This Privacy Policy explains how Find Yourself Forever Sp. z o.o. ("TwoCum", "we", "us", "our") collects, uses and protects your personal data when you use the TwoCum website and application (the "Service"). TwoCum is a subscription-based, moderated, one-to-one live video chat service for adults aged 18 and over.
1. Who we are
The data controller is Find Yourself Forever Sp. z o.o., ul. Marszałkowska 84/92, 00-514 Warszawa, Polska, registered in the Polish National Court Register (KRS) under number 0000987654, NIP 5251234567, REGON 141234567. For any privacy request, contact our data protection contact at contact@live-twocum.com (no dedicated Data Protection Officer has been appointed).
2. Data we collect
- Account data — your email address. We use passwordless "magic-link" sign-in, so we never create or store passwords.
- Age confirmation — a record that you confirmed being 18 or older.
- Usage & device data — IP address, browser and device type, operating system, language, referring pages, and in-app interaction events.
- Approximate location — country/region derived from your IP address (never precise GPS location).
- Cookies & similar technologies — see our Cookie Policy.
- Safety & moderation data — reports you submit, blocks, and limited metadata needed to keep the community safe.
- Billing & subscription data — for paid subscriptions: your name, billing email, subscription status and transaction metadata. Full card numbers are handled only by our payment providers (Stripe, PayPal) and are never stored by us.
3. Live video and audio are never recorded
Your one-to-one live video and audio are transmitted in real time and are not recorded, stored or retained by TwoCum. We keep no copies of your conversations. Moderation relies on real-time signals and user reports, not on stored recordings.
4. Why we use your data, and our legal bases
- To provide the Service (create your account, match you with others) — performance of a contract.
- To keep the community safe (moderation, preventing and investigating abuse, enforcing our rules, age assurance) — our legitimate interests and compliance with legal obligations.
- Analytics and product improvement — your consent, or our legitimate interest where permitted.
- Advertising and measurement — your consent.
- Security and fraud prevention — our legitimate interests and legal obligations.
- Service communications (login links, security and policy notices) — performance of a contract.
5. Cookies and similar technologies
We use strictly necessary cookies to operate the Service and, only with your consent, functional, analytics and advertising cookies. You can change your choices at any time. Full details are in our Cookie Policy.
6. Who we share data with
We share personal data only with service providers ("processors") acting on our documented instructions, including hosting and infrastructure (Hostinger International Ltd), transactional email delivery (our email service provider), analytics (Google Analytics 4), advertising measurement (Google Ads), and payment processing and fraud prevention: Stripe (Stripe Payments Europe, Limited, 1 Grand Canal Street Lower, Grand Canal Dock, Dublin, D02 H210, Ireland) and PayPal (PayPal (Europe) S.à r.l. et Cie, S.C.A., 22-24 Boulevard Royal, L-2449 Luxembourg). We are the merchant of record; your full card number is handled solely by Stripe or PayPal and is never stored by us. These processors are bound by contract to protect your data and may only use it to provide their service to us. We do not sell your personal data. We may disclose data where required by law or to protect the rights and safety of our users.
7. International data transfers
Where personal data is transferred outside your country or the European Economic Area, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses or an adequacy decision. Contact us for a copy of the relevant safeguards.
8. How long we keep your data
We keep account data while your account is active and until you delete it; inactive accounts are deleted after 24 months. Server logs are kept for up to 12 months. Billing and transaction records are retained as required by law and accounting rules (for example, up to 5 years). Safety and moderation records may be retained longer where necessary to protect the community or comply with the law. These periods are defaults and may be adjusted. As noted above, live video and audio are never stored.
9. Your rights
Subject to applicable law, you have the right to access your data; to rectify inaccurate data; to erase data; to restrict or object to processing; to data portability; and to withdraw consent at any time without affecting prior processing. You may also lodge a complaint with your local supervisory authority (in the EU, your national data protection authority). To exercise any right, contact contact@live-twocum.com; we respond within the timeframe required by law.
10. Children — strictly 18+
The Service is for adults only. We do not knowingly collect data from anyone under 18. If we learn that a person under 18 has used the Service, we will delete their data and terminate access.
11. Security
We apply technical and organizational measures — including encryption in transit, access controls and monitoring — to protect your data. No method of transmission or storage is perfectly secure, but we work continuously to safeguard your information.
12. United States — your privacy choices (CCPA/CPRA)
We do not sell or share your personal information as those terms are defined under the California Consumer Privacy Act. California residents have the right to know, delete and correct their personal information, and not to be discriminated against for exercising these rights. To exercise them, contact contact@live-twocum.com.
13. Changes to this policy
We may update this Privacy Policy from time to time. We will notify you of material changes in-app or by email. The date below reflects the latest revision.