Privacy Policy

Last Updated: 13 June 2025

WE WILL POST ANY CHANGES TO THIS PRIVACY POLICY IN A NOTICE OF THE  CHANGE AT THE BOTTOM OF OUR WEB PAGE WITH A HYPERLINK THERETO.  PLEASE REGULARLY REVIEW THIS PRIVACY POLICY. NOTWITHSTANDING IF YOU CONTINUE TO USE OUR SERVICES, YOU ARE BOUND BY ANY CHANGES THAT WE  MAKE TO THIS PRIVACY POLICY.

1. INTRODUCTION
twocents.ai Ltd. (“twocents,” “we,” “us,” or “our”) respects the privacy of its Users (“User,” “your,” or “you”). This Privacy Policy (the “Privacy Policy”) explains how we collect, use, disclose, and safeguard your information when you use twocents.ai platform (the “Platform”) through twocents.ai website at https://www.twocents.ai/ (the “Website”) or Twocents’ mobile application (the “App”). Twocents is a platform that provides AI agentic services designed to help users manage their daily tasks, schedules, and communications more efficiently. It integrates with various applications and devices to streamline workflows, automate routine tasks, and provide personalized recommendations based on user preferences and behavior. By leveraging advanced AI technology, twocents.ai aims to enhance productivity and simplify the management of professional responsibilities.
twocents.ai is committed to protecting the privacy of its Users whose information is collected and stored while using Twocents’s Platform through our Website or App. This Privacy Policy is applicable to our Website, Platform and all applications offered for sale to the public.
The capitalized terms have the same meaning as ascribed in our Terms of Use, unless otherwise noted here.
By using the twocents.ai Platform, you acknowledge and agree that you are responsible for obtaining all necessary consent from individuals whose personal information you may access, collect, or share through the use of the Platform. You must ensure that such individuals are aware of and agree to the practices described in this Privacy Policy.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND OUR POLICIES AND  PRACTICES REGARDING YOUR INFORMATION AND HOW WE WILL TREAT IT. BY  ACCESSING OR USING OUR WEBSITE, APP, AND PLATFORM, YOU AGREE TO ACCEPT ALL  THE TERMS CONTAINED IN THIS PRIVACY POLICY AND ACKNOWLEDGE AND AGREE WITH  THE PRACTICES DESCRIBED HEREIN. IF YOU DO NOT AGREE WITH THE TERMS OF THIS  PRIVACY POLICY, PLEASE DO NOT ACCESS AND USE OUR WEBSITE, APP, AND PLATFORM.
IF YOU HAVE ANY QUESTIONS REGARDING THIS PRIVACY POLICY, PLEASE SEND US AN  EMAIL AT privacy@twocents.ai.
WE DO NOT SELL YOUR PERSONAL INFORMATION, NOR DO WE INTEND TO DO SO.

2. WHAT INFORMATION DO WE COLLECT?
When you register to use our Website, App, or Platform, we collect personal information (also referred to  as personally identifiable information or “PII”) which may include your name, address, online contact 
information such as your email address or username, phone number, and other personal information. The  information so collected will be stored on our servers. This personal information is not referring to the personal information of your clients or concerned parties whose information you may store via the services provided by Twocents. You are able to change your personal information  via email by contacting us at privacy@twocents.ai or through your profile or account settings on our Website,  App, or Platform.  
a. Geolocation and Equipment Information. We may collect information that does not personally  identify you such as (i) your geolocation, and (ii) information about your internet connection, the  equipment you use to access our Website, App, or Platform, and usage details. 
b. Financial Information. We currently do not collect or store any credit cards or bank information, as  we are using a third-party payment processor. However, we will update this Privacy Policy when  we start using and storing such information. We will also inform you via reasonable means if we  start collecting such information from you.

3. HOW DO WE COLLECT INFORMATION?
We collect personal information from you in the following ways: 
a. At registration on our Website, App, or Platform;  
b. In email, text, and other electronic messages between you and our Website, App, or Platform; 
c. Through mobile and desktop applications, your downloads from our Website, App, or Platform,  which provides dedicated non-browser-based interaction between you and our Website, App, or  Platform;  
d. When you interact with our advertising and applications on third-party website and services, if  those applications or advertising include a link to this Privacy Policy;  
e. From you placing an order, which includes details of transactions you carry out on our Website,  App, or Platform; 
f. When you subscribe to a newsletter;  
g. From your responses to a survey;  
h. From forms filled out by you;  
i. From records or copies of correspondences (including email addresses) if you contact us;  
j. From search queries on our Website, App, or Platform; and 
k. When you post information to be published or displayed on our Website, App, or Platform. 
We collect information from you automatically when you navigate through our Website, App, or Platform  in the following ways:
a. Usage details;  
b. IP addresses;  
c. Information obtained through browser cookies;  
d. Information obtained through flash cookies;  
e. Web beacons on our Website;  
f. Web beacons on emails sent by us; and 
g. Other tracking technologies.  
User Responsibility for Obtaining Consent 
It is the responsibility of the User to ensure that any collection, use, and sharing of personal information  through the Twocents Platform complies with applicable privacy laws and regulations. Users must obtain explicit  consent from individuals before collecting or sharing their personal information through the Platform. Twocents  is not responsible for any misuse of personal information by Users.

4. HOW DO WE USE YOUR INFORMATION?
We use the information that you provide to: 
a. Personalize your experience in using our Platform;  
b. Provide you with information, products, or services requested from us; 
c. Present our Website, App, and Platform and their contents to you; 
d. Provide you with notices about account and/or subscription, including expiration and renewal  notices; 
e. Carry out obligations and enforce rights arising from contracts entered into between you and us,  including billing and collection;  
f. Notify you about changes to our Website, App, and Platform and any products or services;  g. Allow you to participate in interactive features on our Website, App, and Platform;  h. Improve the Website, App, and Platform;  
i. Improve our customer service; 
j. Administer contests, promotions, and surveys or other Website, App, and Platform features;  k. Process transactions; 
l. Anonymize data and aggregate data for statistics; 
m. Contact you for other purposes with your consent; 
n. Contact you about our products and services that may be of interest;  
o. Contact you about third parties’ goods and services;  
p. Enable the display of advertisements to our advertisers’ target audiences, although personal  information is not shared with advertisers without your consent; and 
q. Send you periodic emails, in accordance with the CAN-SPAM Act of 2003 as detailed in Section  14, via the email address provided by you to (i) send information, respond to inquiries, and/or other  requests or questions; (ii) process orders and send information and updates pertaining to such  orders; (iii) send additional information related to your product and/or service; and (iv) market to  our mailing list or continue to send email to you after the original transaction has occurred. 

5. OUR COOKIE POLICY
Cookies are small pieces of text used to store information on web browsers. Cookies are used to store and receive identifiers and other information on computers, phones, and other devices. Other technologies, including data we store on your web browser or device, identifiers associated with your device, and other software, are used for similar purposes. In this Privacy Policy, we refer to all of these technologies as  “Cookies.”  
We use Cookies on our Website and App to (a) help remember and process items in the shopping cart, (b)  understand and save your preferences for future visits, (c) keep track of advertisements, (d) compile  aggregate data about site traffic and site interactions in order to offer better site experiences and tools in the  future, and (e) allow trusted third-party services that track this information on our behalf. You can set your  browser to refuse all or some browser Cookies, but it may affect your user experience. We honor Do Not  Track signals and, if one is in place, we will not track, plant cookies, or use advertising.  
We allow third party behavioral tracking and links to third-party web pages. Occasionally, at our discretion,  we may include or offer third-party products or services on our Website, App, or Platform. These third party sites have separate and independent privacy policies. We, therefore, have no responsibility or liability  for the content and activities of these linked sites. Nonetheless, we seek to protect the integrity of our  Website, App, or Platform and welcome any feedback at about these sites. Please contact us at privacy@twocents.ai.

6. HOW DO WE PROTECT INFORMATION WE COLLECT?
Our Website and App are reasonably scanned to meet or exceed PCI Compliance. Our Website and App  receive regular security scans and penetration tests. Our Website and App also receive regular malware  scans. In addition, our Website and App use an SSL certificate as an added security measure. We require  username and passwords for our employees who can access your personal information that we store and/or  process on our Platform and servers. In addition, we actively prevent third parties from getting access to  your personal information that we store and/or process on our Platform and servers. We accept payment  by credit card through a third party credit card processor on our behalf. We will implement reasonable  security measures every time you (a) place an order, or (b) enter, submit, or access your information, (c)  register, or (d) access our Platform, on our Website and App. 

7. DATA SECURITY MEASURES
a. Security Measures. We have implemented measures designed to secure your personal information  from accidental loss and from unauthorized access, use, alteration, and disclosure. All information  you provide to us is stored on our secure servers behind firewalls. The safety and security of your  information also depends on you. Where we have given you (or where you have chosen) a password  for access to certain parts of our Website, App, or Platform, you are responsible for keeping this  password confidential. We ask you not to share your password with anyone. Unfortunately, the  transmission of information via the internet is not completely secure. Although we do our best to  protect your personal information, we cannot guarantee the security of your personal information  transmitted to our Website, App, or Platform. Any transmission of personal information is at your  own risk. We are not responsible for circumvention of any privacy settings or security measures  contained on our Website, App, or Platform. 
b. Fair Information Practice Principles. In the event of a personal data breach, we will notify you  within fifteen (15) days via (i) email and/or (ii) our Platform notification system on our Website  and/or App. We agree to the individual redress principle, which requires that individuals have a  right to pursue legally enforceable rights against data collectors and processors who fail to adhere  to the law. This principle requires not only that individuals have enforceable rights against data  users, but also that that individuals have recourse to courts or a government agency to investigate  and/or prosecute non-compliance by data processors. 
c. Open-Source Software: We use the following open-source software in the provision of our  Services, which can be found here. 
d. User Responsibility for Security. While Twocents implements reasonable security measures to protect  personal information, Users are also responsible for maintaining the security of any personal  information they collect and share through the Platform. Users must ensure that their use of the  Platform complies with all applicable data protection and privacy laws, including obtaining  necessary consents and providing appropriate notifications to individuals. 

8. DISCLOSURE OF PERSONAL INFORMATION
There are times when we may share Personal Information that you have shared with us may be shared by  twocents.ai with others to enable us to provide you over Services, including contractors, service providers, and  third parties (“Partners”). This section discusses only how twocents.ai may share such information with Partners.  We will ensure that our Partners protect your Personal Information. The following describe how and with  whom we may share your Personal Information:
Disclosure of Personal Information.
a. We may disclose aggregated, de-personalized information about you that does not identify any  individual to other parties without restriction, such as for marketing, advertising, or other uses.
b. We may disclose personal information to our subsidiaries and affiliates. 
c. We may disclose personal information to contractors, services providers, and other third parties. 
d. We require all contractors, service providers, and other third parties to whom we disclose your  personal information to be under contractual obligations to keep personal information confidential  and to use it only for the purposes for which we disclose them. 
e. We may disclose personal information in the event of a merger, sale of business, etc.
f. We may disclose to third parties to market their products and services to you if you have either  consented or not opted out of these disclosures.  
g. We may disclose personal information to third parties to market their products and services if you  have either consented or not opted out of these disclosures.  
h. We require all other Partners, to whom we disclose your personal information, to enter into  contracts with us to keep personal information confidential and use it only for the purposes for  which we disclose it to such Partners.  
i. We disclose personal information to fulfill the purpose for which you have provided it, for instance,  if you gave us an email address to use the “email a friend” feature of the Platform.
j. We may disclose personal information for any other purpose for which you have provided it.
k. We may only disclose personal information as described in this Privacy Policy or your consent.  
User Obligations for Third-Party Information
Users are solely responsible for ensuring that they have obtained necessary consents from any third parties  whose personal information they may disclose to twocents.ai or through the Platform. Users must provide such  third parties with a copy of this Privacy Policy and inform them of their rights regarding their personal  information.
Other Disclosure of Personal Information
a. We will disclose personal information (i) to comply with any court order, law, or legal process,  including to respond to any government or regulatory request, (ii) to enforce or apply our Terms of Use and other agreements, including for billing and collection purposes, (iii) if we believe it is  necessary or appropriate to protect the rights, property, or safety of twocents.ai, our customers or others,  and/or (iv) if it is necessary or appropriate to protect the rights, property, or safety of twocents.ai, our  customers, or others, and this includes exchanging information with other companies and  organizations for the purposes of fraud protection and credit risk reduction.
Third Party Disclosure
a. We do not sell, trade, rent, or otherwise transfer personal information to others, unless we provide  you with advance notice. This does not include our hosting partners and other parties who assist  us in operating our Website, App, or Platform, conducting our business, or servicing you, so long  as those parties agree to keep this information confidential.  
b. We do not provide non-personally identifiable visitor information for marketing purposes. 
Choices Users Have About How Twocents Uses and Discloses Information
a. Tracking Technologies and Advertising. You can set their browser to refuse some or all the browser  cookies, but if you disable or refuse cookies, some parts of our Website may not be accessible or  function properly.  
b. Disclosure of Users’ Information for Third-Party Advertising. Users can opt-out by (i) checking  the relevant form when we collect the data; (ii) logging into the Website, App, or Platform and  adjusting their preferences in their account profile by checking or unchecking the relevant boxes,  or (iii) emailing us their opt-out request at privacy@twocents.ai. Users receiving promotional email  can opt-out by sending a return email requesting to be omitted from future promotional email  distributions. This opt-out will not apply to information provided by Twocents for product purchases,  warranty registration, or other transactions.
c. Disclosure of User’s Information for Targeted Advertising. Users can opt-out by (i) checking the  relevant form when we collect the data, (ii) logging into the Website, App, or Platform and  adjusting their preferences in their account profile by checking or unchecking the relevant boxes,  or (iii) emailing us their opt-out request at privacy@twocents.ai. 

9. GOOGLE ADSENSE AND GOOGLE ANALYTICS
Google, as a third-party vendor, uses Cookies to serve advertisements to Users on our Website, App, and  Platform. Google uses first-party Cookies, such as Google Analytics Cookies, to compile data regarding  User interactions with ad impressions and other ad service functions as they relate to our Platform. We  currently use Google Analytics to collect and process certain Website and App usage data. To learn more  about Google Analytics and how to opt-out, please visit https://policies.google.com/privacy/google partners.  
We have implemented advertising features on our Website, App, and Platform including: (a) remarketing  with Google AdSense; (b) Google Display Network Impression Reporting; (c) Google Demographics and  Interests Reporting; and (d) Google’s DoubleClick platform integration.  
We use these Cookies to compile data regarding User interactions with ad impressions and other ad  service functions as they relate to our Website or App. 

10. FOR OUR EUROPEAN CUSTOMERS AND VISITORS
We are headquartered in the United States. Most of the operations are located in the United States. Your  Personal Information, which you give to us during registration or use of our Website, App or Platform,  may be accessed by or transferred to us in the United States. If you are visiting our Web site or registering  for our Services from outside the United States, be aware that your Personal Information may be transferred  to, stored, and processed in the United States. Our servers or our third-party hosting services partners are  located in the United States. By using our site, you consent to any transfer of your Personal Information  out of Europe, UK, or Switzerland for processing in the US or other countries. 
● If you are a resident of or a visitor to Europe, you have certain rights with respect to the processing  of your Personal Data, as defined in the General Data Protection Regulation (“GDPR”).
● Please note that in some circumstances, we may ask you to provide us with additional information  in connection with your request, which may be Personal Data, for example, if we need to verify  your identity or the nature of your request. 
● In such situations, however, we will still respond to let you know of our decision.
● As used herein, “Personal Data” means any information that identifies you as an individual, such  as name, address, email address, IP address, phone number, business address, business title,  business email address, company, etc. 
a. EU Standard Contractual Clauses.
On June 4, 2021, the EU promulgated a new set of SCCs (the  “New SCCs”), which replaced the old SCCs which had been in place for over a decade. We now  comply with the New SCCs with respect to the transfer of Personal Data from the EU to the US  and other countries for Processing, as defined in the GDPR. If there is any conflict between the  terms and conditions in this Privacy Policy and your rights under the New SCCs, the terms and  conditions in the new SCCs will govern.
b. The New SCCs.
● The New SCCs took effect on June 27, 2021. 
● The Old SCCs may still be used for new data transfers in new contracts during a three-month  transition period that ends on September 27, 2021. 
● Existing data transfers contracts that rely on the Old SCCs can be used until December 27, 2022,  by which time all data transfers relying on the Old SCCs must be transitioned to the New SCCs.
● As of now, we and our customers are using the New SCCs to transport Personal Data from the EU  to other countries including the US for processing by us. 
● You are the Controller, as defined in the GDPR, and the Exporter, as defined in the New SCCs, of  the Personal Data and we are a processor, as defined in the GDPR, and the Importer of such  Personal Data.  
● You agree to comply with the GDPR rules that apply to Controllers and the New SCCs rules that  apply to Data Exporters. We agree to comply with the GDPR rules that apply to Processors and the  New SCCs rules that apply to Data Importers.  
c. Our GDPR Compliance Commitment.
● We agree to fully comply with the letter and the spirit of the GDPR and the New SCCs with respect  to the transfer or your Personal Data for Processing outside the EU.  
● As a Data Importer, a User may contact us as set forth in Subsection 9(d) below with respect to the  Personal Data we store and process on you.  
● We hereby notify you that we will be processing, as defined in the GDPR, the Personal Data of  your Authorized Users (i.e., those individuals whom you have authorized to access our Platform  and to use our Services) in the US, Canada, and Turkey for us to be able to provide the Services to  you that we have agreed to do in our definitive service agreement between you and us.  
● Upon request, we will provide you with a list of your Personal Data that we will process and a copy  of the New SCCs under which we will transport your Personal Data for processing.  
● We hereby warrant that, at the time of agreeing to the SCCs for the transport of your Personal Data,  we have no reason to believe that the laws and practices applicable to us as a data processor and a  data importer, including those of the US, Canada, and Turkey are not in line with the requirements  of the New SCCs.  
● If we cannot satisfy any request or dispute to your satisfaction, we will agree to arbitrate or litigate  the dispute in the EU jurisdiction in which your reside.  
● We will only transfer your Personal Data to a third country in accordance with documented  instructions from you. 
● Your Personal Data will be transferred and stored in an encryption format.  
● Only our employees, who have a need to access your Personal Data to enable us to meet our  contractual and legal obligations to you, will be given access to your Personal Data.
● Such employees will be given a User Name and Password to access your Personal Data.  
● We will keep an automated record of all persons who have accessed your Personal Data.  
d. Rights of Data Subjects.
To make any of the following requests, with respect to this Privacy  Policy, our Terms or Use, and/or Personal Data, please contact us (i) via email at  privacy@twocents.ai, or (ii) by writing to us at Twocents.ai Ltd, 251 Little Falls Drive, Wilmington, New Castle, Delaware, 19808, USA
i. Access: You can request more information about the Personal Information we hold about you. You  can also request a copy of the Personal Information. 
ii. Rectification: If you believe that any Personal Information we are holding about you is incorrect or  incomplete, you can request that we correct or supplement such data. Please contact us as soon as  possible upon noticing any such inaccuracy or incompleteness. 
iii. Objection: You can contact us to let us know that you object to the collection or use of your Personal  Information for certain purposes. 
iv. Erasure: You can request that we erase some or all of your Personal Information from our systems. v. Restriction of Processing: You can ask us to restrict further processing of your Personal  Information. 
vi. Portability: You have the right to ask for a copy of your Personal Information in a machine-readable  format. You can also request that we transmit the data to another entity where technically feasible. vii. Withdrawal of Consent: If we are processing your Personal Information based on your consent (as  indicated at the time of collection of such data), you have the right to withdraw your consent at any  time. Please note, however, that if you exercise this right, it may limit your ability to use some/ all  of our Services or Platform and you may have to then provide express consent on a case-by-case  basis for the use or disclosure of certain of your Personal Information, if such use or disclosure is  necessary to enable you to utilize some or all of our Services and Platform. 
viii. Right to File Complaint: You have the right to lodge a complaint about our practices with respect  to your Personal Information with the supervisory authority of your country or EU Member State.  Please go to https://ec.europa.eu/justice/article-29/structure/data-protection authorities/index_en.htm to locate your Data Protection Authority in the EU. You may contact the  UK’s Information Commissioner at https://ico.org.uk/make-a-complaint or by telephone: 0303 123  1113. 
ix. We will respond to your inquiry within thirty (30) days of the receipt.  

11. FOR OUR CANADIAN USERS
This Section supplements the information contained in our Privacy Policy above and applies solely to all  visitors, users, and others to our Website, App, or Platform, who reside in Canada (“consumers” or “you”).  We ensure with the Personal Information Protection and Electronics Document Act of 2000 (“PIPEDA”)  and any terms defined in the PIPEDA have the same meaning when used in this Section. 
a. Definition of Personal Information. Any information about an identifiable individual. Whatever  may be the physical form or characteristics of a particular regime for “business contact  information” (name, position, title, address, professional phone number, etc.) 
b. Right to Access Personal Information. You can request to access your personal information we  hold about you. We will first confirm whether you have requested such information, explain how 
we have used your information, provide a list of names with whom your information has been  shared and provide a copy of your information in an accessible format and make alternative formats  available if requested. 
c. Right to Correction/Limited Right to Deletion. You can request us to correct or delete your  information IF you demonstrate that the personal information we hold on you is inaccurate. We  will delete or correct your information within thirty (30) calendar days. When we delete/correct  your personal information we will inform the third parties with whom we have shared your  information. 
d. Right to be Forgotten. Your information will be kept with us for as long as it is required for the  fulfillment of the purposes of Twocents platform. Unless we otherwise give you notice, we will retain  your Information on the Twocents Platform on your behalf until such times as you or we terminate your  User Account. 
e. Data Breach Notification. We will send a notification to you as soon as feasible regarding the  information of any breach that creates a “real risk of significant harm” to you. We keep a record of  every data breach and, on request, provide the Office of the Privacy Commissioner with access to  the record. 
f. Two Factor Authentication. You may enable two-factor authentication on your account to help  ensure that only you can access your account. If you do, in addition to entering your password to  log in to your account to access the Twocents Platform, we will send a code to your mobile number,  which you will need to enter. This added security prevents anyone else from accessing your Twocents account unless they have access to your login information. 

12. YOUR CALIFORNIA PRIVACY RIGHTS
Twocents does not sell, trade, or otherwise transfer to outside third parties your “Personal Information” as the  term is defined under the California Civil Code Section § 1798.82(h). Additionally, California Civil Code  Section § 1798.83 permits Users of our Website, App, or Platform that are California residents to request  certain information regarding our disclosure of their Personal Information to third parties for their direct  marketing purposes. To make a request for such disclosure, or identification and/or deletion of Personal  Information in all our systems that we store on you, please send an email to privacy@twocents.ai or write us  at Twocents.ai Ltd, 251 Little Falls Drive, Wilmington, New Castle, Delaware, 19808, USA
Note that (i) if we delete your Personal Information as requested, we will no longer be able to provide our  services to you and (ii) we may need to keep such Personal Information for a while during the shutting  down and billing process. If you would like to discuss our Personal Information storage and processing  process with us, please send us an email at privacy@twocents.ai or write us at Twocents.ai Ltd, 251 Little Falls Drive, Wilmington, New Castle, Delaware, 19808, USA.

13. CALIFORNIA CONSUMER PRIVACY ACT
This Section supplements the information contained in our Privacy Policy above and applies solely to all  visitors, users, and others to our Website, App, or Platform, who reside in the State of California  (“consumers” or “you”). We adopt this Section to comply with the California Consumer Privacy Act of  2018 (“CCPA”) and any terms defined in the CCPA have the same meaning when used in this Section. 
a. Right to Request Personal Information. Upon request, we will provide you with (i) a list of all  Personal Information that we have collected on you, (ii) from whom we obtained such Personal  Information, (iii) the reason why we collected such Personal Information, and (iv) with whom (if  any) we have shared such Personal Information. If we sell your Personal Information or disclose  your Personal Information to third parties, upon request, we will provide you with (i) a list of the  Personal Information that we have collected on you, (ii) a list of the Personal Information that we  sell or disclose to others on you, and (iii) to whom we have sold or disclosed your Personal  Information. A consumer can make such a request only twice in a 12-month period.  
We require such Personal Information to be able to provide to you our Services. 
Unless otherwise specified, we only collect Personal Information from you. We do not use others to provide  us with your Personal Information. 
a. Disclosure of Personal Information. We only share your Personal Information with service  providers, e.g., billing and collection agents, who enable us to provide our Services to you. We do  not sell or give your Personal Information to third parties for purposes unrelated to our provision  of Services to you. 
b. Right to have Personal Information Deleted. Upon request, we will delete all of your Personal  Information that we have collected on you and will direct our Service Providers to also delete all  of your Personal Information. But note that if we do delete all of this Personal Information, you  will no longer be able to use our Services. 
c. Non-Discrimination Right. We will not discriminate against you for exercising any of your CCPA  rights. Unless permitted by the CCPA, we will not: 
(i) Deny you goods or services. 
(ii) Charge you different prices or rates for goods or services, including through granting  discounts or other benefits, or imposing penalties. 
(iii) Provide you a different level or quality of goods or services. 
(iv) Suggest that you may receive a different price or rate for goods or services or a different  level or quality of goods or services. 
d. Financial Incentives. However, we may offer you certain financial incentives permitted by the  CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial  incentive we offer will reasonably relate to your personal information’s value and contain written  terms that describe the program’s material aspects. Participation in a financial incentive program  requires your prior opt in consent, which you may revoke at any time. 
e. Under 16. We will not sell your Personal Information if you are under the age of 16 unless we have  the consent of your parent or your guardian nor will we sell it if you ask us not to do so. 
f. Opt Out Right. Upon your request, we will stop selling your Personal Information (sometimes  called your Opt Out Right). You may send the request to Opt Out (i) to privacy@twocents.ai, or (ii)  by writing to us at Privacy Officer, Twocents.ai Ltd, 251 Little Falls Drive, Wilmington, New Castle, Delaware, 19808, USA

14. COPPA COMPLIANCE (FOR CHILDREN UNDER 13 USERS ONLY)
The Children’s Online Privacy Protection Act (“COPPA”) is a federal legislation that applies to entities  that collect and store “Personal Information,” as the term is defined under COPPA, from children under the  age of 13. We are committed to ensure compliance with COPPA. Our Website, App, and Platform are not 
meant for use by children under the age of 13. Our Website, App, and Platform do not target children under  the age of 13, but we do not age-screen or otherwise prevent the collection, use, and personal disclosure of  persons identified as under 13. If you would like to know more about our practices and specifically our  practices in relation to COPPA compliance, please email us at privacy@twocents.ai. 
IF YOU ARE UNDER 13, PLEASE DO NOT ACCESS OR USE OUR WEBSITE, APP, OR PLATFORM

15. CAN-SPAM ACT OF 2003
The CAN-SPAM Act establishes requirements for commercial messages, gives recipients the right to have  businesses stop emailing them, and spells out penalties for violations. Per the CAN-SPAM Act, we will:
a. not use false or misleading subjects or email addresses;  
b. identify the email message as an advertisement in some reasonable way;  
c. include the physical address of Twocents, which is 108 W. 13th Street, Suite 100, Wilmington, DE  19801;  
d. monitor third-party email marketing services for compliance, if one is used; 
e. honor opt-out/unsubscribe requests quickly; and 
f. give an “opt-out” or “unsubscribe” option.  
If you wish to opt out of email marketing, follow the instructions at the bottom of each email or contact us  at privacy@twocents.ai and we will promptly remove you from all future marketing correspondences.

16. MODIFICATIONS TO OUR PRIVACY POLICY
We will post any changes to this Privacy Policy in a notice of the change at the bottom of our web  page with a hyperlink thereto. We will also send you an email describing such changes. Please  regularly review this Privacy Policy. Notwithstanding if you continue to use our services, you are  bound by any changes that we make to this Privacy Policy.

17. COPYRIGHT INFRINGEMENT/DMCA NOTICE
If you believe that any content on our Website, App, or Platform violates your copyright, and you wish to  have the allegedly infringing material removed, the following information in the form of a written  notification (pursuant to the Digital Millennium Copyright Act of 1998 (“DMCA Takedown Notice”))  must be provided to our designated Copyright Agent.  
a. Your physical or electronic signature; 
b. Identification of the copyrighted work(s) that you claim to have been infringed; c. Identification of the material on our Website, App, or Platform that you claim is infringing and that  you request us to remove; 
d. Sufficient information to permit us to locate such material; 
e. Your address, telephone number, and email address; 
f. A statement that you have a good faith belief that use of the objectionable material is not authorized  by the copyright owner, its agent, or under the law; and 
g. A statement that the information in the notification is accurate, and under penalty of perjury, that  you are either the owner of the copyright that has allegedly been infringed or that you are authorized  to act on behalf of the copyright owner. 
Twocents’s Copyright Agent to receive DMCA Takedown Notices is Naresh Vyas, at privacy@twocents.ai  and at Twocents.ai Ltd,, Attn: DMCA Notice, 251 Little Falls Drive, Wilmington, New Castle, Delaware, 19808, USA. You acknowledge  that for us to be authorized to take down any content, your DMCA Takedown Notice must comply with all  the requirements of this Section. Please note that, pursuant to 17 U.S.C. § 512(f), any misrepresentation of  material fact (falsities) in a written notification automatically subjects the complaining party to liability for  any damages, costs and attorney’s fees incurred by Twocents in connection with the written notification and  allegation of copyright infringement. 

18. ANTI-BRIBERY COMPLIANCE
Twocents represents and warrants that it is fully aware of and will comply with, and in the performance of its  obligations hereunder will not take any action or omit to take any action that would cause it or its customers  to be in violation of, (i) U.S. Foreign Corrupt Practices Act, (ii) U.K. Anti-Bribery Act, (iii) Singapore Prevention  of Corruption Act of 1960, or (iv) any other applicable anti-bribery statutes and regulations, and (v) any  regulations promulgated under any such laws. Company represents and warrants that neither it nor any of  its employees, officers, or directors is an official or employee of any government (or any department,  agency or instrumentality of any government), political party, state owned enterprise or a public  international organization such as the United Nations, or a representative or any such person (each, an  “Official”). Company further represents and warrants that, to its knowledge, neither it nor any of  the Supplier Personnel has offered, promised, made or authorized to be made, or provided any contribution,  thing of value or gift, or any other type of payment to, or for the private use of, directly or indirectly,  any Official for the purpose of influencing or inducing any act or decision of the Official to secure an  improper advantage in connection with, or in any way relating to, (A) any government authorization or approval involving Twocents, or (B) the obtaining or retention of business by Twocents. Supplier further represents  and warrants that it will not in the future offer, promise, make or otherwise allow to be made or provide  any payment and that it will take all lawful and necessary actions to ensure that no payment is promised,  made or provided in the future by any of the Supplier Personnel.  

19. CLIENT RESPONSIBILITY
“Clients” refer to any third parties whose personal information is accessed, collected, or shared by Users  through the Twocents Platform. These are individuals or entities that Users interact within the course of utilizing  the services provided by Twocents. 
Twocents will handle the information received about Clients through Users with the same level of security and  confidentiality as defined under this Privacy Policy. Twocents implements reasonable security measures to  protect personal information from accidental loss and unauthorized access, use, alteration, and disclosure.  Users are responsible for ensuring that their use of the Platform complies with all applicable data protection  and privacy laws, including obtaining necessary consents from their Clients and providing appropriate  notifications to them. 
Users agree to obtain explicit consent from their Clients regarding the collection, use, and disclosure of  their personal information as described in this Privacy Policy. Users must ensure that Clients are informed  about how their personal information will be used, disclosed, and protected, and must provide them with a  copy of this Privacy Policy or a summary of its key provisions. Users are solely liable for any violations of  privacy laws or regulations resulting from their failure to obtain the necessary consent or provide required  notices. In the event that Users fail to obtain the necessary consent from their Clients, Users agree to  indemnify, defend, and hold harmless Twocents from and against any and all claims, liabilities, damages, losses,  or expenses (including reasonable attorneys’ fees) arising out of or in connection with such failure. 

20. CONSENT AND USER RESPONSIBILITIES
Obtaining Consent 
Users of the Twocents Platform are responsible for obtaining all necessary consent from individuals whose  personal information they may access, collect, or share through the Platform. Users must ensure that  individuals are informed about how their personal information will be used, disclosed, and protected, and  must obtain explicit consent for such uses and disclosures. 
Providing Notice 
Users must provide individuals with a copy of this Privacy Policy or a summary of its key provisions,  including information on how to access the full policy. Users must also inform individuals of their rights regarding their personal information, including the right to access, correct, or delete their information.
Compliance with Laws 
Users must comply with all applicable data protection and privacy laws, including those related to obtaining  consent, providing notice, and protecting personal information. Users must ensure that their use of the twocents.ai platform does not violate any applicable laws or regulations. 
Liability for Non-Compliance 
twocents.ai is not responsible for any misuse or unauthorized disclosure of personal information by Users. Users  are solely liable for any violations of privacy laws or regulations resulting from their use of the Platform,  including any failure to obtain necessary consent or provide required notices.

21. CONTACT US
To ask questions or comment about this Privacy Policy and our privacy practices, contact us at:
– Privacy Officer 
– Email: privacy@twocents.ai
– Address: twocents.ai Ltd, 251 Little Falls Drive, Wilmington, New Castle, Delaware, 19808

PLEASE NOTE: IF YOU USE OUR WEBSITE, APP, OR PLATFORM, YOU HAVE AGREED TO AND  ACCEPTED THE PRACTICES DESCRIBED IN THIS PRIVACY POLICY AND THE TERMS AND  CONDITIONS SET FORTH IN OUR TERMS OF USE. IF YOU DO NOT AGREE WITH THE TERMS  OF THIS PRIVACY POLICY OR OUR TERMS OF SERVICE, PLEASE DO NOT USE OUR WEBSITE,  APP, OR PLATFORM.