Privacy Policy -

Effective Date: January 24, 2024

1. Overview

TwoOneFour, Inc. (“TwoOneFour,” “we,” “us,” or “our“) is committed to transparency about how we handle your information. This Privacy Policy (“Policy“) explains what data we collect, why we collect it, how we use and share it, and the choices available to you.

This Policy applies to all websites, applications, platforms, and services operated by TwoOneFour (collectively, the “Services“). By accessing or using the Services, you acknowledge that you have read and understood this Policy. If you do not agree with our practices described herein, please discontinue use of the Services immediately.

This Policy should be read in conjunction with our [Terms of Use], which govern your overall use of the Services.

2. Information We Collect

We collect information in three broad categories: information you provide directly, information collected automatically, and information obtained from third-party sources.

2.1 Information You Provide

When you interact with the Services, you may voluntarily provide us with information, including:

Account & Registration Data. Name, email address, username, password, and any other details you supply when creating an account or profile.
Communications. Messages, inquiries, feedback, or other content you send to us via email, contact forms, customer support channels, or social media.
User Content. Any text, images, files, or other materials you upload, post, or transmit through the Services.
Transaction Information. Billing address, payment card details (processed by our third-party payment processors), and purchase history if you make a purchase through the Services.
Survey & Promotion Responses. Information you submit when participating in surveys, contests, sweepstakes, or promotional offers.

2.2 Information Collected Automatically

When you access or use the Services, we and our service providers automatically collect certain technical and usage data, including:

Device & Browser Data. Hardware model, operating system and version, browser type and version, screen resolution, device identifiers (e.g., advertising ID, IDFA, GAID), and language settings.
Network Information. Internet Protocol (IP) address, internet service provider, and general geographic location derived from your IP address.
Usage & Interaction Data. Pages or screens viewed, links clicked, search queries entered, referring and exit URLs, date and time stamps of visits, session duration, and other actions taken within the Services.
Cookies & Similar Technologies. We use cookies, pixel tags, web beacons, local storage objects, and similar tracking technologies to collect information about your browsing behavior. See Section 7 for more details.

2.3 Information from Third-Party Sources

We may supplement the information we collect with data obtained from external sources, including:

Advertising & Analytics Partners. Demographic data, interest-based segments, inferred preferences, and cross-device identifiers received from advertising networks, data brokers, or analytics providers.
Social Media Platforms. If you interact with our Services through a social media account or use social login features, we may receive your public profile information, email address, and friend list, as permitted by your social media privacy settings.
Public Sources & Data Providers. Publicly available information such as public records, open databases, and commercially available data sets.
Business Partners. Information shared with us by our partners in connection with co-branded services, joint promotions, or integrated offerings.

3. How We Use Your Information

We use the information we collect for the following purposes:

3.1 Providing & Improving the Services

Operating, maintaining, and enhancing the Services; personalizing your experience; developing new features and functionality; conducting internal research and analytics; and troubleshooting technical issues.

3.2 Communications

Responding to your inquiries and support requests; sending transactional messages (e.g., account confirmations, security alerts, billing notices); and, where you have opted in or where permitted by law, delivering promotional communications about products, services, and offers that may interest you.

3.3 Advertising & Personalization

Delivering, measuring, and improving advertising — including interest-based and targeted advertising — across the Services and third-party platforms; building and refining audience segments; performing attribution and conversion tracking; and personalizing the content you see.

3.4 Security & Fraud Prevention

Detecting, investigating, and preventing fraudulent, unauthorized, or illegal activity; enforcing our Terms of Use and other policies; protecting the rights, property, and safety of TwoOneFour, our users, and the public.

3.5 Legal & Compliance

Complying with applicable laws, regulations, legal processes, and governmental requests; establishing, exercising, or defending legal claims; and fulfilling our contractual obligations.

3.6 Aggregation & De-identification

Creating aggregated, anonymized, or de-identified data sets that can no longer reasonably identify you, which we may use for any lawful business purpose without restriction.

We do not sell your personal information in the traditional sense of exchanging it for monetary payment. However, as described below, we may share your information in ways that certain privacy laws classify as a “sale” or “sharing” for targeted advertising purposes. You have the right to opt out of such sharing — see Section 8.

4.1 Service Providers & Processors

We engage trusted third-party companies and individuals to perform services on our behalf — such as hosting, data analytics, payment processing, email delivery, customer support, and marketing. These providers are contractually obligated to use your information only as directed by us and in a manner consistent with this Policy.

4.2 Advertising Partners

We may share or make available certain information — including device identifiers, cookie data, browsing activity, and inferred interest segments — with advertising networks, demand-side platforms, and other advertising technology partners to deliver relevant advertisements to you across the internet.

4.3 Analytics Partners

We work with analytics providers (e.g., Google Analytics) to understand how the Services are used, measure campaign effectiveness, and improve performance. These partners may combine information collected from our Services with data from other sources.

4.4 Corporate Transactions

If TwoOneFour is involved in a merger, acquisition, reorganization, bankruptcy, asset sale, or similar corporate event, your information may be transferred or disclosed as part of that transaction. We will notify you of any such change in ownership or control of your personal information.

4.5 Legal Obligations & Protection of Rights

We may disclose your information if we believe in good faith that such disclosure is necessary to: comply with applicable law or legal process; respond to requests from public or governmental authorities; enforce our Terms of Use or other agreements; protect TwoOneFour’s operations, rights, or property; or protect the safety of our users or the public.

We may share your information for purposes not described in this Policy when we have obtained your express consent.

4.7 Aggregated & De-identified Data

We may share aggregated or de-identified information that cannot reasonably be used to identify you with any third party for any purpose.

5. Data Retention

We retain your personal information for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting obligations. In determining appropriate retention periods, we consider the amount, nature, and sensitivity of the information; the potential risk of harm from unauthorized use or disclosure; the purposes for which we process the data; and applicable legal requirements.

When personal information is no longer required, we will securely delete or anonymize it. Residual copies may persist in backup systems for a limited additional period before being permanently purged.

6. Data Security

We implement commercially reasonable administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of your personal information. These measures include encryption of data in transit (TLS/SSL), access controls, intrusion detection, regular vulnerability assessments, and employee training.

However, no method of electronic transmission or storage is completely secure. While we strive to protect your information, we cannot guarantee its absolute security. You are responsible for maintaining the confidentiality of your account credentials and for any activity under your account.

7. Cookies & Tracking Technologies

7.1 What We Use

We and our partners use the following technologies to collect information:

Cookies. Small text files stored on your device that help us recognize your browser, remember preferences, and understand how you use the Services.
Pixel Tags / Web Beacons. Tiny, transparent images embedded in web pages or emails that allow us to track page visits, email opens, and conversion events.
Local Storage. Browser-based storage mechanisms (e.g., HTML5 local storage) that enable the Services to store data locally on your device.
Software Development Kits (SDKs). Code libraries embedded in our mobile applications that enable data collection and functionality from third-party partners.

7.2 Categories of Cookies

Category	Purpose
Strictly Necessary	Essential for the Services to function (e.g., authentication, security, load balancing). Cannot be disabled.
Performance & Analytics	Help us understand how visitors interact with the Services, measure traffic patterns, and identify errors.
Functionality	Remember choices you make (e.g., language, region) to provide a more personalized experience.
Advertising & Targeting	Deliver relevant ads, limit ad frequency, and measure the effectiveness of advertising campaigns.

Most web browsers allow you to manage cookie preferences through their settings. You may block or delete cookies, although doing so may impair certain features of the Services. For mobile devices, you can adjust advertising identifier settings through your device’s operating system. Additionally, you may opt out of interest-based advertising through industry programs such as the Digital Advertising Alliance (DAA) at www.aboutads.info/choices or the Network Advertising Initiative (NAI) at www.networkadvertising.org/choices.

8. Your Rights & Choices

Depending on your jurisdiction, you may have some or all of the following rights regarding your personal information:

8.1 Access & Portability

You may request a copy of the personal information we hold about you in a structured, commonly used, and machine-readable format.

8.2 Correction

You may request that we correct inaccurate or incomplete personal information.

8.3 Deletion

You may request that we delete your personal information, subject to certain exceptions (e.g., legal compliance, fraud prevention, completing a transaction).

Where applicable law treats our data practices as a “sale” or “sharing” of personal information, you have the right to opt out. To exercise this right, please contact us at privacy@214inc.com or use the “Do Not Sell or Share My Personal Information” link available on our Services.

8.5 Opt-Out of Targeted Advertising

You may opt out of the use of your personal information for targeted advertising by contacting us or adjusting your preferences through the mechanisms described in Section 7.3.

Where we process your data based on consent, you may withdraw that consent at any time. Withdrawal does not affect the lawfulness of processing that occurred prior to withdrawal.

8.7 Non-Discrimination

We will not discriminate against you for exercising any of these rights. We will not deny you access to the Services, charge different prices, or provide a different level of quality solely because you exercised a privacy right.

8.8 How to Submit a Request

To exercise any of the rights described above, please contact us at privacy@214inc.com. We may need to verify your identity before fulfilling your request. If you designate an authorized agent to submit requests on your behalf, we may require proof of authorization and direct identity verification from you.

We will respond to verified requests within the timeframes required by applicable law — generally within forty-five (45) days, with the possibility of an extension where legally permitted.

9. State-Specific Disclosures (United States)

Residents of certain U.S. states have additional rights under their respective privacy laws. This section provides supplemental information for those residents.

9.1 California (CCPA / CPRA)

If you are a California resident, you have the rights described in Section 8 above, as well as the right to:

Know the categories and specific pieces of personal information collected about you;
Know the categories of sources, purposes for collection, and third parties with whom information is shared;
Limit the use and disclosure of sensitive personal information, where applicable.

Categories of Personal Information Collected. In the preceding twelve (12) months, we may have collected the following categories (as defined by the CCPA): identifiers; commercial information; internet or electronic network activity; geolocation data; inferences; and professional or employment-related information (where applicable).

Shine the Light. California Civil Code § 1798.83 permits California residents to request information about disclosures of personal information to third parties for their direct marketing purposes. To make such a request, contact us at privacy@214inc.com.

9.2 Virginia (VCDPA), Colorado (CPA), Connecticut (CTDPA), Utah (UCPA), and Other State Laws

Residents of Virginia, Colorado, Connecticut, Utah, and other states with comprehensive privacy legislation may exercise the rights to access, correct, delete, and opt out of targeted advertising, sale of personal information, and profiling as provided under their respective laws. If your request is denied, you may have the right to appeal; to do so, please contact us at privacy@214inc.com with the subject line “Privacy Rights Appeal.”

10. International Users

The Services are operated from the United States. If you access the Services from outside the United States, please be aware that your information may be transferred to, stored, and processed in the United States or other jurisdictions where our service providers operate. Data protection laws in these jurisdictions may differ from those in your country of residence.

By using the Services, you consent to the transfer of your information as described in this Policy. Where required by applicable law, we will implement appropriate safeguards — such as Standard Contractual Clauses or other approved mechanisms — to protect your information during international transfers.

10.1 European Economic Area, United Kingdom & Switzerland

If you are located in the EEA, UK, or Switzerland, we process your personal data on the following legal bases as applicable: your consent; performance of a contract with you; compliance with a legal obligation; or our legitimate interests (such as fraud prevention, improving the Services, and direct marketing), provided those interests are not overridden by your fundamental rights. You have the right to lodge a complaint with your local supervisory authority.

11. Children’s Privacy

The Services are not intended for individuals under the age of eighteen (18), and we do not knowingly collect personal information from children. If we learn that we have collected personal information from a child under 18, we will take prompt steps to delete that information. If you believe a child has provided us with personal information, please contact us at privacy@214inc.com.

12. Do Not Track & Global Privacy Control

Some browsers transmit “Do Not Track” (DNT) signals. There is currently no industry standard for how companies should respond to DNT signals, and we do not currently respond to them. However, where we detect a Global Privacy Control (GPC) signal from your browser, we will treat it as a valid opt-out request for the sale or sharing of personal information associated with that browser, as required by applicable law.

13. Third-Party Links & Services

The Services may contain links to websites, applications, or services operated by third parties. This Policy does not apply to those third-party services. We encourage you to review the privacy policies of any third-party service you visit, as we have no control over and assume no responsibility for their practices.

14. Changes to This Policy

We may revise this Policy from time to time to reflect changes in our practices, technologies, legal requirements, or other factors. When we make material changes, we will update the “Effective Date” at the top of this page and, where appropriate, provide additional notice (such as a prominent announcement on the Services or an email notification). Your continued use of the Services after any changes take effect constitutes your acceptance of the revised Policy.

15. Contact Us

If you have questions, concerns, or requests regarding this Privacy Policy or our data practices, please reach out:

Email: privacy@214inc.com

For privacy rights requests specifically, please include “Privacy Request” in your subject line to help us route your inquiry efficiently.