At Two Cents ("twocents", "our", "us" or "we"), we value your privacy. This Privacy Policy outlines how we collect, use, and disclose your personal information when you use our Platform, websites, and any web-based or mobile applications (collectively, our "Service") and how you may exercise any of the rights that are applicable to you. By continuing to use our Services you acknowledge and agree to the practices and policies outlined herein. Any defined term not defined herein shall have that meaning as described in the Terms of Use.

1. Personal Information We Collect and How We Collect It

We may collect personal information from you and about you. Some examples of the information we may collect, how we may collect it, how we may use it, and how we may disclose it are described below. Please note that we do not sell personal information or share personal information for targeted or cross-contextual advertising purposes.

Account Data: If you create an account with us, we collect your age, gender, and approximate location. If you optionally provide an email (e.g., for support or subscription receipts), we process it only for that purpose.
- How we may collect it: Directly from you
Financial Account Connections (Read-Only): When you choose to connect a bank, brokerage, or supported exchange account, connections are established through a third-party data aggregation provider (e.g., Plaid). We do not receive or store your financial-institution credentials. The provider gives us read-only access to balances, positions, and similar information to power features like net-worth and leaderboards. We cannot move your money or place trades through these connections.
- Managing connections: You can view the data shared with twocents, disconnect twocents' access to your financial accounts, and delete data held by our aggregation provider at any time using that provider’s consumer portal (e.g., Plaid Portal). Disconnecting stops future sharing via the aggregator; it does not remove data already in Two Cents’ systems. See §10 for your in-app/account deletion options.
Communication Data: If you communicate with us, such as by email, by our webpages, by our application, or on social media sites, we may collect personal information that you submit to us including your name, username, email address, any other information you voluntarily choose to provide us, and the contents of messages you send.
- How we may collect it: Directly from you or an affiliate you provided it to directly; through a third-party that you may provide it to directly in connection with the Services.
Social Media Information: When you interact with our social media pages, we collect personal information that you choose to provide to us. In addition, the companies that host our social media pages may provide us with aggregate information and analytics about our social media activity.
- How we may collect it: Directly from you or from companies that host our social media pages or our service providers.
Payment Data: For App Store or Google Play purchases, billing is handled by the app store, which provides us limited information (e.g., transaction status). For web purchases, our payment processor provides us limited information (e.g., transaction ID). We do not store full payment card numbers.

We do not aim to collect sensitive personal information (ex. information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric data, criminal background, or trade union membership) and ask that you do not provide us with any such information. We don’t collect government IDs; Social Security numbers; biometric data; precise addresses; phone numbers; or contact lists. We don’t collect emails unless you give one for support, receipts, or account recovery.

2. How We Use Your Personal Information

We may use your personal information for a variety of purposes. Below, you will find examples and additional information regarding how we may use your personal information.

To provide, analyze, develop, and maintain our Service.
To provide support and assistance in relation to our Service.
To develop and improve our Service and to conduct research.
To communicate with you.
To ensure the security and integrity of our Service.
For legal purposes. This may include detecting what country you are located in so we can comply with relevant legal obligations.

We may also aggregate or de-identify your information so that it no longer identifies you and use this information for the purposes described above, such as to analyze the way our Service is being used, to improve and add features to them, and to conduct research. We will maintain and use de-identified information in de-identified form and will not attempt to reidentify the information, unless required by law.

3. How We Disclose Personal Information

We may disclose your personal information to others. Below, you will find examples and additional information regarding how we may disclose your personal information.

To our contracted service providers: To assist in providing the Service to you or performing business operations, we provide your personal information to service providers including providers of hosting, cloud, analytics, content delivery, support and safety monitoring, payment and transaction, and other technology services, for the purposes described above.
In connection with business transfers: In connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction, or proceeding involving sale, transfer, divestiture, or disclosure of all or a portion of our business or assets to another company. If required by applicable laws, we will use reasonable efforts to notify you of any transfer of personal information to an unaffiliated third-party.
For legal purposes: To (i) comply with laws or to respond to lawful requests and legal process, (ii) protect our rights and property and our agents, customers, and others, including to enforce our agreements, policies, and terms of service, (iii) to protect against legal liability, or (iv) to protect our personal safety, our customers, or any person.
To our related companies: To our related or affiliated companies to the extent such sharing is necessary to fulfill a request you have submitted via our Service or for customer management, customer support, technical operations, or the purposes described above.
To third-parties with which you interact or share information: Certain features may allow you to share information with third-parties, such as through a social media platform. Information you share with third-parties is governed by that third-party’s terms and policies.
If you choose to make posts or certain metrics visible, those items may be seen by other users in feeds, leaderboards, search results, emails, and notifications. You can adjust visibility in settings where available.

4. Retention of Personal Information

We retain your personal information where we have an ongoing legitimate business need to do so. In certain circumstances, we will retain your information for legal reasons after our contractual relationship has ended. The specific retention periods depend on the nature of the information and why it is collected and processed and the nature of the legal requirement. For example, we may retain your personal information:

When we have a legal obligation to do so (e.g., if we receive a court order, we would retain your information for longer than our usual retention periods);
To address and resolve requests and complaints (e.g., if there is an ongoing complaint about or from you);
To protect the safety, security, and integrity of our business and the Service, as well as to protect our rights and property and those of others (e.g., if we detect misuse of our Service or otherwise detect unusual activity on your account or in your interactions with us); and
For litigation, regulatory or other legal matters (e.g., we would retain your information if there was an ongoing legal claim and the information was relevant to the claim, or there is an investigation by the U.S. Department of the Treasury’s Office of Foreign Assets Control (“OFAC”) that we may need to participate in).
We generally retain age and general location for as long as your account is active. We may retain de-identified or aggregated metrics (e.g., benchmarks) after account deletion.

5. Marketing

Except as described herein, we do not collect and use your personal information for marketing purposes and do not share your personal information with third-parties for the purpose of marketing. We may send in-app or push messages about features or updates.

6. Security

We implement commercially reasonable technical, administrative, and organizational measures designed to protect personal information from loss, misuse, and unauthorized access, disclosure, alteration, or destruction. However, no security measure or method of data transmission over the internet is 100% secure.

7. Cookies and SDKs

We (and our service providers) may use cookies and mobile SDKs to operate core features (e.g., authentication, performance, crash reporting) and to measure usage in aggregate. We do not use advertising cookies or third-party ad SDKs.

8. Links to Other Sites

Our Service contains links to external websites or social media platforms that are not operated by us. Third-party websites and services have their own terms and conditions and privacy policies, and you should read these carefully before you submit any personal information to them.

9. Users Must Be At Least 18

Users of our Services must be at least 18 years old; any user under 18 is not authorized. Our Platform is not targeted to children under age 18. Additionally, we do not knowingly collect any personal information from children under 18 years of age. If you have reason to believe that a child under the age of 18 has provided personal information to us, please contact us, and we will endeavor to delete that information from our databases. ‍

10. Privacy Rights and Choices

Depending on where you are located and subject to applicable legal exceptions, you may have certain rights in relation to your personal information.

You may have the right to request to access, correct, update or delete your personal information, subject to certain applicable legal exceptions.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
The right to submit certain privacy requests through an Authorized Agent.
The right to be free from discrimination for exercising the rights afforded to you under applicable privacy laws.
The right to appeal a decision we make about your rights request.

Exercising your rights: “To exercise your rights, contact us at team@twocents.com or via in-app settings where available. We may request limited information needed to verify your request (e.g., your username and basic account details).

Please note, however, that your personal information may be exempt from such requests in certain circumstances, for example if we need to keep using your information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will inform you when responding to your request.

Verification: In order to protect your personal information, your ability to exercise some of the rights detailed in this Privacy Policy may be subject to your ability to verify that you are the person about whom your request pertains.

Authorized Agents: To exercise your rights using an Authorized Agent (as defined under applicable law), you must provide your Authorized Agent with written permission to exercise your rights on your behalf, and we may request a copy of this written permission from your Authorized Agent when they make a request on your behalf. We reserve the right to deny a request from an Authorized Agent that does not submit proof that they have been authorized by you to act on your behalf.

Appeals: If we refuse to take action on a request within a reasonable period of time after receiving your request, you may appeal our decision by emailing us at team@twocents.com. In such an appeal, you must (a) provide sufficient information to allow us to verify that you are the person about whom the original request pertains and to identify the original request, and (b) provide a description of the basis of your appeal. Please note that your appeal will be subject to your rights and obligations afforded to you under applicable law. We respond to all appeal requests as soon as we reasonably can, and no later than legally required.

Do Not Track: Please note that because the effect of "Do Not Track" signals remains unclear, and because there continues to be no consistent industry understanding of how to respond to such a signal, we do not alter our privacy practices when we detect a "Do Not Track" signal from your browser.

11. Changes

We may update our Privacy Policy from time to time. When we do, we will publish an updated version and effective date on this page, unless another type of notice is required by applicable law. If you use the Service after any changes to the Privacy Policy have been posted, all of the changes made will apply to your use of the Service.

European Economic Area, United Kingdom, and Switzerland Users

If you are located in the European Economic Area ("EEA"), United Kingdom ("UK") or Switzerland (collectively, "Europe") the following disclosures apply. We do not make decisions based solely on automated processing that produce legal or similarly significant effects about you.

12.1 Data Controller

twocents, which is based in the United States, is the controller of your personal information as described in this Privacy Policy, unless otherwise specified.

12.2 Sensitive Data

We do not aim to collect sensitive personal information (e.g., information related to racial or ethnic origin, political opinions, religion or other beliefs, health, biometric data, criminal background, or trade union membership) and ask that you do not provide us with any such information.

When we process your personal information because this is necessary for our, or someone else’s legitimate interests, we may carry out a balancing test to document our interests, to consider what the impact of the processing is on individuals, and to determine if those interests outweigh our interests in the processing taking place.

12.3 Your Rights

You may access, correct, update, or request deletion of your personal information.
You can object to processing of your personal information when our processing is based on our legitimate interests, ask us to restrict processing of your personal information or request portability of your personal information, (i.e., your data to be transferred in a readable and standardized format).
You have the right to opt-out of any marketing communications we may send at any time and to opt-out of profiling for purposes of direct marketing. We may still send you non-promotional transactional emails, legally required notices, or updates about ongoing business relations.
If we have collected and processed your personal information with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.
You have the right to complain to a supervisory authority about our collection and use of your personal information. For more information, please contact your local supervisory authority. Contact details for supervisory authorities in the EEA and the UK are available here. Certain supervisory authorities may require that you exhaust our own internal complaints process before looking into your complaint.
In France, you can choose to ask us to keep or destroy your personal information, after your death, to a nominated third party. You may also be able to ask us to disclose your personal information, after your death, to a specified recipient.
If you are from a different jurisdiction and believe you may have additional rights, please contact us as described below.

Sometimes your personal information may be exempt from such requests, for example if we need to keep using your information to comply with our own legal obligations or to establish, exercise or defend legal claims. If an exception applies, we will inform you when responding to your request. We may request that you provide us with information necessary to confirm your identity before responding to your request.

You may exercise your rights by contacting as described below.

12.4 Lawful Bases

Where GDPR/UK GDPR applies, we process personal data on these bases: (a) contract (to provide the Service you request), (b) legitimate interests (e.g., security, service analytics, de-identified benchmarking) balanced against your rights, and (c) consent (where required, e.g., optional email updates). You may withdraw consent at any time.

13. California Users

Under California Civil Code Section 1798 (“California's Shine the Light”), California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes. After thorough analysis, we have determined that we are exempt from the California Consumer Privacy Act of 2018, and the later, California Privacy Rights Act of 2020 (collectively, “CCPA”).

If you'd like to request more information under the California Shine the Light law or other laws, and if you are a California resident, you can contact us using the contact information provided below.

14. Nevada Users

If you are a resident of Nevada, you have the right to opt out of the sale of certain Personal Data to third parties who intend to license or sell that Personal Data. You can exercise this right by contacting us as described below with the subject line “Nevada Do Not Sell Request” and providing us with your name and the email address associated with your account. Please note that we do not currently sell your Personal Data as sales are defined in Nevada Revised Statutes Chapter 603A. If you have any questions, please contact us as set forth below.

15. Contact Us

If you have any queries or complaints about our collection, use, or storage of your personal information, or if you wish to exercise any of your rights in relation to your personal information, please contact our Data Protection Officer at team@twocents.com or by mail as described above.