This document is a draft under legal review. Highlighted text is still to be filled in. Until it’s final, the agreement you sign with us governs.
1Who we are
Twospoon legal entity name, of registered address (“Twospoon”, “we”), makes Miles. This policy explains how we handle personal data when you visit this website, contact us, or use Miles as a customer or User. Write to privacy@twospoon.ai with any question about it.
2Our two roles
- As a controller, we decide how to use the personal data in this policy: website visits, call requests, and the account, billing and support details of our customers.
- As a processor, we handle the personal data inside a customer’s workspace (chats, files, what agents see and do) only on that customer’s instructions. The customer is the controller for it, and our Data processing agreement governs it. If you’re a User, ask your organisation about it first.
3What we collect
| What | Examples | Where it comes from |
|---|---|---|
| Call requests | Name, work email, organisation size, monthly AI spend, the page you asked from | You, through the Book a call form |
| Account details | Name, work email, role, team, sign-in and two-step settings | You, your administrator, or your identity provider and directory |
| Billing details | Billing contact, company name and address, invoices | Your organisation |
| Usage and logs | Agent hours, computer time, usage by person, the audit log of actions | The Service, as you use it |
| Support | What you tell us, and what you choose to share | You |
| Website logs | IP address, browser, the pages requested | Your browser, through our hosting provider |
We don’t use advertising or analytics trackers on this website, and we don’t buy personal data.
4How we use it
| Why | Legal basis |
|---|---|
| To reply to call requests and talk to you about Miles | Our legitimate interest in answering you, or steps you asked for before a contract |
| To provide, secure and support the Service | Our contract with your organisation |
| To bill and keep business records | Our contract, and our legal obligations |
| To keep the website and Service secure and working | Our legitimate interest in security |
| To tell customers about changes to the Service or these policies | Our contract, or our legitimate interest |
Miles agents use open-source AI models that Miles runs itself: in Miles Managed Cloud, in your own cloud account, or on your own premises, depending on how you deploy. We don’t send Customer Data to third-party AI model providers, and we don’t use Customer Data to train models.
6Where it’s kept
Where Customer Data lives depends on the deployment the customer chooses: Miles Managed Cloud, the customer’s own cloud account in the region they pick, or their premises. Account, billing and website data is kept with the providers on our Subprocessors page. Where personal data moves out of the UK or the European Economic Area, we protect it with the European Commission’s standard contractual clauses or an equivalent safeguard.
7How long we keep it
- Call requests: up to 24 months after our last contact, unless you become a customer.
- Account and Customer Data: for as long as the customer’s agreement lasts, then deleted within 30 days of it ending, after the export window.
- The audit log: one year, so a workspace can show what happened.
- Billing records: as long as tax and accounting law requires.
8Security
We protect personal data with the controls described on our Security page, including single sign-on, two-step sign-in, role-based access that keeps chats and files private to their owners, credentials that nobody can see, and a tamper-evident audit log.
9Your rights
Depending on where you live, you can ask to see, correct, delete or export your personal data, to restrict or object to how we use it, and to withdraw consent where we rely on it. Write to privacy@twospoon.ai; we’ll answer within one month. If your data is in a customer’s workspace, we’ll pass your request to that customer. You can also complain to your data protection authority.
California residents have the right to know, delete and correct personal information, and not to be discriminated against for using these rights. We don’t sell or share personal information as the CCPA defines those terms.
10Children
Miles is a service for organisations. It isn’t meant for anyone under 16, and we don’t knowingly collect their personal data.
11Changes
We’ll update this policy when our practices change, and change the date at the top. If a change is material, we’ll tell customers before it takes effect.