Data protection

Last updated 16 October 2026

1. Our approach

TwinCity (twincity.app) is operated by Alister Strategies SL, Calle Núñez de Balboa 120, 28006 Madrid, Spain ("Alister", "we", "us"). Contact: dom@alisterstrategies.com, +31 6 27 97 47 57.

We collect as little as we need, keep your work private to your account, and are open about where our numbers come from. This page adds detail to our privacy statement.

2. How your data is protected

• All traffic is encrypted (HTTPS). Data is encrypted at rest by our hosting provider.
• Every ad, upload, result and profile is locked to your account by database access rules. Other users cannot see them unless you create a share link yourself.
• Uploads are stored privately and shown only through short-lived links.
• Payment card data is handled only by our payment provider, which is PCI DSS certified.
• Deleting an ad removes its result and uploaded files.

3. Service providers (processors)

• Hosting, database, storage and sign-in: our cloud platform provider.
• AI processing: AI model providers that generate the simulated reactions to your ad. Data is sent only for your own test and not used for training.
• Payments: Stripe, which may act as the reseller of record and handle tax, fraud checks and receipts.

Some providers may process data outside the European Economic Area. Where that happens, transfers are protected by EU Standard Contractual Clauses or an adequacy decision.

4. Where the digital twin comes from

The simulated society is built only from aggregated, public, commercially licensed statistics, including Eurostat (census, population, ICT usage, household spending, income, prices), the GISCO 1 km population grid and boundaries, the UK Office for National Statistics, and published research datasets on how people react to messages. These contain no personal data about individuals.

5. Data breaches

If a breach affects your personal data, we will notify the authority within 72 hours where required and inform you without undue delay if there is a high risk to you.

6. Contact

For any data protection question or request, email dom@alisterstrategies.com or write to Alister Strategies SL, Calle Núñez de Balboa 120, 28006 Madrid, Spain.