Privacy Policy

Twos is operated by The Twos Company, Inc., a company organized under the laws of the State of Delaware, United States.

If you have questions about this Privacy Policy or our privacy practices, you may contact us at:

hello@twos.net

Mailing Address: The Twos Company, Inc., 800 N State St, Suite 304, Dover, Delaware 19901, United States

This Privacy Policy explains how Twos collects, uses, discloses, and safeguards information when you use the Twos website, mobile applications, and related services.

We design our privacy practices with major global privacy frameworks in mind, including the General Data Protection Regulation (GDPR), the California Consumer Privacy Act and California Privacy Rights Act (CCPA/CPRA), and similar U.S. state and international privacy laws where applicable.

Depending on your location, additional rights and disclosures may apply under applicable U.S. state privacy laws, including the California Consumer Privacy Act (CCPA/CPRA), Colorado Privacy Act (CPA), Virginia Consumer Data Protection Act (VCDPA), Connecticut Data Privacy Act (CTDPA), Utah Consumer Privacy Act (UCPA), and similar laws.

Depending on your location and how you use Twos, our legal bases for processing personal information may include:

• Your consent
• Performance of a contract
• Compliance with legal obligations
• Legitimate interests such as operating, securing, improving, and moderating the platform

By using Twos, you acknowledge that your information will be handled as described in this Privacy Policy.

This Privacy Policy applies to the Twos website, mobile applications, and related services, features, and communications operated by Twos (collectively, the "Services").

This Privacy Policy does not apply to third-party websites, services, or applications that may be linked through Twos or used in connection with the Services. Those third parties operate under their own privacy policies and terms.

We collect only the information reasonably necessary to operate, secure, and improve Twos.

This may include:

• Account information, Email addresses, phone numbers, display names, profile information, and account preferences that you choose to provide.
• Connection and device data, IP address, approximate location derived from IP address, device type, operating system, app version, language preferences, network information, and diagnostic data.
• Usage and activity information, Information about how Twos is used, including connections made, call duration, feature usage, onboarding progress, interaction events, and aggregated or de-identified analytics.
• Communications and support information, Information you provide when contacting support, reporting users, participating in surveys, or communicating with us.
• Safety and moderation information, Information associated with reports, moderation actions, abuse detection systems, trust-and-safety investigations, and enforcement activity.

We do not intentionally collect sensitive personal information beyond what is reasonably necessary to operate the service and maintain platform safety.

Twos is designed for private, real, human conversations. "Private" means conversations are intended for direct communication between participants and are not publicly broadcast to other users by Twos.

Twos does not record or store audio or video from standard calls during normal platform use.

However, limited real-time processing of audio, video, and related media signals may occur to support:

• Platform safety
• Moderation systems
• Abuse and fraud detection
• Connection quality
• Spam prevention
• Service functionality

For example, Twos may temporarily process transient video frames or media signals to detect nudity, spam, harmful behavior, or technical issues.

This processing is generally automated and ephemeral, and the underlying audio and video content is not retained during standard platform use.

Twos may generate and temporarily store text transcripts or derived representations of conversations to support platform functionality, moderation, safety systems, conversation summaries, analytics, product improvement, machine learning systems, research, and related service operations.

Twos may also generate derived metadata, embeddings, classifications, scores, or other inferences from conversations, media signals, or user interactions for purposes described in this Privacy Policy.

Transcripts and related derived data are treated as sensitive information and handled using reasonable administrative, technical, and organizational safeguards.

Unless explicitly disclosed otherwise for optional future features, transient media signals used for safety or technical analysis are generally not stored or retained after processing.

Twos may use automated systems to analyze visual, audio, speech, behavioral, or interaction-related signals for safety, moderation, fraud prevention, analytics, accessibility, personalization, research, or product functionality purposes. Twos does not currently use facial recognition technologies for persistent identity recognition during ordinary platform use.

Twos does not secretly record calls.

Twos does not record calls during standard platform use or during moderation events.

If optional recording-based features are introduced in the future, users will receive appropriate notice and any required consent mechanisms before recording begins.

Twos may use automated systems, including AI, machine learning, statistical models, and algorithmic analysis tools, to analyze transcripts, media signals, metadata, behavioral signals, and platform interactions for purposes such as:

• Supporting safety and moderation systems
• Detecting spam, fraud, or harmful behavior
• Generating conversation summaries and related functionality
• Improving platform performance and reliability
• Improving recommendation, matching, and personalization systems
• Training, evaluating, and improving moderation, safety, ranking, recommendation, and platform-quality systems
• Conducting product research, analytics, and service optimization
• Developing and improving machine learning models and AI-enabled features
• Supporting academic, scientific, or behavioral research initiatives in aggregated, pseudonymous, or de-identified form where appropriate

Twos may use service data to develop generalized platform intelligence, safety systems, recommendation systems, and conversational quality systems that are not uniquely associated with any individual user.

This analysis is designed to support platform functionality, moderation, and user safety. It is not intended to provide medical, therapeutic, psychological, employment, insurance, credit, housing, or legal determinations.

Twos does not make legally significant decisions based solely on automated processing.

Twos generally does not retain full audio or video recordings from standard calls, but may temporarily process, analyze, transform, classify, or derive information from media signals in connection with safety systems, moderation, analytics, research, machine learning systems, or platform operations.

Where required by applicable law, users may have the right to object to certain forms of automated processing or request additional information regarding such processing.

Twos may process short-lived technical, behavioral, and media-related signals to maintain service quality and platform safety, including:

• Connection quality
• Audio clarity
• Device integrity signals
• Transient video frame analysis for coarse safety detection
• Spam or abuse indicators
• General behavioral patterns associated with platform misuse

These signals are generally processed in real time and are not retained longer than necessary unless associated with a safety investigation, legal obligation, fraud prevention effort, or policy violation.

We use information collected through Twos to:

• Provide and operate the platform
• Facilitate video conversations between users
• Maintain platform security and integrity
• Personalize matching and product experiences
• Improve performance, moderation, and reliability
• Investigate abuse, fraud, or policy violations
• Comply with legal obligations
• Communicate with users about accounts, updates, support requests, and transactional matters
• Send marketing communications where permitted by law and where users have opted in or not opted out
• Develop, train, evaluate, and improve machine learning and AI-enabled systems
• Conduct internal research, analytics, experimentation, and platform-quality measurement
• Support academic, scientific, or behavioral research initiatives where appropriate safeguards are applied

Users may unsubscribe from marketing communications at any time.

Twos does not sell personal information and does not share personal information for cross-context behavioral advertising.

Twos also does not use conversation transcripts, transient media signals, or safety-related processing for third-party advertising purposes.

We do not sell or license transcripts or call content to third parties.

We may share limited information with:

• Infrastructure providers
• Analytics providers
• Authentication providers
• Customer support tools
• Email and SMS delivery providers
• Trust and safety service providers

These providers process information on our behalf under contractual obligations designed to protect confidentiality and security.

We may also disclose information:

• To comply with applicable law, regulation, legal process, or government request
• To enforce our Terms or policies
• To detect, prevent, or investigate fraud, abuse, security incidents, or illegal activity
• To protect the rights, safety, and security of Twos, users, or others

Twos may share aggregated, pseudonymous, or de-identified information for research, analytics, safety, or product improvement purposes where permitted by applicable law.

If Twos is involved in a merger, acquisition, financing, restructuring, bankruptcy, asset sale, or similar transaction, information may be transferred as part of that transaction subject to applicable legal requirements.

Twos operates internationally and information may be processed, transferred, or stored in countries other than your own, including the United States.

Where required by applicable law, we implement reasonable safeguards intended to protect personal information during international transfers.

We retain information only for as long as reasonably necessary for the purposes described in this Privacy Policy, including operational, safety, legal, and business needs.

Examples include:

• Connection and device data, Generally retained for limited periods for security, fraud prevention, diagnostics, and operational reliability.
• Transcripts, Generally retained for up to 14 days unless a longer retention period is necessary for safety investigations, abuse prevention, dispute resolution, legal obligations, or enforcement purposes.
• Metadata and analytics, May be retained in aggregated, pseudonymous, or de-identified form for longer periods to support analytics, abuse prevention, operational reporting, and service reliability.
• Account information, Retained while the account remains active and for a reasonable period afterward where necessary for security, fraud prevention, dispute resolution, legal compliance, or legitimate business purposes.

Derived data, aggregated analytics, safety-related signals, model-training datasets, and de-identified information may be retained for longer periods where reasonably necessary for platform integrity, research, analytics, abuse prevention, machine learning systems, legal compliance, or service improvement.

Some information may remain temporarily in backups, logs, security systems, or archived records before deletion or de-identification.

Users may request deletion of personal information by contacting hello@twos.net, subject to applicable legal exceptions and operational requirements.

When you use the Twos website, we use cookies and similar technologies.

We group these into two categories:

• Strictly necessary technologies, Required for authentication, security, language preferences, and core functionality.
• Analytics technologies, Used to help us understand site performance, feature usage, onboarding flows, and product improvements. We currently use tools such as Google Analytics and PostHog.

Analytics technologies are not used for targeted advertising or cross-site behavioral advertising.

Where required by applicable law, analytics technologies remain disabled until consent is provided.

We may use privacy-enhancing measurement technologies such as Google Consent Mode v2, which can allow limited cookieless or aggregated measurement signals without directly identifying users.

The Twos mobile applications do not rely on traditional web cookies. Mobile analytics and permissions are governed by platform-level disclosures, app permissions, and in-app settings.

Depending on your location and applicable law, you may have rights regarding your personal information, including the right to:

• Access information we hold about you
• Request correction of inaccurate information
• Request deletion of personal information
• Request portability of certain data
• Object to or restrict certain processing
• Withdraw consent where processing is based on consent
• Opt out of marketing communications
• Request information about automated processing practices

Residents of certain U.S. states may have additional rights regarding targeted advertising, profiling, automated decision-making, and the sale or sharing of personal information under applicable law.

Twos does not currently sell personal information or use personal information for cross-context behavioral advertising as those terms are defined under applicable U.S. privacy laws.

Depending on applicable law, users may have rights related to profiling, automated decision-making, machine learning systems, or AI-enabled processing.

We respond to applicable privacy rights requests in accordance with relevant laws.

To exercise your rights, contact: hello@twos.net

We may need to verify your identity before processing certain requests.

We use administrative, technical, and organizational measures designed to help protect information and maintain platform security.

Our infrastructure may include trusted third-party providers such as Amazon Web Services (AWS) and other cloud, communications, analytics, and infrastructure providers.

Security measures may include:

• Encryption of data in transit using industry-standard protocols
• Encrypted or access-controlled storage systems
• Authentication and access controls
• Monitoring and abuse detection systems
• HTTPS-secured communications
• Periodic review of security practices and infrastructure

No system can guarantee absolute security, and users should understand that internet-based services inherently involve some risk.

While Twos uses reasonable safeguards designed to protect information, no internet-based service or electronic storage system can be guaranteed to be completely secure. Users use the service at their own risk and should exercise caution when sharing sensitive information online.

Twos is intended only for adults aged 18 and older.

We do not knowingly permit minors to use the platform or knowingly collect personal information from individuals under 18.

If we become aware that personal information has been collected from a minor in violation of this policy, we will take reasonable steps to delete the information and restrict the associated account.

We may update this Privacy Policy from time to time.

If material changes are made, we may provide notice through the website, application, or other appropriate communication channels.

The "Last Updated" date indicates when this Privacy Policy was most recently revised.

If you have questions, concerns, or privacy requests, please contact:

hello@twos.net

The Twos Company, Inc., 800 N State St, Suite 304, Dover, Delaware 19901, United States