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LEGAL

Privacy Policy

Effective: August 5, 2026
•
Last Updated: August 5, 2026
•
Entity: 24 Operating Company LLC

Welcome to 24. At 24, we believe meaningful relationships begin with trust. That trust extends beyond the people you meet—it also includes how your personal information is collected, used, protected, and shared. This Privacy Policy explains how 24 Operating Company LLC ("24," "we," "our," or "us") collects, uses, stores, discloses, and otherwise processes information when you access or use our Services.

Table of Contents (Jump to section)
1. Introduction2. Who We Are3. Scope of this Privacy Policy4. Our Privacy Principles5. Eligibility6. Definitions7. Acceptance of this Privacy Policy8. Changes to this Privacy Policy9. Information We Collect10. How We Use Your Information11. How We Share Your Information12. Your Privacy Rights and Choices13. Data Retention and Security14. Cookies, Analytics, Advertising & SDKs15. Children's Privacy16. International Users17. State-Specific Privacy Disclosures18. Third-Party Websites and Services19. Changes to This Privacy Policy20. Contact Us21. MiscellaneousAPPENDIX A — California Privacy Notice

Table of Contents

1.Introduction2.Who We Are3.Scope of Policy4.Privacy Principles5.Eligibility6.Definitions7.Acceptance8.Policy Changes9.Info We Collect10.How We Use Info11.How We Share Info12.Rights & Choices13.Retention & Security14.Cookies & SDKs15.Children's Privacy16.International Users17.State Disclosures18.Third Parties19.Policy Updates20.Contact Us21.MiscellaneousA.Appendix A (CCPA)

1Introduction

Welcome to 24.

At 24, we believe meaningful relationships begin with trust. That trust extends beyond the people you meet—it also includes how your personal information is collected, used, protected, and shared.

This Privacy Policy explains how 24 Operating Company LLC ("24," "we," "our," or "us") collects, uses, stores, discloses, and otherwise processes information when you access or use:

  • the 24 mobile application;
  • 24.app and related websites;
  • our ambassador platform;
  • waiting room experiences;
  • promotional events;
  • customer support; and
  • any other products or services that reference this Privacy Policy (collectively, the "Services").

This Privacy Policy is intended to help you understand:

  • what information we collect;
  • why we collect it;
  • how we use it;
  • who we share it with;
  • how long we keep it;
  • what choices you have regarding your information; and
  • the rights available to you under applicable law.

Please read this Privacy Policy carefully before using our Services. If you do not agree with this Privacy Policy, you should not use 24.

2Who We Are

24 is operated by:
24 Operating Company LLC
United States

Throughout this Privacy Policy:

  • "24," "we," "our," and "us" refer to 24 Operating Company LLC.
  • "You" and "your" refer to anyone who accesses or uses the Services.

Although 24 initially launches only within the United States, we may expand internationally in the future. If we do, additional disclosures required under local laws may apply.

3Scope of this Privacy Policy

This Privacy Policy applies whenever you interact with 24, including when you:

  • create an account;
  • browse profiles;
  • upload photographs;
  • send messages;
  • record voice notes;
  • participate in the Waiting Room experience;
  • participate in the Ambassador Program;
  • purchase Premium subscriptions;
  • purchase Time Packs or Shine Packs;
  • communicate with customer support;
  • visit our website;
  • respond to surveys;
  • enter promotions or contests; or
  • otherwise interact with our Services.

This Privacy Policy also applies to future features that reference or incorporate this Privacy Policy unless those features are accompanied by a separate privacy notice.

Certain third-party services integrated into 24 may have their own privacy policies. This Privacy Policy does not govern the practices of those independent third parties.

4Our Privacy Principles

We built 24 around several core privacy principles:

We collect only what we need
We strive to collect information that allows us to provide the Services while minimizing unnecessary collection of personal information.
You remain in control
Whenever reasonably possible, you may review, update, modify, or delete your information through your account settings.
Safety comes first
Some information is processed to protect our community from spam, fraud, impersonation, harassment, scams, fake accounts, abusive conduct, and other violations of our Terms of Service.
Privacy and transparency
We aim to explain our data practices in plain language. While some legal terminology is necessary, we believe privacy policies should be understandable.
Security by design
Protecting user information is incorporated into the design and operation of our systems through administrative, technical, and organizational safeguards.

5Eligibility

24 is intended only for individuals who are 18 years of age or older. You may not create an account if you are under 18.

By using 24, you represent that:

  • you are at least 18 years old;
  • the information you provide is accurate;
  • you have authority to provide the information you submit; and
  • your use of 24 complies with applicable laws.

If we learn that an account belongs to someone under the age of 18, we may suspend or permanently delete that account and associated information.

6Definitions

For purposes of this Privacy Policy:

  • Account: means the user profile you create to access 24.
  • Content: means photographs, messages, voice notes, profile information, prompts, icebreakers, reports, feedback, comments, and any other information submitted through the Services.
  • Personal Information: means information that identifies, relates to, describes, or can reasonably be linked to an identifiable individual.
  • Sensitive Personal Information: includes categories of information that receive heightened protection under applicable law, such as precise geolocation or certain demographic information.
  • Processing: means any operation performed on information, including collection, storage, organization, analysis, transmission, disclosure, deletion, or destruction.
  • Service Provider: means a company that processes information on our behalf pursuant to contractual obligations.
  • Device Information: includes technical information regarding the phone, tablet, browser, operating system, network, IP address, device identifiers, language settings, crash logs, and similar technical data.

7Acceptance of this Privacy Policy

By accessing or using 24, you acknowledge that you have read and understood this Privacy Policy. Where required by law, you also consent to the collection, use, disclosure, and processing of your information as described herein.

If you do not agree with this Privacy Policy, you should discontinue use of the Services.

8Changes to this Privacy Policy

Technology evolves, our Services evolve, and privacy laws continue to change. Accordingly, we may modify this Privacy Policy from time to time. When we make changes, we may:

  • revise the "Last Updated" date;
  • notify users within the application;
  • send an email (when available);
  • display a prominent notice within 24; or
  • provide any other notice required by applicable law.

If changes materially affect how we process personal information, we will provide notice as required by applicable law before those changes become effective. Your continued use of 24 after an updated Privacy Policy becomes effective constitutes acceptance of the revised Privacy Policy.

9Information We Collect

The information we collect depends on how you use 24, the features you choose to use, the permissions you grant, and your interactions with our Services. Information generally falls into four categories:

  1. Information you provide directly.
  2. Information collected automatically.
  3. Information received from third parties.
  4. Information generated through your use of 24.

9.1 Account Information

When you create a 24 account, we collect information necessary to establish and maintain your account, including:

  • mobile phone number and country code;
  • verification status and OTP records;
  • optional recovery email address;
  • account creation date, identifier, and status; and
  • authentication tokens, login history, and device verification records.

9.2 Profile Information

To help facilitate meaningful introductions, information you choose to provide may include: first name, age, birthday, hometown, current city, profile photos, biography, gender identity, languages, education, occupation, employer, height, ethnicity, religion, political views, relationship preferences, dating intentions, prompts, interests, and lifestyle details.

Some of this information may be considered sensitive personal information under certain laws. Providing optional profile information is entirely your choice.

9.3 Photographs and Media

You may upload profile photos, verification photos, images shared in conversations, or support screenshots. Uploaded media is processed to display your profile, operate messaging, moderate content, and improve safety.

9.4 Messages

When you send messages, we process message content, timestamps, sender/recipient data, delivery/read receipts, attachments, and metadata.

Although 24 removes conversations from the user interface after expiration, information may continue to be retained for limited periods where reasonably necessary for abuse investigations, fraud prevention, legal compliance, dispute resolution, and Terms enforcement.

9.5 Voice Notes

When you record or receive a voice note, we process audio recordings, duration, upload timestamps, playback status, and technical metadata to operate voice messaging and maintain security.

9.6 Icebreakers and Interactive Features

Responses to Multiple Choice, Two Truths and a Lie, This or That, AMAs, Rate This, and Red Flag / Green Flag prompts become part of your interactive profile experience.

9.7 Preferences

We collect discovery age/distance ranges, gender preferences, relationship goals, notification settings, and block lists.

9.8 Purchases

We collect subscription status, renewal dates, Time/Shine Pack transactions, and purchase IDs. Complete credit card details are processed directly by Apple, Google, or Stripe and are not stored by 24.

9.9 Customer Support

Support messages, attachments, troubleshooting logs, and correspondence history are retained for service quality and dispute resolution.

9.10 Reports and Safety Information

When reports are submitted, we collect report details, reported content, timestamps, investigation notes, and moderation decisions.

9.11 Ambassador Program

Participating ambassadors share school affiliation, referral codes, invitation statistics, verified referrals, and prize eligibility.

9.12 Waiting Room Experiences

We collect prompt entries, competition rankings, referral milestones, and participation records.

9.13 Surveys, Promotions, and Events

Voluntary surveys, interviews, and contest submissions are collected according to the specific event.

9.14 Device Information

We automatically collect IP addresses, OS, browser type, device model, language, app version, network info, and crash logs.

9.15 Usage Information

We collect session duration, profiles viewed, matches created, conversations initiated, and interactions with features.

9.16 Location Information

With your permission, we collect GPS or city-level location to calculate distances and provide nearby recommendations. You may revoke permissions at any time.

9.17 Cookies, SDKs, and Similar Technologies

Used to remember preferences, maintain secure sessions, and measure app performance.

9.18 Information from Third Parties

Received from Apple, Google, payment processors, analytics providers, and users submitting safety reports.

9.19 Information We Generate

Includes recommendation scores, fraud detection signals, account security metrics, and internal moderation logs.

10How We Use Your Information

24 processes personal information only where there is a legitimate business purpose, contractual necessity, legal obligation, or consent. Key operational purposes include:

10.1 Providing the Services

Operating core accounts, delivering profiles, enabling time-limited chats and voice notes, synchronizing settings, and administering purchases.

10.2 Matching and Recommendations

Using mutual preferences, geographic proximity, and activity levels to recommend compatible members. Recommendation algorithms assist—but never replace—human choice.

10.3 Account Security

Detecting suspicious logins, recognizing trusted devices, and preventing account takeovers.

10.4 Community Safety

Investigating reports, removing abusive accounts, detecting impersonation, and enforcing Community Guidelines.

10.5 Fraud Prevention

Stopping payment fraud, referral manipulation, duplicate accounts, and bot generation.

10.6 Customer Support

Troubleshooting account issues, resolving disputes, and improving service quality.

10.7 Personalization

Delivering customized prompt suggestions, onboarding flows, and relevant notifications.

10.8 Communications

Sending verification codes, purchase receipts, security alerts, and optional promotional announcements.

10.9 Analytics and Product Improvement

Monitoring crash rates, feature adoption, and messaging stability using aggregated metrics.

10.10 Research and Development

Improving accessibility, usability, and statistical algorithms using de-identified datasets.

10.11 Artificial Intelligence and Automated Systems

Using automated safety systems to flag spam, bot networks, and abusive content.

10.12 Identity Verification

Authenticating users and curbing catfishing if identity verification is activated.

10.13 Promotions, Ambassador Program, and Waiting Room

Managing leaderboard positions, reward distribution, and referral tracking.

10.14 Legal Compliance

Satisfying tax obligations, accounting rules, lawful court orders, and regulatory audits.

10.15 Protecting Rights and Interests

Defending legal claims, establishing rights, and protecting public safety.

10.16 Business Operations

Supporting risk management, internal auditing, and disaster recovery planning.

10.17 Aggregated and De-Identified Information

Using non-identifiable statistics for research, marketing insights, and benchmarking.

10.18 Lawful Bases for Processing (International Users)

Relying on contractual performance, legitimate interests, legal obligations, or user consent where international laws apply.

11How We Share Your Information

We do not sell personal information for money. We share information only as described below:

11.1 Information Shared With Other Members

Profile details (photos, name, age, bio, interests, mutual interactions, and voluntary messages) are intentionally visible to connected members. Once sent, 24 cannot prevent recipients from taking screenshots or recording content.

11.2 Service Providers

Contracted vendors for cloud hosting, databases, customer support, analytics, and security process data strictly under confidentiality terms.

11.3 Payment Processors

Apple, Google, and Stripe handle transactions directly under their own privacy policies.

11.4 Analytics Providers

Share pseudonymized crash metrics and stability data.

11.5 Security and Fraud Prevention Partners

Specialized cybersecurity vendors help detect botnets, account takeovers, and fraudulent transactions.

11.6 Customer Support Providers

Ticket software vendors receive data needed to answer user inquiries.

11.7 Promotional Partners

Limited data shared only where necessary to administer joint giveaways or ambassador events.

11.8 Legal Compliance

Disclosures made to comply with subpoenas, search warrants, or emergency requests involving imminent physical danger.

11.9 Business Transactions

In the event of a merger, acquisition, or asset transfer, user records may be transferred with appropriate notice.

11.10 Professional Advisors

Attorneys, auditors, and insurers bound by professional privilege.

11.11 With Your Consent

Shared with external services when you expressly instruct us to do so.

11.12 Aggregated and De-Identified Information

High-level statistical trends that cannot reasonably identify you.

11.13 We Do Not Sell Personal Information for Money

24 does not sell your personal data for monetary consideration.

11.14 International Transfers

Standard Contractual Clauses or statutory transfer safeguards are implemented if international data transfers occur.

11.15 No Unauthorized Sharing

We never disclose your contact information to unrelated third parties for independent cold marketing.

11.16 Data Minimization

Only the minimum information necessary is shared with trusted partners.

11.17 Future Features

New integrations will be updated in this section with notice provided as required by law.

12Your Privacy Rights and Choices

You maintain control over your personal information:

12.1 Access to Your Information

You may request a breakdown of categories and specific personal data we hold about you.

12.2 Correcting Information

Update profile bios, cities, photos, and preferences anytime in your app settings.

12.3 Account Deletion

Delete your account directly in the app. Public profile and discovery are removed immediately; limited safety records may be retained per our retention policy.

12.4 Downloading Your Information

Request an export copy of your account profile and purchase history.

12.5 Marketing Communications

Opt out of promotional emails via the unsubscribe link. Essential service emails (codes, receipts) cannot be unsubscribed.

12.6 Push Notifications

Adjust notification alerts in device or app settings.

12.7 Location Permissions

Toggle GPS access on or off in operating system settings.

12.8 Camera, Microphone, and Photo Permissions

Manage device permissions required for taking photos or recording voice notes.

12.9 Cookie Preferences

Control tracking cookies via your web browser controls.

12.10 California Privacy Rights (CCPA/CPRA)

California residents have rights to know, delete, correct, opt out of data sharing, and limit the use of sensitive data without discrimination.

12.11 Connecticut Privacy Rights (CTDPA)

Connecticut residents have access, correction, deletion, portability, and appeal rights.

12.12 Other U.S. State Privacy Laws

We honor applicable statutory privacy requests across all operating states.

12.13 Future International Rights

GDPR and foreign rights will be honored in designated regions.

12.14 Identity Verification

To safeguard account security, we may verify your phone number before honoring data requests.

12.15 Authorized Agents

Agents may submit requests with verifiable written power of attorney.

12.16 Limitations

Requests may be limited where disclosure would infringe another person's privacy or ongoing safety probes.

12.17 Exercising Your Rights

Contact privacy@twofour.app to submit a formal privacy request.

12.18 No Retaliation

24 will never unlawfully discriminate against you for exercising your privacy rights.

13Data Retention and Security

24 retains personal data only as long as necessary to provide Services, comply with statutory obligations, resolve disputes, and maintain platform safety.

13.1 General Retention Principles

Retention spans reflect information sensitivity, legal statute limitations, fraud prevention needs, and active account status.

13.2 Active Accounts

Maintained continuously while your profile is active.

13.3 Account Deletion

Public profile removed immediately. Back-end records undergo scheduled disposal cycles.

13.4 Safety Retention

Records involving severe safety reports or banned accounts may be retained to prevent predator re-registration.

13.5 Financial Records

Subscription and refund records are retained to comply with tax and auditing laws.

13.6 Customer Support Records

Retained to maintain customer service history and resolve recurring issues.

13.7 Reports and Moderation Records

Maintained to protect the community and defend against legal disputes.

13.8 Messages and Voice Notes

Expired chats in the UI are archived from view and subsequently scrubbed per operational backup schedules.

13.9 Backups

Encrypted disaster recovery backups cycle on automated rotation schedules.

13.10 Legal Holds

Preserved when formal statutory subpoenas or preservation demands are received.

13.11 De-Identification

Identifiers may be permanently stripped for aggregated analytics.

13.12 Security Program & Safeguards

We maintain comprehensive technical safeguards, including TLS encryption in transit, AES encryption at rest for sensitive data, firewalls, intrusion detection, least-privilege role access, and regular vulnerability audits.

13.16 Account Security Responsibilities

You are responsible for keeping your phone access and OTP codes private.

13.18 No Absolute Guarantee

No electronic transmission is 100% impenetrable. Exercise sound personal judgment when uploading personal details online.

14Cookies, Analytics, Advertising, and Similar Technologies

We use cookies, SDKs, APIs, and local storage to provide and measure the Services:

  • Essential Technologies: Maintain login sessions and balance traffic.
  • Mobile SDKs: Send push alerts and track crash diagnostics.
  • Analytics: Measure feature engagement trends.
  • Advertising: 24 does not serve third-party ads at launch.

15Children's Privacy

24 is strictly intended for adults 18 and older. We do not knowingly collect information from minors under 18. Any accounts discovered to belong to minors will be deleted immediately.

16International Users

24 launches in the United States. Future international expansions will implement Standard Contractual Clauses and statutory safeguards for cross-border data transfers.

17State-Specific Privacy Disclosures

Residents of California, Connecticut, Colorado, Virginia, and other states with enacted privacy statutes possess specific rights outlined in Section 12 and Appendix A.

18Third-Party Websites and Services

External links (e.g. venues, payment partners) operate under independent privacy policies not governed by 24.

19Changes to This Privacy Policy

We may update this policy periodically. Continued use of 24 after updates become effective constitutes acceptance.

20Contact Us

If you have questions, concerns, or privacy requests, please contact:

24 Operating Company LLC
Business Mailing Address:
1178 Broadway, Floor 3
New York, NY 10001
Privacy Email: privacy@twofour.app
Website: https://twofour.app

21Miscellaneous

Entire Policy: This policy is the complete privacy statement for 24.

Severability: If any provision is deemed invalid, remaining provisions stay in effect.

Governing Law: Governed by the laws of the State of Connecticut, without regard to conflict principles.

AAPPENDIX A — California Privacy Notice

This appendix supplements the Privacy Policy for California residents under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA).

It includes statutory disclosures regarding:

  • Categories of personal information collected (identifiers, commercial info, internet activity, geolocation data, audio recordings, sensitive demographic information).
  • Categories of sources from which information is derived.
  • Business and commercial purposes for collection.
  • Categories of third parties receiving information.
  • Data retention criteria and deletion schedules.
  • Sensitive Personal Information disclosures.
  • Sale/Sharing disclosure (24 does not sell personal information for monetary compensation).
  • California consumer privacy rights (know, delete, correct, opt out of sharing, non-discrimination).
  • Shine the Light disclosure (California Civil Code §1798.83).
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