Privacy Policy

Last updated: October 9, 2026

This policy explains what personal information 12th Wonder LLC ("12th Wonder", "we", "us") collects, why we collect it, how we handle it, and what rights you have. We collect only what we need to run our business and deliver TITAN and our professional Services to our customers.

Our customers are organizations. They sign an Order Form, a Master Subscription or License Agreement, or a Statement of Work with us, and our Data Processing Addendum (DPA) applies to the personal data we process for them. If a signed agreement between 12th Wonder and a customer conflicts with this policy, the signed agreement controls.

Two roles: our data and our customers' data

We handle personal information in two different roles, and the rules differ for each.

(A) Information we control. For our own website, sales and marketing contacts, customer administrators and billing contacts, and support requests, 12th Wonder decides what to collect and why. We are the "controller" (GDPR/UK GDPR) or "business" (California law) for this information. Part A covers it.

(B) Customer Data in TITAN. Our customers use TITAN to run their test labs. The data they and their users put into TITAN ("Customer Data") belongs to the customer. The customer is the controller. 12th Wonder is a "processor" or "service provider" and handles Customer Data only on the customer's instructions, as set out in the customer's agreement and DPA. Part B covers it.

If you use TITAN because your employer or another organization gave you access (for example, as a lab engineer or as a user of a customer's Booking Portal), that organization decides how your information is used in TITAN. Please contact that organization first with questions or requests about your data. If you contact us instead, we will refer you to them, or help them respond as their agreement with us requires.

Job applicants: see our Job Applicant Privacy Notice.

California residents: see our California Notice at Collection.

Part A: Information 12th Wonder controls

What we collect and why

Website visitors (12thwonder.com and testlifecycle.com). We run two websites: 12thwonder.com for the company and testlifecycle.com for TITAN TLM (titantlm.com redirects to testlifecycle.com). When you visit either one, we collect technical information such as your IP address, browser and device type, pages visited, referring site, and time of visit. We use it to run and secure the site, understand how it is used, and improve it. If you fill in a contact or demo form, we collect what you enter, typically your name, work email, company, job title, phone number, and your message. Form submissions are stored in our customer relationship management (CRM) system, Nimble. We use them to respond to you and to keep a record of our conversation.

Business contacts (prospects, customers, partners). We keep contact information for people we do business with: name, work email, phone, company, job title, and records of our conversations, meetings, and proposals. Our CRM may add business details from public and professional sources, such as job title, company information, and public professional profiles, to the details you give us. We use it to discuss, sell, and deliver our products and Services, manage the relationship, and send relevant business updates. You can opt out of marketing emails at any time with the unsubscribe link or by writing to [email protected]. We will still send you messages we need to send to perform a contract, such as service and security notices.

Customer administrators and billing contacts. When an organization becomes a customer, we collect the names and work contact details of its contract signatories, administrators, project contacts, and billing contacts, plus billing address, purchase order and tax details. We invoice our customers through our accounting system, QuickBooks Online (Intuit). Customers can pay through a QuickBooks payment link by card or bank account; those payment details are entered directly with Intuit, which processes the payment under its own terms and privacy policy. We see only limited payment information, such as the payer's name, amount, date, and the last digits of the card or account, and we do not store full card or bank account numbers. We use this information to set up and administer the customer's TITAN instance and tenants, deliver Services, send invoices, collect payment, calculate tax, and keep proper business records.

Support requests. When you contact support (by email to [email protected] or through our support channel), our support system, Freshdesk, keeps your name, contact details, the content of your request, and any attachments, screenshots, or logs you send. We use it to resolve your request and to keep a history so we can help you faster next time. Support requests sometimes contain Customer Data. When they do, we treat that Customer Data as described in Part B.

Account and security information for 12th Wonder services. For the TITAN instances we host, we keep sign-in and access logs (such as user ID, IP address, timestamp, and whether sign-in succeeded) to secure the service, detect misuse, and investigate incidents. Where these logs relate to a customer's users, they are part of operating the customer's service under Part B; we also use them for our own legitimate interest in keeping our systems secure.

Events, surveys, and interviews. If you attend a webinar, training session, or event, or answer a survey, we keep what you give us. We will only record a call or meeting with your consent.

We do not use your name, your company's name, or your logo in our marketing without permission.

Cookies and analytics

On our websites. We use cookies and similar technologies to make our websites work, remember preferences, understand how the sites are used, and, on testlifecycle.com, measure and target our advertising. The tools differ by site.

On 12thwonder.com we use:

  • Google Tag Manager (Google), which loads our other website tags.
  • Google Analytics (Google), to measure visits and how pages are used.
  • Microsoft Clarity (Microsoft), which records how visitors move through pages, such as clicks, scrolling, and heatmaps, so we can improve the site.
  • Google reCAPTCHA (Google), to protect our forms from spam and abuse.
  • Cloudflare Web Analytics (Cloudflare), for basic traffic statistics without cookies.
  • Vimeo video players embedded on some pages, which Vimeo may use to set its own cookies when a video loads.

We don't use advertising pixels on 12thwonder.com.

On testlifecycle.com we use:

  • Google Tag Manager (Google), which loads our other website tags.
  • Google Analytics (Google), to measure visits and how pages are used.
  • Google Ads (Google), to measure how our ads perform and to show our ads to people who have visited the site. Google receives cookie identifiers, your IP address, and the pages you visit, and may combine them with other information it holds. See Sale and sharing.
  • Factors.ai (Factors.ai), which uses your IP address to identify the company or organization you are visiting from and shows us how visitors from that organization use the site. We use this to understand which organizations are interested in TITAN.
  • Microsoft Clarity (Microsoft), which records how visitors move through pages, such as clicks, scrolling, and heatmaps, so we can improve the site.

Where the law requires consent for non-essential cookies, including analytics and advertising cookies, we will ask for it first. You can also block or delete cookies in your browser settings.

In TITAN. TITAN uses cookies and browser storage that are necessary for signing in, keeping your session, security, and remembering your preferences (such as layout and grid settings). TITAN does not use analytics, advertising, or third-party tracking cookies. For customer-hosted TITAN, the customer controls its own environment and any tools it adds.

If the GDPR or UK GDPR applies to you, we rely on these legal bases for the information in Part A:

  • Contract: to perform our agreement with a customer, or to take steps a prospect asked for before entering one.
  • Legitimate interests: to run, secure, and improve our website and services; to market our products to business contacts; to keep business records; and to establish, exercise, or defend legal claims. We weigh these interests against your rights, and you can object (see Your rights).
  • Consent: for non-essential cookies, including analytics and advertising cookies and Factors.ai visitor identification on testlifecycle.com; certain marketing where the law requires consent; and call recordings. You can withdraw consent at any time.
  • Legal obligation: to keep tax and accounting records and respond to lawful requests.

Who we share it with

We do not sell personal information for money. We share information only as follows:

  • Service providers. We use other companies to help us run our business and operate hosted TITAN. They may only use the information to provide services to us, under written agreements. For our own business, these include Nimble (CRM and contact forms), Intuit QuickBooks (invoicing and payments), Freshdesk (support), Microsoft 365 (email and files), and the website tools listed under Cookies and analytics. The providers that may process Customer Data are listed on our Subprocessors page.
  • At a customer's direction. When a customer connects TITAN to another system (for example, its single sign-on provider such as Microsoft Entra ID, Okta, or another SAML provider, or an integration we build for it), data flows to that system because the customer asked for it.
  • Advertising (testlifecycle.com only). The Google Ads tag on testlifecycle.com sends Google cookie identifiers, IP address, and browsing activity on that site so we can measure our ads and show them to past visitors. California law treats this as "sharing" personal information for cross-context behavioral advertising. See Sale and sharing for how to opt out.
  • Professional advisers. Lawyers, accountants, auditors, and insurers, under duties of confidentiality.
  • Legal requirements. When we are legally compelled, see Requests from authorities.
  • Business transfers. If 12th Wonder is involved in a merger, acquisition, or sale of assets, personal information may transfer to the new owner. We will give notice before your information becomes subject to a different privacy policy.
  • Aggregated or de-identified data. We may use aggregated or de-identified information that can no longer identify you or a customer, for example to understand how our website is used. We will not try to re-identify it.

Sale and sharing

We don't sell personal information for money. On testlifecycle.com, we share identifiers (cookie IDs and IP address) and internet activity on that site with Google for advertising, as described above. Under California law this counts as "sharing" for cross-context behavioral advertising, and some other US state laws treat it as targeted advertising or a "sale". We don't do this on 12thwonder.com, and we don't knowingly share the personal information of anyone under 16.

How to opt out:

  • Use the Do Not Sell or Share My Personal Information link in the testlifecycle.com footer, which goes to testlifecycle.com/privacy-choices, or reject advertising cookies in our cookie banner.
  • Turn on Global Privacy Control (GPC) in your browser. We treat a GPC signal as an opt-out request for that browser.
  • Email [email protected].

Requests from authorities

We do not hand over data to government authorities unless we are legally compelled to, or in a genuine emergency involving risk of death or serious harm. We review each request to make sure it is valid and narrow it where we can. When a request concerns Customer Data, we will redirect the authority to the customer where possible, and we will notify the customer before disclosing unless the law prohibits it. If a tax authority audits us, we disclose only the minimum billing information needed.

Part B: Customer Data in TITAN

Customer Data is everything a customer and its users put into or generate in TITAN: for example, user profiles, test requests, vehicle and test article records, equipment and facility records, bookings made through a customer's Booking Portal, workflows, test results and measurement data, attachments, and reports. It can include personal information about the customer's employees, contractors, and its own customers.

The customer is in charge. The customer decides what goes into TITAN, who can access it, how long it is kept, and how its users sign in. The customer is responsible for having a lawful basis for that data and for giving its own privacy notices to its users. Our duties for Customer Data are set out in the customer's agreement with us and its DPA. Where that agreement says something different from this policy, the agreement controls.

What we do with Customer Data. We process Customer Data only to provide TITAN and the Services the customer has asked for, to keep the service secure and working, and as the law requires. We do not sell Customer Data. We do not use it for advertising. We do not use it for our own purposes outside the customer's instructions.

The details depend on how the customer runs TITAN:

TITAN Hosted

12th Wonder operates the customer's TITAN instance on infrastructure we manage, on a *.12thwonder.com subdomain, with our hosting provider, Microsoft Azure. In this model:

  • Customer Data is stored and processed by us and our subprocessors.
  • Our people access Customer Data only when needed to provide the service: to respond to a support request, to deliver Services the customer has ordered (such as data migration or configuration), to fix a problem that stops the service working, to investigate a security incident or abuse, or when the law requires. Access is limited to people who need it.
  • Our security commitments apply.
  • When an agreement ends, Customer Data is returned and deleted as described in our Termination & Data Export policy and the customer's agreement.

Customer-hosted (on-premises or customer cloud)

The customer runs TITAN on its own infrastructure. The customer stores and controls the data; we do not host it. In this model:

  • 12th Wonder only sees Customer Data when the customer authorizes access, for example by granting us a support session, remote access, a database copy, or log files to diagnose a problem or deliver Services.
  • We use what we see only for that authorized purpose, and we delete copies we receive once the work is done, unless the customer's agreement says otherwise.
  • The hosting, backup, retention, and security commitments in this policy and in our Security and SLA policies apply to the hosted service, not to the customer's own environment. The customer is responsible for securing its environment.

Requests from TITAN users

If you are a user of a customer's TITAN instance and want to access, correct, or delete your information, please contact that customer. If you contact us, we will pass your request to the customer and help it respond as required by its agreement with us.

Your rights

Depending on where you live, you may have some or all of these rights over personal information we control (Part A):

  • Know and access: to know what we collect, how we use and share it, and to get a copy.
  • Correction: to fix inaccurate information.
  • Deletion: to ask us to delete your information, subject to legal exceptions (for example, records we must keep for tax purposes).
  • Portability: to receive your information in a usable format and send it elsewhere.
  • Objection and restriction: to object to, or ask us to limit, certain uses, including direct marketing.
  • Withdraw consent: where we rely on consent, at any time.
  • Not to be subject to solely automated decisions with legal or similarly significant effects. We do not make such decisions about you.
  • Non-discrimination: we will not treat you differently for exercising your rights.
  • Complain: to a data protection authority.

GDPR and UK GDPR. If you are in the EEA or UK, you have the rights above. You can complain to your local data protection authority, or to the UK Information Commissioner's Office.

California. California residents have rights to know, delete, correct, and opt out of the sale or sharing of personal information, and to limit the use of sensitive personal information. See our California Notice at Collection.

How to make a request. Email [email protected] or write to 12th Wonder LLC, 5890 Stoneridge Dr, Suite 216, Pleasanton, CA 94588, USA. We will need to verify your identity before acting, usually by confirming your name and email address, and more for sensitive requests. If someone is acting for you as an authorized agent, we will need proof of their authority, such as your signed permission. If we deny your request, we will explain why, and where the law gives you a right to appeal, we will tell you how.

For Customer Data in TITAN (Part B), please contact the customer organization that controls it.

Data retention

We keep personal information only as long as we need it for the purposes in this policy, or as long as the law requires, then delete or de-identify it. We may keep information longer where needed to resolve disputes, enforce agreements, or meet legal obligations.

  • Website analytics data: 14 months. Microsoft Clarity session recordings: 30 days.
  • Business contact and sales records: for as long as we have an active relationship with you or your organization, plus 3 years without contact. If you opt out of marketing, we keep your email address on a suppression list so we don't contact you again.
  • Customer administrator, billing, and contract records: 7 years after the contract ends.
  • Support tickets: for the term of the customer's agreement plus 2 years. Attachments that contain Customer Data are deleted when the agreement ends.
  • Sign-in and security logs for hosted TITAN: 12 months.

Customer Data is kept for as long as the customer's agreement says, and then returned and deleted as described in our Termination & Data Export policy. Hosted backups are kept for 35 days and then deleted.

How we secure data

We use administrative, technical, and physical safeguards appropriate to the information we handle. Data sent to and from hosted TITAN is encrypted in transit with TLS. Access to Customer Data is limited to people who need it. For details, see our Security overview. If you think you have found a security issue, see how we handle security reports or email [email protected].

No system is perfectly secure. If we become aware of a breach affecting personal information we handle, we will notify affected customers and individuals as the law and our agreements require.

International transfers

12th Wonder is based in the United States. Information we control (Part A) is processed in the United States and wherever our subprocessors operate.

For TITAN Hosted, Customer Data is stored in Microsoft Azure data centers in the United States, India, or West Europe (the Netherlands). Each Hosted instance runs in one of these regions. Where a customer's agreement specifies a hosting region, we follow it.

When we transfer personal information out of the EEA, UK, or Switzerland, we rely on the European Commission's Standard Contractual Clauses, with the UK International Data Transfer Addendum for UK transfers and the changes Swiss law requires for Swiss transfers. We are not certified under the EU-U.S. Data Privacy Framework. For Customer Data, the transfer terms are in our Data Processing Addendum or the customer's signed DPA.

Children

Our website, TITAN, and our Services are for businesses and their professional users. They are not directed at children, and we do not knowingly collect personal information from anyone under 16. If you think a child has given us personal information, contact [email protected] and we will delete it.

Changes to this policy

We may update this policy to reflect changes in our practices or the law. When we do, we will change the date at the top of this page. For significant changes, we will also give notice as described in Policy updates, and to customers as their agreements require.

Contact us

Questions, concerns, or requests about this policy or your personal information:

12th Wonder LLC 5890 Stoneridge Dr, Suite 216 Pleasanton, CA 94588, USA [email protected]