Effective Date: October 8, 2025
1.1 These Terms of Use and Privacy Policy (collectively referred to as the "Terms") constitute a legally binding agreement between you ("User", "you", or "your") and Twin Digital Services India Private Limited, a company incorporated under the Companies Act, 2013, having its registered office in India ("Twin India"), and its affiliates, including Twin Health, Inc. (collectively referred to as "Twin Health", "we", "us", or "our").
1.2 These Terms govern your access to and use of Twin Health's digital health platforms, mobile application, website, and related connected health monitoring and telehealth services (the "Services"). By accessing or using the Services, you acknowledge that you have read, understood, and agree to be bound by these Terms and all applicable laws and regulations. If you do not agree, you must discontinue use of the Services immediately.
1.3 Twin Health operates in compliance with the applicable laws of India, including the Digital Personal Data Protection Act, 2023 (DPDP Act), Telemedicine Practice Guidelines, 2020, and, where applicable, U.S. HIPAA standards for Protected Health Information (PHI).
This document is structured as follows:
By signing the medical consent (digitally or physically), you acknowledge and agree as follows:
2.1.1 Language and Understanding: The nature, purpose, and potential risks of the procedures and teleconsultation services have been explained to me in a language I understand: ____________________.
2.1.2 Consent to Telehealth: I hereby consent to receive remote medical consultation and health management services through Twin Health's digital platforms, including all data processing and sharing as per the Privacy Policy.
2.1.3 Scope of Consent: I authorize the attending healthcare professional(s) to perform or attempt additional procedures or interventions deemed necessary in their professional judgment during the course of treatment.
2.1.4 Alternatives and Risks: I acknowledge that alternative treatment options, potential benefits, and reasonably foreseeable risks have been explained to me. I have received explanations and understand that the proposed telehealth treatment has certain material risks/complications and I have been provided with their quite information about the same, including that there are other undefined, unanticipated, unexplainable risks/complications that may occur during or after the proposed treatment/intervention.
2.1.5 No Guarantee: I understand after full explanation and the opportunity for discussion that despite best efforts there can be no assurance about the results or outcome of the proposed treatment/intervention. I confirm that I have not been given any guarantee or warranty about the results or outcome of the proposed treatment/intervention.
2.1.6 Clarifications: I confirm that the Provider has answered all my questions to my satisfaction regarding the proposed treatment/intervention and the medical teams involved.
2.1.7 Right to Second Opinion: I have been advised of my own election to seek and obtain a second opinion from another doctor regarding the proposed treatment/intervention.
2.1.8 Right to Withdraw: I understand that I have the right to refuse treatment or to withdraw my consent at any time. I understand that if I do refuse treatment, the consequences of my decision have been explained to me. I confirm that after explanation, discussion, counselling and disclosures I have had ample time to provide consent.
2.1.9 Voluntary Consent: This consent has been given voluntarily, without coercion or undue influence.
Note: All teleconsultations shall be conducted in accordance with the Telemedicine Practice Guidelines, 2020 and any subsequent amendments issued by the Medical Council of India or relevant authority.
3.1.1 Users are responsible for procuring and maintaining approved third-party devices (such as CGM sensors, fitness trackers, BP monitors, and body composition scales) required for the program.
3.1.2 Twin Health shall not be liable for any inaccuracy, malfunction, or operational failure of third-party devices.
3.1.3 Continuous Glucose Monitor (CGM) users are required to upload readings daily via the designated portal or email (e.g., remote@twinhealth.com). Approximately six (6) CGM patches are expected to be used annually unless medically indicated otherwise.
3.2.1 Blood and diagnostic tests shall be conducted at baseline and at approximately 90-day intervals thereafter.
3.2.2 Users shall ensure that all laboratory results are shared with Twin Health to facilitate clinical monitoring.
3.2.3 A representative list of test parameters is provided in Annexure A.
3.3.1 Routine technical and sensor-related assistance will be rendered by the Twin Service Assistant (TSA) via virtual channels.
3.3.2 Any escalation or unresolved issue may be directed to care@twinhealth.com.
DISCLAIMER: I understand this program is a No Refund Policy and I agree that I will fully comply to the program guidelines and instructions for my journey
Effective Date: July 07, 2023
Last Modified: July 07, 2023
Twins Digital Services India Private limited otherwise called as "Twin Health", and its related entities (hereinafter referred to as "Twin Health", "We", "Us") are committed to protecting the privacy, confidentiality, and security of all personal and sensitive information collected through our mobile application, therapy, and other health-related services (collectively, the "Services"). This Privacy Policy ("Policy") outlines the manner in which we collect, process, store, use, and share personal information from users in compliance with the Digital Personal Data Protection Act, 2023 (DPDP Act), the Information Technology Act, 2000 (and its amendments), as well as applicable international regulations such as HIPAA in the United States.
By accessing or using the Services, you acknowledge that you have read, understood, and consent to the practices described herein. In case you do not agree to the terms of this Policy, you should immediately cease using the Services. This Policy is subject to updates, and continued use of the Services after changes are posted constitutes acceptance of such changes.
This Policy governs the collection, use, and disclosure of personal information through the App and Services provided by Twin Health. The Policy does not apply to information collected through other websites, third-party services, or external applications linked to or accessible from our App. Twin Health also maintains a separate Notice of Privacy Practices regarding protected health information ("PHI"), which will prevail in case of any inconsistency with this Policy.
Twin Health collects personal and sensitive information that is necessary for the provision of our Services. The information may be collected directly from you, from third parties, or automatically through your interaction with our App.
When you register for the Services, we collect information necessary to create and maintain your account. This includes your name, date of birth, contact details (such as email address, telephone number, and addresses), password, health and medical information, insurance details, racial or ethnic origin, medical history including diagnoses, symptoms, and other relevant personal details. You may provide additional information voluntarily, including health reports, lifestyle information, or feedback to improve the Services.
In certain cases, Twin Health may collect information about you from third parties such as your employer, health insurance providers, or authorized business partners. This information is used solely for the purpose of delivering and enhancing the Services. Twin Health ensures that any such collection is compliant with the applicable Indian and international privacy laws and that appropriate contractual or legal safeguards are in place.
Twin Health may automatically collect certain data when you access or use the App. This may include your device type, operating system, mobile network details, IP address, geolocation, activity logs, and usage patterns. Cookies and similar tracking technologies may be used to improve user experience, analyse App usage, and personalize content. We may also utilize third-party analytics tools, including Google Analytics and Mix panel, which may collect information on your interactions with the Services. Twin Health does not currently respond to "Do Not Track" (DNT) browser signals.
The information collected is used exclusively for legitimate purposes required to provide the Services and comply with legal obligations. Twin Health uses your personal information to:
4.6.1 Deliver the Services requested and respond to inquiries or support requests;
4.6.2 Maintain accurate records for billing, payment, and contractual compliance;
4.6.3 Notify you of updates, changes, or enhancements to the Services or App;
4.6.4 Comply with legal and regulatory requirements, including those under Indian law and HIPAA for U.S.-based users;
4.6.5 Conduct research, statistical analysis, and quality improvement initiatives in a de-identified or aggregated form;
4.6.6 Communicate with insurers, employers, or other authorized parties to facilitate healthcare and benefits administration;
4.6.7 Ensure the security of Services, prevent fraud, and detect unauthorized access.
For PHI, Twin Health strictly adheres to HIPAA regulations and will only use or disclose such information as permitted under the law or with your explicit consent. PHI will not be used for marketing purposes without your prior consent.
Twin Health does not sell your personal information. Disclosure is limited to purposes necessary to deliver the Services or as required by law. Personal information may be shared with:
4.7.1 Your employer or authorized service providers for the purpose of delivering the Services;
4.7.2 Business associates or contractors providing IT, infrastructure, analytics, billing, or marketing support, subject to binding confidentiality agreements;
4.7.3 Legal or regulatory authorities in compliance with Indian laws, court orders, or to protect the rights, property, or safety of Twin Health, its users, or the public;
4.7.4 Third parties in connection with corporate transactions, such as mergers, acquisitions, restructuring, or asset sales;
4.7.5 De-identified or aggregated data may be shared for research, analytics, product development, or scientific studies.
Any disclosure is governed by appropriate contracts or legal obligations ensuring compliance with applicable privacy laws.
As Twin Health operates internationally, your information may be stored or processed in countries such as the United States or Singapore. Twin Health ensures such transfers comply with applicable laws, including the DPDP Act, IT Act, and HIPAA, and implements safeguards such as Standard Contractual Clauses (SCCs) and binding Data Processing Agreements with third parties. By using the Services, you consent to such cross-border transfers.
Under the DPDP Act, 2023, and related Indian privacy regulations, you have the following rights:
4.9.1 Right to Access and Portability: You may request access to your personal information and obtain a copy in a portable format.
4.9.2 Right to Correction and Update: You may request correction of any inaccurate, incomplete, or outdated information.
4.9.3 Right to Erasure: Subject to legal and contractual obligations, you may request deletion of your personal information.
4.9.4 Right to Restriction/Objection: You may restrict or object to processing for specific purposes, including direct marketing.
4.9.5 Right to Withdraw Consent: You may withdraw consent for processing where applicable.
4.9.6 Right to Complaint: You may submit complaints regarding data privacy practices to Twin Health or the appropriate regulatory authority.
Requests for exercising these rights can be sent to PrivacyIndia@TwinHealth.com.
Twin Health retains personal information only as long as necessary to provide Services, comply with legal obligations, resolve disputes, and enforce agreements. After the retention period, personal data is either securely deleted or anonymized. Retention periods are documented and reviewed in accordance with DPDP Act and IT Act compliance guidelines.
Twin Health has implemented reasonable technical, administrative, and physical safeguards to protect personal information against unauthorized access, disclosure, alteration, or destruction. Security measures include encryption (SSL/TLS, AES-256), role-based access, multi-factor authentication, audit logging, and secure data storage. Despite these measures, no system is completely secure. Transmission of information over the Internet carries inherent risks, and users are encouraged to take appropriate precautions.
The Services are not intended for children under 18 years of age. Twin Health does not knowingly collect personal information from children. Any information inadvertently collected from a minor will be deleted promptly upon discovery. Parents or guardians may contact PrivacyIndia@TwinHealth.com to request deletion or correction of such information.
The App may contain links to third-party websites or services, which are not under Twin Health's control. Twin Health is not responsible for the privacy practices of such third parties. Third-party advertisers may use cookies, web beacons, or other tracking technologies to deliver interest-based advertising. No personal health information from the App or Apple Health is shared with advertisers.
Twin Health may amend this Policy at any time to reflect changes in legal requirements, services, or business practices. Amendments will be effective immediately upon posting on the App. Users are responsible for reviewing this Policy periodically. Continued use of the Services constitutes acceptance of such changes.
For queries, complaints, or to exercise your rights under this Policy, please contact:
Privacy/Data Protection Office
Email: PrivacyIndia@TwinHealth.com
Address: Twin Digital Services India Pvt. Ltd., Chennai, India
This Policy and any dispute arising out of its application shall be governed by the laws of India, including the DPDP Act, IT Act, and other applicable regulations. For U.S.-based users, HIPAA and relevant federal or state laws shall govern the use of PHI. Disputes will be first attempted to be resolved informally with the Privacy Office. Legal proceedings, if necessary, will be under the exclusive jurisdiction of courts in Bengaluru, India (for Indian users) and Santa Clara, California (for U.S. users).
By accessing or using Twin Health Services, you acknowledge that you have read, understood, and agreed to the terms and practices described in this Privacy Policy.