Privacy
Policy

Introduction and Commitment

This Privacy Policy ("Policy") describes how BTWNBROS ("we," "us," or "our") collects, uses, stores, discloses, and protects the personal information of users ("you" or "your") of the BTWNBROS platform, including all associated websites, applications, and services (collectively, the "Platform"). By accessing or using the Platform, you acknowledge that you have read, understood, and agree to the terms of this Policy.

Legal Basis for Processing

BTWNBROS processes your personal information pursuant to one or more of the following legal bases:

• Contractual necessity: Processing that is necessary for the performance of our agreement with you, including account creation, identity verification, and provision of Platform services.
• Legitimate interest: Processing that is necessary for the legitimate interests pursued by BTWNBROS, including fraud prevention, platform security, abuse detection, and enforcement of our Terms of Service, provided such interests are not overridden by your fundamental rights and freedoms.
• Legal obligation: Processing that is necessary for compliance with applicable law, regulation, or legal process, including but not limited to mandatory reporting obligations under 18 U.S.C. Section 2258A and applicable tax and financial record-keeping requirements.
• Consent: Processing based on your freely given, specific, informed, and unambiguous consent, where applicable. You may withdraw consent at any time without affecting the lawfulness of processing based on consent prior to its withdrawal.

Categories of Personal Information Collected

BTWNBROS collects the following categories of personal information in connection with your use of the Platform:

• Identity information: Name as it appears on a government-issued identification document, date of birth, and government-issued identification number. Identification numbers are used exclusively for the purpose of identity verification and shall not be retained following successful completion of the verification process.
• Contact information: Email address.
• Verification records: Identity verification outcome (pass or fail) and confirmed age. These records are permanently associated with your account to enforce our one-verified-identity-per-account policy and shall not be subject to deletion upon account termination.
• Profile information: Username, profile content, photographs, and any additional information you voluntarily provide in connection with your profile.
• Communication data: Messages transmitted through the Platform. Messages designated as "Burn After Read" shall be permanently and irreversibly deleted upon being read by the intended recipient and are not retained thereafter.
• Payment and transaction data: Transaction references and subscription status. Full payment card information is processed and stored exclusively by our third-party payment processor and is not collected, accessed, or retained by BTWNBROS.
• Usage and technical data: Basic platform usage information, device identifiers, IP addresses (stored in hashed form only), and technical metadata required for safety monitoring and fraud prevention.

Purpose and Use of Personal Information

BTWNBROS shall use your personal information exclusively for the following purposes:

• Identity verification: Confirming your identity, age, and eligibility to access and use the Platform.
• Safety and integrity: Detecting and preventing abuse, fraud, impersonation, and violations of Platform policies, including automated scanning of all uploaded media for child sexual abuse material ("CSAM").
• Platform operations: Providing, maintaining, and improving the core functionality and performance of the Platform.
• Legal compliance: Fulfilling obligations under applicable law, including mandatory reporting requirements under 18 U.S.C. Section 2258A and cooperation with valid legal process.
• Communications: Sending service-related notices, security alerts, and administrative messages necessary for the operation of your account.

BTWNBROS shall not use your personal information for advertising, marketing profiling, behavioral analytics, or any purpose not expressly set forth in this Policy.

Disclosure of Personal Information

BTWNBROS does not sell, rent, lease, or trade your personal information to any third party. Disclosure of your personal information shall occur only under the following limited circumstances:

• Service providers: Third-party service providers essential to Platform operations, including identity verification providers, payment processors, and infrastructure providers, each of which shall be bound by written data processing agreements that restrict the use of your information to the services performed on behalf of BTWNBROS.
• Legal process: In response to valid legal process, including subpoenas, court orders, search warrants, or as otherwise required by applicable law, including mandatory reporting to the National Center for Missing & Exploited Children ("NCMEC") pursuant to 18 U.S.C. Section 2258A.
• Safety emergencies: When disclosure is reasonably necessary to prevent imminent and serious harm to any individual.
• Business transfers: In connection with a merger, acquisition, reorganization, or sale of assets, provided that the successor entity shall be bound by the terms of this Policy with respect to your personal information.

Platform Non-Disclosure Commitment

BTWNBROS shall not confirm or deny the membership status of any individual to any third party under any circumstances. BTWNBROS shall not respond to informal inquiries from spouses, domestic partners, private investigators, employers, family members, or any other non-governmental third party regarding the existence or status of any member account.

All requests for member information received through formal legal process shall be reviewed by qualified legal counsel prior to any disclosure. No information shall be released absent a determination that the request constitutes valid, enforceable legal process.

Billing Discretion

BTWNBROS permits members to designate a custom merchant descriptor to appear on billing statements associated with Platform transactions. Members may select from a curated list of discreet merchant descriptors or create a custom descriptor at the time of subscription enrollment.

Neither "BTWNBROS" nor any variation thereof shall appear on any billing statement unless the member expressly elects such a descriptor. This setting may be modified at any time through the member's account settings.

Data Retention

BTWNBROS shall retain your personal information in accordance with the following schedule:

• Profile data: Retained for thirty (30) days following account deletion, after which it shall be permanently and irreversibly destroyed.
• Burn After Read messages: Permanently and irreversibly deleted immediately upon receipt and reading by the intended recipient. Such messages are not recoverable by any party, including BTWNBROS.
• Identity verification records and ban records: Retained indefinitely to enforce the one-identity-per-account policy and to maintain the integrity of permanent bans.
• Transaction records: Retained for seven (7) years as required for compliance with applicable financial and tax regulations.
• Government-issued identification documents: Document images shall be deleted immediately upon successful completion of the verification process. Only the verification outcome (pass or fail) and confirmed age shall be retained.
• Usage and technical data: Retained for a period not to exceed twelve (12) months, unless a longer retention period is required for an active investigation or legal proceeding.

Your Rights

Subject to applicable law and the exceptions set forth herein, you shall have the following rights with respect to your personal information:

• Right of access: You may request a copy of the personal information BTWNBROS holds about you.
• Right of correction: You may request correction of personal information that is inaccurate or incomplete.
• Right of deletion: You may request deletion of your personal information, subject to our legal retention obligations, permanent ban records, and verification records as described in this Policy.
• Right of portability: You may request a copy of your profile data in a commonly used, machine-readable format.
• Right to withdraw consent: Where processing is based on consent, you may withdraw such consent at any time without affecting the lawfulness of processing conducted prior to withdrawal.

To exercise any of the foregoing rights, submit a verifiable request to privacy@btwnbros.com. BTWNBROS shall respond to all verified requests within thirty (30) days of receipt. BTWNBROS reserves the right to request additional information to verify the identity of the requestor before processing any rights request.

California Privacy Rights (CCPA/CPRA)

If you are a resident of the State of California, you are entitled to the following additional rights under the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, "CCPA"):

• Right to know: You have the right to request that BTWNBROS disclose the categories and specific pieces of personal information collected about you, the categories of sources from which such information was collected, the business or commercial purpose for collecting such information, and the categories of third parties with whom such information is shared.
• Right to delete: You have the right to request the deletion of personal information collected about you, subject to certain exceptions provided under the CCPA.
• Right to correct: You have the right to request correction of inaccurate personal information maintained by BTWNBROS.
• Right to opt out of the sale or sharing of personal information: BTWNBROS does not sell your personal information as defined under the CCPA. BTWNBROS does not share your personal information for cross-context behavioral advertising purposes. Accordingly, there is no need to submit an opt-out request; however, you may contact privacy@btwnbros.com at any time to confirm this status.
• Right to non-discrimination: BTWNBROS shall not discriminate against you for exercising any of your rights under the CCPA.
• Right to limit the use of sensitive personal information: To the extent BTWNBROS processes sensitive personal information as defined under the CCPA, such processing shall be limited to purposes authorized under the CCPA.

California residents may submit CCPA requests to privacy@btwnbros.com. Requests shall be processed within forty-five (45) days of receipt, with the possibility of a forty-five (45) day extension where reasonably necessary, provided notice of such extension is given.

Security Measures

BTWNBROS implements and maintains reasonable administrative, technical, and physical safeguards designed to protect the confidentiality, integrity, and availability of your personal information, including but not limited to:

• Encryption of personal data at rest and in transit using industry-standard protocols.
• Strict role-based access controls limiting access to personal information to authorized personnel on a need-to-know basis.
• Comprehensive audit logging of all access to personal information.
• Periodic security assessments, vulnerability scans, and penetration testing.
• Hashing of IP addresses using a salted, one-way cryptographic hash function prior to storage.

Notwithstanding the foregoing, no system of electronic data storage or transmission is entirely secure. In the event of a data breach affecting your personal information, BTWNBROS shall notify affected individuals and applicable regulatory authorities in accordance with the timeframes and procedures required by applicable law.

Children's Privacy

The Platform is strictly restricted to individuals eighteen (18) years of age or older. BTWNBROS does not knowingly collect, solicit, or maintain personal information from any individual under the age of eighteen (18).

Upon discovery or notification that a minor has accessed or attempted to access the Platform, BTWNBROS shall immediately: (i) terminate the associated account; (ii) permanently ban the associated device and identity credentials; (iii) preserve all relevant data for potential law enforcement review; (iv) submit a CyberTip report to NCMEC as required by federal law; and (v) cooperate fully with any resulting law enforcement investigation.

International Users

The Platform is operated from the United States of America. If you access the Platform from a jurisdiction outside the United States, you acknowledge and consent to the transfer, processing, and storage of your personal information in the United States, where data protection laws may differ from those of your jurisdiction of residence.

BTWNBROS shall take reasonable steps to ensure that your personal information is treated securely and in accordance with this Policy, regardless of the jurisdiction from which you access the Platform.

Changes to This Privacy Policy

BTWNBROS reserves the right to modify this Privacy Policy at any time at its sole discretion. Material changes shall be communicated to you via the Platform, email to the address associated with your account, or other reasonable means prior to the effective date of such changes.

Your continued use of the Platform following the posting or notification of changes to this Policy shall constitute your acceptance of such changes. If you do not agree with the revised Policy, you must discontinue use of the Platform and may request deletion of your account in accordance with the procedures set forth herein.

The "Last Updated" date at the top of this Policy indicates the date on which the most recent revisions became effective.

Severability

If any provision of this Privacy Policy is held to be invalid, illegal, or unenforceable by a court of competent jurisdiction, such invalidity, illegality, or unenforceability shall not affect the remaining provisions of this Policy, which shall continue in full force and effect. The invalid, illegal, or unenforceable provision shall be modified to the minimum extent necessary to make it valid, legal, and enforceable while preserving the original intent of the provision to the greatest extent permitted by applicable law.

Contact

For all privacy-related inquiries, data subject requests, complaints, or concerns regarding this Policy or the processing of your personal information: