Privacy policy.

Duoloft Digital is a Malaysian sole proprietorship that operates Duoloft (“Duoloft,” “we,” “us,” or “our”) at duoloft.com and through related applications, subdomains, and features (collectively, the “Service”). This Privacy Policy describes how we collect, use, disclose, and safeguard personal information when you visit our website, create an account, share a room with a partner, use early-access features, or otherwise interact with the Service.

By using the Service, you acknowledge that you have read and understood this Privacy Policy. Where required by law, we will ask for your consent before processing certain categories of data or using certain technologies.

This policy applies to personal information processed by the proprietor trading as Duoloft Digital in connection with the Service. It does not apply to third-party websites, applications, or services that we do not own or control, even when linked from the Service.

For users in the European Economic Area, the United Kingdom, and Switzerland, the proprietor trading as Duoloft Digital acts as the “controller” of personal information processed through the Service. For users in California, Duoloft Digital is the “business” that determines the purposes and means of processing.

3.1 Account & profile

When you create an account we collect identifiers from your sign-in provider (such as email address, name, and the provider user ID), and profile fields you choose to provide, including display name, date of birth, country, gender, and relationship details used to personalize the Service.

3.2 Room & partner data

We collect information needed to operate shared rooms: room slugs, invite links, partner connections, room customizations, and content you and your partner create inside a room, such as prompts, gifts, drawings, photos, songs, pet activity, and other interactive elements. Content created jointly with a partner is, by design, accessible to that partner.

3.3 Communications

When you contact support, submit feedback, reply to an email, or otherwise communicate with us, we collect the contents of those communications and associated metadata.

3.4 Billing & subscriptions

Duoloft does not currently offer paid subscriptions in this launch build. If paid billing is introduced later, payments may be processed through Stripe on the web and through the Apple App Store or Google Play in native mobile apps, with RevenueCat helping us verify mobile subscription status. Payment providers would collect payment card, Apple ID, Google Play, or other payment instrument details directly. We would receive limited identifiers and subscription details such as customer or transaction IDs, billing country, subscription status, plan, renewal dates, and invoice or purchase history. We do not store full payment card numbers on our servers.

3.5 Device, log & usage data

We automatically collect technical information when you use the Service, including IP address, approximate location derived from IP, browser type and version, operating system, device type and identifiers, language preference, referring and exit pages, timestamps, performance metrics (such as Web Vitals), and actions taken in the Service.

3.6 Marketing attribution

When you arrive from a marketing channel, we may collect attribution data such as UTM parameters, referrer URL, and ad-click identifiers passed by the originating platform, so we can understand which campaigns are effective.

3.7 Third-party integrations

If you choose to connect an optional third-party integration (for example, Spotify), we will receive the data you authorize that provider to share with us. You can disconnect those integrations at any time from your account settings.

3.8 Information we do not intentionally collect

We do not request government-issued ID, biometric identifiers, precise GPS location, contact lists, or health data. If you voluntarily place such information into free-form fields or uploads, it will be stored as content under your account.

• Directly from you when you sign up, complete your profile, or interact with the Service.
• From your partner, where they connect a room with you or invite you to one.
• Automatically from your device through cookies, local storage, and similar technologies.
• From service providers and integrations (sign-in providers, future billing providers such as Stripe, Apple, Google, and RevenueCat if paid billing is enabled, email delivery, analytics, advertising platforms, optional integrations you connect).

We use personal information for the following purposes:

• Provide the Service. Authenticate you, render your rooms, sync content with your partner, deliver requested features, and operate the application.
• Communications. Send transactional and service emails (account, future billing, security, room activity, requested reminders) and respond to your inquiries.
• Billing. If paid billing is enabled later, process subscriptions and refunds, prevent fraudulent charges, and meet tax and accounting obligations.
• Product analytics & improvement. Understand how the Service is used, diagnose issues, prioritize improvements, and measure feature performance.
• Safety, integrity & abuse prevention. Detect, investigate, and respond to violations of our Terms, fraud, abuse, or threats to the Service or its users.
• Marketing & measurement. Operate, attribute, and measure marketing campaigns; with your consent where required, deliver tailored marketing.
• Legal compliance. Comply with applicable law, lawful requests, court orders, audits, and enforce our agreements.

We do not use personal information to make decisions that produce legal or similarly significant effects about you without human involvement (see Automated decision-making).

If you are located in the European Economic Area, the United Kingdom, or Switzerland, we process personal information on one or more of the following legal bases under the GDPR / UK GDPR:

• Performance of a contract: to provide the Service you have signed up for, including authenticating you and syncing your rooms.
• Legitimate interests: to operate, secure, debug, analyze, and improve the Service; to prevent fraud and abuse; and to communicate non-marketing service messages. We balance these interests against your privacy rights.
• Consent: for optional analytics, non-essential cookies, session replay, marketing communications, and tailored advertising where required by local law. You may withdraw consent at any time.
• Legal obligation: to comply with tax, accounting, and other legal requirements.

We do not sell personal information for money. We disclose personal information in the following circumstances:

• With your partner. Content placed inside a shared room is, by design, visible to the partner you share that room with.
• Service providers (subprocessors). Vendors that host, store, process, deliver, secure, or analyze data on our behalf under written agreements. See Service providers.
• Payment processors. If paid billing is enabled later, Stripe, Apple, Google, and RevenueCat may process or verify payments and subscriptions under their own privacy policies.
• Analytics & advertising partners. See Advertising & measurement for the categories shared and how to opt out.
• Legal, safety & compliance. When we believe in good faith that disclosure is necessary to comply with law, lawful process, or government requests; to enforce our Terms; or to protect the rights, property, or safety of Duoloft, our users, or others.
• Corporate transactions. In connection with a merger, acquisition, financing, reorganization, bankruptcy, or sale of all or part of our assets, subject to standard confidentiality protections and notice where required.
• With your consent or at your direction. For any other purpose disclosed to you at the point of collection.

The following categories of providers receive personal information to help us run the Service. This list may change as the Service evolves; the categories below describe the function, not an exhaustive snapshot of any given day.

• Hosting & infrastructure: Vercel (application hosting, edge delivery).
• Database, storage & authentication: Supabase (Postgres database, object storage, authentication).
• Future payments & billing: Stripe, Apple App Store, Google Play, and RevenueCat, if paid billing is enabled later.
• Transactional email: Resend.
• Product analytics: PostHog (event analytics and, where enabled, session replay).
• Web performance: Vercel Analytics, Vercel Speed Insights, Web Vitals.
• Advertising & measurement: Google (Google Ads), Reddit (Reddit Ads), and similar platforms for campaign attribution and conversion measurement.
• Optional integrations you connect: e.g., Spotify, where you authorize access.
• Customer support: email correspondence tooling used by our team.

We require providers to use personal information only for the purposes for which we engaged them and to apply appropriate technical and organizational security measures.

We use cookies, local storage, session storage, and similar technologies to keep you signed in, remember preferences, maintain session state, secure the Service, measure performance, and understand product usage. Some are strictly necessary for the Service to function and cannot be turned off; others are used only with your consent where required by local law.

You can clear cookies and local storage at any time from your browser settings. Blocking strictly necessary cookies may prevent you from signing in or using core features.

We use a session-replay technology (rrweb, delivered through PostHog) to record interactions such as page navigations, clicks, scrolls, and viewport changes within the Service. This helps us reproduce bugs and improve usability. We configure session replay to mask text inputs by default and to avoid capturing payment fields, and we do not intentionally record payment details or full passwords. Replay data is retained for a limited period and used solely for product debugging and improvement. Where consent is required by local law, replay is activated only after consent is given.

We run marketing campaigns on platforms such as Google and Reddit. To measure whether those campaigns drive sign-ups and future subscriptions, we share limited information with those platforms: hashed identifiers, event identifiers, conversion values, and technical metadata. Under some U.S. state laws (including California’s CPRA), this kind of cross-context advertising activity is treated as “sharing” even where no money changes hands.

You can opt out of cross-context advertising and sharing for targeted advertising as described in California (CCPA/CPRA) and Other U.S. states. We also honor recognized opt-out signals such as the Global Privacy Control (GPC) when transmitted by your browser.

Duoloft is operated from Malaysia, and our service providers may process personal information in the United States and other countries. When we transfer personal information from the EEA, the UK, or Switzerland to a country that has not been found to provide an adequate level of protection, we rely on appropriate safeguards, including the European Commission’s Standard Contractual Clauses and, where applicable, the UK International Data Transfer Addendum and the Swiss equivalent. You may contact us to request more information about these safeguards.

We keep personal information only as long as needed for the purposes described in this policy. Typical retention periods:

• Account & profile: for the life of the account, then deleted or anonymized after account deletion, subject to legal holds.
• Room content: until you or your partner remove it, or the room or account is deleted.
• Future billing records: if paid billing is enabled later, for the period required by applicable tax, accounting, and anti-fraud laws (typically up to seven years).
• Logs, analytics & session replay: for a limited rolling window, typically not more than 24 months.
• Marketing attribution: for the period needed to attribute and measure the relevant campaigns.
• Support communications: for the period needed to resolve your inquiry and meet legal obligations.

When information is no longer needed, we delete or aggregate it so it can no longer be associated with you.

We use administrative, technical, and physical safeguards designed to protect personal information, including encryption in transit, access controls, infrastructure provided by security-certified vendors, and continuous monitoring. No method of transmission or storage is completely secure, and we cannot guarantee absolute security. You are responsible for keeping your sign-in credentials secure and notifying us promptly if you suspect unauthorized access to your account.

Subject to applicable law, you may:

• Access & export a copy of personal information we hold about you.
• Correct inaccurate or incomplete information from your profile, or by contacting us.
• Delete your account from in-app settings or by contacting us. Deletion removes or disconnects associated personal information, subject to legal holds and limited backups.
• Object to or restrict certain processing, including direct marketing.
• Withdraw consent where processing is based on consent, without affecting prior lawful processing.
• Opt out of marketing emails via the unsubscribe link in any marketing message; transactional and service messages will continue while your account is active.

To exercise any of these rights, email support@duoloft.com from the address associated with your account, or use in-app controls where available. We will respond within the time required by applicable law. We may need to verify your identity before fulfilling certain requests. We will not discriminate against you for exercising your privacy rights.

If you are a California resident, the California Consumer Privacy Act, as amended by the California Privacy Rights Act (collectively, “CCPA”), provides you with the following rights:

• Right to know the categories and specific pieces of personal information we collect, the sources, the business purposes, and the categories of recipients.
• Right to delete personal information we collect from you, subject to legal exceptions.
• Right to correct inaccurate personal information.
• Right to opt out of the “sale” or “sharing” of personal information for cross-context behavioral advertising.
• Right to limit the use and disclosure of sensitive personal information to the purposes permitted under the CCPA.
• Right to non-discrimination for exercising your CCPA rights.

Sale of personal information.We do not sell personal information for money. We do engage in “sharing” as defined by the CCPA when we use advertising and measurement partners that may process identifiers and interaction data for cross-context behavioral advertising. You can opt out of this sharing by emailing support@duoloft.com with the subject line “Do Not Sell or Share,” or by sending a Global Privacy Control (GPC) signal from your browser, which we honor.

Categories collected. In the last 12 months we have collected the following CCPA categories of personal information: identifiers; customer records; commercial information (future subscription/purchase history if paid billing is enabled); internet or other network activity; geolocation (approximate, from IP); inferences drawn from the foregoing; and limited sensitive personal information that you choose to provide (such as date of birth). We obtain these categories from the sources listed in Sources of information and disclose them for the business purposes listed in How we use information.

Authorized agents. You may designate an authorized agent to submit CCPA requests on your behalf. We will require written authorization and may require you to verify your identity directly.

Shine the Light.California Civil Code § 1798.83 permits California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. We do not disclose personal information to third parties for their own direct marketing purposes.

In addition to the rights described in Your rights, individuals in the EEA, UK, and Switzerland have the right to lodge a complaint with the data protection authority where they live or work, or where they believe an infringement has occurred. We encourage you to contact us first so we can address your concerns. We do not currently have an EU or UK representative under Article 27 GDPR given our scale; we will appoint one when required.

If you are a resident of a U.S. state that has enacted a comprehensive consumer privacy law (including Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Tennessee, Indiana, Delaware, New Hampshire, New Jersey, Maryland, Minnesota, Rhode Island, or Kentucky), you may have rights to access, correct, delete, obtain a portable copy of, and opt out of certain processing of your personal information, including targeted advertising and the sale of personal data. Nevada residents may submit a request that we not sell certain personal information under SB 220. You can exercise these rights by emailing support@duoloft.com. If we deny your request, you may appeal by replying to our response with the word “Appeal.”

The Service is intended for adults. It is not directed to anyone under 18, and we do not knowingly collect personal information from anyone under 18. Users confirm they are 18 or older when they complete their profile. If you believe a minor has provided personal information to us, please contact support@duoloft.com and we will take steps to delete it.

We do not use personal information to make decisions based solely on automated processing that produce legal or similarly significant effects about you. We may use automated systems for fraud and abuse detection, but human review is available where an account-level action is taken.

We do not respond to legacy “Do Not Track” browser signals, because no common interpretation has been finalized. We do honor the Global Privacy Control (GPC) as a valid request to opt out of the sale or sharing of personal information under the CCPA and equivalent state laws.

The Service may contain links to third-party websites, integrations, or media (for example, Spotify embeds). Their privacy practices are governed by their own policies. We are not responsible for the content or practices of third parties.

We may update this policy from time to time. If we make material changes, we will notify you by updating the “effective” date at the top of this page and, where required by law, by providing additional notice (for example, by email or an in-app notice). Your continued use of the Service after an update constitutes acceptance of the revised policy.

Questions, requests, or complaints about this policy or our privacy practices can be sent to:

support@duoloft.com

Duoloft Digital
Malaysian sole proprietorship
SSM Registration No. NS0326615-U

If you contact us about a privacy right or request, please tell us which jurisdiction’s law you are exercising rights under so we can route the request correctly.