Privacy

Twinded is the sole proprietorship of Thomas Cloarec, in Montreal (Québec). I am the person in charge of the protection of personal information at Twinded, and the only person who works there. This English text is a translation: the French version of this policy is the official one.

For any question, request or complaint, write to me at contact@twinded.ca. My mailing address is available on request.

The site uses three kinds of cookies.

• Necessary cookies, which protect the form against bots (Cloudflare) and remember your cookie choices. They do not require consent.
• Audience measurement, with Google Analytics 4.
• The Google calendar, loaded when you want to book a call.

The last two are off by default. They only load if you accept them in the banner. You can change your mind at any time with the "Cookies" link at the bottom of every page. Withdrawing your consent is as simple as giving it.

The site uses no advertising cookies.

I do not sell or rent your information. I use providers who process it for me, each for a specific purpose. Most of them are outside Québec. For each one, I give the country where it says it keeps the data.

• Cloudflare hosts the site, delivers form messages, counts visits and keeps my backups. Mainly in the United States and the European Union, with possible access from other countries.
• Google provides my email (Gmail), my calendar, my file storage (Drive) and Google Analytics. On servers located in several countries, which Google does not specify.
• Invoice Ninja is the quoting and invoicing software I install on my own server. It keeps your details as a client or prospect.
• OVH rents me that server, as well as those of my clients' websites. In Canada.
• Brevo sends my quotes and invoices by email. In the European Union.
• Stripe processes card payments and pre-authorized debits. In the United States.
• 1Password keeps the passwords and access you entrust to me. In the United States.
• Todoist keeps my task list, which may contain the name of a client or project. In the United States, and in other countries it does not specify.
• Anthropic provides Claude, the assistant I use to match received transfers with my invoices, keep my billing and work on project code. In the United States, and in the countries of its subprocessors.
• GitHub keeps project code. In the United States, and in other countries where it operates.
• Desjardins and Revolut, my banks, receive the transfers you send me, with the sender's name. My Revolut account is European, so Revolut processes this information in the European Union.

Before entrusting information to a provider outside Québec, I assess the privacy risks, as the law requires, and I keep that assessment. These providers are bound by their own data processing terms.

I may also have to disclose information when the law requires it, for example to a tax authority.

• A request without a quote, or a declined quote, is deleted 12 months after the last exchange.
• Client files (quotes, contracts, invoices) are kept 6 years after the end of the fiscal year they relate to, as tax laws require.
• Emails and appointments follow the retention period of the file they belong to.
• Google Analytics data is deleted after 14 months.
• My clients' website data is deleted 30 days after the end of the contract. Backup copies disappear on their rotation.

When a period has passed, I delete the information or make it anonymous.

I am the only person with access to this information. Passwords and access are kept in a password manager. I only use your information for the purpose you were told about.

I do not add you to any mailing list. I write to you about your request or your project, not to sell you something else.

If an incident affects your information, I record it in a register. If it presents a risk of serious injury, I notify the Commission d'accès à l'information and the people concerned.

You can ask me:

• to see the information I hold about you and to know where it comes from;
• to correct it if it is inaccurate or incomplete;
• to withdraw a consent you gave me;
• to stop disseminating information about you;
• to receive your information in a common format, to pass it on elsewhere.

Write to me at contact@twinded.ca. I answer within 30 days. I may ask you to confirm your identity first.

If my answer does not satisfy you, you can turn to the Commission d'accès à l'information du Québec. Outside Québec, in Canada, it is the Office of the Privacy Commissioner of Canada.

The date of the current version is at the top of this page. If I change something important, I announce it on the site before the change applies. Previous versions remain available on request.