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Privacy Policy

Last updated: July 24, 2026

This Privacy Policy explains how Hover Digital Inc. ("itwo," "we," "us," or "our"), a company incorporated in the Province of Ontario, Canada, collects, uses, discloses, and protects information when you interact with our SMS-based interactive story experiences, our website, and related services (collectively, the "Service"). We handle personal information in accordance with Canada's Personal Information Protection and Electronic Documents Act (PIPEDA) and, where applicable, Quebec's Act respecting the protection of personal information in the private sector (Law 25). We are the data controller for the purposes of the EU and UK General Data Protection Regulation (GDPR / UK GDPR) and a "business" for the purposes of the California Consumer Privacy Act (CCPA / CPRA).

1. Information We Collect

We collect the following categories of personal data:

  • Mobile phone number. When you text our published number, your mobile carrier transmits your phone number to us so we can reply.
  • SMS/MMS message content. The messages you send us as part of the story (text, emoji, images if any) and our replies to you.
  • Game state and progress. Which case you are playing, choices you have made, branch positions, and timestamps.
  • Technical metadata. Approximate carrier, country code, message delivery status, error codes, and rate-limiting information from our messaging provider.
  • Website data. IP address, browser/device type, pages viewed, referrer, and similar log data collected when you visit our website.
  • Optional contact info. Email address if you choose to subscribe to news of new cases, and any information you provide if you contact support.

We do not intentionally collect government identifiers, payment card data, precise geolocation, biometric data, or special categories of personal data (such as health, race, religion, or political opinions). Please do not send such information by text.

2. How and Why We Use Your Information

We use personal data for the following purposes, relying on the legal bases shown in brackets (GDPR/UK GDPR) and the equivalent grounds under PIPEDA and Quebec Law 25:

  • To deliver the interactive story, send replies, and remember your progress in a case [contract / performance of the service you requested].
  • To prevent abuse, fraud, spam, and security incidents, and to enforce our Terms [legitimate interests].
  • To measure aggregate engagement, debug, and improve the writing, pacing, and reliability of the Service [legitimate interests].
  • To send you transactional service messages required to operate the game (for example, "your case has expired") [contract].
  • To send you optional marketing messages about new cases, only if you have opted in [consent, withdrawable at any time].
  • To comply with legal obligations and respond to lawful requests [legal obligation].

We do not use your personal data for automated decision-making that produces legal or similarly significant effects, and we do not engage in profiling for advertising purposes.

3. SMS / Text Messaging Terms

Program name: The Cat's Meow, by itwo (Hover Digital Inc.). By texting our published phone number (for example, texting START to opt in), you consent to receive automated and non-automated SMS/MMS interactive story messages from itwo at the mobile number you used. Message and data rates may apply from your mobile carrier. Message frequency varies based on your choices within the story — approximately 100+ messages per case.

You can stop messages at any time by replying STOP, END, CANCEL, UNSUBSCRIBE, or QUIT. You can request help by replying HELP or emailing hello@hovergrp.com. We do not sell, rent, or share your mobile number, SMS opt-in data, or consent records with any third parties or affiliates for their marketing purposes. Mobile carriers are not liable for delayed or undelivered messages.

We rely on telecommunications providers (such as Twilio, Inc.) to deliver SMS. Your messages and number are processed by those providers under their own privacy terms, solely to deliver the Service. Our SMS practices are also designed to comply with Canada's Anti-Spam Legislation (CASL) for commercial electronic messages sent to recipients in Canada.

4. Who We Share Information With

We do not sell your personal data, and we do not "share" it for cross-context behavioral advertising as those terms are defined under California law. We disclose personal data only to:

  • Service providers / processors who help us operate the Service: SMS/MMS delivery (e.g., Twilio), cloud hosting, error monitoring, analytics, and email delivery for opt-in newsletters. These vendors are bound by written contracts limiting their use of your data to providing services to us.
  • Professional advisors (lawyers, accountants, auditors) when reasonably necessary.
  • Authorities or other parties where required by law, valid legal process, or to protect rights, safety, and the integrity of the Service.
  • A successor entity in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this Policy.

5. International Data Transfers

Hover Digital Inc. operates from Ontario, Canada, and our service providers are located in Canada, the United States, and the European Economic Area. Personal information about users in Canada (including Quebec) may therefore be stored or processed outside of the province or country in which it was collected, and may be accessible to foreign courts, law enforcement, or national security authorities under the laws of those jurisdictions.

Before transferring personal information outside of Canada, and in particular outside of Quebec, we conduct a privacy impact assessment as required under Quebec Law 25, and put in place written contractual protections requiring our vendors to provide a level of protection equivalent to that afforded under Canadian law. When personal data is transferred from the EEA, the United Kingdom, or Switzerland to a country that has not been deemed to provide an adequate level of protection, we rely on appropriate safeguards such as the European Commission's Standard Contractual Clauses (and the UK International Data Transfer Addendum where applicable), together with supplementary measures where necessary. A copy of the relevant safeguards is available on request via the contact details below.

6. Data Retention

We keep personal data only for as long as we need it for the purposes described in this Policy:

  • Active game state is kept while you are playing a case and for up to 90 days after the case ends, so you can resume.
  • SMS message logs are kept for up to 12 months for debugging, abuse prevention, and carrier compliance, then deleted or aggregated.
  • Marketing opt-in records are kept while your subscription is active and for up to 24 months after you unsubscribe, as proof of consent.
  • Records we are required to retain for legal, tax, or accounting purposes are kept for the period required by applicable law.

7. Your Rights (General)

Depending on where you live, you have some or all of the following rights:

  • Access a copy of the personal data we hold about you.
  • Correct inaccurate or incomplete personal data.
  • Delete your personal data ("right to erasure" / "right to delete").
  • Restrict or object to certain processing, including processing based on legitimate interests and direct marketing.
  • Data portability — receive your data in a structured, commonly used, machine-readable format.
  • Withdraw consent at any time where processing is based on consent (this does not affect prior processing).
  • Non-discrimination for exercising your privacy rights.

To exercise your rights, email hello@hovergrp.com. We may need to verify your identity by asking you to confirm the mobile number used in the Service. You may use an authorized agent where permitted by law. We will respond within the timeframes required by applicable law (generally 30 days under PIPEDA and Quebec Law 25, 30 days under GDPR, and 45 days under CCPA — each extendable once where the law allows).

8. Canadian Users (PIPEDA and Quebec Law 25)

If you are located in Canada, your personal information is protected under PIPEDA and, if you reside in Quebec, additionally under Law 25. In addition to the general rights above, you have the right to:

  • Access and request correction of the personal information we hold about you.
  • Be informed of the source of the information, the categories of third parties to which it has been disclosed, and the retention period.
  • (Quebec) Request that certain personal information be de-indexed or ceased to be disseminated where the criteria under Law 25 are met.
  • (Quebec) Receive computerized personal information you provided in a structured, commonly used technological format (data portability).
  • (Quebec) Be informed if a decision is based exclusively on automated processing, and to submit observations. As noted above, we do not currently make such decisions.
  • Withdraw consent to the collection, use, or disclosure of your personal information at any time, subject to legal or contractual restrictions and reasonable notice.

We have designated a Privacy Officer responsible for our compliance with PIPEDA and Quebec Law 25. You can reach the Privacy Officer at hello@hovergrp.com. If you are not satisfied with our response, you may file a complaint with the Office of the Privacy Commissioner of Canada (OPC) at priv.gc.ca, or, if you reside in Quebec, with the Commission d'accès à l'information du Québec (CAI) at cai.gouv.qc.ca. Residents of Alberta and British Columbia may also contact their provincial Information and Privacy Commissioners.

9. European Economic Area, United Kingdom, and Switzerland (GDPR)

If you are located in the EEA, the UK, or Switzerland, Hover Digital Inc. is the controller of your personal data. The legal bases we rely on are described in Section 2. In addition to the rights in Section 7, you have the right to lodge a complaint with your local supervisory authority — for example, your EU member state Data Protection Authority, the UK Information Commissioner's Office (ico.org.uk), or the Swiss Federal Data Protection and Information Commissioner (FDPIC).

We are not required to designate a representative under Article 27 of the GDPR because we do not offer the Service to EEA or UK data subjects on a regular basis, and our processing is unlikely to result in a risk to their rights and freedoms. If this changes, we will appoint a representative and update this Policy. In the meantime, please direct any GDPR enquiries to hello@hovergrp.com.

10. California Residents (CCPA / CPRA)

If you are a California resident, this section provides the disclosures required by the California Consumer Privacy Act, as amended by the CPRA. In the last 12 months, we have collected the following categories of personal information:

  • Identifiers: mobile phone number, IP address, device identifiers.
  • Customer records: optional email address for newsletter opt-ins.
  • Commercial information: which cases you have engaged with.
  • Internet or other electronic network activity: browser/device metadata, pages viewed, SMS delivery metadata.
  • Inferences: limited aggregate engagement metrics used to improve the Service.

We collect this information from you directly and from our service providers. We use it for the business purposes described in Section 2 and disclose it only to the categories of recipients described in Section 4.

We do not "sell" or "share" personal information as those terms are defined under the CCPA/CPRA, and we do not knowingly sell or share the personal information of consumers under 16. We do not use or disclose sensitive personal information for purposes that would trigger the right to limit under the CPRA.

As a California resident, you have the right to: (i) know what personal information we collect, use, and disclose; (ii) access and receive a portable copy; (iii) correct inaccurate personal information; (iv) delete personal information; (v) opt out of sale or sharing (not applicable here — we do neither); (vi) limit use of sensitive personal information (not applicable here); and (vii) be free from discrimination for exercising your rights. You may also submit requests through an authorized agent. To exercise these rights, email hello@hovergrp.com. California's "Shine the Light" law (Civil Code § 1798.83) — we do not disclose personal information to third parties for their own direct marketing purposes.

11. Security

We use administrative, technical, and physical safeguards designed to protect personal data, including encryption in transit (TLS), access controls, least-privilege production access, and logging. No system is perfectly secure, and we cannot guarantee absolute security. If we become aware of a confidentiality incident (Quebec Law 25) or personal data breach (GDPR / PIPEDA) posing a real risk of significant harm, we will notify you and the relevant authorities where required by law, including the Office of the Privacy Commissioner of Canada and the Commission d'accès à l'information du Québec.

12. Children

The Service is intended for adults. We do not knowingly collect personal data from children under 16 (or the equivalent minimum age in your jurisdiction — 13 in the United States under COPPA, 14 in Quebec). If you believe a child has provided us personal data, contact us and we will delete it.

13. Cookies and Analytics

Our website uses strictly necessary cookies and a small amount of privacy-friendly analytics to understand aggregate usage. We do not use advertising cookies or cross-site tracking. Where required (including under the EU ePrivacy Directive and Quebec Law 25), we will ask for your consent before setting non-essential cookies or activating tracking technologies, and you can change your preferences at any time in your browser.

14. Do Not Track / Global Privacy Control

Because we do not sell or share personal information or serve targeted advertising, we treat browser "Do Not Track" and Global Privacy Control signals as a confirmation of those defaults.

15. Changes to This Policy

We may update this Privacy Policy from time to time. If we make material changes, we will update the "Last updated" date and, where appropriate, notify you by SMS or email or via a notice on our website before the changes take effect.

16. Contact Us

Data controller: Hover Digital Inc.
Location: Ontario, Canada
Privacy Officer / General contact: hello@hovergrp.com

Canadian users may also contact the Office of the Privacy Commissioner of Canada or, in Quebec, the Commission d'accès à l'information du Québec. EEA/UK users may contact their local data protection authority. California residents may contact the California Privacy Protection Agency or the California Attorney General.