Privacy Policy for DEUX

DRAFT, NOT YET PUBLISHABLE. Written 2026-10-09 from the app's real data flows (see CLAIMS_LEDGER.md for the proof behind each statement), using a legal-template skill for structure and a review of how comparable apps (couples, sexual-wellness and sex-tech) cover the same topics. Not legal advice. DEUX handles information about people's sex lives, which many laws treat as sensitive: have a privacy lawyer read this before launch (LAWYER_PACKET.md lists the exact questions). Replace every [PLACEHOLDER]; the site builder refuses to publish while any remain.

Effective date: [EFFECTIVE_DATE] · Last updated: [EFFECTIVE_DATE] · Policy version: 1

Elena Rudinski ("we", "us") makes DEUX, an app for couples. This policy explains what we collect, why, who can see it, how long we keep it, and what you can do about it, wherever you live. Section 12 adds details for the places where DEUX is offered. If anything is unclear, write to support@letsdeux.com.

The short version. DEUX stores private information about your relationship and your intimate life. We use it only to run the app for you and your partner. We do not sell it, we do not run advertising, we do not track you across other apps or websites, we do not use analytics, and we do not use your information to train AI models. If you link a partner, the two of you can see certain things about each other (section 4). You can export your data and delete your account inside the app at any time.

1. Who is responsible for your information

Elena Rudinski, support@letsdeux.com, support@letsdeux.com, is the controller of the information described here. Representatives for people in specific regions are named in section 12 where the law requires one.

2. Information we collect

Information you give us

• Account: your email address and a password (the password is handled by our authentication provider and stored only in hashed form; we cannot read it). When you sign up you confirm that you are 18 or older and that you consent to this policy; we keep the time of each confirmation and the policy version.
• Profile: the names you enter for yourself and your partner; your anniversary date and how long you have been together, if you choose to enter them; your preferred moods and difficulty.
• Your settings: choices that shape your sessions, for example which furniture you have, effort limits, physical abilities, face-to-face and oral preferences, who leads, and similar. These describe your sexual activity, so we treat them as sensitive.
• Your sessions: which positions you played, when, for how long, your ratings, achievements, XP and streaks.
• Your notes: the private notes you write about a session.
• Your lists: bookmark lists you create and the positions you save in them.
• Your partner link: a one-time pairing code, any pairing request, and whether you and another account are linked.
• Purchases: whether you hold an active subscription.
• Feedback you send in the app: the message you write in Profile > Send feedback, the kind you choose (idea, question, something broke, other), the optional email address you give for a reply, and your app version and phone platform. It is stored with your account, only we can read it (it is never shown to your partner; it is emailed to us through Resend), and we use it to answer you and to improve the app. It is user content you write yourself, so please do not put passwords or things you would not want us to read in it.
• Support: if you email us, your email address and your message.

Information our systems record automatically. When the app talks to our servers, our hosting provider's logs record your IP address, the time, which function was called and basic device and app-version information. We use this for security and fixing faults and keep it for 7 days days. Our email provider records delivery of sign-in and reset emails.

Information that stays on your phone. Your profile photo, if you choose one, is stored only on your device. Some settings, a copy of your session state and (if you turn them on) your reminder choices are also stored on your device so the app works offline. Reminders are scheduled on your phone only; nothing about them is sent to us.

Information we do not collect. We do not collect your location, contacts, microphone or camera recordings, or advertising identifiers. We do not use analytics or advertising SDKs. [IF CRASH REPORTING IS ADDED, SAY SO HERE: what it records and that it is stripped of your identity.]

3. Why we use it, and our legal bases

Automated personalization. DEUX builds suggested sessions automatically from your settings and ratings. This has no legal or similarly significant effect on you, uses no AI model trained on your information, and you can change the result at any time.

We do not sell your information, share it for advertising, build advertising profiles, share it with researchers or universities, or give it to data brokers. We do not make decisions with legal effects about you by automated means.

Consent and withdrawing it. The intimate information you enter is used only because you chose to enter it. You can withdraw consent at any time by deleting the settings, notes or lists concerned, unlinking your partner, or deleting your account (Settings > Delete account). Withdrawing does not affect what we did before.

4. Who can see your information

Your partner. If you link with a partner, each of you can see the other's profile names, session history, ratings, settings and (under the rule below) notes. Linking only happens after the person who created the pairing code approves the request, and either of you can unlink at any time in Profile (the other person is not asked). After unlinking you can no longer see each other's data; anything already exported or screenshotted stays with the person who has it.

• Notes: a note you write is private to you until both of you have written a note on that session; then each can read the other's. [CONFIRM AFTER THE NOTES CHANGE: today notes are stored on our servers in a form we can technically access; see section 9.]

Our service providers, who process data for us and only for that purpose, under written terms:

Legal and safety. We may disclose information if the law requires it, or to protect people's safety or our rights. When we receive a legal request we ask for valid legal process, give only what it requires, and tell you unless the law forbids us to. [LAWYER: confirm this wording and add your law-enforcement-request process.]

Business changes. If we are sold or merge, your information may transfer to the new owner under the same promises; we will tell you first.

5. Where your information goes (international transfers)

Our servers and our providers' systems are in the United States, so if you use DEUX from another country your information is transferred to, and stored in, the United States, which may have different data-protection law from your country. Where the law requires safeguards, we rely on the provider's data-processing agreement with the European Commission's standard contractual clauses and the UK and Swiss addenda, and/or the provider's certification under the EU-US Data Privacy Framework (with its UK and Swiss extensions). [CONFIRM for each provider: Supabase, RevenueCat, Resend, the email provider; keep their signed data-processing agreements on file.] Authorities in the United States can in some circumstances demand access to data held there.

6. How it is protected

• Online data is sent over encrypted connections (HTTPS/TLS) and encrypted at rest by our hosting provider. Each account can read only its own rows, plus what your linked partner shares as described above; this is enforced in the database. [GATE: publish only after scripts/rlsCheck.js passes.]
• On your phone, data is protected by your device's own passcode and encryption. [ONLY SAY MORE ONCE APP LOCK AND KEYCHAIN STORAGE SHIP.]
• Access to our systems is limited to Elena Rudinski and is protected by two-factor sign-in. [GATE: turn on two-factor sign-in on the Supabase, Apple, Expo and RevenueCat accounts before publishing.]
• To report a security problem, email support@letsdeux.com. We welcome reports and will not take action against good-faith research.
• No system is perfectly secure. If a breach affects your information we will tell you, and the authorities, as the law requires and without unreasonable delay.

7. How long we keep it

8. Your choices and rights

Everywhere, you can: see and change your profile and settings in the app; export your data (Settings > Export my profile); delete your account and data (Settings > Delete account); unlink your partner; turn off reminders; and remove the profile photo.

To use any other right (access, correction, deletion, a copy, restriction, objection, withdrawing consent, or a question), write to support@letsdeux.com from the address on your account. We may need to confirm it is really you (for example by asking you to reply from, or sign in with, that account). You may use an authorized agent; we will ask for proof they are authorized. Timing: we answer within 30 days (45 days where US state law allows, one month under UK/EU law), and tell you in writing if we need longer. If we decline a request you can appeal by replying with the word "appeal"; we answer within 60 days and tell you how to contact your regulator (section 12).

9. Things we want to be upfront about

• Your partner sees a lot by default (section 4). If that is not what you want, do not link, or unlink.
• Notes between partners are currently stored in a form we could technically read. [UPDATE WHEN END-TO-END ENCRYPTION OF NOTES SHIPS.]
• If you use the export feature, the file contains your history in plain text. You decide where to send it; once it leaves DEUX it is outside our control.
• Anyone who unlocks your phone may be able to open DEUX unless you use [APP LOCK, when available] and your device passcode.

10. If you do not feel safe

DEUX is meant for people who choose to use it together. If a partner link, or anything about this app, makes you feel unsafe or pressured: you can unlink at any time in Profile (the other person is not asked), delete your account in Settings, and nothing about leaving requires their agreement. If you are in immediate danger call your local emergency number. In the United States the National Domestic Violence Hotline is 1-800-799-7233 (or text START to 88788).

11. Age

DEUX is for adults. You must be 18 or older (or the higher age of majority where you live). We do not knowingly collect information from anyone under 18; we do not sell or share anyone's information, including anyone under 16. If we learn we hold a minor's information we delete it. If you think a minor has an account, email support@letsdeux.com.

12. Region-specific information

Where the law of your place gives you more than the rest of this policy, you get the more protective rule.

12.1 United States

Washington and Nevada (consumer health data). Because DEUX handles information about sexual activity, we publish a separate Consumer Health Data Privacy Notice at https://legal.letsdeux.com/health-data-privacy.html; read it with this policy.

California, Colorado, Connecticut, Virginia, Texas, Utah, Oregon and other states. In the last 12 months we collected these categories (we do not sell or share any of them, and nothing is collected from sources other than you and your linked partner's actions you can see):

You may have the right to know, access, correct, delete, get a portable copy, and opt out of sale, sharing or targeted advertising (we do none of these). We use sensitive personal information only to provide the service you requested, so the right to limit its use is already met. We do not discriminate against you for using your rights. Methods and timing: section 8 (45 days; appeal within the response, then your state attorney general where your state provides one).

12.2 Canada (including Quebec)

Our accountability for your personal information is held by Elena Rudinski (support@letsdeux.com), who you can ask about anything in this policy. Because information about your sex life is sensitive, we collect and use it only with your express consent, which you can withdraw (section 3). Your information is stored in the United States and may be accessible to US authorities under US law; for Quebec residents we carry out a written privacy-impact assessment before such a transfer [GATE: complete the assessment]. You may ask to access or correct your information and withdraw consent; we reply within 30 days. If a confidentiality incident presents a risk of serious harm we notify the affected people and the privacy regulator (Office of the Privacy Commissioner of Canada; in Quebec the Commission d'accès à l'information) and keep a register of incidents. Our personalization (section 3) is automated but has no legal effect; you can ask us to explain it or have it reviewed by a person. Complaints: the Office of the Privacy Commissioner of Canada (priv.gc.ca), the Commission d'accès à l'information du Québec (cai.gouv.qc.ca), or your provincial commissioner. DEUX is for adults; Quebec treats those under 14 as needing a parent's consent, so we do not accept anyone under 18.

12.3 United Kingdom

For UK residents, UK GDPR and the Data Protection Act 2018 apply and our bases are in section 3 (explicit consent for the intimate information, Art. 9(2)(a)). Our UK representative is [UK_REPRESENTATIVE_NAME_AND_ADDRESS]. Transfers to the United States use the UK addendum to the standard clauses or the UK Extension to the EU-US Data Privacy Framework. You have the rights to access, rectification, erasure, restriction, portability and objection, and to withdraw consent; we reply within one month. We use no non-essential cookies or similar technologies in the app (PECR). You can complain to the Information Commissioner's Office (ico.org.uk, 0303 123 1113).

12.4 European Economic Area

For EEA residents, the GDPR applies and our bases are in section 3 (explicit consent for the intimate information, Art. 9(2)(a)). Our EU representative is [EU_REPRESENTATIVE_NAME_AND_ADDRESS]. Transfers to the United States use the standard contractual clauses and/or the EU-US Data Privacy Framework (section 5). You have the rights to access, rectification, erasure, restriction, portability and objection, and to withdraw consent; we reply within one month. You can complain to your national data-protection supervisory authority. [LAWYER: confirm whether a data protection officer is required. GATE: complete the written data-protection impact assessment before opening the EEA, then say "this processing has been assessed in a data-protection impact assessment".]

12.5 Switzerland

For Swiss residents the revised Federal Act on Data Protection applies; we handle the intimate information only with your express consent. Our Swiss representative is [CH_REPRESENTATIVE_NAME_AND_ADDRESS]. Transfers to the United States rely on the standard clauses recognised in Switzerland and/or the Swiss-US Data Privacy Framework. You have the right of access, correction, deletion, restriction, portability and objection; we reply within 30 days. You can complain to the Federal Data Protection and Information Commissioner (edoeb.admin.ch).

12.6 Australia

For Australian residents the Privacy Act 1988 and the Australian Privacy Principles apply. Information about your sexual practices is "sensitive information" and we collect it only with your consent. Before sending your information overseas (to the United States) we take reasonable steps to make sure the recipient treats it consistently with the Principles. You can ask to access or correct your information; we reply within 30 days. We follow the Notifiable Data Breaches scheme and will notify you and the regulator of an eligible breach. You can complain to us first and then to the Office of the Australian Information Commissioner (oaic.gov.au). We send no marketing messages.

13. Changes

If we change this policy in a way that matters we will update the date and version above and tell you in the app before it takes effect; where the law requires fresh consent, we will ask for it.

14. Contact

Elena Rudinski · support@letsdeux.com · support@letsdeux.com · https://legal.letsdeux.com