21 Group โ Terms & Conditions and Privacy Notice
DRAFT โ this policy is still being finalized and has not had full legal review. Several sections below are explicitly marked as open items.
Scope
This notice covers 21 ID (21login.com), the shared account system for 21 Group. It applies to your account itself โ your name, login method, and which services you've activated. Once you activate an individual 21 Group service (e.g. 21finder, 21 Communicator), that service's own activity and data are governed by its own terms, which may be added separately as each service connects to 21 ID.
1. Your Account
1.1 Eligibility
OPEN ITEM: minimum age for creating an account is not yet set.
1.2 Signing in
You can create an account with an email address and password, or by signing in with your existing Google or Facebook account. Either way, you're issued a unique account number, which is what identifies you across every 21 Group service you choose to use.
1.3 Keeping your account secure
You're responsible for keeping your password confidential and for any activity that happens under your account. Tell us promptly if you believe your account has been accessed without your permission.
2. What We Collect
2.1 Provided directly by you
Full name, email address, and mobile number (mobile is optional)
Password (stored as a one-way cryptographic hash โ we cannot see or recover your actual password)
2.2 From Google or Facebook, only if you choose that sign-in method
Your name, email address, and profile photo, as provided by that platform
Confirmation that the platform has verified your email address
2.3 Collected automatically
IP address, and an approximate location derived from it (country, region, city โ not GPS-precise)
Device type (mobile, tablet, or desktop), inferred from your browser
Timestamps of each sign-in
2.4 Your preferences
Language preference
Whether you've opted in to be notified about new 21 Group services
2.5 What we deliberately do not collect
We do not currently collect age, gender, date of birth, relationship status, or similarly sensitive personal details as part of your 21 ID account. Individual services you activate may collect information relevant to that service specifically โ that data stays within that service and is not shared back into your core 21 ID profile.
3. How We Use This Information
To create, secure, and let you sign in to your account
To let you sign in to any 21 Group service you choose to activate, without creating a separate account for each one
To detect and prevent fraud, abuse, and unauthorized access
To send you service-related messages, and โ only if you've opted in โ a one-time notice when a new 21 Group service becomes available
4. Sharing Your Information
With a 21 Group service, only once you've actively chosen to open/activate it โ never automatically
With Google or Facebook, only in the technical sense required to complete sign-in if you choose that method
With ip-api.com, a third-party IP geolocation service, to approximate your location for security and mobile-number formatting purposes
We do not sell your personal information to anyone.
OPEN ITEM: an international data transfer note for Google/Facebook (US-based) may be needed here.
5. Cookies
A session cookie, needed for the site to function while you're actively using it
A "remember me" cookie, lasting up to 365 days, so you don't need to sign in again on a device you've already used โ this can be cleared by signing out
6. Data Retention
OPEN ITEM: no formal retention period is defined yet.
7. Your Rights
Subject to applicable law, you generally have the right to access, correct, or request deletion of your data, object to or restrict certain processing, receive your data in a portable format, and withdraw consent at any time where processing is based on consent.
OPEN ITEM: a contact method for exercising these rights needs to be added.
8. Security
Passwords are never stored in plain text. Long-lived login cookies use a rotating, hashed-token scheme so that a copied cookie stops working once the legitimate one is used again. All traffic to 21login.com is encrypted (HTTPS).
9. Changes to This Notice
We may update this notice as 21 ID and connected services evolve. Material changes will be highlighted rather than published silently.
10. Limitation of Liability
OPEN ITEM: needs to be drafted by counsel to be enforceable in your jurisdiction.