Age Policy — Lounge & Co.

🚧 DRAFT — Pre-launch counsel review required. This document is a working draft authored 2026-05-22 as part of the pre-launch legal-doc cascade. Do not publish without counsel review. Counsel review paired with PRIVACY_POLICY_PLATFORM.md and MEMBER_TERMS_OF_SERVICE.md.

Effective: [PENDING LAUNCH DATE] · Last revised: 2026-05-22 (draft v1)

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1. About this Policy

This Age Policy describes how Lounge & Co., LLC (“Lounge & Co.”, “we”, “us”) verifies that every Member of the Lounge & Co. platform (the “Platform”) is at least 21 years of age, what data we collect during that verification, and what happens if a verification check fails or is later contradicted by evidence.

Lounge & Co. is a consumer network for premium tobacco and spirits venues — cigar lounges, whiskey bars, bourbon clubs, and craft spirits speakeasies. The Platform itself does not sell tobacco or alcohol products and does not facilitate any such sales (see Member Terms of Service §10 and BUSINESS_MODEL.md §0.1); the participating venues do, in their own physical premises, under their own licenses. The Platform’s audience is nevertheless restricted to verified 21+ adults because:

• The Platform’s content, recommendations, and concierge interactions are oriented around tobacco and spirits consumption.
• A consistent 21+ floor is a regulatory expectation in our vertical and a non-negotiable brand commitment.
• Our App Store framing, Section 230 posture, and member-trust narrative all depend on uniform adult verification.

This Policy is incorporated by reference into the Member Terms of Service and should be read together with the Platform Privacy Policy.

2. Minimum age requirement

You must be at least 21 years of age to create an account, post content, take a concierge turn, send a DM, or join any venue on the Platform. This 21+ floor applies globally to every Member, in every state, regardless of subscription tier.

Several U.S. states permit the consumption or purchase of tobacco or alcohol at ages below 21. The Platform’s 21+ floor is stricter than the legal minimum in some jurisdictions, intentionally. We apply a single uniform floor because:

• The federal Tobacco 21 standard set 21 as the nationwide tobacco minimum in 2019.
• A uniform floor avoids confusing state-by-state experience and reduces the risk of geofence-detection failures becoming compliance vectors.
• It matches the audience our venue partners expect to see on the Platform.

There is no “under-21 mode” of the Platform. There is no waitlist for under-21 prospective members. Accounts that cannot satisfy the 21+ verification check cannot be created.

3. How we verify age

Lounge & Co. uses Token of Trust as our identity + age-verification provider. Token of Trust is a sub-processor disclosed in the Platform Privacy Policy §4 and is bound by a data-processing agreement that restricts its use of your data to performing the verification check on our behalf.

When verification happens. Once, at account creation, before you can complete signup. A successful verification result is valid across every participating venue on the Platform thereafter — you do not re-verify each time you join a new venue.

What you submit to Token of Trust. You choose between two methods:

• ID-only: a photo of a government-issued identity document (driver’s license, state ID, passport).
• ID + selfie: the document above plus a one-time selfie used for face-geometry matching against the document photo.

The ID + selfie method is the higher-confidence path; ID-only is supported for members who decline the biometric step. Either method, on success, returns the same result to Lounge & Co.: a boolean confirmation that you are 21 or older, plus a verification reference ID.

Who pays for verification. Lounge & Co. absorbs the Token of Trust verification cost as customer-acquisition cost (CAC). Verification is not bundled into any venue’s subscription, is not passed through to participating venues, and is not billed to you. (See BUSINESS_MODEL.md §0.2.)

The verification step is described in more detail in the Platform Privacy Policy §11 (BIPA compliance), which governs the biometric portion of the ID + selfie path.

4. What we collect (and don’t)

Per the Platform Privacy Policy §2.1, Lounge & Co. collects:

• Token of Trust verification status — identity name + age, collected only to verify you are 21+; not retained in plain form beyond the verification check.

What Lounge & Co. retains long-term, after the verification check completes, is essentially a boolean flag indicating “this account passed the Token of Trust 21+ check” together with the verification reference ID returned by Token of Trust.

What Lounge & Co. does not store:

• Government-issued ID document images.
• Selfie images.
• Face-geometry biometric templates.
• Date of birth in plain form.

Those data categories are processed by Token of Trust under their own DPA with us. Per Platform Privacy Policy §11 and the Token of Trust sub-processor row in §4, Token of Trust retains the underlying ID + biometric data for no more than 30 days post-verification, after which it is purged on a contractual schedule. Only the long-term verification flag and reference ID remain with us.

Lounge & Co. does not sell, lease, trade, or otherwise profit from verification data, and does not disclose it to any third party except (i) Token of Trust as the processor performing verification, (ii) as required by law, or (iii) with your separate written consent.

5. Geographic scope

The Platform is currently available only in the United States (see BUSINESS_MODEL.md §11.4 and Platform Privacy Policy §8).

• Non-U.S. visitors hit a waitlist page at the Token of Trust gate at signup and cannot complete account creation.
• IP-based geofence detection runs at the verification step; precise GPS is not used.
• As we expand into new jurisdictions, re-verification may be required to confirm the 21+ floor under the new jurisdiction’s rules and to update our records.

If you relocate outside the United States after creating an account, you are required to notify us at the contact address in Member ToS §2. Continuing to use the Platform from outside the United States is not permitted.

6. What happens if verification fails

A “failure” means the Token of Trust check did not return a positive 21+ result — for example, an unreadable ID image, a face-match below the confidence threshold, or a returned age below 21.

• Re-attempts. You may retry the verification flow. Lounge & Co. does not cap re-attempts in advance, but persistent failures may trigger additional review.
• Verification-pending state. While verification has not yet returned a positive result, your account sits in a verification-pending state: you cannot post content, take a concierge turn, send a DM, or join a venue. You can complete the verification step at any time to leave this state.
• Appeal. If you believe a verification result is incorrect (for example, a document was misread or a face-match falsely rejected your selfie), you can contest the result via the appeal surface in the application. [Appeal route: surfaced in Settings → Account → Age verification — exact URL pending — placeholder.] Appeals are reviewed in coordination with Token of Trust’s verification-review process.
• Manual review. In a small number of cases — for example, valid identity documents that the automated reader cannot parse — Lounge & Co. or Token of Trust may request additional information for manual review. Manual review does not change the 21+ floor; it only re-runs the same check with human assistance.

A failed verification is not, by itself, a basis for permanent account suspension. A pattern of repeated failures combined with other signals (e.g., evidence of attempted bypass) may be.

7. Account suspension for misrepresentation

If Lounge & Co. discovers — through report, audit, sub-processor signal, or any other means — that a Member misrepresented their age at signup (for example, a person under 21 used another adult’s identity document, or a member’s documented date of birth contradicts other on-Platform evidence), the account is subject to immediate termination under the Member Terms of Service §11 and the Acceptable Use Policy §5.

• No refund. No refund is owed for any unused portion of a paid subscription on termination for misrepresentation of age.
• Member Content. Member Content posted by a terminated account is removed under our normal moderation cascade.
• Re-registration. A terminated account cannot be re-created using the same identity documents. Re-registration once the Member legitimately reaches 21 is at Lounge & Co.’s discretion and may be denied.
• Other consequences. Misrepresentation may also be referred to Token of Trust as fraud signal and may, where applicable law requires it, be reported to law enforcement.

8. Updates to this Policy

We may revise this Age Policy. Material revisions (changes to the minimum-age floor, the verification provider, the data categories collected, or the geographic scope) will be announced via in-app notification + email at least 30 days before they take effect. Non-material revisions (clarifications, formatting) take effect immediately with notice in the revision history below.

This 30-day-notice pattern matches the cadence used in the Member Terms of Service §17 and the Platform Privacy Policy §10.

9. Questions

• Age verification + appeals: [contact: legal@loungeco.lounge.app — placeholder pending real address]
• General privacy inquiries: see Platform Privacy Policy §12
• Legal: see Member Terms of Service §19

10. Revision history