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Privacy policy

This English version is a complete translation of our German privacy policy. Both versions have the same content; in case of divergence, the German version serves as the reference for interpretation. This does not limit your rights under the GDPR.

Last updated: October 2026

1. Controller

ZUHÖRRAUM UG (haftungsbeschränkt)
c/o Michael Spitzenberger
Haushamer Straße 3
81547 München
Germany
represented by its managing director Michael Spitzenberger
E-mail: info@twomo.app

2. In brief

This website (twomo.app) provides information about our company and the app two mo. It sets no cookies and uses no analytics or tracking tools. Fonts, images and the product video are delivered from the same server as this website; no third-party content is loaded. The host is Netlify (see section 3). We only process personal data where this is technically necessary to deliver the website or when you write to us.

3. Hosting and server log files

This website is hosted by Netlify, Inc., San Francisco, USA. When a page is requested, Netlify automatically processes technically necessary data transmitted by your browser:

  • IP address
  • date and time of access
  • page requested and amount of data transferred
  • previously visited page (referrer)
  • browser and operating system

The purpose is the secure and stable delivery of the website. The legal basis is Art. 6(1)(f) GDPR; our legitimate interest lies in a functioning and secure website.

A data processing agreement pursuant to Art. 28 GDPR is in place with Netlify, Inc. (Netlify Data Processing Agreement, incorporated by reference into Netlify's terms). Netlify in turn uses sub-processors, among others for logging and security monitoring; Netlify publishes the current list in its Trust Center.

The transfer to the USA is based on the European Commission's adequacy decision for the EU-US Data Privacy Framework (Art. 45 GDPR); in addition, the European Commission's standard contractual clauses apply (Implementing Decision (EU) 2021/914, Art. 46(2)(c) GDPR). You can obtain a copy of these safeguards from us at info@twomo.app.

The log data is created solely at our hosting provider. We do not retrieve or analyse it. Netlify processes it only to deliver and secure the website and deletes it according to its own retention periods.

4. Contact by e-mail and early access requests

If you send us an e-mail, for example to request early access to the app, we process your e-mail address, your name (if provided) and the content of your message in order to handle your request and, where applicable, invite you to the testing phase. The legal basis is Art. 6(1)(b) GDPR, and Art. 6(1)(f) GDPR for other enquiries.

We operate our mailbox with Google Workspace; the processor pursuant to Art. 28 GDPR is Google Ireland Limited, Gordon House, Barrow Street, Dublin 4, Ireland. Processing by affiliated companies in the USA is possible; it is based on the EU-US Data Privacy Framework and, in addition, on the European Commission's standard contractual clauses.

We delete your data as soon as your request has been answered; for early access requests, no later than six months after the public launch of the app. Statutory retention obligations remain unaffected.

Providing your data is neither required by law nor by contract. Without your e-mail address, however, we cannot answer your request.

5. Links to other websites

This website contains simple links to external services (LinkedIn, Instagram, momohoertzu.de, momo.space and zuhoerraum.eu). Data is only transferred to these providers when you click a link. The privacy notices of the respective provider apply there.

On our contact page we link to the waiting list at momo.space. ZUHÖRRAUM UG (haftungsbeschränkt) is the controller there as well. The form is provided by our service provider Waitlister; details are in the privacy policy on momo.space. We use your details solely to inform you about the launch of two mo.

6. The two mo app

A separate privacy policy applies to the two mo app. It describes which data is processed during a MOMOLOG, which service providers are involved and in which regions processing takes place. It is available in the app.

7. Your rights

You have the right of access (Art. 15 GDPR), rectification (Art. 16), erasure (Art. 17), restriction of processing (Art. 18) and data portability (Art. 20). You can withdraw any consent you have given at any time with effect for the future (Art. 7(3)). Please write to info@twomo.app.

Right to object: Where we process data on the basis of legitimate interests (Art. 6(1)(f) GDPR), you may object at any time on grounds relating to your particular situation, informally to info@twomo.app.

Competent supervisory authority: Bayerisches Landesamt für Datenschutzaufsicht (BayLDA), Postfach 1349, 91504 Ansbach, Germany, www.lda.bayern.de. You may also contact the supervisory authority of your place of residence.

8. Encryption

This website is delivered exclusively via an encrypted connection (HTTPS/TLS).

9. No automated decision-making

No automated decision-making, including profiling, pursuant to Art. 22 GDPR takes place on this website.