222 PRIVACY NOTICE

Last Updated: 6/26/2023

222 is a platform that curates social, real-life experiences to help foster meaningful connections. This Privacy Notice explains how TwoTwoTwo Inc., doing business as 222 (“222”, “we”, “us” or “our”) collects your personal information and what we do with it, including how we use it and share it. When we say personal information we mean information that identifies, relates to, describes, or could be associated with a person.

Our services include:

• Our website, including www.222.place (the “Site”) and other websites that link to this Privacy Notice;

• Our mobile app (the “App”) and the related content, platform, services, products, and other functions we offer on or through our service, including the survey we use to match you with people and places.

Throughout this Privacy Notice, we refer to these collectively as the “Services”.

1. What Personal Information Do We Collect ?

The personal information we collect, the way we collect it, and how we use it depends on our relationship with you and how you interact with us.

Personal Information We Collect from You

We may collect personal information that you submit to us, including:

• Contact Information: When you contact us, such as if you email us directly or use the Contact form on our website, we may collect your name, email address, and communication preferences. If you are a business representative from a restaurant or venue that is interested in hosting an experience, we may also collect your business email address, business mailing address, employer, job title, company name, and phone number.

• Your Mobile Contacts: If you choose to use our App, with your permissions, we collect your phone contacts. If you choose to invite guests to our events or find others through your phone contacts, we will access and collect information such as names and phone numbers, and match that information against those on our platform.

• Account Information: If you complete our sign up survey, or if you are a venue that we are partnering with to provide an experience, we may ask you to create an account. The personal information we collect may include your first and last name, phone number, user ID and password.

• Order Information: If you buy one of our products, we collect personal information such as your first and last name, shipping address, phone number, email address, and payment information. Note we use third-party payment processors to process payments on our store (please see additional information in the Payment Information section below).

• Information You Provide Through our Services, Including Our Survey: You may create, upload, or send us data, files, documents, videos, images, or other information when you communicate with us or use our Sites or App. Collectively, we call this “User Content”. For example, when you select to “sign up” for our Services, you will be directed to a self-assessment survey that asks detailed questions about you. Though this survey, we may collect personal information such as your phone number, first and last name, birthday, philosophical beliefs, demographic information (such as age, gender, historical income level, and the city you live in), and any other information you choose to submit in response to the approximately 100 questions in our survey.

• Payment Information: If you complete our sign-up survey and agree to receive invites to experiences, you will be asked to submit a payment for a chance to participate in that experience. We may also collect your payment information if you sign up for a subscription. If you represent a venue or restaurant that we partner with to host experiences, you will also be asked to submit a payment. However, we use a third-party payment processor, such as Stripe, to process credit card payments made to us. Therefore, we do not keep any personally identifiable financial information in connection with those credit card payments, such as credit card numbers. Instead, this information is provided directly by you to our third-party processor. You can read more about how Stripe uses your personal information through their privacy notice here.

• Event Information: If you participate in our events, such as our experiences, we may collect your contact information. For example, we may collect your phone number during check-in.

• Feedback Information: We may also ask for your feedback and ratings about our Services, and our experiences.

• Job Application Information: If you are interested in joining our team (for example, if you use the “careers” section of our Site), we may collect your name, email, phone, demographic information, educational and work history, employment interests, information obtained during interviews, and any other information you choose to share with us about yourself.

Personal Information Automatically Collected Through Cookies and Tracking Technologies

When you use our Services, we (or our third-party service providers, vendors, or partners) may automatically collect certain information from your web browser (like Chrome or Safari) or through your device (such as your phone or tablet).

This information may be collected via tracking technologies, such as (i) cookies or small data files that are stored on your computer and (ii) other, related technologies, such as web beacon, pixels, embedded scripts, location-identifying technologies and logging technologies (we refer to all of these as “cookies”).

The information may include:

• Device Data, such as your internet protocol (IP) address, browser and/or device type and versions, internet service provider, device operating system, a unique ID that allows us to uniquely identify your browser, mobile device, or your account (including, for example, a persistent device identifier or an Ad ID), and other similar types of information.

• Information About How You Access our Services, such as the site from which you came and the site you are going to when you leave our Services, how frequently you access the Services, whether you open emails or click the links contained in our emails, whether you access the Services from multiple devices, and other browsing behavior and actions you take on the Site.

• Information About How You Use our Services, such as the pages you visit, the links you click, the time you spend on our Sites, products you view and purchase, and other browsing behavior on our Services. We may also use third-party tools to collect information you provide to us or information about how you use the Services. These tools only collect information if you press submit during our survey.

• Information About Your Location, which may include your general geographic location. We or our third-party providers may determine this based on your IP address. This may also include more precise geolocation, which we may receive with your permission when you access our App or Sites from a mobile device.

• Analytics Information, such as traffic and usage trends. We may collect this analytics data directly or use third-party analytics tools. For example, we use Google Analytics to recognize the devices you use when you visit our Services on your browser or mobile device. For more information on how Google Analytics collects and processes data and how you can control information sent to Google, please visit Google’s website, “How Google uses information from sites or apps that use our services” at https://www.google.com/policies/privacy/partners/. You can also learn about Google Analytics’ opt-outs, including the Google Analytics Browser Add-On, here: https://tools.google.com/dlpage/gaoptout/.

The information collected automatically through these technologies allows us to improve your experience. For example, we may use this information to remember information so that you do not have to re-enter it during your visit or the next time you visit the Site, to monitor aggregated metrics (such as total number of visitors, traffic, usage, and demographic patterns on our Site), to diagnose or fix technology problems, and otherwise to plan for and improve our Services, marketing, and customer service capabilities.

For more information about your choices regarding cookies, please see the Your Personal Information Choices section below.

Personal Information We Collect from Third Parties

We also may collect personal information from third parties listed below. We typically combine this with the personal information we collect from you directly or automatically.

• Social Media: When you engage with us through social media, such as if you follow us or share our content on Google, Instagram, TikTok, or other social networks, we may receive some information about you. The information we receive depends on your privacy settings with the social network, and what you’ve allowed the social network to share with us. For example, it may include your profile information, profile picture, gender, username, user ID associated with your social media account, age range, language, country, and any other information you allow the social network to share with third parties. You should review and, if necessary, change your privacy settings on the social media networks before sharing information and/or linking or connecting them to other services.

• Service Providers: Our service providers that perform services solely on our behalf, such as survey and payment processors, collect personal information and often share some or all of this information with us.

• Authentication Services You Connect to our Service: You might be able to login to our Services through a third-party social network, such as Spotify. These services will authenticate your identity and provide you the option to share certain personal information with us, which could include your name, email address, or other contact information and music preferences. The data we receive depends on that third party’s policies and your privacy settings on that third-party site. This data would only be collected in order to provide you better social experiences.

• Business Partners: We may receive your information from our business partners, such as venues and restaurants that partner with us to host our in-personal experiences.

• Publicly Available Sources: We may also collect personal information about you that we do not otherwise have, such as contact information or information about your interest in our Services, from publicly available sources.

2. How Do We Use Personal Information ?

We touched on how personal  information is used when we outlined it above, but we’ll expand on how we use your information here:

• Provide our Services, like matching you with other users for group social experiences and coordinating with venues;

• Manage our day-to-day operations;

• Verify your identity when you contact us or eligibility to use our Services. This is solely for your and other members’ safety and comfort;

• Register you for and provide you access to events and experiences;

• Contact and communicate with you (including through email, text messages, social media) for customer service purposes, service notifications, security alerts, and notices regarding our policies.

• Request that you complete surveys about our Services, other users, businesses we partner with, and particular experiences;

• Invite you to our in-person experiences including through text messaging, based on your interests and interactions with us;

• Improve and personalize our Services and grow our business, including by training the machine learning model we leverage to improve its ability to match you with other people and places;

• Identify and analyze how individuals use our Services;

• Conduct market research and analytics on our user base and our Services;

• Test, research, develop, improve, and customize our Services, including developing new features and experiences;

• Identify or fix technology problems;

• Help maintain the safety, security, and integrity of our property and Services, technology assets and business;

• Enforce our terms, resolve disputes, carry out our obligations, enforce our rights, and protect our business interests and the interests and rights of third parties;

• Prevent, investigate, or address fraud, breaches of policies or terms, and unlawful or criminal activity;

• Comply with contractual obligations;

• Comply with legal obligations and requirements;

• Fulfill any other purpose at your direction or your consent.

3. How Do We Share Personal Information ?

We may share personal information with third parties:

• Other Users: If you register for an account and engage with our Service, other registered users may be able to see your profile information, such as name and phone number.

• Survey Providers: We share personal information with third parties, such as Typeform, who assist us in providing our survey offerings and processing the responses.

• Other Service Providers: In addition to survey providers, we also share personal information with other service providers that provide services on our behalf, such as payment processing, data analytics, website hosting, and technical support.

• Business Partners: Occasionally, we may share aggregate data with our business partners. For example, we may share aggregated user information regarding music preferences, gender, and demographics with our venue and restaurant business partners, who use this information to tailor an experience to the interests of the crowds we send to their locations. This information would not be personally identifiable.

• Business Transaction or Reorganization: We may be a part of or be involved with a corporate business transaction, such as a merger, acquisition, joint venture, or financing or sale of company assets. We may disclose personal information to a third party during negotiation of, in connection with, or as an asset in such a corporate business transaction. Personal information may also be disclosed in the event of insolvency or in the bankruptcy context.

• Legal Obligations and Rights: We will not disclose any personal information to third parties such as legal advisors and law enforcement. We will only do so under these circumstances:
  • to establish, exercise or defend legal claims;
  • to comply with laws or to respond to lawful requests and legal process;
  • to protect our rights and property and the rights and property of others, including to enforce our agreements and policies;
  • to detect, suppress, or prevent fraud;
  • to protect the health and safety of us and others; or
  • as required by law.

• With Your Consent: We may share your personal information to other third parties or publicly with your consent or if you tell us to.

4. Your Personal Information Choices

Choosing to directly provide us with your personal information, such as through completing our sign-up survey, is completely optional. However, if you do provide us with your personal information, you have the following options:

• Changing Email Communication Preferences: From time to time, we may send you emails regarding updates to our products or Services, or marketing information that we think may be of interest to you. You can stop receiving marketing email communications from us by clicking on the “unsubscribe” link at the bottom of marketing-related emails. However, please note you may not be able to opt-out of service-related communications such as emails about verifying your account, any changes or updates to our Services, or technical or security notices.

• Changing Push Notifications: You can stop receiving push notifications from us by changing your preferences in the iOS notifications settings menu.

• Opting Out of SMS Text Messaging: You may opt out of receiving promotional SMS text messages at any time. Please note that unsubscribing from promotional text messages will not prevent you from receiving texts related to your use of the Services, such as sending you a security code to help you login to your account. To unsubscribe from promotional SMS texts, you can reply STOP or UNSUBSCRIBE. For more information, see our Terms of Service.

• Modifying or Deleting Your Information: If you have any questions about reviewing, modifying, or deleting your information, please contact us at hey@222.place. We may not be able to modify or delete your information in all circumstances.

• Cookies and Other Tracking Technologies Opt-Out: If you prefer not to accept cookies, most browsers will allow you to change the setting of cookies by adjusting the settings on your browser. You can change the settings to: (i) notify you when you receive a cookie, which lets you choose whether to accept it; (ii) disable existing cookies; or (iii) set your browser to automatically reject cookies. Depending on your device and operating system, you may not be able to delete or block all cookies. In addition, if you want to reject cookies across all your browsers and devices, you will need to reject them on each browser on each device you actively use. Separately, you may also set your email options to prevent the automatic downloading of images that may contain technologies that would allow us to know whether you have accessed our email and performed certain functions with it.

5. Children’s Personal Information

Our Services are not directed to, and we do not intentionally collect or solicit personal information from children or teens who we know or reasonably should know are under the age of 18. If you are under the age of 18, please do not use our Services or otherwise provide us with any personal information. If you believe a child under the age of 18 has provided personal information to us, we encourage the child’s parent or guardian to contact us to request that we remove the personal information from our systems. We will promptly delete that personal information from our systems.

6. Links to Third-Party Websites or Services

Our Services may include links to some third-party websites, plug-ins, and applications. We don’t control your personal information once you navigate to those links.

Except where we post, link to, or directly refer to this Privacy Notice, this Privacy Notice doesn’t apply to (and we are not responsible for) any personal information practices of third parties. To learn about the personal information practices of third parties, you should review their privacy notices.

7. State-Specific Disclosures

Some states require us to provide additional information about processing your personal information. Please see below to see if any further information may apply to you:

• Nevada: If you live in Nevada, you have the ability to opt out of future sales of certain covered information that we have collected or will collect about you. We do not currently sell covered information as defined under the applicable Nevada law, Chapter 603A of the Nevada Revised Statutes. However, if you would like to submit a related request, please contact us at hey@222.place.

8. Updates to This Privacy Notice

From time to time, we may update this Privacy Notice. When we make changes to this Privacy Notice, we will change the “last updated” date at the beginning of this Privacy Notice. If we make material changes to this Privacy Notice, we will notify you by email, by a prominent posting on our Services, or through other communication channels. All changes will be effective once they are published, unless we indicate otherwise.

9. Closing Words and Contact Details

We’ve described our data collection and use policies above, if you have any questions or requests about any of this, please send us an email at hey@222.place.