Privacy Policy & Legal Disclaimer

SPrivacy Policy

Second Phone Number Operated by We Up LLC (“We Up,” “we,” “our,” or “us”)

Last Updated: July 3, 2026

1. Acceptance of This Policy

This Privacy Policy (“Policy”) explains how We Up LLC collects, uses, shares, retains, and protects information in connection with the Second Phone Number mobile application, any related websites, and all associated services (collectively, the “Service”).

You must read, understand, and accept this Policy before creating an account or using the Service. By downloading, accessing, registering for, or using the Service in any way, you expressly agree to this Policy in its entirety. If you do not agree to any part of this Policy, you must not access or use the Service, and you must uninstall the application and cease all use immediately.

Your continued use of the Service constitutes ongoing acceptance of this Policy as amended from time to time. This Policy applies to all users worldwide.

2. Definitions

“Service” means the Second Phone Number application and all features, numbers, messaging, calling, and related functionality we provide.
“User,” “you,” or “your” means any individual or entity that accesses or uses the Service.
“Second Number” or “Number” means any telephone number allocated, assigned, or made available to you through the Service.
“Content” means any message, call, text, media, or other material transmitted, sent, received, or generated by you through the Service.
“Prohibited Conduct” has the meaning given in Section 9.

3. Information We Collect

We are committed to collecting only the information reasonably necessary to operate the Service. We do not require you to provide an email address, a name, or any directly identifying personal details to create an account or use the Service.

Account identification:

Each user is identified by a unique account identifier assigned to the device through the Apple platform. We use this identifier to associate your account with your Second Number(s), manage your access to the Service, and enforce this Policy. We do not receive or store your name, email address, or Apple account credentials.

Payments:

We do not collect, receive, or store payment information. All purchases are made and processed entirely through the Apple platform using your own Apple payment method. Your payment details are handled solely by Apple in accordance with Apple’s terms and privacy policy, and are never provided to or accessible by us.

Information processed to deliver telecommunications features:

Telecom metadata, including originating and receiving phone numbers, message logs, call durations, timestamps, and routing information.
The Second Number(s) allocated to your account.

Information collected automatically:

Device and technical information, including IP address, device type, operating system, application version, crash logs, and performance metrics.
Usage information relating to how you interact with the Service, used to maintain security, detect abuse, and improve performance.

We do not require and do not collect government identification, biometric identifiers, or facial recognition data through the Service.

4. How We Use Information

We use the information we collect to:

Provide, operate, maintain, and secure the Service.
Allocate, manage, and reclaim Second Numbers.
Associate your account identifier with your access rights and manage your subscription status as reported by the Apple platform.
Respond to support requests you submit to us.
Monitor, detect, investigate, prevent, and address fraud, abuse, security incidents, and Prohibited Conduct.
Enforce this Policy and our applicable terms, including suspending or terminating accounts and reclaiming Numbers.
Analyze and improve the performance, reliability, and safety of the Service.
Comply with applicable law and respond to lawful requests from courts, regulators, or government or law-enforcement authorities.

5. Legal Bases for Processing

Where required by applicable data-protection law (including the EU and UK GDPR), we process personal information on the following legal bases:

Contractual necessity — to provide the Service you have requested.
Legal obligation — to comply with telecommunications, payment, tax, and other legal requirements.
Legitimate interests — to secure, protect, and improve the Service, prevent fraud and abuse, and defend our legal rights, provided such interests are not overridden by your rights.
Consent — where you have opted into specific optional communications or features.

6. How We Share Information

We do not sell or rent personal information, including your Second Number(s) or telecom metadata, and we do not share personal information for advertising or marketing purposes.

We may share information only in the following limited circumstances:

With trusted service providers and sub-processors that perform functions on our behalf (such as telecommunications routing, payment processing, cloud hosting, analytics, and crash reporting), strictly for the purpose of operating the Service and under obligations of confidentiality and data protection. A current list of the categories of our sub-processors is available on request.
With courts, regulators, or government or law-enforcement authorities, where we believe in good faith that disclosure is required by law, regulation, legal process, subpoena, or lawful request, or is necessary to protect our rights, safety, property, or the rights and safety of others.
In connection with a business transfer, such as a merger, acquisition, reorganization, financing, or sale of assets, subject to this Policy.
With your consent, or at your direction.

You acknowledge that we may be legally compelled to disclose certain information, and you agree that we shall not be liable for any disclosure made in good-faith compliance with a legal obligation or lawful request.

7. Data Retention

We retain personal information only for as long as necessary to provide the Service, comply with our legal obligations, resolve disputes, prevent fraud and abuse, and enforce this Policy. Telecom metadata and account records may be retained for the periods required by applicable telecommunications, financial, and legal-compliance requirements. When information is no longer required, we delete, anonymize, or otherwise render it inaccessible in accordance with applicable law.

Following account termination — including termination for Prohibited Conduct — we may retain certain information as reasonably necessary for legal, compliance, security, fraud-prevention, and record-keeping purposes.

8. Acceptable Use of the Service

The Service is provided solely for lawful personal and legitimate communications. As a condition of using the Service, you agree that you are solely and exclusively responsible for all activity conducted through your account and through any Second Number allocated to you.

You represent and warrant that you will use the Service only for lawful purposes and in full compliance with all applicable laws, regulations, telecommunications rules, and this Policy.

9. Prohibited Conduct

You are strictly prohibited from using the Service, directly or indirectly, for any of the following. This list is illustrative and not exhaustive:

Fraud, scams, phishing, “smishing,” identity theft, or any deceptive, misleading, or fraudulent activity of any kind.
Impersonating any person or entity, or misrepresenting your identity or affiliation.
Sending spam, bulk unsolicited messages, robocalls, or any communications that violate anti-spam or telemarketing laws.
Harassment, threats, intimidation, stalking, bullying, hate speech, or abusive conduct toward any person.
Transmitting or soliciting any unlawful, obscene, defamatory, or exploitative content, including any content that sexualizes, endangers, or harms minors.
Any activity that facilitates or constitutes illegal transactions, including the sale or trafficking of illegal goods, drugs, weapons, or stolen data.
Money laundering, terrorist financing, extortion, blackmail, or any financially motivated criminal activity.
Circumventing verification, security, or anti-abuse systems of any platform, service, or third party using a Second Number.
Attempting to gain unauthorized access to the Service, other users’ accounts, or any connected system; introducing malware; or interfering with or disrupting the integrity or performance of the Service.
Reselling, sublicensing, or commercially exploiting the Service or any Second Number without our express written authorization.
Any use that violates the rights of others, including privacy, publicity, intellectual-property, or contractual rights.
Any use that violates applicable law or exposes We Up LLC to legal liability or regulatory sanction.

10. Enforcement, Suspension, Termination, and Number Reclamation

We reserve the right, at our sole and absolute discretion and without prior notice or liability, to take any of the following actions where we suspect, detect, or determine that you have engaged in Prohibited Conduct, violated this Policy, or otherwise misused the Service:

Suspend, restrict, or permanently terminate your account and access to the Service.
Immediately revoke, reclaim, deactivate, and reassign any Second Number allocated to you, without refund.
Remove, block, or withhold any Content.
Retain and preserve relevant records for investigation, legal, and compliance purposes.
Report the activity to, and cooperate fully with, courts, regulators, and government or law-enforcement authorities.
Take any other action we deem necessary or appropriate to protect the Service, other users, third parties, and We Up LLC.

You acknowledge and agree that a Second Number is allocated to you on a temporary, non-ownership basis; you acquire no property right, title, or ownership interest in any Number, and any Number may be reclaimed or reassigned upon termination, expiration, non-payment, inactivity, or violation of this Policy. We are not liable for any loss, damage, or inconvenience resulting from the suspension, termination, or reclamation of your account or Number.

11. No Responsibility for User Conduct or Content

The Service is a neutral communications tool. You are exclusively responsible for all Content and all activity transmitted through your account or Number.

To the fullest extent permitted by law, We Up LLC:

Does not monitor, control, endorse, or assume any responsibility for any Content or conduct of any user.
Disclaims all responsibility and liability for any act, omission, communication, or conduct of any user of the Service, including any unlawful, fraudulent, harmful, or abusive activity.
Is not responsible for any harm, loss, or damage of any kind arising from your interactions or communications with any other person through the Service.

Any consequences arising from your use or misuse of the Service are your sole responsibility.

12. Indemnification

To the fullest extent permitted by law, you agree to defend, indemnify, and hold harmless We Up LLC and its owners, officers, employees, agents, affiliates, and service providers from and against any and all claims, demands, liabilities, damages, losses, costs, and expenses (including reasonable legal fees) arising out of or related to:

Your use or misuse of the Service;
Your violation of this Policy or any applicable law;
Your Content or any communication transmitted through your account or Number; or
Your infringement or violation of the rights of any third party.

This indemnification obligation survives the termination of your account and your use of the Service.

13. Disclaimer of Warranties

The Service is provided on an “AS IS” and “AS AVAILABLE” basis, without warranties of any kind. To the fullest extent permitted by law, We Up LLC disclaims all warranties, whether express, implied, statutory, or otherwise, including any implied warranties of merchantability, fitness for a particular purpose, title, non-infringement, and any warranties regarding availability, reliability, accuracy, security, or uninterrupted or error-free operation of the Service. We do not warrant that any Number will remain available, uninterrupted, or free from interference.

14. Security

We employ reasonable technical and organizational safeguards designed to protect information. However, no method of transmission or storage is completely secure, and we cannot and do not guarantee absolute security. We cannot guarantee protection against unauthorized access, hackers, third parties, governments, or other external threats. By using the Service, you acknowledge and accept these inherent risks and agree that we are not liable for any unauthorized access to or loss of information that occurs despite our reasonable safeguards.

15. Limitation of Liability

To the fullest extent permitted by applicable law:

In no event shall We Up LLC or its owners, officers, employees, agents, affiliates, or service providers be liable for any indirect, incidental, special, consequential, exemplary, or punitive damages, or for any loss of profits, revenue, data, goodwill, or other intangible losses, arising out of or related to the Service or this Policy, whether based in contract, tort, negligence, strict liability, or any other theory, even if advised of the possibility of such damages.
Our total aggregate liability arising out of or related to the Service or this Policy shall not exceed the greater of (a) the total amount you paid to us for the Service in the twelve (12) months immediately preceding the event giving rise to the claim, or (b) fifty U.S. dollars (USD $50).

Some jurisdictions do not allow certain limitations or exclusions of liability; in such jurisdictions, our liability is limited to the maximum extent permitted by law.

16. Assumption of Risk

You acknowledge that telecommunications services carry inherent risks, including exposure to unwanted communications, fraud attempts by other parties, and service interruptions. You knowingly and voluntarily assume all such risks associated with your use of the Service.

17. Children’s Privacy

The Service is not directed to and may not be used by children under the age of 13 (or under 16 where required by applicable law). We do not knowingly collect personal information from children. If we become aware that we have collected information from a child in violation of applicable law, we will take steps to delete it. A parent or guardian may contact us to request deletion.

18. International Data Transfers

We may process and store information on servers and with service providers located in the United States or other jurisdictions that may not provide the same level of data protection as your home country. Where required, we implement appropriate safeguards for such transfers. By using the Service, you consent to the transfer of your information as described in this Policy.

19. Your Rights

Depending on your jurisdiction, you may have the right to access, correct, delete, or port your personal information, to object to or restrict certain processing, and to withdraw consent. To exercise these rights, contact us at the address in Section 23. We will respond within the timeframe required by applicable law. We may need to verify your identity before acting on a request, and certain information may be retained where permitted or required by law.

20. No Sale or Sharing for Marketing

As required by certain privacy laws (including the California Consumer Privacy Act), we disclose that We Up LLC does not sell personal information and does not share personal information for cross-context behavioral advertising or marketing purposes. This includes your Second Number(s) and telecom metadata, which we never sell or share for marketing or advertising. Limited sharing with service providers and legal authorities, as described in Section 6, is conducted solely to operate the Service or to comply with law.

21. Dispute Resolution

The Service is offered globally and is not directed at or governed by the laws of any single country or territory. Where mandatory local laws apply to you, nothing in this Policy is intended to override rights that cannot lawfully be waived in your jurisdiction.

Before initiating any formal proceeding, you agree to first contact us and attempt in good faith to resolve any dispute, claim, or controversy arising out of or relating to this Policy or the Service through informal negotiation for a period of at least thirty (30) days.

If a dispute cannot be resolved informally, you agree that it shall be resolved on an individual basis through final and binding arbitration, conducted remotely where practicable, under internationally recognized arbitration rules, rather than in court. To the fullest extent permitted by applicable law, you waive any right to participate in a class action, class arbitration, collective, or representative proceeding, and any right to a jury trial. Any claim must be brought solely in your individual capacity.

These provisions apply to the maximum extent permitted by the mandatory laws applicable to you.

22. Changes to This Policy

We may update this Policy at any time. The revised Policy will be indicated by an updated “Last Updated” date. Where required by law, we will provide additional notice of material changes. Your continued use of the Service after any update constitutes your acceptance of the revised Policy.