Privacy notice
Last updated: 2026-11-10. Applies from: 2026-12-11
1. Who we are
Twiceme Technology AB (“Twiceme Technology”, “we”, “our” or “us”), reg. no. 559120-3905, is a company registered in Sweden. Twiceme Technology is the data controller and can be contacted at the following address: Kronobergsgatan 21, 112 33, Stockholm, Sweden, e-mail: info@twiceme.com. Twiceme Technology respects your privacy and is committed to responsibly collecting, maintaining, and using personal information about you. Our aim is to ensure that all personal data processed by us should be kept safe and secured at all times and that personal integrity is respected.
2. Introduction to privacy notice
To pursue the lawful processing of personal data within Twiceme Technology, we process personal data in our daily operations following the General Data Protection Regulation (“GDPR“) and, where it applies, other personal data protection legislation, such as the Australian Privacy Act 1988 for individuals in Australia.
This Privacy Notice (“Privacy Notice”) applies to anyone visiting Twiceme.com, referred to as “Twiceme Technology Site”, as well as to anyone using our services, products or that we interact with such as customer representatives, representatives of rescue organizations, supplier, and distributor representatives or salespersons, and to anyone who scans Twiceme equipment. We may also process your personal data if we believe the company you represent may be interested in our services. Additionally, we process personal data to comply with legal obligations under applicable laws and governmental decisions.
Please note that this Privacy Notice does not apply to:
Twiceme Technology employees, interns or employee or intern candidates.
Medical Data (such as medical conditions, allergies, current medications, medical history, identifiable physical traits (e.g., eye colour, height, weight), religion, identification numbers (e.g., national identity or social security number, passport number), insurance details, or other health-related data) that is uploaded by you to the Twiceme Hardware.
Personal data that we process on behalf of a customer, for example an employer using the Safety Management Portal, including Work Related Documents that you upload to your employer's workspace. For that processing, the customer is the data controller and its privacy notice applies. If you have questions about that processing, please contact the customer, for example your employer.
If you want to learn more about how we use cookies, please see our Cookie Notice.
3. Personal data processed
Personal data refers to any information that can be directly or indirectly linked to a living person. Twiceme Technology collects and processes various types of personal data within the scope of its activities.
Twiceme Technology may collect the following personal data from you:
Information on identity – e.g. Twiceme Hardware UID, username, first and last name, profile picture and login credentials from Google or Apple.
Contact details - e.g. address, email address, phone number and job title.
Location information – e.g. location and timestamp.
Usage and device data – e.g. which screens and features of the Twiceme app and the Safety Management Portal you use, device type, operating system, app version, crash reports and an internal identifier linked to your account.
Equipment data – e.g. the Twiceme equipment you have registered and its UID.
Scan data – e.g. the UID of the scanned chip, the IP address and browser information (user agent) of the device used to scan, and the time of the first and most recent scan and the number of scans of a chip.
Device information – the push token that lets us send notifications to your phone.
ICE contact – e.g. first and last name, mobile phone number, verification status, and, where applicable, the timestamp recorded when the ICE contact confirms their status, of the designated In Case of Emergency (ICE) person.
Newsletter statistics - e.g. topics of interest, open and click-through rates.
Participation and feedback – e.g. data collected before, during or after an event or webinar.
Payment information - e.g. data necessary for payments, invoicing, or financial transactions with Twiceme Technology.
Social media activity - e.g. information on interactions with us via social media.
Website and cookie data – e.g. IP address, cookie identifiers, your cookie choices and, if you consent, information on how you use the website, such as clicks, time spent on pages, navigation patterns and interactions. If you consent, we also use cookies to enable marketing and search. For more information, see our Cookie Notice.
Additionally, we collect information about the organization you belong to and its contact details. We collect most personal data directly from you. Information about ICE contacts and about friends or colleagues you have selected is provided by the user who designates them, and information about you as a representative of a company may be provided by that company.
4. Purposes of the processing
Twiceme Technology processes your personal data for the following purposes:
To fulfil contractual obligations.
To provide services and communicate with you.
To let you share your location with friends or colleagues you select, for a period you choose.
To run safety sessions, the get-back timer and the immobility alert, which follow where you are while the feature is on and raise an alert if you do not return in time or stop moving.
To send your location to your ICE contacts and to the group members who respond when an alert is raised, including by SMS with a link to a page that shows your live location.
To show the emergency phone number for the area you are in.
To record where a safety observation was made, so that colleagues in your workspace can see it.
To provide a webpage where your designated ICE contact can review information about this feature, access our Privacy Notice, and confirm their status as your ICE contact, including recording a timestamp of that confirmation; and, once confirmed, to notify your ICE contact by SMS when you start a safety session, if an emergency alarm is triggered or resolved, or if you do not return within the timeframe you have indicated. Message frequency: up to 3 messages per event; we do not send recurring or marketing messages. Message and data rates from the ICE contact's mobile carrier may apply.
To authenticate your account
To connect your Twiceme hardware with your user's account and enable adding friends through tapping the hardware
To develop and improve the Twiceme app and our other services.
To fix problems and keep our services secure.
To send you information and tips about features of the Twiceme app.
To create aggregated statistics for equipment manufacturers.
To show the information stored on Twiceme equipment when it is scanned, and to notify the owner that the equipment has been scanned.
To send information about our services or other activities that you may have indicated an interest in or registered for.
To conduct targeted marketing via social media, other digital channels or events.
To handle inquiries and complaints.
To facilitate invoicing.
To comply with legal obligations imposed by authorities and applicable laws.
For detailed information on the purposes for processing, please refer to the table in section 7 below.
How we use your location
The Twiceme app only uses the location of your phone when you turn on a feature that needs it, and only while that feature is on. For some features the app also collects your location in the background, that is while the app is closed or you are not using it. Your phone shows when this happens, for example with the location indicator on iPhone. You can turn off location access for the app in your phone's settings at any time, but these features will then not work.
Your location is sent to and stored on Twiceme's servers in your hosting region (see "Where your data is stored" in section 8). We do not store your route. Apart from the position stored with an alert, we keep only your most recent position, and each new position replaces it.
Feature | When your location is collected | Who can see it | How long we keep it |
|---|---|---|---|
Location sharing | In the background, about every 30 seconds, from when you start sharing until the end time you choose. | The members of the group you share with, until sharing ends. | Your most recent position is kept until a newer position replaces it or your account is deleted. |
Safety session | In the background, about every 30 seconds, for the whole session. | Your ICE contacts: in the Twiceme app, or by SMS with a link to a page that shows your live position. The link stops working 2 minutes after the session ends. | The session and the return area you set are deleted when the session ends. The copy of your ICE contacts' details made for the session is deleted 1 hour after it ends. Your most recent position is kept as for location sharing. |
Get-back timer | In the background while the timer runs. Your position is sent to our servers at most every 5 minutes. The area you plan to return to stays on your phone. | The members of the group you chose, if an alert is raised. | The timer is deleted when you stop it or return. Your most recent position is kept as for location sharing. |
Immobility alert | In the background while the alert is on. Your phone uses it to check that you are still moving. It is not sent to our servers unless an alert is raised. | No one, unless an alert is raised. | Not stored unless an alert is raised. |
Alerts (SOS, immobility alert, late return) | When an alert is raised, and about every 10 seconds while the alert screen is open in the app. | Your ICE contacts (in the Twiceme app, or by SMS with a link to a page that shows your live position for up to 6 hours), the group members who respond and, where available, nearby Twiceme users who have agreed to help in emergencies. | Your position at the time of the alert is stored with the alert until your account is deleted. |
Emergency phone number | When you open the SOS screen in the app, and when someone opens the page that shows your live position. | No one at Twiceme. In the app, the location service built into your phone finds which country you are in. On the page that shows your live position, OpenStreetMap does this (see section 8). | Not stored. |
Safety observations (Twiceme Pro) | Once, when you create an observation. | Colleagues and administrators in your workspace who have access to observations. | As long as the observation is kept in the workspace. It is part of the workspace's records and is not deleted when your account is deleted. |
Push notifications about location sharing, sessions and alerts never contain your location.
5. Lawful basis for processing
Twiceme Technology processes your personal data based on the following legal grounds:
Agreement – The processing is necessary for the performance of a contract to which you, or the company you represent, are a party, or to take steps at your or your company’s request prior to entering into such a contract.
Legal obligation – The processing is necessary for compliance with a legal obligation under applicable laws, regulations, or governmental decisions.
Legitimate interest – The processing is necessary for the purposes of legitimate interests pursued by us or by a third party, such as your employer, provided that such interests are not overridden by your fundamental rights and freedoms.
Consent – The processing is based on your consent, which we ask for separately and after informing you of what you are consenting to.
If you use our products or services, or otherwise interact with Twiceme Technology, as part of your employment, we will generally not rely on your consent. Where we process your personal data as data controller, we instead rely on our legitimate interests, which include ensuring the functionality, security and emergency-readiness of Twiceme-enabled equipment and services. Where we process your personal data on behalf of your employer, see section 2.
If you are uncertain whether you are interacting with Twiceme Technology as an individual or as part of your employment, please contact your employer or Twiceme for clarification.
For detailed information on the legal basis for processing, please refer to the table in section 7 below.
6. Retention of personal data
Personal data is retained as long as necessary to fulfil the specified purposes. Most personal data is deleted when the purpose for which it was collected has been fulfilled, for example when you delete your account or when the client relationship ends, unless we are required by law to keep it longer.
For instance, under the Swedish Accounting Act, Twiceme Technology is required to retain specific personal data (e.g., invoices and accounting documents) for seven years. Such data will only be used for accounting purposes.
Client related data is retained while you are considered a client of Twiceme Technology. After contract termination, most of your data will be deleted unless retention is required for other purposes. Certain data, such as identity and contact details, will be kept for 36 months for marketing and follow-up purposes.
For full details on data retention periods, see the table in section 7 below.
7. Deletion of personal data
Personal data will be deleted or anonymized when it is no longer necessary for retention. Once deletion is executed, it cannot be reversed, and no individual can be linked to the remaining information.
The table below sets out, for each purpose, the legal basis for the processing, the categories of personal data processed and how long we retain the data.
Purpose | Legal basis | Categories of personal data | Retention time |
|---|---|---|---|
Client management | Agreement | - Information on identity | For as long as you are a client. |
Newsletters | Consent | - Information on identity | For as long as you are an active subscriber to our newsletter. |
Manage cookies | Consent | - IP address | Until you withdraw your consent. |
To authenticate and link your Twiceme Hardware UID as you create it | Agreement | - Information on identity | Until account is deleted upon user action or request |
To provide location sharing, safety sessions, the get-back timer, the immobility alert and alerts to your ICE contacts and group members | Consent/Legitimate interest (see section 5) | - Information on identity | Most recent position: until a newer position replaces it or your account is deleted. Position stored with an alert: until your account is deleted. Live-location link: until 2 minutes after a session ends, or 6 hours after an alert is raised. Copy of ICE contact details made for a session: 1 hour after the session ends. |
To show the emergency phone number for the area you are in | Legitimate interest (see section 5) | - Location information | Not stored. |
To record where a safety observation was made (Twiceme Pro) | Processed on behalf of your employer (see section 2) | - Location information | As long as the observation is kept in the workspace. |
To send notifications to your phone | Agreement/Legitimate interest (see section 5) | - Device information | Until you sign out of the app or your account is deleted. |
Profile Picture | Consent | - Information on identity | Until you withdraw your consent. |
To display your phone number with selected friends or colleagues once an alert has been sent | Consent/Legitimate interest (see section 5) | - Information on identity | Until feature is turned off |
To provide a webpage where your designated ICE contact can confirm their status, and to notify the ICE contact when you start a safety session and in case of an emergency alarm or delayed return, Message frequency: up to 3 messages per event. Message and data rates may apply. | Legitimate interest (see section 5) | - ICE contact | Until feature is turned off or until you replace/remove the ICE contact; or until the ICE contact opts out by texting STOP. |
To record evidence that the ICE contact confirmed their status (timestamp) | Legitimate interest (see section 5) | - ICE contact | Until feature is turned off or until you replace/remove the ICE contact |
Adding functionalities to your Twiceme Hardware UID | Agreement | - Information on identity | Until your account is deleted. |
To measure how the Twiceme app is used in order to develop and improve it, using analytics in the app (for example which screens are viewed and what is tapped) | Consent (EU/EEA and UK); legitimate interest (other countries) | - Usage and device data | For as long as you have an account. When your account is deleted, the records can no longer be linked to you and are kept only as statistics. |
To measure how our services are used, based on the requests the Twiceme app and the Safety Management Portal make to our servers, in order to develop and improve them | Legitimate interest | - Usage and device data | For as long as you have an account. When your account is deleted, the records can no longer be linked to you and are kept only as statistics. |
To fix problems and keep our services secure, including crash reporting | Legitimate interest | - Usage and device data | Maximum 12 months. |
To send you information and tips about features of the Twiceme app that are relevant to how you use it | Legitimate interest | - Information on identity | Until you opt out, using the link in each email, or your account is deleted. |
To create aggregated statistics for equipment manufacturers | Legitimate interest | - Usage and device data | As for the records used to develop and improve the Twiceme app; the statistics are aggregated. |
To show the information stored on Twiceme equipment when it is scanned, and to notify the owner that the equipment has been scanned. The notification contains no information about the person who scanned. | Agreement (owner); legitimate interest (person scanning) | - Scan data | IP address, browser information and UID in technical logs: 30 days. First and most recent scan time and number of scans: as long as the equipment is registered. |
Marketing by letter, telephone or e-mail. | Legitimate interest | - Information on identity | Maximum 36 months after you ceased to be considered a client of ours. You can opt out of marketing at any time by contacting us at info@twiceme.com. |
Referrals | Legitimate interest | - Information on identity | Maximum 12 months after you have been referred to us. You can opt out at any time by contacting us at info@twiceme.com. |
Social media marketing | Legitimate interest | - Information on identity | Maximum 36 months after you ceased to be considered a client of ours or you stopped interacting with us. |
Connecting Twiceme equipment | Agreement | - Information on identity | Until you disconnect the equipment or your account is deleted. |
To abide by laws and regulations | Legal obligation | - Information on identity | For as long as we are obliged to store the data according to applicable law or government decision, such as 7 years in accordance with the Swedish Accounting Act. |
Investigate any complaints | Legitimate interest | - Information on identity | 12 months after the end of the client relationship. |
Preventing and investigating possible fraud | Legitimate interest | - Information on identity | 12 months after the end of the client relationship. |
8. Recipients of personal data
Twiceme Technology collaborates with various companies, including partners and suppliers. As a result, we may share your personal data with third parties when necessary. The following types of recipients may process your data as our processors (meaning that they process your data only on our instructions, they are contractually bound to maintain confidentiality and may not use the data for their own purposes):
Web hosting platform provider
Notification services that we use for communication (e.g., newsletters or reminders)
SMS gateway provider (Twilio Ireland Limited), acting as our processor, used solely to deliver text messages about safety sessions and alerts to designated ICE contacts. Mobile phone numbers disclosed to this provider are never sold, rented, or shared with any other third party for marketing purposes
Online accounting system
Customer relationship management (CRM) provider
Payment provider, for subscriptions to the Safety Management Portal
Crash reporting provider for the Twiceme app
Map provider (Mapbox), to show locations on a map in the Twiceme app and on the page that shows your live position to your ICE contacts
Push notification services (Expo, which delivers through Apple Push Notification service and Google Firebase Cloud Messaging), to send notifications to your phone
Weather provider (WeatherAPI.com, run by Zoomash Ltd), which receives a position rounded to about 1 km to show the weather in the Twiceme app and on the page that shows your live position to your ICE contacts
Provider of the AI assistant our staff use to support customers and operate the services (Anthropic)
When we use social media platforms and providers of marketing and search services, they may process your personal data for their own purposes, as independent controllers or jointly with us. Their processing is governed by their own privacy notices. The page that shows your live position to your ICE contacts sends the position to the OpenStreetMap lookup service (Nominatim, run by the OpenStreetMap Foundation) to find which country you are in, so that the page can show the right emergency number. The OpenStreetMap Foundation does not act on our instructions and handles the request under its own privacy policy.
Other users
When you use features that share information, for example location sharing, safety sessions or alerts, the information is shared with your ICE contacts and with the friends, colleagues or group members you have selected, and, if an alert is raised, with nearby Twiceme users who have agreed to help in emergencies. See “How we use your location” in section 4 for details.
Equipment brands
Manufacturers of equipment registered in our services can see figures about how their equipment is used, through a Twiceme partner portal. For equipment held by a company, the figures are shown with the name of the company's workspace and include the number of people in that workspace, how many of them have added a Medical ID to their equipment, and how many valid, expiring and expired certificates they hold. Figures about people are not shown for workspaces with fewer than five users. For equipment registered by individuals, the figures may be grouped by the company part of the email address used (for example, example.com); addresses at public email services are never shown. Equipment brands never see your name, contact details, or the content of your Medical ID or documents.
Twiceme Technology may also be legally required to disclose information to different authorities. In some cases, we may be prohibited from informing you about such disclosures.
Where your data is stored
Our services are hosted on Microsoft Azure. Your data is stored in one hosting region, chosen from the location given when the account was set up. Hosting regions are available in the United States and Australia, and we may add more. If there is no hosting region for your location, your data is stored in the United States. Some of the service providers listed above, for example for email, text messages, payments, crash reporting and push notifications, process limited personal data such as your name, email address, job title and how you use the services in the United States, whichever region your data is stored in.
Transfers outside the EU/EEA are protected by an adequacy decision, including the EU-U.S. Data Privacy Framework where the recipient is certified, or by the European Commission's standard contractual clauses. For transfers from the United Kingdom, the corresponding UK mechanisms apply.
Links to third party sites
Our websites may include links to other websites (“Third Party Sites”) which are outside of our control and not covered by this Privacy Notice. If you access other sites using the links provided, the operators of these sites may collect information from you which will be used by them in accordance with their Privacy Notice, which may differ from our Privacy Notice. If you decide to access any of the Third Party Sites linked to from Twiceme Technology Site, you should understand that you do so at your own risk.
9. Information security
As a data controller, Twiceme Technology implements appropriate technical and organizational measures to safeguard personal data, adhering to GDPR regulations. We maintain internal policies and procedures to address security risks and prevent unauthorized access or leaks.
In the event of a security breach (a "personal data breach"), we will inform you where required by Article 34 of the GDPR. If you are in Australia, we will notify you and the Office of the Australian Information Commissioner of an eligible data breach as required by the Notifiable Data Breaches scheme.
10. Your rights
You have the following rights regarding your personal data:
Right to Withdraw Consent:
You may withdraw consent at any time without affecting the lawfulness of prior processing. Email us at info@twiceme.com.
If you would like to review or change your Cookie consent settings, click on the widget in the lower left-hand corner of the website.
Right to Restrict Processing:
You may request that we restrict the processing of your personal data, for example while we check whether your data is accurate or whether your objection is justified. Restricted data will in principle only be stored. Contact us at info@twiceme.com.
Right to Object:
You may object to processing based on legitimate interests or for direct marketing purposes. For instance, you may unsubscribe from newsletters and other mailings by following a link in these mailings. Contact us at info@twiceme.com.
Right of Access:
You may request a record of how your data is processed, which will be provided within one month. Request this by emailing info@twiceme.com.
Right to Rectification:
You may request corrections to inaccurate personal data or add missing details. Contact us at info@twiceme.com.
Right to Data Portability:
You can request to receive the personal data you have provided to us in a structured, commonly used and machine-readable format, and have it transmitted to another company, where the processing is based on your consent or on an agreement and is carried out by automated means. Email: info@twiceme.com.
Right to Erasure:
You may request deletion of personal data not required for legal compliance or certain other activities such as contractual obligations. Email: info@twiceme.com.
We do not make decisions based solely on automated processing, including profiling, that produce legal effects concerning you or similarly significantly affect you.
Please note that Twiceme Technology may ask you for additional information to help us verify who you are before completing any of the above requests.
If you believe we are not complying with this privacy notice, we encourage you to contact us at info@twiceme.com. We will respond to your complaint within 30 days. You also have the right to file a complaint with the Swedish Data Protection Authority (www.imy.se) or with the data protection authority in the EU/EEA country where you live or work. If you are in the United Kingdom, you can also complain to the Information Commissioner’s Office (www.ico.org.uk). If you are in Australia, you can also complain to the Office of the Australian Information Commissioner (www.oaic.gov.au).
11. Privacy notice updates
We reserve the right to modify this privacy notice at any time, so please review it frequently. Changes and clarifications will take effect immediately upon their posting on the website. If we make material changes to this policy, we will notify you here and, where appropriate, in the Twiceme app or by email, so that you are aware of what information we collect, how we use it, and under what circumstances, if any, we use and/or disclose it.
