Last updated: May 1, 2026
Contents
Timothy Schofield ("we," "us," or "our") respects your privacy and is committed to protecting it through this Privacy Policy ("Policy"). This Policy explains what information we collect, how we use and share it, and what rights you have when you install and/or use our mobile application "2nd Line App" (the "App"), which allows users to obtain a virtual (second) phone number and use it to make and receive calls, and send and receive text messages.
This Policy applies to all users of the App ("you," "User"). By downloading, installing, or using the App, you confirm that you have read, understood, and agree to this Policy. If you do not agree with this Policy, please do not use the App.
For the purposes of the EU General Data Protection Regulation ("GDPR"), we act as the data controller with respect to your personal data, unless otherwise stated.
We may receive limited information about you from our service providers (e.g., our telecom/messaging infrastructure provider, payment processor, or analytics providers) as necessary to operate the App.
We use the information described above to:
We do not sell your personal information to third parties.
Where the GDPR applies, we process your personal data on the following legal bases: (a) performance of a contract with you (providing the App's services); (b) compliance with a legal obligation; (c) our legitimate interests (e.g., fraud prevention, service improvement), balanced against your rights; and (d) your consent, where required (e.g., for certain analytics or marketing).
We share information only as described in this Policy, with the following categories of recipients:
| Entity name | Services performed | Entity HQ Location | Privacy Policy |
|---|---|---|---|
| Amazon Web Services, Inc. | Cloud hosting and data storage | U.S.A. | Link |
| Cloudflare, Inc. and its subsidiaries | Network security, content delivery, DDoS protection | U.S.A. | Link |
| Twilio Inc. | Cloud communications provider (call routing, SMS/MMS delivery, content monitoring for fraud/abuse prevention) | U.S.A. | Link |
| Apple Inc. | In-app purchase processing, app distribution, cloud storage (iOS devices) | U.S.A. | Link |
| RevenueCat, Inc. | Subscription and in-app purchase management | U.S.A. | Link |
| Amplitude Inc. | Analytics service provider | U.S.A. | Link |
| AppsFlyer Inc., AppsFlyer Ltd. and its affiliates | Analytics and marketing attribution service provider | U.S.A. / Israel | Link |
| Firebase (Google LLC) | Data storage, user authentication, analytics and crash reporting | U.S.A. | Link |
| Facebook (Meta Platforms, Inc.) | Analytics and marketing service provider | U.S.A. | Link |
| OpenAI, L.L.C. and its affiliates | AI-powered content management and moderation tool, used to help verify that message content complies with applicable laws and our messaging policies | U.S.A. | Link |
We require these providers to use your information only for the purposes we specify and to apply appropriate security measures. We are not responsible for the independent privacy practices of third parties, and we encourage you to review their privacy policies via the links above.
Note: "Entity HQ Location" refers to where each provider is legally established, not necessarily the physical location(s) where your data is actually processed or stored, which may involve servers in multiple countries. See Section 7 for information about international data transfers.
We may also disclose your information: (a) if required by law, subpoena, or legal process; (b) if we believe in good faith it is necessary to protect our rights, your safety, or the safety of others, or to investigate fraud or a violation of our Terms of Use; or (c) in connection with a merger, acquisition, or sale of assets, in which case you will be notified of any change in ownership or use of your personal information.
Because the App relies on Twilio Inc. and other third-party telecommunications infrastructure to deliver calls and messages, please note:
We operate internationally, and your information may be transferred to, stored in, and processed in countries other than your own, including countries that may not offer the same level of data protection. Where required, we implement appropriate safeguards (such as standard contractual clauses) to protect your information when it is transferred internationally.
The App is intended exclusively for legitimate person-to-person (P2P) communication. This includes personal conversations and an individual's own professional communication (e.g., discussing work matters with clients or colleagues). Any automated messaging, Application-to-Person (A2P) traffic, high-volume, or mass-marketing use of the App is strictly prohibited.
The App must not be used for any unlawful, fraudulent, or abusive purpose. By using the App, you represent and warrant that you will not use your virtual number, calls, or messages to commit or facilitate fraud, scams, phishing, identity theft, or impersonation; harass, threaten, stalk, or deceive any person; send unsolicited bulk messages; or violate any telecommunications, consumer protection, anti-fraud, or data protection law applicable in your jurisdiction or the recipient's jurisdiction.
We reserve the right to monitor your calling, messaging, and account activity to verify compliance with the rules below. The summaries in this Section are an integral part of this Policy and of our Terms of Use. Tap each heading to expand the detailed rules.
You agree not to use the App, including any number assigned to you, for fraudulent, abusive, or illicit calling activity. Prohibited practices include, without limitation:
To detect the practices above, we rely on internal quantitative thresholds, algorithms, and detection criteria ("Enforcement Metrics"). The specific values and logic of our Enforcement Metrics are confidential and will not be disclosed — publishing them would give bad-faith actors a roadmap to engineer abuse around our detection systems and would weaken our ability to protect good-faith users. By using the App, you acknowledge that the determination of a violation under this Section 8.2 is made at our sole discretion based on these confidential Enforcement Metrics.
Consequences. A violation of this Section typically results in the combined blocking of your account(s) and linked device(s), forfeiture of your assigned phone number(s), and termination of your calling and messaging functions. At our discretion, a first-time minor violation may instead receive a temporary suspension; any repeat violation results in the full enforcement response.
It is strictly prohibited to use a number obtained via the App to send messages containing, among other things:
This list is illustrative, not exhaustive. Because we rely on third-party messaging infrastructure, your messages must also comply with our providers' own acceptable-use policies (see Section 5 and Section 6), and all messages are subject to filtering regardless of whether you obtained the recipient's consent to send them.
Recipient consent. You must have the recipient's consent before messaging them. An inbound message from someone to you is itself proof of consent — but only for that conversation. Consent may also be implied by an existing relationship where the person gave you their number and took an action inviting contact (e.g., booking an appointment, placing an order), such as for confirmations, reminders, or one-time passcodes. For personal contacts, verbal consent is sufficient, provided the person has not indicated they don't want to hear from you.
No spoofing. You may not misrepresent your identity, or use your assigned number or message content in a way that leads a recipient to believe you are someone else.
If you believe your account was blocked in error, contact us via the details in Section 15 and we will review the matter.
You are personally and solely responsible for your use of the App and for any calls, messages, or other content you send or receive through it. We do not monitor, endorse, or take responsibility for the legality of your conduct. Violations of this Section may result in immediate suspension or termination of your access to the App, forfeiture of any unused balance or phone number, and disclosure of your information to law enforcement or affected third parties, without prior notice. Full details of prohibited use and your obligations are set out in our Terms of Use, which form an integral part of your agreement with us.
We retain your personal information for as long as necessary to provide the App's services and to comply with our legal, accounting, and fraud-prevention obligations. Certain records (e.g., transaction history, information related to suspected violations of Section 8) may be retained even after you delete your account, to the extent permitted or required by law.
Depending on your location, you may have the right to: (a) access the personal information we hold about you; (b) request correction of inaccurate information; (c) request deletion of your information; (d) object to or restrict certain processing; (e) request a copy of your data in a portable format; and (f) withdraw consent where processing is based on consent. Residents of California and other U.S. states with comprehensive privacy laws may have additional rights under applicable state law, including the right to know, delete, and opt out of certain sharing of personal information; we do not sell personal information.
To exercise any of these rights, contact us using the details in Section 15. We may need to verify your identity before processing your request, and we will respond within the time frame required by applicable law.
We implement reasonable technical and organizational measures designed to protect your information from unauthorized access, disclosure, alteration, or destruction. However, no method of transmission or storage is 100% secure, and we cannot guarantee absolute security. If we become aware of a security incident affecting your personal information, we will notify you as required by applicable law.
The App is not directed to, and must not be used by, anyone under the age of 18. We do not knowingly collect personal information from children under 18. If we learn that we have collected personal information from a child under 18 without appropriate consent, we will delete it promptly. If you believe a child has provided us with personal information, please contact us.
The App and any related web pages may use cookies, SDKs, or similar technologies for analytics and functionality purposes. You can manage tracking permissions through your device settings (e.g., iOS Settings → Privacy & Security → Tracking).
We may update this Policy from time to time. We will notify you of material changes by posting the updated Policy within the App or by other reasonable means, and will indicate the "Last updated" date above. Your continued use of the App after changes take effect constitutes acceptance of the updated Policy.
If you have questions about this Privacy Policy or wish to exercise your privacy rights, please contact us at: