Client : any professional or capable natural person within the meaning of Articles 1123 et seq. of the French Civil Code, or legal entity, who visits the Site which is the subject of these general conditions.

Services : TwinL makes available to Clients:

Content : All the elements making up the information present on the Site, in particular text – images – videos.

Client information : Hereinafter referred to as “Information (s)” which corresponds to all the personal data which may be held by TwinL for the management of your account, the management of client relations and for the purposes of analysis and statistics.

User : Internet user connecting to and using the above-mentioned site.

Personal information : “Information that allows, in any form whatsoever, directly or not, the identification of the natural persons to whom it applies” (article 4 of law n° 78-17 of 6 January 1978).

The terms “personal data”, “data subject”, “sub-processor” and “sensitive data” have the meaning defined by the General Data Protection Regulation (RGPD: n° 2016-679)


1. Website Presentation.


By virtue of article 6 of law n° 2004-575 of 21st June 2004 for confidence in the digital economy, users of the TwinL website are informed of the identity of the various parties involved in its creation and monitoring:

Owner : SAS TwinL Share capital of 1 000,00 € VAT number: FR40901753202 – 42 Avenue Montaigne 75008 Paris

Responsible for publication : TwinL – msg@twinl.com

The person responsible for publication is a natural person or a legal entity.

Webmaster : Laurent Loubaresse – msg@twinl.com

Host : ovh – 2 rue Kellermann 59100 Roubaix 1007

Data Protection Officer : Laurent Loubaresse – msg@twinl.com


2. General conditions of use of the site and the services offered.


The Site constitutes an intellectual work protected by the provisions of the Intellectual Property Code and the applicable International Regulations. The Client may not in any way reuse, transfer or exploit on his own behalf all or part of the elements or works on the site.

The use of the TwinL site implies full and complete acceptance of the general conditions of use described below. These conditions of use may be modified or completed at any time, and users of the TwinL site are therefore invited to consult them regularly.

This website is normally accessible to users at all times. However, TwinL may decide to interrupt the site for technical maintenance purposes and will endeavour to inform users of the dates and times of the intervention beforehand. The TwinL website is regularly updated by TwinL responsible. Similarly, the legal notices may be modified at any time: they are nevertheless binding on the user, who is invited to refer to them as often as possible in order to take note of them.


3. Description of the services provided.


The purpose of the TwinL website is to provide information about the company’s activities. TwinL endeavours to provide information on the TwinL website which is as accurate as possible. However, it cannot be held responsible for omissions, inaccuracies or shortcomings in updating, whether these are its own fault or the fault of third party partners who supply this information.

All information on the TwinL website is given for information purposes only and is subject to change. Furthermore, the information on the TwinL site is not exhaustive. It is given subject to modifications having been made since it was put on line.

4. Contractual limitations on technical data.


The website uses JavaScript technology. The website cannot be held responsible for any material damage related to the use of the site. Furthermore, the user of the site undertakes to access the site using recent, virus-free equipment and with an up-to-date browser. The TwinL site is hosted by a service provider in the European Union in accordance with the provisions of the General Data Protection Regulation (RGPD: n° 2016-679)

The aim is to provide a service that ensures the best possible level of accessibility. The host ensures the continuity of its service 24 hours a day, every day of the year. Nevertheless, it reserves the right to interrupt the hosting service for the shortest possible period of time, in particular for maintenance purposes, to improve its infrastructures, in the event of infrastructure failure or if the Services generate traffic which is considered abnormal.

TwinL and the host cannot be held responsible in the event of malfunctioning of the Internet network, telephone lines or computer and telephone equipment, particularly in the event of network congestion preventing access to the server.


5. Intellectual property and counterfeiting.


TwinL is the owner of the intellectual property rights and holds the rights of use on all the elements accessible on the website, notably the texts, images, graphics, logos, videos, icons and sounds. Any reproduction, representation, modification, publication, adaptation of all or part of the elements of the site, whatever the means or process used, is forbidden, except with the prior written authorisation of : TwinL.

Any unauthorised use of the site or of any of the elements it contains will be considered as constituting an infringement and will be prosecuted in accordance with the provisions of articles L.335-2 et seq. of the Intellectual Property Code.

6. Limitations of liability.



TwinL acts as the publisher of the website. TwinL is responsible for the quality and truthfulness of the Content it publishes.

TwinL cannot be held responsible for direct and indirect damage caused to the user’s material when accessing the TwinL website, and resulting either from the use of material which does not meet the specifications indicated in point 4, or from the appearance of a bug or incompatibility.

TwinL cannot be held responsible for indirect damage (such as loss of market or loss of opportunity) resulting from the use of the TwinL website. Interactive areas (possibility of asking questions in the contact area) are available to users. TwinL reserves the right to delete, without prior notice, any content placed in this area which contravenes the legislation applicable in France, in particular the provisions relating to data protection. Where applicable, TwinL also reserves the possibility of calling into question the civil and/or penal responsibility of the user, particularly in the case of messages of a racist, insulting, defamatory or pornographic nature, whatever the medium used (text, photographs etc.).

7. Management of personal data.


The Customer is informed of the regulations concerning marketing communication, the law of 21 June 2014 for confidence in the Digital Economy, the Data Protection Act of 06 August 2004 as well as the General Data Protection Regulation (RGPD: n° 2016-679).


7.1 Persons responsible for the collection of personal data


For the Personal Data collected in the context of the creation of the User’s personal account and their browsing on the Website, the person responsible for the processing of Personal Data is: TwinL. TwinLest represented by Frank Loubaresse, its legal representative

As the party responsible for processing the data it collects, TwinL undertakes to respect the legal provisions in force. In particular, it is the Client’s responsibility to establish the purposes of its data processing, to provide its prospects and clients, once their consent has been obtained, with complete information on the processing of their personal data and to maintain a register of processing which is in conformity with reality. Whenever TwinL processes Personal Data, TwinL takes all reasonable steps to ensure that the Personal Data is accurate and relevant to the purposes for which TwinL processes it.

7.2 Purpose of the data collected



TwinL may process all or part of the data:

– to enable browsing on the Site and the management and traceability of services ordered by the user: connection and use data for the Site, invoicing, order history, etc.

– to prevent and fight against computer fraud (spamming, hacking, etc.): computer equipment used for browsing, IP address, password (hashed)

– to improve navigation on the Site: connection and usage data

– to conduct optional satisfaction surveys on TwinL: email address

– to carry out communication campaigns (sms, email): telephone number, email address

TwinL does not sell your personal data, which is therefore only used for statistical and analysis purposes.


7.3 Right of access, rectification and opposition


In accordance with current European regulations, TwinL Users have the following rights:

– right of access (article 15 RGPD) and rectification (article 16 RGPD), updating, completeness of Users’ data right to block or erase Users’ personal data (article 17 RGPD), when it is inaccurate, incomplete, equivocal, out of date, or whose collection, use, communication or conservation is prohibited

– the right to withdraw consent at any time (Article 13-2c GDPR)

– the right to limit the processing of Users’ data (Article 18 GDPR)

– right to object to the processing of Users’ data (Article 21 GDPR)

– the right to portability of data provided by Users, where such data are subject to automated processing based on their consent or on a contract (Article 20 GDPR)

– the right to define the fate of Users’ data after their death and to choose to whom TwinL should communicate (or not) their data to a third party that they have previously designated

As soon as TwinL becomes aware of the death of a User, and in the absence of instructions from them, TwinL undertakes to destroy their data, unless it is necessary to keep it for evidential purposes or to fulfil a legal obligation.

If the User wishes to know how TwinL uses their Personal Data, to request rectification or to oppose their processing, the User can contact TwinL in writing at the following address

TwinL – DPO, Laurent Loubaresse

42 Avenue Montaigne 75008 Paris.

In this case, the User must indicate the Personal Data which he/she would like TwinL to correct, update or delete, identifying him/herself precisely with a copy of an identity document (identity card or passport).

Requests for the deletion of Personal Data will be subject to the obligations imposed on TwinL by law, particularly with regard to the conservation or archiving of documents. Finally, Users of TwinL can lodge a complaint with the supervisory authorities, and in particular with the CNIL (https://www.cnil.fr/fr/plaintes).


7.4 Non-communication of personal data



TwinL will not process, host or transfer the Information collected from its Clients to a country outside the European Union or one recognised as “non-adequate” by the European Commission without informing the Client in advance. However, TwinL remains free to choose its technical and commercial subcontractors, provided that they present sufficient guarantees with regard to the requirements of the General Data Protection Regulation (RGPD: n° 2016-679).

TwinL undertakes to take all necessary precautions to preserve the security of the Information and in particular that it is not communicated to unauthorised persons. However, if TwinL becomes aware of an incident which affects the integrity or confidentiality of the Client’s Information, it will inform the Client as soon as possible and inform them of the corrective measures taken. On the other hand, TwinL does not collect “sensitive data”.

The Personal Data of the User may be processed by TwinL’s subsidiaries and subcontractors (service providers), exclusively in order to achieve the aims of the present policy.

Within the limits of their respective attributions and for the purposes mentioned above, the main people who may have access to the data of TwinL Users are mainly our customer service agents.

8. Incident notification


Despite our best efforts, no method of transmission over the Internet and no method of electronic storage is completely secure. We therefore cannot guarantee absolute security. If we become aware of a security breach, we will notify affected users so that they can take appropriate action. Our incident reporting procedures take into account our legal obligations, whether at national or European level. We are committed to fully informing our customers of all matters relating to the security of their account and to providing them with all the information necessary to help them meet their own regulatory reporting obligations.

No personal information of the user of the TwinL site is published without the user’s knowledge, exchanged, transferred, ceded or sold in any form to third parties. Only the assumption of the purchase of TwinL and its rights would allow the transmission of this information to the eventual purchaser who would in turn be bound by the same obligation to conserve and modify the data with regard to the user of the TwinL site.



To ensure the security and confidentiality of Personal Data and Personal Health Data, TwinL uses networks protected by standard devices such as firewalls, pseudonymisation, encryption and passwords.

When processing Personal Data, TwinL takes all reasonable steps to protect it from loss, misuse, unauthorised access, disclosure, alteration or destruction.

9. Hypertext links, cookies and internet tags


The TwinL site contains a certain number of hypertext links to other sites, set up with the authorisation of TwinL. However, TwinL does not have the possibility of checking the content of the sites thus visited, and consequently does not assume any responsibility in this respect.

Unless you decide to deactivate cookies, you accept that the site may use them. You can deactivate these cookies at any time and free of charge using the deactivation options offered to you and recalled below, knowing that this may reduce or prevent access to all or part of the Services offered by the site.


9.1. « COOKIES »


A “cookie” is a small information file sent to the User’s browser and stored within the User’s terminal (e.g. computer, smartphone), (hereinafter “Cookies”). This file includes information such as the User’s domain name, the User’s Internet service provider, the User’s operating system and the date and time of access. Under no circumstances will cookies damage the User’s terminal.

TwinL may process information from the User regarding their visit to the Web Site, such as the pages consulted and the searches carried out. This information allows TwinL to improve the content of the Website and the User’s navigation.

Cookies facilitate navigation and/or the provision of services offered by the Site, and the User can configure their browser to allow them to decide whether or not to accept them so that cookies are recorded in the terminal or, on the contrary, that they are rejected, either systematically or according to their sender. The User can also configure their browser so that they are offered the option of accepting or rejecting Cookies from time to time, before a Cookie is recorded in their terminal. TwinL informs the User that, in this case, it is possible that not all the functions of their browser software will be available.

If the User refuses to accept the recording of Cookies in their terminal or browser, or if the User deletes those recorded, the User is informed that their navigation and experience on the Website may be limited. This may also be the case when TwinL or one of its service providers cannot recognise, for technical compatibility purposes, the type of browser used by the terminal, the language and display settings or the country from which the terminal appears to be connected to the Internet.

In this case, TwinL will not be held responsible for the consequences of the deterioration in the functioning of the Website and of any services offered by TwinL, resulting from (i) the refusal of Cookies by the User (ii) the impossibility for TwinL to save or consult the Cookies necessary for their functioning due to the choice made by the User. For the management of Cookies and the choices of the User, the configuration of each browser is different. This is described in the help menu of the browser, which will allow the User to know how to modify their wishes in relation to Cookies.

At any time, the User can choose to express and modify their wishes with regard to Cookies. TwinL may also use the services of external service providers to help it collect and process the information described in this section.

Finally, by clicking on the icons dedicated to the social networks Twitter, Facebook, Linkedin and Google Plus which appear on the TwinL Website or in its mobile application, and if the User has accepted the deposit of cookies by continuing to browse the TwinL Website or mobile application, Twitter, Facebook, Linkedin and Google Plus can also deposit cookies on your terminals (computer, tablet, mobile phone).

These types of cookies are only deposited on your terminals if you consent to them by continuing to browse the TwinL website or mobile application, although the User can withdraw their consent to the deposit of these types of cookies by TwinL at any time.





TwinL may occasionally use Internet tags (also known as “tags”, or action tags, single-pixel GIFs, transparent GIFs, invisible GIFs and one-to-one GIFs) and deploy them via a partner specialising in web analysis who may be located (and therefore store the corresponding information, including the IP address of the User) in a foreign country.

These beacons are placed both in the online advertisements that allow users to access the Site and on the different pages of the Site.

This technology allows TwinL to evaluate the responses of visitors to the Site and the effectiveness of its actions (for example, the number of times a page is opened and the information consulted), as well as the use of the Site by the User.

The external service provider may collect information about visitors to the Site and other websites using these tags, compile reports on Site activity for TwinL, and provide other services relating to the use of the Site and the Internet.


10. Applicable law and attribution of jurisdiction.


Any dispute relating to the use of the TwinL site is subject to French law. Except in cases where the law does not allow it, exclusive jurisdiction is given to the competent courts of Paris.