Privacy policy
Last updated: 21 August 2026
This policy explains how TwoCum collects, uses and protects your personal data, in accordance with the General Data Protection Regulation (GDPR) and applicable data protection law.
1. Data controller
The data controller is TwoCum — Find Yourself Forever Sp. z o.o., ul. Marszałkowska 84/92, 00-514 Warszawa, Poland. For any question relating to your data: contact@twocum.com.
2. Data we collect
- Account: phone number, and the name you choose to display on a call.
- Contact: the message you send to contact@twocum.com, and the phone number you call us from.
- Calls: technical data needed to connect a voice or video call (device, connection, time). The content of a call is not read for advertising.
- Browsing: IP address, device and browser type, pages viewed (via cookies — see the cookie policy).
If a paid option is offered later, banking data is processed by the payment provider and is not stored by TwoCum.
3. Purposes and legal bases
| Purpose | Legal basis |
|---|---|
| Answer a contact request | Pre-contractual measures |
| Provide voice and video calls | Performance of the contract |
| Accounting and legal obligations | Legal obligation |
| Audience measurement, site improvement | Consent / legitimate interest |
| Sending commercial offers (if you accept) | Consent |
4. Retention periods
- Contact messages: 3 years after the last message.
- Account: for as long as the account is open, then the legal retention period (accounting documents: 10 years, when a payment exists).
- Measurement cookies: 13 months maximum.
5. Recipients
Your data is accessible to our teams and, only where necessary to connect a call or process a payment, to our technical and payment providers. We never sell your data. A transfer outside the European Economic Area, if it happens, is framed by appropriate safeguards.
6. Your rights
You have the rights of access, rectification, erasure, restriction, objection and portability, as well as the right to withdraw your consent at any time. To exercise them, write to contact@twocum.com. You may also lodge a complaint with the competent data protection authority (e.g. the CNIL in France, www.cnil.fr).
7. Security
TwoCum implements appropriate technical and organisational measures to protect your data against any unauthorised access, loss or disclosure.