Effective Date: May 29, 2025
This Privacy Policy (“Policy”) describes how 2wai, Inc. (collectively, “2wai,” “Company,” “we” or “us”) collects, uses, discloses and otherwise processes the personal information described below, as well as the rights and choices you have regarding such personal information.
You can review more detailed information about our privacy practices and your rights and choices below in our Policy, which is organized into the following sections:
Scope
Personal Information Collected
Purposes of Collection and Processing
Disclosure of Personal Information
Cookies, Analytics and Targeting
Your Privacy Choices
Third-Party Sites and Services
International Transfers
Security
Retention
Children’s Privacy
Changes to Our Privacy Policy
Contact Us
This Policy applies to the personal information that we collect or receive related to:
Our sites and services, includinghttps://www.2wai.ai/ (the “Site”), the 2wai mobile application (“App”), and the 2wai HoloAvatar (collectively, all of these are the “2wai Services” or the “Services”);
2wai events and programs and that we provide or sponsor;
Contests, sweepstakes and other promotions, as well as surveys and research, conducted or sponsored by 2wai;
Newsletters, reminders, updates, and other information and marketing communications that we send, including emails; and
Your communications and interactions with us related to our business, the 2wai Services, our Site and our App.
Not In Scope. This Privacy Policy does not apply to job applicants and candidates who apply for employment through our job application portal, or to employees and non-employee workers, whose personal information is subject to different privacy notices.
Your use of our Services, participation in any 2wai promotions or events, and communications and interactions with us, and any dispute over privacy, is subject to this Policy and our Terms of Use, including its applicable limitations on damages and the resolution of disputes. Our Terms of Use are incorporated by reference into this Policy.
In some cases, additional or supplemental privacy notices may be provided that apply to certain personal information collected and processed by us. If there is a conflict with this Policy, these additional or supplemental privacy notice will control, with respect to your personal information that is subject to that notice.
As further described below, we collect personal information directly from individuals, as well as from third parties and automatically related to the use of our Services or other interactions with us.
The personal information we collect from you depends upon how you use our Services or otherwise interact or engage with us, but generally includes:
Registration and profile information. If you create an account or profile with us or otherwise register for our Services or sign up for a subscription, we collect personal information from you, including name, email address, contact information, and other profile information you choose to provide (e.g., preferences).
Avatar interactions. If you interact with 2wai avatars, we may collect information about your interactions and conversations, such as your inquiries, who you interact with (i.e., your favorite stars, historical figures, and fictional characters), and past conversations and games played with avatars. If you create an avatar, we may collect information about your preferences, language, audio or video files, photo/image, voice, texts, comments, personalization, and other information you provide, and will obtain your consent where necessary.
Inferences: We may also draw inferences from the information described in this section, including inferences reflecting your preferences, characteristics, behavior, and abilities.
Payments and purchases. In order to process payments, we collect your name and payment details when you make a purchase. We also maintain records about your past purchases.
Other communications and interactions. When you otherwise communicate or interact with us, whether through the Site, Services, via email or otherwise, we collect and maintain a record of your contact details, contact preferences, communications, and our responses. Interactions may include when requesting a product demonstration or filling out a ‘Contact Us’ form, requesting additional information about our Services, signing up for our mailing lists, or otherwise providing us information through the Site or Services. We also maintain records of communications and information that you post on our social media channels, and information you provide to us related to any customer support requests. We also collect information that you provide us as feedback or submit to us through surveys, reviews, or other interactive features.
Sweepstakes, contests and promotions. If you participate in sweepstakes, contests and promotions that we offer, we will collect your name, age, email address, and other registration information related to contests, sweepstakes and promotions.
Programs, events and other requests. We also collect personal information related to your participation in our programs and events as well as other requests that you submit to us related to our Services. For example, if you register for an event through the Services, we may receive information about your participation and attendance. When you fill out a ‘Contact Us’ form, signup for our mailing lists, or otherwise request information from us, we collect and maintain records of your requests.
We automatically collect personal information related to your use of our Services and interactions with us and others, including information we collect automatically (e.g., using cookies and pixel tags), and we may we derive information about you and your use of the Services, including:
Device and browsing information. We use cookies, log files, pixel tags and other tracking technologies to automatically collect information when users access or use our website or other Services online, such as IP address, general location information, domain name, page views, a date/time stamp, browser type, device type, device ID, Internet service provider, referring and exiting URLs, operating system, language, clickstream data, and similar device and usage information. For more information, seeSection 5. Cookies, Analytics and Targeting, below.
Activities and usage. We also collect activity information related to your use of the Services, such as information about the links clicked, searches, features used, items viewed, and time spent within the Services.
Location information. We may collect or derive location information about you, such as through your IP address. Further, with your permission, we may collect geolocation information from your device. You may turn off location data sharing through your device settings.
We collect information about you from other sources, such as public sources, partners, and other third parties. For example, we may collect information such as:
Business customers and partners. Our Services may be offered in conjunction with our business customers and/or partners where you’re a customer (i.e., retail stores, restaurants, amusement parks, media streaming channels, and other businesses). Our partners may share information with us so that we can provide you with our Services and make improvements. Please consult their respective privacy policies to learn more about their privacy practices.
Vendors and service providers. We outsource some of our operations to our service providers and vendors in order to provide and operate our Services. They may collect and provide us with IP address and unique identifiers.
Third-party accounts and third-party platforms. If you engage with us on third-party platforms (i.e., social media platforms) or choose to link your 2wai account to or log in to our Services with a third-party account (i.e., Google), we may collect personal information about you from that third-party platform or account. These third-party platforms and services control the information they collect and share about you. For information about how they may use and disclose your information, including any information you make public, please consult their respective privacy policies.
Lead information. We may receive lead and prospect information from third parties, about prospective business customers that may be interested in our Services. We may also engage with third parties to enhance or update our prospective customer information.
In general, we use personal information for the purposes set forth below.
Providing Services, Site, and support. To provide and operate our Site and Services, communicate with you about your use of the Site and Services, provide troubleshooting and technical support, respond to your inquiries and requests, process your payments, communicate with you, and for similar service and support purposes.
Communicating with you about the Services. For example, to send notices, updates, security alerts and other administrative messages. We may also send user surveys and questionnaires, such as for market research.
Analytics and improvement. To better understand how users access and use the Site and Services, and our other products and offerings, and for other research and analytical purposes, such as to evaluate and improve our services and business operations, to develop new services and features, and for internal quality control and training purposes.
Customization and personalization. To tailor content we may send or display on the Services, including to offer location customization and personalized help and instructions, and to otherwise personalize your experiences.
Marketing and promotional purposes. For marketing purposes, including to send you newsletters, updates, alerts, and promotional information we think may interest you, as well as to evaluate, measure, and improve our marketing.
Our advertising services. To promote our products and services on third-party websites or newsletters, as well as to measure and understand the reach and effectiveness of these ads and provide analytics and reporting to advertisers and ad partners.
Research and surveys. To administer surveys and questionnaires, such as for market research or member satisfaction purposes.
Rewards program. If you are part of our referral rewards program, we use your personal information in order to administer that program, including to send referrals to your friends and other new users upon your request.
General business operations. To consider and implement mergers, acquisitions, reorganizations, and other business transactions, and where necessary to the administration of our general business, accounting, recordkeeping, auditing, compliance, and legal functions.
Security and protection of rights. To protect the Services and our business operations, including to prevent and detect fraud, misuse and unauthorized activities, as well as where we believe necessary to investigate, prevent or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety or legal rights of any person or third party, or violations of our Terms of Use or this Policy.
Defending our legal rights. To manage and respond to actual and potential legal disputes and claims, and to otherwise establish, defend, or protect our legal rights or interests, including in the context of anticipated or actual litigation with users of our Site and/or Services or third parties.
Complying with legal obligations. To comply with the law or legal proceedings. For example, we may disclose information in response to subpoenas, court order, and other lawful requests by regulators and law enforcement, including responding to national security or law enforcement disclosure requirements.
We may disclose the information, including personal information, that we collect to others, as reasonably necessary for the purposes described above and as otherwise directed or authorized to by you, which may include:
Business customers and partners. To our business customers and/or partners so that we can provide our Services to you, including interactions with 2wai avatars, and make improvements.
Vendors and service providers. To vendors, service providers, contractors, or agents who process such information on our behalf, in order to provide services to us or perform functions on our
behalf, including for example, service providers, help desk, payment processors, analytics providers, consultants, auditors and legal counsel.
Affiliates and subsidiaries. To our affiliates or subsidiaries; however, if we do so, their use and disclosure of your personal information will be subject to this Policy.
Marketing, analytics, advertising and campaign management. We may disclose certain information that includes personal information to third-party ad network providers, sponsors and/or traffic measurement services, who may use this data to improve and measure the effectiveness of our ads and those of third parties. For more information,Section 5. Cookies, Analytics and Targeting, below.
Protecting rights and interests. To law enforcement and others where we believe doing so is necessary to protect the Services, our rights and property, or the rights, property and safety of others. For example, in order to (i) prevent, detect, investigate and respond to fraud, unauthorized activities and access, illegal activities, and misuse of the Services, (ii) situations involving potential threats to the health, safety or legal rights of any person or third party, or (iii) enforce, and detect, investigate and respond to violations of our Terms of Use. We may also disclose personal information, related to litigation and other legal claims or proceedings in which we are involved, as well as for our internal accounting, auditing, compliance, recordkeeping, and legal functions.
Legal compliance. To regulators, law enforcement and other third parties in order to comply with applicable legal or regulatory obligations, including as part of a judicial proceeding, in response to a subpoena, warrant, court order or other legal process, or as part of an investigation or request, whether formal or informal, from law enforcement or a government official.
We and our third-party providers use cookies, pixels, tags, scripts, log files, and other mechanisms to automatically collect browsing, activity, device, usage and similar information within our Services. We use this information to, for example, analyze and understand how users access, use and interact with our Services, to identify and resolve bugs and errors, and to assess secure, protect, optimize and improve the performance of our Services. In addition, some cookies and trackers allow us and third parties to track activity and usage data, provide targeted advertising, and measure and improve ad campaigns within the Services and on third party sites and services. We may also use pixel tags in HTML e-mails we send, to help us track e-mail response rates, identify when our e-mails are viewed, and track whether our e-mails are forwarded.
Additional information about the third-party cookies and trackers we may use and the choices you have about our use of cookies and other tracking tools within the Services, is provided below.
Third-Party analytics and tools. We use third-party tools, such as Google Analytics, which are operated by third-party companies. These third-party analytics companies may collect usage data (using cookies, pixels and similar tools) about our Services in order to provide us with reports and metrics that help us to evaluate usage of our Services and improve performance and user experiences. You can also download the Google Analytics Opt-out Browser Add-on to prevent their data from being used by Google Analytics at https://tools.google.com/dlpage/gaoptout.
Targeted advertising. As noted, we work with third parties, such as ad networks, channel partners, mobile ad networks, analytics and measurement services and others (“third-party ad companies”) to manage our advertising on third-party sites, mobile apps and online services. We may share certain information with these third-party ad companies, and we and them may use cookies, pixels tags, and other tools to collect usage and browsing information within our Services, as well as on third-party sites, apps and services, such as IP address, location information, device ID, cookie and advertising IDs, and other identifiers, as well as browsing information. We and these third-party ad companies use this information to provide you more relevant ads and content on third-party sites and apps, and to evaluate the success of such ads and content.
Additional choices. You can review or change your preferences for most cookies on our website as follows:
Industry ad choice programs. You can control how participating third-party ad companies use the information that they collect about your visits to our Sites and those of third parties, in order to display more relevant targeted advertising to you. For more information and to opt out of receiving targeted ads from participating third-party ad networks go to:
U.S. Users: https://aboutads.info/choices (Digital Advertising Alliance) (You can also download the DAA AppChoices tool in order to help control interest-based advertising on apps on your mobile device.)
Please note that opting out of participating ad networks does not opt you out of being served advertising. You may continue to receive generic or contextual ads on our Services. You may also continue to receive targeted ads on other websites, from companies that do not participate in the above programs.
Browser settings. If you wish to prevent cookies from tracking your activity on our website or visits across multiple websites, you can set your browser to block certain cookies or notify you when a cookie is set. The Help portion of the toolbar on most browsers will tell you how to prevent your device from accepting new cookies, how to have the browser notify you when you receive a new cookie, or how to disable cookies altogether. Visitors to our Site and Services who disable cookies will be able to browse the Site, but some features may not function.
Do-Not-Track. Currently, our systems do not recognize browser “do-not-track” requests. You may, however, disable certain tracking as discussed in this section (e.g., by disabling cookies); you also may opt out of targeted advertising as discussed above.
Users have several choices regarding their personal information and privacy preferences, as described in this section.
Account Profile. You can update much of the personal information we maintain about you, by logging into and updating your account profile.
Access to Phone Functionalities. Note that if you do not want the Services to have access to your phone’s camera, microphone, and/or photo album, you can disable the access when prompted or in the settings menu of your phone, but disabling access may result in the Services not working as intended and you will lose access to certain functionalities and features (such as creating animations from your movements or creating a character from a photo of you).
Marketing Communications. We may send periodic promotional emails to you. You may opt out of such communications by following the opt-out instructions contained in the email or emailing us at hello@2wai.ai. Please note that it may take up to ten (10) business days for us to process opt out requests. If you opt out of receiving promotional emails about recommendations or other information we think may interest you, we may still send you emails about your account or any Services you have requested or received from us.
Cookie and Targeted Advertising. As described in the “Cookies, Analytics and Targeting” section above, you can manage your preferences for cookies (including targeting cookies) on our Site and Services by adjusting your preferences.
For more information about our privacy practices and your privacy choices, you may contact us as set
forth in the ‘Contact Us’ section below.
Our Services may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy, but instead is governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites.
2wai is headquartered in the United States and has operations and service providers in the United States and throughout the world. As such, we and our service providers may transfer your personal information to, or access it in, jurisdictions (including the United States) that may not provide equivalent levels of data protection as your home jurisdiction. We will take steps to ensure that your personal information receives an adequate level of protection in the jurisdictions in which we process it, including through appropriate written data processing terms and/or data transfer agreements.
We have implemented safeguards and technical measures to protect the personal information that we have under our control from unauthorized access, use or disclosure. However, no data security measures can guarantee 100% security. You should take steps to protect against unauthorized access to your password, phone, and computer by, among other things, signing off after using a shared device.
As a general rule, we retain your personal information for as long as necessary to fulfill the purposes for which it was collected and is used by us, as stated in this Policy. Further, to the extent permitted by applicable law, we will retain and use your personal information as necessary to comply with our legal obligations, resolve disputes, maintain appropriate business records, and enforce our agreements.
We are committed to protecting the privacy of children who use our Site and Services. We do not knowingly collect personal information online from children that we know are under 13 years old. If we discover that a child under 13 has provided us with personal information in violation of applicable law, we will delete such information from our systems. If you’re a parent and you believe we have collected your child’s information in violation of applicable law, please contact us as set forth below, in Section 13. Contact Us.
This Policy is current as of the Effective Date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. We will post any changes to this Policy on our Site. If we make any changes to this Policy that materially affect our practices with regard to the personal information we have previously collected from you, we will endeavor to provide you with notice in advance of such change, such as via email or prominent notice on the Site.
If you have questions or concerns regarding the way in which your personal information is being processed or this Policy, please email us at hello@2wai.ai or reach out to 2wai using the contact information below:
8500 Burton Way, PH 803, Los Angeles, CA 90048, USA
© 2025 2wai, Inc.
Disclaimer: All people, brands and characters are shown for demonstration purposes only.
