twintellityThis website collects no personal data itself, sets no cookies and uses no analytics. This notice explains the two things that still happen: our hosting provider keeps server logs, and you may e-mail us.
Our products (MyLoyalty, Ignition Hub, Loyalty Academy) are covered separately by the Customer Terms, Part B, and by the controller's own notices. This page only covers the website.
1. Who we are
This website is operated by Twintellity Oy, business ID 3387106-4, Otakaari 7, 02150 Espoo, Finland ("we"). Twintellity Oy is part of the Twintellity Group, whose parent company is Twintellity Pte. Ltd., Singapore. For this website, Twintellity Oy is the data controller. Contact: privacy@twintellity.com.
2. What this website does not do
The site does not use cookies or similar storage. It does not use analytics, tracking pixels, advertising networks, embedded social media or third-party fonts. It has no forms and no user accounts. We do not build profiles of visitors and we do not sell or share visitor data.
3. What data is processed anyway
| Data | Why | Legal basis | Kept for |
|---|---|---|---|
| Server logs: IP address, time of request, requested page, browser type | Operating and securing the site (detecting attacks, fixing errors) | Legitimate interest, GDPR Art. 6(1)(f) | 30 days, then deleted |
| E-mail you send us: your address, name if you give it, and the content of your message | Answering you | Legitimate interest, Art. 6(1)(f); where the message leads to a contract, Art. 6(1)(b) | As long as needed to handle the matter |
The site is hosted on Google Cloud (Google Cloud Run, provided by Google Cloud EMEA Limited, Ireland). Servers are located in Finland (Hamina, region europe-north1). The hosting provider processes the server logs on our behalf under a data processing agreement. No other third party receives website data.
4. E-mail
Our contact links open your own e-mail application. Nothing is sent until you choose to send it, and the site does not see or store the message. E-mail is delivered through Google Workspace under Google's data processing terms. If you prefer not to use e-mail, you can write to the postal address above.
5. Transfers outside the EU/EEA
Website data is not transferred outside the European Union or the European Economic Area, except that e-mail you send to us is handled by our e-mail provider as described above. Google may process e-mail outside the EU/EEA; such transfers are covered by the EU–US Data Privacy Framework and the European Commission's Standard Contractual Clauses.
6. Your rights
Under the GDPR you may ask us to access, correct or delete personal data we hold about you, to restrict or object to its processing, and to receive data you have given us in a portable form. To use these rights, e-mail privacy@twintellity.com. We answer within one month. If you believe we have processed your data unlawfully, you may complain to the Finnish Data Protection Ombudsman (tietosuoja.fi) or to the supervisory authority of your own country.
7. Links to our products and other sites
This site links to Twintellity MyLoyalty, Ignition Hub and Loyalty Academy. Those services have their own privacy notices and, for business customers, a data processing agreement. Loyalty Academy runs on HubSpot and collects registration data as described in its own notice. This notice does not cover them.
8. Changes
If the site starts collecting data in a new way, for example a contact form or analytics, we will update this notice before it happens and change the date at the top.