Our Approach to Privacy
1.1. TWO FINGERS (“TwoFingers”, “we”, “our”, or “us”) is dedicated to safeguarding and respecting your privacy. This privacy policy outlines how we gather, store, process, transfer, share, and utilize data that identifies or is linked to you (“personal information”), as well as information regarding our use of cookies and similar technologies.
1.2. TwoFingers is an application that enables users to instantly connect with new friends and engage in discussions (“TwoFingers Service”).
1.3. This privacy policy pertains to the TwoFingers Service. Prior to accessing or utilizing the TwoFingers Service, please ensure that you have reviewed and comprehended how we collect, store, use, and disclose your personal information as outlined in this privacy policy. If you are a minor and have any uncertainties regarding this Policy, please consult with a trusted adult before using the TwoFingers Service. If you require clarification on any point, feel free to reach out to us at support@twofingers.app.
1.4. We act as the data controller for the personal information we maintain. This means we determine and are responsible for how your personal information is utilized.
Recipients of Personal Information
While we do not sell your personal information, we collaborate with third parties to deliver the best service possible. For instance, our partner Yoti verifies users’ age eligibility for the TwoFingers Service by requesting a selfie. Rest assured, we ensure that they adhere to the same level of care as we do.
3.1. In addition to the recipients listed in Annex 1 and Annex 2, we may share your personal information with the following entities (as necessitated in accordance with the purposes outlined in Annexes 1 and 2):
(a) Service providers and advisors: We may share your personal information with third-party vendors and service providers that perform services on our behalf, including but not limited to mailing, email or chat services, fraud prevention, web hosting, and analytics services. Our service providers include Yoti for facial recognition age verification, Hive for media moderation, Two Hat for written content moderation, and Keywords Studios for written content moderation after report submission.
(b) Third parties through integrated technology with the TwoFingers Service: We may collect certain personal information through software provided by our partners, such as Mixpanel or Adjust. These partners may have access to the collected personal information to maintain the software and provide us with services.
(c) Affiliates: This includes other companies owned by or under common ownership as TwoFingers, including subsidiaries and our ultimate holding company. These companies will use your personal information in the same manner as outlined in this Privacy Policy.
(d) Purchasers and third parties in connection with business transactions: Your personal information may be disclosed to third parties in connection with a business transaction, such as a merger, sale of assets, reorganization, or acquisition.
(e) Law enforcement, regulators, and other parties for legal reasons: We may share your personal information with third parties as required by law or if reasonably believed to be necessary to comply with the law, detect and investigate illegal activities, and protect the rights, property, or safety of TwoFingers, its users, or others.
Marketing and Advertising
If you provide consent to TwoFingers, we may use your personal information to send you marketing communications tailored to your preferences and interests, which may include emails or in-app advertisements. You can withdraw your consent at any time.
4.1. Before sending information about products and services, we will seek your consent. We may contact you with information about our products and services, including marketing messages and requests for feedback.
4.2. Most marketing messages will be sent via email or within the app. We may use personal information collected about you to determine the most relevant marketing information to share with you.
4.3. We will only send you marketing messages if you have provided consent. You can withdraw your consent at any time by clicking on the unsubscribe link in our marketing emails.
Storing and Transferring Your Personal Information
We prioritize your privacy and the protection of your personal information. We implement adequate security measures and, when necessary, employ adequate measures for international data transfers with the same level of security.
5.1. Security: We utilize appropriate technical and organizational measures to protect your personal information against accidental or unlawful destruction, loss, alteration, or damage. All personal information we collect is stored on secure servers.
5.2. International Transfers of Your Personal Information: Your personal information may be transferred to and stored in countries outside the jurisdiction where you are located. If you are in the European Union, your personal information may be processed outside of the EU, including in the United States. We ensure that such transfers adhere to appropriate safeguards.
5.3. In the event of such a transfer, we ensure that either: (a) the personal information is transferred to countries recognized as offering an equivalent level of protection; (b) the transfer is made pursuant to appropriate safeguards, such as standard data protection clauses adopted by the European Commission. If you require further information about these safeguards, please contact us at support@twofingers.app.
Your Rights in Respect of Your Personal Information
Your personal information belongs to you, and we will ensure that your rights are respected. You can contact us at support@twofingers.app