CoupleAI

Privacy Policy

Last updated 29 May 2026

This Privacy Policy (the “Policy”) describes the manner in which the operator of the CoupleAI mobile application (the “App”) and the website located at coupleai.link together with its associated subdomains (collectively, the “Website,” and together with the App, the “Service”) (such operator being referred to herein as the “Company,” “we,” “us,” or “our”) collects, receives, records, organizes, structures, stores, adapts, alters, retrieves, consults, uses, discloses, transmits, disseminates, aligns, combines, restricts, erases, or otherwise processes information that relates to an identified or identifiable natural person (“Personal Data”). This Policy is intended to satisfy, among other instruments, the transparency and notice obligations arising under Regulation (EU) 2016/679 (the “General Data Protection Regulation” or “GDPR”), the United Kingdom General Data Protection Regulation as incorporated into United Kingdom domestic law (the “UK GDPR”), the California Consumer Privacy Act of 2018 as amended by the California Privacy Rights Act of 2020 (collectively, the “CCPA”), and other applicable data protection and privacy laws, in each case to the extent such laws are applicable to the processing activities described herein. By accessing, downloading, installing, registering for, or otherwise using the Service, you acknowledge that you have read and understood this Policy in its entirety.

1. Introduction and Scope of Application

The purpose of this Policy is to provide a comprehensive, detailed, and exhaustive account of the categories of Personal Data that may be collected through your interaction with the Service, the purposes for which such Personal Data may be processed, the legal bases relied upon in respect of such processing where applicable, the categories of recipients to whom such Personal Data may be disclosed, the periods for which such Personal Data may be retained, the safeguards applied to international transfers of such Personal Data, and the rights that you may be entitled to exercise in relation to such Personal Data. This Policy applies to all individuals who interact with the Service in any capacity, including, without limitation, registered account holders, the partners with whom such account holders are paired within the App, prospective users who browse the Website, and any individual whose Personal Data is otherwise processed in connection with the operation, maintenance, improvement, or commercialization of the Service. This Policy should be read in conjunction with any supplementary or product-specific privacy notices, just-in-time disclosures, or consent prompts that we may present to you from time to time within the App, each of which forms part of, and is incorporated by reference into, this Policy.

2. Definitions and Interpretation

For the purposes of this Policy, the following terms shall have the meanings ascribed to them below, and cognate expressions shall be construed accordingly. The term “Personal Data” means any information relating to an identified or identifiable natural person. The term “Processing” means any operation or set of operations performed on Personal Data, whether or not by automated means. The term “Controller” means the natural or legal person that, alone or jointly with others, determines the purposes and means of the Processing of Personal Data, and for the purposes of this Policy the Controller is the Company. The term “Processor” and the term “Sub-Processor” mean a natural or legal person that Processes Personal Data on behalf of the Controller. The term “Call Content” means, collectively, the microphone audio captured during a voice or video call conducted through the App, the textual transcripts derived from such audio, and the analytical outputs, metrics, classifications, characterizations, and other derived data generated from such transcripts. The term “Insights” means the analytical outputs presented to users following a call, as further described in Section 5.4. Headings are included for convenience only and shall not affect the interpretation of this Policy.

3. Categories of Personal Data We Collect

In the course of providing the Service, we may collect, generate, derive, infer, or otherwise come to Process the following non-exhaustive categories and sub-categories of Personal Data. The precise categories of Personal Data Processed in respect of any particular individual will depend upon the manner in which that individual interacts with the Service and the features of the Service that that individual elects to use.

3.1 Identity and Account Data

When you create an account, we collect and Process the authentication identifier associated with the sign-in method that you elect to use, which may comprise an electronic mail address (in the case of sign-in mediated by Google or Apple), a telephone number together with a one-time verification code transmitted to that telephone number (in the case of telephone-based sign-in), and the unique account identifiers assigned to you by the relevant identity provider, including, as applicable, the Google account identifier and the Apple user identifier. We additionally generate and assign to your account a unique internal identifier for the purpose of distinguishing your account from other accounts within our systems. Where the identity provider makes available to us, and you have not restricted the disclosure of, your given name, family name, or both, we may collect and Process such name information.

3.2 Profile Data

We collect and Process the display name that you provide for presentation to yourself and to the partner with whom you are paired, the preferred language or locale setting that you select or that is inferred from your device configuration for the purpose of localizing the Service, and, where you elect to upload one, a profile photograph or avatar image, which is stored in our cloud object storage infrastructure. We additionally Process metadata associated with your profile, including timestamps recording when certain profile fields were last modified, for the purpose of enforcing reasonable rate limits on the alteration of such fields.

3.3 Partner and Pairing Data

The App is designed to be used by two individuals who are paired together as a couple. To facilitate such pairing, we generate a short alphanumeric pairing code and associate it with your account; when your prospective partner enters that pairing code, we establish a bidirectional association between the two accounts and Process the resulting linkage as Personal Data relating to both individuals. As a consequence of pairing, certain Personal Data relating to you, including your display name and the Insights derived from calls in which you participate, becomes accessible to your paired partner, and certain Personal Data relating to your partner becomes accessible to you.

3.4 Call Content Data

When you conduct a voice or video call through the App, we collect, generate, and Process Call Content as more particularly described in Section 5 below. Call Content includes the microphone audio of each participant, the textual transcript derived from that audio (including the words spoken, the attribution of utterances to individual participants, and the temporal positioning of utterances within the call), and the Insights derived from that transcript. We additionally Process metadata relating to each call, including the identifiers of the participants, the timestamps marking the commencement and conclusion of the call and of individual recording segments, the type of the call, the status and outcome of the call, the durations and storage references of recording segments, and records of in-call interactions such as the dismissal or selection of conversational prompt cards presented during the call.

3.5 Subscription and Transaction Data

Where you elect to purchase a subscription or other paid feature, we Process data relating to the status and lifecycle of that subscription, including the date and time at which the subscription was first activated, the date and time of the most recent renewal, the date and time of any cancellation, the date and time of any expiration, and a flag indicating whether the subscription is presently active. Such subscription transactions are processed by the operator of the relevant mobile application distribution platform (namely the Apple App Store or Google Play) and by our subscription-management service provider. We do not collect, receive, store, or otherwise Process your payment card number, your bank account details, or any equivalent financial instrument data, all of which are handled exclusively by the aforementioned platform operators.

3.6 Device, Technical, and Diagnostic Data

We collect and Process technical data relating to the device and software environment through which you access the Service, including the operating system and operating system version of your device, the model designation of your device, the unique token issued by the applicable push-notification transport for the purpose of delivering notifications to your device, a counter reflecting the number of undelivered or unread notifications, and diagnostic data relating to crashes, errors, exceptions, and performance characteristics of the App, which diagnostic data may include stack traces, the internal identifier associated with your account, and the version of the App in use at the time of the relevant event.

3.7 Support and Communications Data

Where you communicate with us, including by means of electronic mail directed to our support address, we Process the contents of such communications together with any Personal Data that you elect to include therein, for the purposes of responding to your inquiry, providing support, and maintaining a record of our correspondence.

3.8 Personal Data Concerning Other Individuals

By reason of the inherently interpersonal nature of the Service, Personal Data that you provide or generate may relate not only to you but also to your paired partner and, to the extent that the substance of your calls references third parties, to other identifiable individuals. You acknowledge and agree that you bear responsibility for ensuring that you have an appropriate basis for any Personal Data relating to other individuals that you introduce into the Service.

4. Sources From Which We Collect Personal Data

We collect Personal Data from the following sources: directly from you, when you provide it in the course of registering for, configuring, or using the Service; automatically, by means of the operation of the App and the Website, including the capture of Call Content and the collection of device and diagnostic data; from your paired partner, to the extent that your partner generates Personal Data that relates to you, including by participating in calls with you; and from third-party service providers, including identity providers that authenticate your sign-in and subscription-management providers that report the status of your subscription.

5. Call Recording, Transcription, and Automated Analysis

5.1 Recording of Call Audio

You acknowledge, understand, and agree that, when you commence or join a voice or video call through the App, the microphone audio of each participant to that call is captured, recorded, and stored. Recording is effected on a per-participant basis, such that each participant’s microphone audio is recorded as one or more discrete audio segments, and such recording commences upon the publication of a participant’s microphone audio stream within the call and continues for the duration of the call, subject to segmentation. For the avoidance of doubt, the video component of a video call is not recorded, retained, or stored; only the microphone audio is recorded. The recorded audio is transmitted to and stored within our cloud object storage infrastructure.

5.2 Transcription of Call Audio

The recorded audio described in Section 5.1 is subsequently submitted, by means of a time-limited access reference, to a third-party automated speech-to-text service provider for the purpose of generating a textual transcript of the spoken contents of the call. Such transcript includes the words spoken by each participant, the attribution of each utterance to the participant who spoke it, the temporal positioning of each utterance within the call timeline, and an automated determination of the language in which the call was conducted. The resulting transcript is stored within our cloud object storage infrastructure.

5.3 Automated Analysis and Generation of Insights

The transcript described in Section 5.2, together with the given names of the participants, is submitted to a third-party artificial-intelligence model provider for the purpose of generating the Insights described in Section 5.4. Certain analytical outputs are computed locally within our systems without recourse to such third-party provider, while others are generated by means of the third-party provider’s large language model. The Insights so generated are stored in association with the relevant call record within our database.

5.4 Categories of Insights Generated

The Insights generated from your Call Content may include, without limitation: quantitative speaking statistics, including per-participant word counts, proportions of speaking time, measures of silence, and comparative percentile rankings; enumerations of the words most frequently uttered by each participant; selections of purportedly humorous or otherwise notable quotations attributed to each participant together with their temporal context; characterizations of each participant’s personality, including trait-based mappings and narrative summaries; quantifications of conversational interruptions, including counts and a timeline of individual interruption events attributed to individual participants; relationship-oriented metrics, including assessments described in terms such as emotional intelligence, alignment of expressed affection, mutual respect, compatibility, and mutual understanding, in each case expressed as a score together with a comparative percentile ranking; and classifications described in terms of favorable and unfavorable behavioral indicators attributed to each participant. You acknowledge that such Insights constitute inferences and characterizations derived by automated means and may relate to intimate aspects of your conduct, disposition, and relationship.

5.5 Consent and Joint Participation

Calls conducted through the App necessarily involve two participants. By commencing or joining a call, each participant acknowledges and agrees, on that participant’s own behalf, to the recording, transcription, and analysis of that call as described in this Section 5, and acknowledges that the resulting Insights describe the shared conversation and are made accessible to both participants. You are responsible for ensuring that, in your jurisdiction and in the jurisdiction of your partner, the recording and analysis of the call as described herein is permissible, including where the consent of all parties to a communication is required by applicable law.

5.6 Storage and Location of Call Content

Call Content, comprising audio recordings, transcripts, and Insights, is stored within cloud infrastructure operated by our hosting and storage service providers, which infrastructure may be located in, and accessible from, jurisdictions outside your country of residence, including the United States.

6. Purposes of Processing and Legal Bases

We Process Personal Data for the following purposes and, where the GDPR or the UK GDPR is applicable, in reliance upon the following legal bases. We Process identity, account, profile, partner, and Call Content data for the purpose of providing the Service to you, including the core functionality of conducting calls and generating Insights, in reliance upon the necessity of such Processing for the performance of a contract to which you are party. We Process device, technical, and diagnostic data, and we Process Personal Data for the purposes of securing the Service, preventing fraud and abuse, diagnosing and remedying defects, and improving the Service, in reliance upon our legitimate interests in operating, securing, and improving a reliable Service, save where such interests are overridden by your interests or fundamental rights and freedoms. We Process Personal Data to the extent necessary for the purpose of complying with legal obligations to which we are subject, in reliance upon the necessity of such Processing for compliance with a legal obligation. Where we rely upon your consent in respect of any particular Processing activity, you may withdraw that consent at any time, without affecting the lawfulness of Processing carried out prior to such withdrawal.

7. Sub-Processors and Third-Party Service Providers

We engage the following categories of third-party service providers, each of which Processes Personal Data on our behalf or receives Personal Data from us, in each case for the limited purposes described, and each of which is, where required, engaged under contractual terms imposing appropriate obligations of confidentiality and data protection:

8. Disclosures of Personal Data to Third Parties

We do not sell your Personal Data, and we do not share your Personal Data for purposes of cross-context behavioral advertising. We may disclose Personal Data to the categories of service providers described in Section 7; to your paired partner, to the extent inherent in the operation of the Service; to professional advisers, auditors, and insurers; to a successor entity in connection with a merger, acquisition, reorganization, or sale of assets; and to governmental authorities, courts, or other third parties where we believe in good faith that such disclosure is necessary to comply with a legal obligation, to respond to lawful requests, or to protect the rights, property, or safety of the Company, our users, or others.

9. International Transfers of Personal Data

The service providers described in Section 7 may Process Personal Data in jurisdictions other than your jurisdiction of residence, including the United States. Where we transfer Personal Data originating in the European Economic Area, the United Kingdom, or Switzerland to a jurisdiction that has not been the subject of an adequacy decision, we rely upon appropriate safeguards for such transfers, which may include the Standard Contractual Clauses approved by the European Commission and, as applicable, the United Kingdom International Data Transfer Addendum.

10. Data Retention and Account Deletion

We retain Personal Data for such period as is necessary to fulfill the purposes for which it was collected, including for the purposes of providing the Service, complying with our legal obligations, resolving disputes, and enforcing our agreements. You may initiate the deletion of your account at any time by means of the account-deletion function available within the settings of the App. Upon your initiation of account deletion, we will delete your profile data, your profile photograph, your subscription-status record, and your authentication credentials, and we will dissolve the pairing between your account and that of your partner. You acknowledge and agree that records relating to your past calls, including the associated audio recordings, transcripts, and Insights, are retained following the deletion of your account and are not automatically deleted by the account-deletion function. Should you wish for such call-related records also to be deleted, you may submit a request to that effect to the contact address set out in Section 19, and we will give effect to such request subject to any overriding retention obligation to which we are subject.

11. Information Security

We implement and maintain technical and organizational measures designed to protect Personal Data against accidental or unlawful destruction, loss, alteration, unauthorized disclosure, or unauthorized access, including the encryption of Personal Data in transit and the storage of Personal Data with established cloud-infrastructure providers. Notwithstanding the foregoing, no method of transmission over the internet and no method of electronic storage is perfectly secure, and we are therefore unable to guarantee the absolute security of Personal Data.

12. Your Privacy Rights

12.1 Rights Available to Users Generally

Subject to the conditions and limitations prescribed by applicable law, you may have the right to request access to the Personal Data that we Process concerning you, to request the rectification of inaccurate Personal Data, to request the erasure of your Personal Data, and to request that we provide you with a copy of certain of your Personal Data.

12.2 Rights of Individuals in the European Economic Area, the United Kingdom, and Switzerland

If you are located in the European Economic Area, the United Kingdom, or Switzerland, you may additionally have the right to restrict our Processing of your Personal Data, the right to object to Processing carried out in reliance upon our legitimate interests, the right to data portability, the right to withdraw consent where Processing is based upon consent, and the right to lodge a complaint with a supervisory authority, in particular in the Member State or country of your habitual residence, place of work, or place of the alleged infringement.

12.3 Rights of California Residents

If you are a resident of the State of California, you may have the right to know the categories and specific pieces of Personal Data we have collected about you, the categories of sources, the business or commercial purposes for collection, and the categories of third parties to whom Personal Data is disclosed; the right to request deletion of your Personal Data; the right to correct inaccurate Personal Data; and the right not to receive discriminatory treatment for the exercise of your rights. We do not sell or share Personal Data within the meaning of the CCPA.

12.4 How to Exercise Your Rights

You may exercise the rights described in this Section 12 by submitting a request to the contact address set out in Section 19. We may be required to verify your identity before giving effect to your request. You may be entitled to use an authorized agent to submit a request on your behalf, subject to our verification of the agent’s authority.

13. Sensitive Personal Information

You acknowledge that the contents of your communications, including the audio recordings and transcripts of your calls, and the Insights derived therefrom, may constitute sensitive Personal Data or sensitive personal information within the meaning of applicable law. We Process such information solely for the purpose of providing the Service to you, namely the generation and presentation of Insights, and not for the purpose of inferring characteristics about you for any incompatible purpose.

14. Automated Decision-Making and Profiling

The generation of Insights involves the automated analysis of your Call Content and the production of inferences, characterizations, and profiles concerning you and your relationship, as described in Section 5.4. Such automated analysis is undertaken for the purpose of providing the analytical features of the Service and does not produce legal effects concerning you or similarly significantly affect you. The Insights are provided for informational and entertainment purposes and ought not to be relied upon as professional advice of any kind.

15. Children’s Privacy

The Service is intended for, and may be used only by, individuals who are at least eighteen (18) years of age. The Service is not directed to children, and we do not knowingly collect Personal Data from any individual under the age of eighteen. If we become aware that we have collected Personal Data from an individual under the age of eighteen, we will take reasonable steps to delete such Personal Data.

16. Cookies, Analytics, and the Website

The Website does not deploy advertising cookies, analytics cookies, or third-party tracking technologies. A funnel subdomain associated with the Website performs a device-aware redirection to the appropriate application distribution platform by reference to the user-agent string transmitted by your browser; such redirection is performed transiently and the user-agent string is not retained for this purpose. The analytics and crash-reporting functionality described elsewhere in this Policy pertains to the App rather than to the Website.

17. Third-Party Links and Services

The Service may contain links to, or interoperate with, third-party websites, applications, or services that are not operated or controlled by us. This Policy does not apply to such third-party websites, applications, or services, and we are not responsible for their privacy practices. We encourage you to review the privacy policies of any such third party.

18. Changes to This Privacy Policy

We may amend, revise, supplement, or otherwise modify this Policy from time to time. Where we make a material change to this Policy, we will update the “Last updated” date set out at the head of this Policy and, where appropriate, provide additional notice within the App or by other means. Your continued use of the Service following the effective date of any such modification constitutes your acknowledgment of the modified Policy.

19. How to Contact Us

The Controller responsible for the Processing of Personal Data described in this Policy may be contacted as follows:

Attention: Iman Modarressi
2261 Market Street, STE 35679
San Francisco, CA 94114, United States of America
Electronic mail: support@coupleai.link

This Policy, and any non-contractual obligations arising out of or in connection with it, are governed by the laws of the State of California, United States of America, without regard to its conflict-of-laws principles, save to the extent that the mandatory data protection laws of your jurisdiction of residence apply.

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