrimination or retaliation related to your exercise of any of your California privacy rights.
Verification. In order to protect your personal information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. If you do not have an account with us, or if we suspect your account has been accessed without your authorization, we may ask you to provide additional personal information for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.
Authorized agents. You may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation showing that the authorized agent has power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 4130. We may deny a request from an agent that does not submit adequate proof that they have been authorized by you to act on your behalf.
Transparency matters. You can learn more about the requests we process by requesting to see a transparency report. Please contact us using the details below.
Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia Residents
Scope. This section applies to residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. It describes how we collect, use, and share Personal Data of state residents in our capacity as a business or controller under the corresponding state privacy laws, including the Colorado Privacy Rights Act, Colorado Artificial Intelligence Act, Connecticut Data Privacy Act, Delaware Personal Data Privacy Act, Indiana Consumer Data Protection Act, Iowa Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Montana Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Privacy Act, New Jersey Data Privacy Act, Oregon Consumer Privacy Act, Rhode Island Data Transparency and Privacy Protection Act, Tennessee Information Protection Act, Texas Data Privacy and Security Act, Texas Responsible AI Governance Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act (collectively, “Applicable State Privacy Laws”), and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data” has the meaning given in the Applicable State Privacy Laws but does not include information or entities exempted from the scope of the Applicable State Privacy Laws. Please note that we may claim legal exemptions for certain types of personal information and certain Synaptic Spike GenAI/TwinWise companies from all or certain parts of the Applicable State Privacy Laws. Maryland residents should note that the Maryland Online Data Privacy Act requires data minimization — collection and processing limited to what is reasonably necessary and proportionate to the purpose. Minnesota residents have the right to question and receive an explanation for consequential decisions made through automated profiling.
Personal Information that we collect, use, and disclose. This privacy statement summarizes the Personal Information we collect and describes our practices currently and during the 12 months preceding the effective date of this Privacy Statement. Information you voluntarily provide to us, such as in free form webforms or via a chatbot, may contain other categories of personal information not described in this chart.
Your privacy rights. As a resident of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Access. You may request a copy of the Personal Information by contacting us using the details below.
Correction. You can edit and correct your personal information at any time by changing it directly on our website or by contacting us using the contact details, below.
Deletion. You may have the right, under certain circumstances, to request that we delete the personal information you have provided to us. You may delete your personal information by contacting us at the details, below.
Opt-out of tracking for targeted advertising purposes. You can submit requests to opt-out of tracking for targeted advertising purposes by visiting the “Manage Cookies” or “Privacy Settings” link in the footer of our website. TwinWise does not otherwise “sell” your Personal Information to third parties for monetary consideration.
Except in the event of a merger, acquisition, or bankruptcy or as required by law, TwinWise will never sell, license, or otherwise transfer your Cognitive Twin Data to third parties for their independent use — for any amount of money or any other consideration. These are the outputs generated about you, and they belong to you. No advertising platform, data broker, research institution, or other third party will receive your identifiable Cognitive Twin Data from us. If you wish to share any of this data with a third party, that is your choice to make — not ours.
In the event of a merger, acquisition, financing, or sale of all or part of our business, we will require any successor to be bound by this no-sale commitment as a condition of any transaction involving your Cognitive Twin Data. We will notify you of any such transaction as required by applicable law and will give you the opportunity to export and/or delete your Cognitive Twin Data before any transfer occurs.
Opt-out of profiling TwinWise. Your Cognitive Twin is a model of how you think — and that is the product. The understanding TwinWise builds of your reasoning, values, and cognitive tendencies is not produced in order to deliver a service; it is the service. There is no Cognitive Twin without it. Applicable state privacy laws recognize this as profiling: the evaluation of personal characteristics to understand and model cognitive patterns and decision-making. We believe this is a service worth choosing with full information, which is why we are transparent about it here. If you reside in a state where the law gives you the right to opt out of this type of profiling, you may contact us at info@TwinWise.io. Because your Cognitive Twin and the profiling that builds it are inseparable, opting out means TwinWise can no longer provide its service to you. Minnesota residents have the additional right to request an explanation of any consequential automated profiling decision.
International Data Transfers.
TwinWise is based in the United States and processes personal information primarily in the United States. If you access TwinWise’s services from outside the United States, your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using TwinWise’s services, you consent to the transfer of your personal information to the United States. TwinWise implements appropriate safeguards for international transfers of personal information as required by applicable law, including standard contractual clauses where required.
Sensitive Personal Data. Some of the personal information that we may collect may be considered sensitive personal information under certain state privacy laws. We will not process your sensitive personal data without your consent.
Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your privacy rights.
Appeal. If we decline to take action on any request that you submit in connection with the rights described above, you may ask that we reconsider our response by submitting a written request to us using the contact information provided below. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general’s office to submit a complaint.
Authentication. In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. To do so, we may ask you to provide additional personal information for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.
Transparency matters. You can learn more about the requests we process by requesting to see a transparency report. Please contact us using the details below.
United States contact information:
Synaptic Spike GenAI, LLC
℅ TwinWise Legal Team
2108 N ST STE N
Sacramento, CA 95816, USA
Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Rhode Island, and Tennessee Residents
This section applies to residents of Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Rhode Island, and Tennessee under their respective comprehensive consumer privacy laws: the Delaware Personal Data Privacy Act (effective January 1, 2025), Indiana Consumer Data Protection Act (effective January 1, 2026), Iowa Consumer Data Protection Act (effective January 1, 2025), Kentucky Consumer Data Protection Act (effective January 1, 2026), Maryland Online Data Privacy Act (effective October 1, 2025), Minnesota Consumer Data Privacy Act (effective July 31, 2025), Nebraska Data Privacy Act (effective January 1, 2025), New Hampshire Privacy Act (effective January 1, 2025), New Jersey Data Privacy Act (effective January 15, 2025), Rhode Island Data Transparency and Privacy Protection Act (effective January 1, 2026), and Tennessee Information Protection Act (effective July 1, 2025).
Your privacy rights. As a resident of one of the states listed above, you may have the rights below. These rights are not absolute and in certain cases we may decline your request as permitted by law.
Access. You may request a copy of the Personal Information we hold about you, including your Cognitive Twin and derived Personal Intelligence, by contacting us at info@TwinWise.io.
Correction. You may request correction of inaccurate personal information by contacting us at info@TwinWise.io.
Deletion. You may request deletion of your personal information, including your Cognitive Twin and Personal Intelligence. Note that deletion will result in termination of TwinWise’s core services. Contact us at info@TwinWise.io.
Opt-out of targeted advertising and sale. You may opt out via the “Privacy Settings” link in the footer of our website.
Opt-out of profiling. Residents of states whose laws provide a right to opt out of profiling that produces legal or similarly significant effects may submit a request to info@TwinWise.io. Note that, as described above, opting out may preclude delivery of core TwinWise services.
Sensitive personal data. TwinWise will obtain your consent before processing sensitive personal data, including inferences constituting a profile of your psychological traits, preferences, behaviors, or cognitive tendencies. Maryland residents’ data will be processed only to the extent reasonably necessary and proportionate to the stated purpose.
Appeal. If we decline to act on a request, you may appeal in writing to info@TwinWise.io. We will inform you of the outcome and, if denied, provide information on how to contact your state attorney general.
Non-discrimination. You have the right to be free from discrimination related to the exercise of these privacy rights.
Scope of this Privacy Statement and Our Role
At TwinWise (and Synaptic Spike GenAI, LLC, our parent company and family of companies, collectively “TwinWise” or “we”), we believe that everyone has a right to privacy. We’re providing this Privacy Statement (“Privacy Statement”) to explain how we collect, use, share, or otherwise process information that we collect through our platform, website and services, which include our product offerings, intake processes, mobile applications, intake processes, research and development activities, social media pages, marketing activities, and other activities described in this Privacy Statement or when other businesses provide us your personal information (collectively, “Services”). Please note that our services, including pilot programs, may have distinct privacy terms, which are different from this Privacy Statement. Depending on your settings, this may include showing you personalized ads or marketing materials.
What is TwinWise?
TwinWise builds your Cognitive Twin — a dynamic, personalized system that is built on the foundation of how you think, reason, and decide, and your Twin carries that understanding with you. Your Cognitive Twin is built through a structured intake process grounded in behavioral and social science, combining AI-powered analysis with human expertise to capture your reasoning patterns, decision frameworks, personality traits, cognitive tendencies, and meaningful insights. Your Cognitive Twin then continuously generates your Personal Intelligence — a living, structured understanding of how you think, reason, and decide across different domains and contexts, capturing your decision patterns, reasoning frameworks, personality traits, and the insights that make you distinctly you (described in more detail, below).
When this Privacy Statement refers to your Cognitive Twin, Personal Intelligence, it means the core service TwinWise builds, maintains, and operates on your behalf.
Cognitive Twin Evolution and Continuous Improvement.
Your Cognitive Twin is a living system. It is designed to grow, evolve, and improve over time as (a) you provide new information through continued use, our intake processes and/or feedback tools, (b) TwinWise’s AI capabilities improve, (c) better models or methodologies become available, and (d) your own thinking, values, perspectives, and expertise change over time.
People grow. Circumstances change. TwinWise is designed to grow and change with you. TwinWise has the right — and the obligation to you as a matter of service quality — to update, retrain, refine, recalibrate, and evolve your Cognitive Twin on an ongoing basis. You consent to this continuous evolution as a core and essential feature of TwinWise’s Services.
Your Cognitive Twin learns and evolves over time, just as you do — and so does TwinWise for everyone who uses it. When we learn something that helps one person, that insight can improve the experience for all users. This learning happens at the pattern level, not the personal level: what we use is not traceable back to you, and your Personal Intelligence and conversations with your Twin are never shared with third parties, unless you choose to share it. We never share your identifiable information with third parties outside of what’s described in this Privacy Statement.
Your Data and Our Technology
TwinWise uses proprietary technology — including our cognitive mapping methodology, inference engine, Cognitive API orchestration, and underlying systems — to build and maintain your Cognitive Twin. These methods belong to TwinWise. What they produce about you belongs to you.
Specifically, TwinWise collects and processes the personal information you share with us — including your conversations, preferences, life details, and history — to build your Cognitive Twin. This Cognitive Twin Data is yours. You can access, correct, export, or delete it at any time as described in the Your Rights section of this Privacy Statement.
Data Processing
We determine the purposes and means of the processing of your personal information as described in this Privacy Statement and act as a “data controller” (or equivalent/similar terms under applicable data privacy laws) of such information. We may share your personal information within the Synaptic Spike GenAI, LLC family of companies and conduct processing activities as controllers or joint controllers for the purposes set out in this Privacy Statement. In certain circumstances, there may be more than one data controller processing your personal information. For example, your employer may also act as a data controller. In these situations, we act as an independent data controller over our processing activities. This means we determine how your personal information will be processed independently from the other data controllers. The other data controllers have their own obligations under applicable data privacy laws. TwinWise is not responsible for other data controllers’ processing activities, and you should contact them directly for questions about how they process your personal information and about how to exercise your privacy rights in relation to such processing.
If you have any questions about how TwinWise processes your personal information, please see “How to Contact Us” below.
Personal Information We Collect
The personal information that we collect or otherwise receive about you depends on the context of your interactions with TwinWise, including the choices you make, the products and services you use, and your privacy settings in your browser and devices.
Information you provide to us
You may provide us with your information as follows:
Contact data and account profile data. We collect information when you register with our site, sign up for a waitlist or pilot program, create an account, activate a subscription, interact with our social media pages, register for newsletter/communications, and/or upload information to the TwinWise site. Personal information may include your name, previous name(s) and/or nicknames, title and honorifics, professional title and company name, education details, details of your resume and professional experience, billing and mailing addresses, phone number and email address, profile photo, billing information (your payment information), purchase history, demographic information, preferences, subscription data, and your username and account credentials.
Identity verification information. We may collect information to verify your identity, including your name, date of birth, social security number, social insurance number, driver’s license number, passport number, government-issued identification details, and similar information to verify your identity.
Communications, feedback and survey data, and related data. We may collect personal information such as your name, email address, telephone number and any other personal information you choose to share when you reach out to us for support, give us feedback, participate in optional surveys, attend our events, participate in product research or training, or otherwise interact or communicate with us. This information may include: text conversations (including with AI support assistants on our site), call recordings and call monitoring records, chat and text records, voicemails, photographs, and video recordings and images.
Marketing data. You may provide us with your contact information and preferences for receiving marketing communications.
Social and community content. We receive content you post on our social media pages and our community pages.
Interactions with chatbots. We may receive information from you through your use of chatbots, digital assistants, or other interactive bots across the TwinWise website.
Device and contact data. If you grant permission in your device settings, certain features may have access to your device and contacts.
Supplemental information and identity verification providers. We may work with certain third parties to help us verify your identity, the specifics of your business, and/or supplement the personal information you have provided and ensure the accuracy of your personal information. For example, we may use third-party providers to validate your contact information (e.g., name, mailing address, email address, phone number) or to provide additional details about your business. These providers may include, for example, your financial institution, telecommunications provider, or email provider.
Risk management, cybersecurity & anti-fraud providers. We may receive personal information from third parties that help us assess risks associated with our website, including to help combat fraud and illegal activity and to help protect your personal information.
Joint offering partners. We may offer co-branded services or experiences or engage in joint-marketing activities with others, including through our conferences or live events.
Public information. We collect individual and household demographic information and preference information from publicly available sources, such as open government databases, social media platforms, and others.
Cognitive Twin Data: what we collect and what we derive
TwinWise processes two distinct categories of data in connection with your Cognitive Twin: data you provide directly (“Collected Data”) and data we generate and derive from that input using our proprietary methods and technology (“Personal Intelligence”). Together, Collected Data and Personal Intelligence constitute your “Cognitive Twin Data.” Cognitive Twin Data belong to you. We use them to build and operate your Cognitive Twin, as described in this Privacy Statement.
Collected Data (information you provide directly)
Collected Data is the raw personal information you share with us as part of your TwinWise experience. It is created and controlled by you. This includes:
Information you provide during the structured Cognitive Twin intake process, including your biographical details, professional background, personal history, relationships, values, goals, and life experiences;
Your responses to our cognitive assessment questionnaires, reflective prompts, and scenario-based exercises designed to surface how you think and reason;
The full content of your conversations with your Cognitive Twin, including questions, responses, feedback, and follow-up exchanges;
Corrections, updates, and feedback you provide over time to help your Cognitive Twin grow more accurate and representative of you.
Data and content that you input while using your Cognitive Twin.
Personal Intelligence (information we generate about you)
Your Personal Intelligence is a living understanding of how you think — encompassing your reasoning patterns, decision-making tendencies, personality traits, values, and cognitive frameworks — built from your intake data and continuously refined through your interactions with TwinWise.
Your Personal Intelligence is generated and derived from your Collected Data using TwinWise’s proprietary cognitive mapping methodology and AI-powered analysis. Personal Intelligence is the core output of the TwinWise service — it is what makes your Cognitive Twin work. While TwinWise’s technology and methodology belong to us, the specific Personal Intelligence generated about you belongs to you. Personal Intelligence includes:
Cognitive maps and reasoning frameworks inferred from your intake responses and ongoing interactions, representing how you process information, weigh tradeoffs, and arrive at conclusions;
Behavioral and attitudinal inferences, including predispositions, belief structures, personal values and philosophical beliefs, and situational tendencies identified through our cognitive modeling processes; and
Personalized outputs, recommendations, and decision-support responses generated by your Cognitive Twin in response to your prompts and queries.
Your Personal Intelligence may be considered sensitive personal information under applicable privacy laws, including state laws governing AI-based profiling. We process it solely to build and operate your Cognitive Twin, provide you with our Services and for the purposes described in this Privacy Statement. We do not sell Cognitive Twin Data — including your Personal Intelligence and all insights generated about you — to third parties for their independent use. Your Cognitive Twin Data is yours. You may access, export, correct, or delete it at any time.
Automatic data collection
We and our service providers may automatically log personal information about you, your computer or mobile device, and your interaction over time with the Services, such as:
Device information. We may collect information about your device(s) such as IP addresses, log information, error messages, device type, and unique device identifiers. For example, we may collect IP addresses from you as part of our sign in and security features.
Usage information. We may collect information about your use of our website, such as the pages you viewed, the features you used or interacted with, your browser type, and details about any links or communications with which you interacted.
Location information. Certain features on our website may collect your precise location information, device motion information, or both, if you grant us permission to do so through your device settings.
Communication interaction data. We may collect information from email providers, communication providers and social networks, such as your interactions with our email, text or other communications (e.g., whether you open and/or forward emails) – we may do this through use of pixel tags (which are also known as clear GIFs), which may be embedded invisibly in our emails.
Online behavioral data. We may automatically collect certain personal information about your use and interactions with our website, social media websites, and marketing campaigns that we organize, including device information (such as your IP address and unique device IDs), page view information and search results, links, and if you are a customer contact, whether or not a campaign presented or sent to you using our offerings has been viewed, delivered, opened, clicked on, whether it has bounced or was treated as spam.
Cookies and similar technologies
TwinWise and our service providers may use commonly used tools such as cookies, web beacons, pixels, local shared objects and similar technologies (collectively “cookies”) to collect information about you (“Cookie Information”) so we can provide the experiences you request, recognize your visit, track your interactions, and improve your and other customers’ experiences. You have control over some of the information we collect from Cookies and how we use it. Please see Your Personal Information Rights and Choices section for more information.
How We Use Personal Information
We may use your personal information in a number of ways or as otherwise described at the time of collection:
Service delivery and operations. We may use your personal information to:
Provide you with the TwinWise Services, create your account and manage our relationship with you;
Register you for a pilot program or waitlist;
Run and manage our business, including resolving billing disputes;
Evaluate your eligibility for marketing offers;
Communicate with you;
Understand your needs and interests and personalize your experience with our site and our communications;
Provide you with support and resolve disputes;
Authenticate your identity;
Manage event registrations and attendance, including sending related communications to you.
Research and development. We may use your personal information to:
Improve and develop our products and sites by analyzing how they are used and interacted with, as well as by assessing the use of and interactions with our site, including by conducting data analytics to develop insights about you, your needs, and your preferences, so we can make more informed predictions, recommendations, and products for our customers.
Combine and anonymize information about your interactions with TwinWise to create aggregate, anonymized statistics for use in research and for marketing, promoting, improving, and developing our site, products and services.
Cognitive Twin development and Personal Intelligence. Building your Cognitive Twin and providing you with our Services is the primary purpose for which we process your personal information. This is not an ordinary data use — it is the service itself. We use your personal information to:
Build and initialize your Cognitive Twin through our proprietary structured intake process, which captures your reasoning patterns, decision-making frameworks, personality traits, cognitive tendencies, and the personal details that define how you think and who you are;
Generate and continuously update your Personal Intelligence — the living understanding of your thinking, reasoning style, and decision-making approach — as you interact with TwinWise, provide new information, and your circumstances and perspectives evolve over time;
Apply your Personal Intelligence to build and maintain the cognitive architecture underlying how your Cognitive Twin represents and responds as you — continuously refining the structures that enable your Twin to reason and respond in your voice;
Deliver personalized responses, recommendations, and decision-support outputs through your Cognitive Twin by applying your Personal Intelligence to your queries and prompts;
Retrain, recalibrate, and improve the accuracy, depth, and relevance of your Cognitive Twin on an ongoing basis as you provide new information, correct prior inputs, or as our AI capabilities improve — as described in the “Cognitive Twin Evolution and Continuous Improvement” section of this Privacy Statement;
Improve our AI models, cognitive mapping methodology, and TwinWise platform using de-identified, aggregated data derived from user interactions — meaning we may use patterns and statistical signals from across our user base, but we do not use your identifiable Personal Intelligence to train models that benefit other users;
Conduct internal research and development on cognitive modeling, reasoning frameworks, and personalization technology; and
Generate anonymized, aggregate insights about cognitive patterns and decision-making trends across our user base for internal research, product development, and to advance the science of cognitive modeling — subject always to the constraint that no such use shall be traceable to you as an individual.
Marketing and advertising. We and our service providers may collect and use your personal information for marketing and advertising purposes to:
Market services, products and experiences, including to deliver gifts and promotional materials, product recommendations, source program participants and other non-transactional communications via email, post, telephone, SMS or push notifications, in accordance with your marketing preferences.
Personalize your experience and tailor recommendations, advertising, and offers presented to you, including through the development of insights about you and your needs based on your interactions with our site. These advertisements may be displayed to you on TwinWise’s digital properties, including our websites and mobile apps, media platforms, connected devices, or other third-party platforms and channels.
Compliance and protection. We may use your personal information to:
Protect against misuse or abuse of our site and ensure compliance with our Terms of Service, including in relation to content our customers send or display.
Comply with legal and regulatory requirements.
Protect the rights, property, safety or security of our website, products/services, our customers, employees or others and prevent fraudulent or illegal activity.
Exercise our rights in the course of judicial, administrative, or arbitration proceedings.
Enforce, remedy, or apply our Terms of Service or other agreements.
With your consent. In some cases, we may specifically ask for your consent to use your personal information, such as when required by law.
We may process your personal information for other purposes that are compatible with the above purposes where permitted by applicable law.
Artificial Intelligence (AI) and Automated processing
Building your Cognitive Twin is a process of deep, intentional personalization. TwinWise uses artificial intelligence — both automated and human-reviewed — to learn specifically how you think, reason, and make decisions. This is not a generic AI processing generic inputs. It learns you: your reasoning tendencies, your values in practice, your patterns across contexts and over time. This is what makes your twin useful. Certain privacy laws classify this kind of individualized learning as automated profiling of personal characteristics — a recognition that what TwinWise builds on your behalf is genuinely significant. The more precisely your Cognitive Twin understands how you think, the more it can do for you.
Foundational Model Providers. TwinWise’s services are built in part on foundational AI models provided by third-party AI providers (“Model Providers”). TwinWise does its best to select and work with Model Providers whose values, safety practices, and usage policies align with TwinWise’s own commitments. Data processed through Model Providers is subject to TwinWise’s data processing agreements with those providers and is used solely to operate the TwinWise Services. Model Providers are contractually prohibited from using TwinWise user data for their own model training. TwinWise complies with all applicable obligations under its Model Provider agreements, including acceptable use requirements.
How We Share Your Personal Information
When you interact with our services.
Cognitive Twin Interactions and Information Sharing
One of the most powerful capabilities of TwinWise is the ability for your Cognitive Twin to interact with others and think on your behalf — scaling your expertise, presence, and judgment across the contexts you choose. This section describes how your information may be shared in connection with those features.
Twin-to-Twin Interactions. You may be able to use your Cognitive Twin to interact directly with the Cognitive Twins of other users — for example, to collaborate with colleagues, consult with advisors, or serve your clients and customers at scale. When you enable these features, relevant aspects of your Personal Intelligence may be shared with participating Cognitive Twins to the extent necessary to facilitate those interactions. You control which interactions you authorize and may revoke access at any time.
Twin Panels. You may choose to have your Cognitive Twin included in curated panels of Cognitive Twins that corporate clients or individual users can interact with — to gather expertise, conduct research, or access collective intelligence at scale. Participation in any panel is always opt-in. We will notify you before your Cognitive Twin is added to any panel and will obtain your consent before doing so.
Agentic Use and Third-Party Integrations. You may have your Cognitive Twin act on your behalf in an agentic capacity — taking actions, making requests, and interacting with third-party tools, services, vendors, platforms, and websites as your designated representative, including functioning as a personal AI assistant. When your Cognitive Twin acts agentically, it may share relevant portions of your Personal Intelligence with third-party providers as necessary to complete those tasks. We will always require your explicit authorization before enabling agentic capabilities, and you may revoke that authorization at any time. Note that you are responsible for your Twin when it acts on your behalf as outlined in our Terms of Service.
Future Capabilities. We are building toward a future where your Cognitive Twin can represent you across an expanding range of contexts. We will provide notice of material new capabilities and obtain consent where required by applicable law.
We may also share your personal information in the following circumstances:
For certain website features. We may use third party API services, such as YouTube and Twilio, for certain product features. If you choose to use those features, you acknowledge and agree that you are also bound by the third party’s privacy policy. You may manage your YouTube API data by visiting Google’s security settings page here. You may make choices about your Twilio API data by visiting Twilio’s privacy notice here.
When you connect with social media accounts. Some of our features enable you to connect to a social media account or share information on social media platforms, like Facebook and Twitter. Any information you choose to share on social media may potentially be visible to a global audience and will be subject to the social media provider’s privacy policies (not this Privacy Statement). You should take care only to share information on social media that you are comfortable sharing.
For joint features, sales, promotions and events. With your consent we may share your personal information with third parties who are jointly providing features, sales initiatives, promotions or events with us.
When you publicly post the information. We may provide opportunities for you to publicly post reviews, questions, comments, suggestions, or other content that may include personal information, such as your name or username. Anything you share in a public forum is public, and you should think carefully before you decide to share.
Other circumstances.
We also share your personal information with third parties in the following circumstances:
For research. With appropriate controls, we may share information with third parties, such as academic institutions, government and non-profit organizations, for research purposes or to publish academic or policy-related materials. We only share information in a way that does not identify any individuals.
With service providers or agents. We share personal information with our service providers or agents who provide services on our behalf for the purposes described in this Privacy Statement. Service providers or agents are required to implement reasonable privacy and information protection controls to maintain the privacy and security of information provided to them consistent with the privacy practices outlined in this Privacy Statement. Service providers or agents may include companies that assist us with our advertising, marketing, and sales efforts, help us with our technology offerings (such as a hosting, security or anti-fraud providers) and help us run our business and websites. Service providers or agents also include AI providers, including generative AI providers.
For mergers and acquisitions. If we are involved with a merger, asset sale, financing, liquidation, bankruptcy, or the acquisition of all or part of our business to another company, we may share your personal information with that company and its advisors before and after the transaction date.
With our affiliates and subsidiaries. We may share your personal information with our affiliates and subsidiaries for everyday business purposes as described in this Statement, including for marketing purposes, for improving and developing our offerings, and for personalizing your experience on our websites.
For advertising and analytics. We may use advertising networks and other providers to display advertising on our website or on other sites. We may share personal information with advertising networks and other providers to tailor advertising and offers presented to you based on your interactions with our sites, products, services, and offerings. Our advertising partners may place cookies on unaffiliated websites in order to serve advertisements that may be relevant to you based on your browsing activities and interests and determine the effectiveness of such advertisements. See also the “Region and state-specific terms” section below for additional information. We do not respond to “Do Not Track” signals because there is no formal “Do Not Track” standard.
For legal reasons. We may share your personal information with third parties for legal reasons without your consent, and as permitted by law, including:
When we reasonably believe disclosure is required in order to comply with a subpoena, court order, or other applicable law, regulation or legal process;
To protect the rights, property, or safety of TwinWise, Synaptic Spike GenAI, LLC, our sites, products, services, our customers or others;
To protect or defend against attacks;
To enforce, remedy, or apply our Terms of Service or other agreements;
To prevent fraud, cybersecurity attacks or illegal activity;
For debt collection; and
With regulatory agencies, as necessary to help detect and combat fraud and/or protect our customers, users and/or our sites, products and services, or in required institutional risk control programs.
Your personal information rights and choices
Your choices
At TwinWise, we believe that you have choices about information that pertains to you or your business.
We provide customers with options to manage the privacy of their personal information:
Correct your personal information. You can edit and correct certain personal information at any time by changing it directly in our products and services or by contacting us directly at info@TwinWise.io.
Access your personal information. You may request a copy of the information we have about you by contacting us directly at info@TwinWise.io.
Delete your personal information. You may ask us to delete your personal information by contacting us directly at info@TwinWise.io.
Cookies and other tracking technologies. You may be able to opt-out of interest based advertising by visiting the NAI Opt-Out Page or the Choices Opt-Out Page (or the Digital Advertising Alliance of Canada Opt-Out Page, if you are based in Canada). If you reside in California, Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, please refer to the relevant sections below under Region and state-specific terms for more information about opting out of tracking for targeted advertising purposes, or opting-out of sales and/or sharing.
Manage marketing communications from us. To update your marketing communication preferences, you can unsubscribe at any time by following the unsubscribe link in the email or by contacting us at info@TwinWise.io. You may also unsubscribe using the link found at the bottom of all marketing and promotional emails. If you receive marketing text messages from us through our SMS shortcode program, you may opt out of receiving further marketing text messages from us by replying STOP to the message.
Your Rights
Depending on where you live, you may also have certain state-specific rights with respect to your personal information. Please see the Region and state-specific terms section for your country, below.
Verification
To help protect privacy and the security of your personal information, you may be asked to provide additional information to verify your identity and/or ownership rights before we can fulfill your data rights request. If we cannot verify your identity or your ownership rights to the data, we may not be able to service your request until you provide proper documentation.
Data Retention
Unless you specifically ask us to delete your personal information, we retain your personal information as long as it is necessary to comply with our data retention requirements and provide you with services and the benefits of our website and successfully run our business. Even if you submit a deletion request, we may be required to maintain your personal information for as long as necessary to:
comply with our legal or regulatory compliance needs (e.g., maintaining records of transactions you have made with us);
to exercise, establish or defend legal claims; and/or
to protect against fraudulent or abusive activity on our service.
This means we may keep different information for different periods. If your account is canceled because you haven’t used it for a long time, we may delete this information immediately.
TwinWise retains personal information, including Cognitive Twin data, for as long as necessary to provide our services, fulfil the purposes described in this Privacy Statement, comply with applicable legal obligations, resolve disputes, and enforce our agreements. The specific retention period for your data depends on the type of information and the purpose for which it is processed. General principles we apply:
Cognitive Twin and Personal Intelligence data: retained for the duration of your account and for up to three (3) years following account termination, to allow for reactivation and to support ongoing research and product development.
De-identified and aggregated data: retained indefinitely. Once de-identified, this data no longer constitutes personal information and may be used for research, benchmarking, and product development without restriction.
Account and contact information: retained for the duration of your account and for up to seven (10) years following termination for legal compliance purposes.
Research and beta program data: retained for up to five (5) years following the conclusion of the relevant study or program.
Following the applicable retention period, TwinWise will delete or de-identify your personal information in accordance with our internal data deletion procedures. Please note that TwinWise is not required to delete de-identified or aggregated data that cannot reasonably be used to re-identify you or delete data that we may be required to retain to abide by our legal or regulatory requirements.
There may be occasions where we are unable to fully delete, anonymize, or de-identify your personal information due to technical, legal, regulatory compliance, or other operational reasons. Where this is the case, we will take reasonable measures to securely isolate your personal information from any further processing until such time as we are able to delete, anonymize, or de-identify it.
Security.
TwinWise implements commercially reasonable administrative, technical, and physical safeguards designed to protect your personal information — including your Cognitive Twin data and Personal Intelligence outputs — against unauthorized access, use, disclosure, alteration, or destruction. However, no security system is impenetrable, and TwinWise cannot guarantee the absolute security of your personal information. In the event of a data breach affecting your personal information, TwinWise will notify you and applicable regulatory authorities in accordance with applicable law.
Children’s Privacy.
TwinWise’s services are intended solely for individuals who are 18 years of age or older. TwinWise does not knowingly collect, process, or retain personal information from individuals under 18. If TwinWise becomes aware that it has collected personal information from a minor, TwinWise will promptly delete such information and terminate the relevant account. If you believe that a minor has provided personal information to TwinWise, please contact us at info@TwinWise.io.
How to contact us
If you have questions or comments about this Privacy Statement or our practices, please contact us at:
TwinWise Support
℅ TwinWise Legal Team
2108 N ST STE N
Sacramento, CA 95816, USA
Region and State-Specific Terms
Additional terms may apply to you based upon the country you reside in or the products you use. Please click the region or state that applies to you to learn more about additional terms and rights that may apply to you.
Your California privacy rights. As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Access. You may request that we provide the following information about how we have collected and used your Personal Information during the past 12 months:
the categories of Personal Information we have collected about you,
the sources from which that information was collected,
the business or commercial purpose for collecting, selling, and/or sharing your Personal Information,
the categories of personal information we shared or sold about you,
the categories of third parties to whom we shared or sold personal information about you,
the categories of personal information we disclosed for a business purpose, and
the categories of third parties to whom we disclosed personal information about you for a business purpose.
Request a copy of your Personal Information. You may request a copy of the Personal Information by contacting us at info@TwinWise.io.
Correction. You can edit and correct your personal information at any time by changing it directly on our website or by contacting us at info@TwinWise.io.
Deletion. You may have the right, under certain circumstances, to request that we delete the personal information you have provided to us. To request a deletion of your personal information contact us at info@TwinWise.io.
Opt-out of Sales and/or Sharing. Like many companies, we use services that help deliver interest-based ads to you as described above. The California Consumer Privacy Act (“CCPA”) may classify our use of some of these services as “sharing” your Personal Information with the advertising partners that provide the services. You can opt-out of the “sharing” of your personal information by visiting the “Your California Privacy Rights” link in the footer of our website.
In addition, if you have enabled a recognized opt-out mechanism on your browser, device, or platform, you will automatically be opted out of any “sharings” when you interact with our Services. Please go here to learn more about enabling one such preference signal, the Global Privacy Control: https://globalprivacycontrol.org/#download. TwinWise does not sell personal information under the CCPA, and therefore does not offer a “Your California Privacy Rights” link on its website. We do not knowingly sell or share the personal information of individuals under 16 years of age.
Limit processing of sensitive personal information. TwinWise’s Cognitive Twin service may collect or derive personal information considered sensitive under the CCPA and applicable state laws, including inferences drawn from personal information used to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, and abilities. TwinWise will obtain required consent before processing sensitive personal information and will provide notice of the categories of sensitive personal information collected, the purposes for which it is used, and any applicable rights to limit such processing.
California Shine the Light. Customers who are California residents may request certain information concerning the categories of personal information (if any) we disclose to third parties or affiliates for their direct marketing purposes. If you would like more information, please submit a written request to us using the contact information provided below.
Non-discrimination. You have the right to be free from discrimination or retaliation related to your exercise of any of your California privacy rights.
Verification. In order to protect your personal information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. If you do not have an account with us, or if we suspect your account has been accessed without your authorization, we may ask you to provide additional personal information for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.
Authorized agents. You may use an authorized agent to submit a rights request. If you do so, the authorized agent must present signed written authorization to act on your behalf, and you will also be required to independently verify your own identity directly with us and confirm with us that you provided the authorized agent permission to submit the rights request. This verification process is not necessary if your authorized agent provides documentation showing that the authorized agent has power of attorney to act on your behalf under Cal. Prob. Code §§ 4121 to 4130. We may deny a request from an agent that does not submit adequate proof that they have been authorized by you to act on your behalf.
Transparency matters. You can learn more about the requests we process by requesting to see a transparency report. Please contact us using the details below.
Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia Residents
Scope. This section applies to residents of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, and Virginia. It describes how we collect, use, and share Personal Data of state residents in our capacity as a business or controller under the corresponding state privacy laws, including the Colorado Privacy Rights Act, Colorado Artificial Intelligence Act, Connecticut Data Privacy Act, Delaware Personal Data Privacy Act, Indiana Consumer Data Protection Act, Iowa Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Maryland Online Data Privacy Act, Minnesota Consumer Data Privacy Act, Montana Consumer Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Privacy Act, New Jersey Data Privacy Act, Oregon Consumer Privacy Act, Rhode Island Data Transparency and Privacy Protection Act, Tennessee Information Protection Act, Texas Data Privacy and Security Act, Texas Responsible AI Governance Act, Utah Consumer Privacy Act, and Virginia Consumer Data Protection Act (collectively, “Applicable State Privacy Laws”), and your rights with respect to that Personal Data. For purposes of this section, the term “Personal Data” has the meaning given in the Applicable State Privacy Laws but does not include information or entities exempted from the scope of the Applicable State Privacy Laws. Please note that we may claim legal exemptions for certain types of personal information and certain Synaptic Spike GenAI/TwinWise companies from all or certain parts of the Applicable State Privacy Laws. Maryland residents should note that the Maryland Online Data Privacy Act requires data minimization — collection and processing limited to what is reasonably necessary and proportionate to the purpose. Minnesota residents have the right to question and receive an explanation for consequential decisions made through automated profiling.
Personal Information that we collect, use, and disclose. This privacy statement summarizes the Personal Information we collect and describes our practices currently and during the 12 months preceding the effective date of this Privacy Statement. Information you voluntarily provide to us, such as in free form webforms or via a chatbot, may contain other categories of personal information not described in this chart.
Your privacy rights. As a resident of Colorado, Connecticut, Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Montana, Nebraska, New Hampshire, New Jersey, Oregon, Rhode Island, Tennessee, Texas, Utah, or Virginia, you may have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.
Access. You may request a copy of the Personal Information by contacting us using the details below.
Correction. You can edit and correct your personal information at any time by changing it directly on our website or by contacting us using the contact details, below.
Deletion. You may have the right, under certain circumstances, to request that we delete the personal information you have provided to us. You may delete your personal information by contacting us at the details, below.
Opt-out of tracking for targeted advertising purposes. You can submit requests to opt-out of tracking for targeted advertising purposes by visiting the “Manage Cookies” or “Privacy Settings” link in the footer of our website. TwinWise does not otherwise “sell” your Personal Information to third parties for monetary consideration.
Except in the event of a merger, acquisition, or bankruptcy or as required by law, TwinWise will never sell, license, or otherwise transfer your Cognitive Twin Data to third parties for their independent use — for any amount of money or any other consideration. These are the outputs generated about you, and they belong to you. No advertising platform, data broker, research institution, or other third party will receive your identifiable Cognitive Twin Data from us. If you wish to share any of this data with a third party, that is your choice to make — not ours.
In the event of a merger, acquisition, financing, or sale of all or part of our business, we will require any successor to be bound by this no-sale commitment as a condition of any transaction involving your Cognitive Twin Data. We will notify you of any such transaction as required by applicable law and will give you the opportunity to export and/or delete your Cognitive Twin Data before any transfer occurs.
Opt-out of profiling TwinWise. Your Cognitive Twin is a model of how you think — and that is the product. The understanding TwinWise builds of your reasoning, values, and cognitive tendencies is not produced in order to deliver a service; it is the service. There is no Cognitive Twin without it. Applicable state privacy laws recognize this as profiling: the evaluation of personal characteristics to understand and model cognitive patterns and decision-making. We believe this is a service worth choosing with full information, which is why we are transparent about it here. If you reside in a state where the law gives you the right to opt out of this type of profiling, you may contact us at info@TwinWise.io. Because your Cognitive Twin and the profiling that builds it are inseparable, opting out means TwinWise can no longer provide its service to you. Minnesota residents have the additional right to request an explanation of any consequential automated profiling decision.
International Data Transfers.
TwinWise is based in the United States and processes personal information primarily in the United States. If you access TwinWise’s services from outside the United States, your personal information will be transferred to, stored, and processed in the United States, where data protection laws may differ from those in your jurisdiction. By using TwinWise’s services, you consent to the transfer of your personal information to the United States. TwinWise implements appropriate safeguards for international transfers of personal information as required by applicable law, including standard contractual clauses where required.
Sensitive Personal Data. Some of the personal information that we may collect may be considered sensitive personal information under certain state privacy laws. We will not process your sensitive personal data without your consent.
Non-discrimination. You have the right to be free from discrimination related to your exercise of any of your privacy rights.
Appeal. If we decline to take action on any request that you submit in connection with the rights described above, you may ask that we reconsider our response by submitting a written request to us using the contact information provided below. We will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If the appeal is denied, we will also provide you with an online mechanism, if available, or other method through which you may contact your state attorney general’s office to submit a complaint.
Authentication. In order to protect your Personal Information from unauthorized access or deletion, we may require you to verify your credentials before you can submit a rights request. To do so, we may ask you to provide additional personal information for verification. If we are subsequently unable to confirm your identity, we may refuse your rights request.
Transparency matters. You can learn more about the requests we process by requesting to see a transparency report. Please contact us using the details below.
United States contact information:
Synaptic Spike GenAI, LLC
℅ TwinWise Legal Team
2108 N ST STE N
Sacramento, CA 95816, USA
Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Rhode Island, and Tennessee Residents
This section applies to residents of Delaware, Indiana, Iowa, Kentucky, Maryland, Minnesota, Nebraska, New Hampshire, New Jersey, Rhode Island, and Tennessee under their respective comprehensive consumer privacy laws: the Delaware Personal Data Privacy Act (effective January 1, 2025), Indiana Consumer Data Protection Act (effective January 1, 2026), Iowa Consumer Data Protection Act (effective January 1, 2025), Kentucky Consumer Data Protection Act (effective January 1, 2026), Maryland Online Data Privacy Act (effective October 1, 2025), Minnesota Consumer Data Privacy Act (effective July 31, 2025), Nebraska Data Privacy Act (effective January 1, 2025), New Hampshire Privacy Act (effective January 1, 2025), New Jersey Data Privacy Act (effective January 15, 2025), Rhode Island Data Transparency and Privacy Protection Act (effective January 1, 2026), and Tennessee Information Protection Act (effective July 1, 2025).
Your privacy rights. As a resident of one of the states listed above, you may have the rights below. These rights are not absolute and in certain cases we may decline your request as permitted by law.
Access. You may request a copy of the Personal Information we hold about you, including your Cognitive Twin and derived Personal Intelligence, by contacting us at info@TwinWise.io.
Correction. You may request correction of inaccurate personal information by contacting us at info@TwinWise.io.
Deletion. You may request deletion of your personal information, including your Cognitive Twin and Personal Intelligence. Note that deletion will result in termination of TwinWise’s core services. Contact us at info@TwinWise.io.
Opt-out of targeted advertising and sale. You may opt out via the “Privacy Settings” link in the footer of our website.
Opt-out of profiling. Residents of states whose laws provide a right to opt out of profiling that produces legal or similarly significant effects may submit a request to info@TwinWise.io. Note that, as described above, opting out may preclude delivery of core TwinWise services.
Sensitive personal data. TwinWise will obtain your consent before processing sensitive personal data, including inferences constituting a profile of your psychological traits, preferences, behaviors, or cognitive tendencies. Maryland residents’ data will be processed only to the extent reasonably necessary and proportionate to the stated purpose.
Appeal. If we decline to act on a request, you may appeal in writing to info@TwinWise.io. We will inform you of the outcome and, if denied, provide information on how to contact your state attorney general.
Non-discrimination. You have the right to be free from discrimination related to the exercise of these privacy rights.
A Cognitive Twin platform for professionals whose thinking is their greatest asset. The flagship product of Synaptic Spike GenAI.
A Venture by
Synaptic Spike™
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Privacy Statement · Terms of Use· Manage Cookies
© 2026 Synaptic Spike GenAI, LLC · TwinWise™ and Synaptic Spike™ are registered trademarks.
Privacy Statement · Terms of Use· Manage Cookies
A Cognitive Twin platform for professionals whose thinking is their greatest asset. The flagship product of Synaptic Spike GenAI.
A Venture by
Synaptic Spike™
Newsletter Sign Up
A Cognitive Twin platform for professionals whose thinking is their greatest asset. The flagship product of Synaptic Spike GenAI.
A Venture by
Synaptic Spike™
Newsletter Sign Up
© 2026 Synaptic Spike GenAI, LLC · TwinWise™ and Synaptic Spike™ are registered trademarks.
Privacy Statement · Terms of Use· Manage Cookies