Submit offer Twinspire GDPR Legal Advisory - Data Processing Agreement (DPA) Framework for Sensitive Physiological & Biometric Data

1. General Information

Title of Tender:  Twinspire GDPR Legal Advisory - Data Processing Agreement (DPA) Framework for Sensitive Physiological & Biometric Data

Company Name:  Twinspire Neural Solutions

Address:  

CVR nr.:  45077705

Date:  01.05.2025

Deadline for Tender:  20.07.2026

Contact:  Pouya Nikoui – pouyanikoui@live.ca

2. Presentation of the Company

Twinspire is a Danish sports technology company founded in 2023 and headquartered in Copenhagen, Denmark. The company was established at the Technical University of Denmark (DTU) through DTU Skylab, the university's innovation and entrepreneurship hub, and has been developed in close collaboration with DTU Health Tech. Twinspire develops an AI-powered digital twin platform for professional athletes, with an initial focus on elite football. The platform integrates data from existing athlete management systems, including GPS and training load, strength and movement testing, heart rate variability, sleep data, and rehabilitation records and transforms this data into predictive outputs, including individual readiness scores, reinjury risk flags, and return-to-play guidance. Twinspire does not replace existing tools used by clubs but operates as a predictive intelligence layer on top of them. Twinspire holds a filed patent application covering its proprietary training methodology and operates in a formal partnership with the Danish Football Union's (DBU/DIF) Innovation Lab.

Website: twinspire.ai  |  Contact: info@twinspire.ai

3. Description of the Task

Twinspire is seeking a quotation from a qualified independent legal consultant with specialist expertise in GDPR and data protection law, specifically concerning the processing of special category health and biometric data, for the provision of legal advisory services to inform how Data Processing Agreements (DPAs) covering Twinspire's club relationships should be structured. This is a consulting and knowledge-acquisition engagement. Twinspire is not purchasing the production or signature of DPAs with individual clubs. Twinspire is purchasing specialist legal advice to understand what such agreements are legally required to contain, and how the underlying data processing framework, data classification, and risk assessment should be structured, given that Twinspire processes health-related data on professional athletes across multiple club relationships. This is specialist knowledge that Twinspire's team does not currently hold in-house and cannot acquire without external legal expertise. 

3.1 Advisory on DPA Structure & Legal Requirements
The consultant will advise Twinspire's team on the legal requirements that Data Processing Agreements must satisfy when covering special category health and biometric athlete data, including the respective obligations of controller and processor, and how these requirements should be reflected when Twinspire's own team subsequently structures agreements across multiple, differently-configured club relationships. This is advisory guidance only; the consultant will not negotiate, or sign agreements with any club on Twinspire's behalf.
3.2 GDPR Compliance Advisory
The consultant will advise on the legal basis, purpose limitation, data minimisation, retention, and the specific safeguards required under GDPR for processing special category health and biometric data of professional athletes. 
3.3 Data Classification & Risk Assessment Guidance
The consultant will advise on how Twinspire should classify the sensitivity levels of the different data types it processes (e.g. physiological, biometric, training, health and rehabilitation data), and on the methodology Twinspire's team should apply to conduct its own data protection risk assessment. This is guidance and knowledge transfer; the risk assessment and data classification exercise itself will subsequently be carried out by Twinspire's own team.
3.4 Advisory Documentation for Internal Use
The consultant will produce written advisory documentation for Twinspire's internal team to use as the basis for its own subsequent work of drafting records of processing, data flow documentation, and club-specific agreements. The consultant's deliverable is this advisory documentation itself, not the finished agreements or compliance artefacts it will inform.
3.5 Context and Background
Twinspire is a data-driven sports technology company handling special category health and biometric data on professional athletes across several club relationships. Correctly structuring the associated data processing framework is a precondition for Twinspire's own team to be able to move its club partnerships forward, but the specialist legal knowledge required to do so does not currently exist in-house. Engaging an experienced external legal consultant with direct expertise in GDPR, data protection law, and the treatment of special category personal data is essential to closing this knowledge gap, so that Twinspire's own team can subsequently execute with confidence.
4. Task Objectives and Success Criteria

4.1 Primary Objective
The primary objective of this engagement is for Twinspire's team to acquire, by end of July 2026, a clear and legally sound understanding, through external advisory input, of how DPAs, data classification, and risk assessment should be structured for the special category health and biometric data Twinspire processes across its club relationships. The deliverable is advisory knowledge and documentation; the subsequent execution (drafting, negotiating, and finalising agreements with individual clubs) remains Twinspire's own responsibility and is outside the scope of this engagement.
4.2 Success Criteria
The task shall be considered successfully completed when the following measurable criteria have been met:
●      Advisory assessment on DPA structure and legal requirements delivered and reviewed by the founding team

●      GDPR compliance advisory assessment delivered - approved by CEO

●      Data classification and risk assessment guidance delivered, providing Twinspire's team with a methodology it can apply internally

●      Written advisory documentation for internal use finalised, to serve as the basis for Twinspire's subsequent drafting of records of processing, data flow documentation, and club-specific agreements

4.3 Acceptance Procedure
Twinspire's CEO will review all deliverables upon submission. Written acceptance or a documented list of required revisions will be provided within 5 working days of receipt of each deliverable. The engagement will be considered fully completed upon written sign-off from Twinspire's CEO confirming that all deliverables meet the agreed quality standard.

5. Budget and Specification of an Offer

Twinspire ApS invites qualified consultants to submit a written offer for the advisory task described in sections 3 and 4. This is a consulting engagement only; no negotiation, or signature of agreements with third parties (including clubs) is included in, or may be invoiced under, this tender. The total budget available for this engagement is DKK 43,000 excluding VAT.

All offers must include as a minimum the following elements:

Date of submission of offer
The offer must be dated and submitted no later than 20.07.2026. Offers received after this date will not be considered.
Brief presentation of the bidder
The offer must include the full legal name and CVR number of the bidding individual or entity, contact details including email address and telephone number, and a brief description of relevant professional background and experience. The bidder is encouraged to include references from comparable advisory assignments involving GDPR compliance, data processing agreements, or legal structuring of special category / health data processing arrangements. Experience with data protection law in a health-data, sports-science, or early-stage technology venture context is considered particularly relevant.
Bidder's proposal for solving the task
The offer must include a clear description of the proposed advisory approach to delivering the scope outlined in sections 3 and 4, including proposed methodology, work sequencing, and any assumptions or preconditions relevant to delivery. The proposal should clearly reflect that the engagement is advisory in nature and that execution of any resulting agreements will be carried out by Twinspire's own team.

6. Background for the Tender

Beyond Beta is subject to a number of requirements for good, healthy financial management, including documentation that the agreed price for external purchases is an expression of the market price. This tender is part of these requirements. We emphasise that the bidder must make an offer only for the requested task. Services of an executing or implementing nature cannot be approved, this tender is limited to the purchase of specialist legal advisory input, and does not cover the negotiation, or signature of Data Processing Agreements with Twinspire's club partners, which remains Twinspire's own responsibility to execute following receipt of the advisory deliverables. The winning bid is chosen based on an assessment of the best correlation between price and quality.