Privacy Policy – ImmerTwin™

Effective date: 01 February 2026
Last updated: 01 February 2026

This Privacy Policy explains how ImmerTwin SARL (“ImmerTwin”, “we”, “us”) collects, uses, shares, and protects personal data when you interact with:

• our website (immertwin.com), and/or

• our tours subdomain (tours.immertwin.com), and/or

• our services (including 360° / 3D capture, virtual tours, and related deliverables).

We aim to comply with the EU GDPR (and, where applicable, the UK GDPR and the UK Data Protection Act 2018).

1) Who we are (Data Controller)

Data controller: ImmerTwin SARL
Registered address:
144 Route Des Avaloirs,
61140, Juvigny-Val-d’Andaine
Basse Normandie, France
Contact: contact@immertwin.com

UK related company (information): A Gibson Consulting Ltd may support certain operational activities for ImmerTwin. Where it processes personal data on behalf of ImmerTwin, it does so under ImmerTwin’s instructions.

2) How this policy applies (Website vs Client Projects)

We handle personal data in two main contexts:

A) Website & marketing context (we act as controller)
When you browse our website, submit an enquiry, request a quote, or interact with our marketing, we decide how and why your data is used.

B) Client project context (controller/processor depends)
For scanning/tour production delivered to a client, the client may be the controller of project data (they determine the purpose), and ImmerTwin may act as a processor (we process data only to deliver the service). If needed, we can put a Data Processing Agreement (DPA) in place.

3) What personal data we collect

We may collect the following categories of personal data (depending on how you interact with us):

A) Identity & contact data

• Name, email address, phone number

• Company name, role/job title

• Communications with us (emails, messages, call notes)

B) Account, booking & transaction data

• Quotes, invoices, payment status (and limited payment-related information as required for billing)

• Service details (dates, locations, scope)

C) Technical & usage data

• IP address (or partial IP where applicable), device type, browser type, operating system

• Website usage data, logs, referral/UTM parameters

• Cookie identifiers (see Cookie Policy)

D) Project & spatial capture data (when relevant)

• Imagery/360° capture and spatial representations of properties/venues

• Project metadata (capture dates, internal IDs, tour settings, floor/room labels)

• User-generated content added to a tour (text, labels, hotspots), if applicable

Important note: Project content can sometimes incidentally include personal data (e.g., a person appearing in imagery, names on displays, vehicle plates, personal photos on walls). Where possible, we recommend removing/covering personal items before capture or requesting blurring/removal.

4) How we use your data (Purposes & legal bases)

We only use personal data where we have a lawful basis. Common purposes include:

A) Delivering our services (Contract / steps to enter a contract)

• Provide quotes, plan capture sessions, deliver tours/files, provide support

• Manage client communication and project administration

B) Billing & compliance (Legal obligation / Contract)

• Issue invoices, manage payments, maintain accounting records

• Comply with legal and regulatory obligations

C) Service improvement & operations (Legitimate interests)

• Improve quality, troubleshoot issues, maintain business records

• Protect our business and users (fraud prevention, security)

D) Analytics & performance measurement (Consent where required)

• Understand usage of our Website/Tours Site and improve content and user experience

• We use Google Analytics 4 (GA4) where enabled

E) Marketing & targeting (Consent where required / legitimate interests for limited B2B communications)

• Send relevant updates if you request them or where permitted

• Measure and improve campaigns; build audiences/remarketing where enabled

• We may use Google Ads and related tagging for advertising measurement/targeting where configured

5) Marketing communications (your choices)

• You can opt out of marketing emails at any time by using the unsubscribe option (where provided) or by contacting contact@immertwin.com.

• Where consent is required (e.g., certain targeting/remarketing), we will ask you first and provide a way to withdraw consent.

6) Sharing your data (Recipients)

We do not sell personal data. We may share data with:

A) Service providers (processors)

• Hosting, IT support, security tooling

• Email/communication tools

• Analytics and advertising providers (where enabled)
  These providers are only permitted to process data under our instructions and must apply appropriate safeguards.

B) Professional advisers

• Accountants, legal advisers, insurers (as needed)

C) Legal & compliance

• Regulators, courts, law enforcement where required by law

D) Business transfers

• If we undergo a merger, acquisition, restructuring, or asset sale, data may be transferred subject to appropriate protections.

7) International transfers

Some service providers may process data outside France/EEA/UK. Where personal data is transferred internationally, we use appropriate safeguards (e.g., adequacy decisions, standard contractual clauses, or equivalent measures) as required by applicable law.

8) Data retention

We keep personal data only as long as necessary for the purposes described above, including:

• delivering services and ongoing support,

• meeting legal/accounting obligations,

• resolving disputes and enforcing agreements.

Retention depends on the data type and context (website enquiries vs contracted projects). When data is no longer required, we delete or anonymise it.

9) Security

We implement reasonable technical and organisational measures to protect personal data, which may include access controls, least-privilege permissions, secure storage, and operational safeguards. No method of transmission or storage is 100% secure, but we work to reduce risk and respond to incidents appropriately.

10) Your rights

Depending on your location and applicable law, you may have rights to:

• access your data,

• correct inaccurate data,

• delete data (in certain circumstances),

• restrict or object to processing,

• data portability (where applicable),

• withdraw consent (where processing is based on consent).

To exercise your rights, contact: contact@immertwin.com.
We may need to verify your identity before responding.

11) Cookies & tracking

We use cookies and similar technologies for essential operation, preferences, analytics, and marketing (where enabled and where consent is required). For details, please refer to our Cookie Policy and the cookie settings/banner on the Website/Tours Site.

12) Children

Our services and websites are not intended for children, and we do not knowingly collect personal data from children. If you believe a child has provided personal data to us, contact contact@immertwin.com.

13) Complaints

If you have concerns, please contact us first at contact@immertwin.com so we can address them. You may also have the right to lodge a complaint with your local data protection authority, including the CNIL (France) and the Information Commissioner’s Office (UK), depending on your circumstances.

14) Changes to this policy

We may update this Privacy Policy to reflect changes in our services, legal requirements, or processing activities. The “Last updated” date at the top indicates when changes were made.