Privacy Policy

Effective date: May 11, 2026 Last updated: May 11, 2026

This Privacy Policy explains how datasamy, Inc. ("datasamy," "Closer," "we," "us," or "our") collects, uses, shares, and protects information when you use the Closer mobile application and our website at https://closerapp.us (together, the "Service"). By creating an account or using the Service, you acknowledge that you have read and understood this Privacy Policy.

Quick summary. Closer is a couples app. You and your partner each have your own account, and you share the answers you write inside the app with each other once you've both responded. We collect the minimum data we need to run the product. We do not sell your personal information, we do not use your content to train AI, and we do not show you ads.

1. Who we are

The controller of your personal information is:

datasamy, Inc. 2261 Market Street, #10168 San Francisco, CA 94114 United States Email: privacy@closerapp.us

If you have questions about this Privacy Policy or how we handle your data, email privacy@closerapp.us and we will respond within thirty (30) days.

2. Scope

This Privacy Policy applies to the Closer mobile application on iOS and Android, our website at https://closerapp.us, and any related services we operate. It does not apply to third-party websites, apps, or services that we link to. Those third parties have their own privacy policies, and we encourage you to read them.

3. Information we collect

We collect only what the Service needs to function. The categories below reflect what is actually implemented in the app today.

3.1 Information you give us directly

• Authentication identifier — one of: an Apple Sign in with Apple subject identifier, a Google account identifier, or an email address used for a password or magic-link login. We use this to recognize you when you return.
• Email address — captured from your authentication provider where available. Used for account recovery and service communications.
• First name (or chosen display name) — as you provide it during onboarding. Shown to you and to your paired partner.
• Relationship context — optional onboarding fields you may fill in, such as relationship stage, duration, living situation, whether you have children, and how you heard about Closer. You can leave these blank.
• Time zone — used to schedule notifications at appropriate local times.
• Activity content — the answers, discussion messages, and reactions you submit to daily questions, weekly quizzes, and games. We refer to this as "Your Content."
• Shared photos — if you choose to attach a photo to a discussion (by taking one with your camera or selecting one from your photo library), we upload and store that image so your paired partner can see it. We access only the specific photo you capture or select — Closer does not scan, index, or upload your photo library.
• Partner invite codes — short codes we generate so you can pair with your partner. Codes expire 48 hours after creation.
• Support correspondence — any messages, attachments, and contact information you send us when you contact support@closerapp.us.

3.2 Information we collect automatically

• Session tokens — random strings we issue when you sign in. Tokens are scoped to your device and expire after approximately ninety (90) days.
• Device push notification identifier — a per-device push token issued by Apple Push Notification service (APNs) or Google Firebase Cloud Messaging (FCM), used by us and our push notification delivery provider to send notifications you have opted into.
• Crash and performance diagnostics — when the app crashes or experiences an error, we receive stack traces, the device model, the operating system version, and non-personal context through our diagnostics provider. We do not intentionally include personal content in crash reports.
• Product analytics events — through our product analytics provider, we log events such as "question answered," "paired with partner," "streak milestone reached," "screen viewed," along with an anonymous device identifier, your Closer user identifier, and your couple identifier. Event properties do not include the text of your answers or discussions.
• Subscription and purchase data — when you subscribe to Closer Premium, our subscription-management provider and the app store process your purchase history, transaction identifiers, and subscription status (linked to your Closer user identifier) so we can deliver Premium to you and your paired partner. We never receive your full payment card details — those are handled directly by Apple or Google.

3.3 Information we do not collect

• We do not collect your precise geolocation.
• We do not access your contacts, calendar, or microphone. We access your camera or photo library only when you explicitly choose to attach a photo to a discussion, and only for the single photo you capture or select — never your broader photo library (see Section 3.1).
• We do not process health, financial-account, or biometric data.
• We do not use cookies or web beacons in the mobile app. Our website uses only the cookies strictly necessary to deliver the page.
• We do not "sell" or "share" your personal information for cross-context behavioral advertising as those terms are defined under California law, and we do not show third-party ads inside the Service.
• We do not use Your Content to train generative artificial intelligence models, ours or anyone else's.

3.4 Sensitive information

Closer is a relationship app, so some of what you choose to write inside it can be personal. We treat the substantive content you write — your answers and discussion messages — as data that should be visible only to you and your paired partner. We do not analyze the substance of Your Content for advertising, profiling, or model training, and we do not disclose it to third parties except as described in Section 6.

4. How we use your information

We use your information to:

• Operate the Service — create and maintain your account, pair you with your partner, assign daily activities, deliver responses, reveals, and discussions, compute streaks and milestones.
• Send notifications you opt into — daily reminders, "partner answered," "reveal ready," streak milestones, "quiz available," and re-engagement messages. You can turn each category on or off in Settings → Notifications.
• Improve reliability — diagnose crashes and performance issues through our diagnostics tooling, which we use only to keep the app working.
• Understand usage in aggregate — measure activation, retention, and feature engagement through our product analytics tooling. We are looking at how the product is being used in the aggregate, not at what you and your partner are saying to each other.
• Communicate with you — respond to support requests, send service-related notices (security alerts, material changes to this policy, account-deletion confirmations).
• Keep the Service safe — investigate fraud, abuse, harassment, terms-of-service violations, and security incidents.
• Comply with law — respond to lawful requests from courts, government agencies, and regulators, and enforce our Terms of Service.

We will not use your information for any materially different purpose without giving you notice and, where required by law, obtaining your consent.

5. Legal bases for processing (EEA / UK)

If you are in the European Economic Area, the United Kingdom, or Switzerland, our legal bases for processing your personal information are:

• Performance of a contract — to provide the Service that you signed up for.
• Legitimate interests — to keep the Service secure, prevent abuse, diagnose crashes, and understand aggregated usage. You can object to processing on this basis at any time by emailing privacy@closerapp.us.
• Consent — for push notifications and, where required, for analytics. You can withdraw consent at any time in Settings.
• Legal obligation — when we have to retain or disclose data because the law requires it.

6. How we share your information

We share the minimum necessary, and only with the categories of recipients described below.

6.1 With your partner

The core function of Closer is that, after you and your paired partner both answer a daily question, complete a quiz, or finish a game, each of you can see the other's response and participate in the discussion thread. Anything you submit inside an activity becomes visible to your partner once the reveal conditions for that activity are met. Do not submit information inside Closer that you would not want your partner to see.

6.2 With our service providers

We use a small set of third-party service providers to operate the Service. Each is contractually bound to use your information only to provide services to us, and only for the purposes listed below:

We may add or change specific service providers within these categories from time to time. If we add a new category of recipient, we will update this list before doing so. To request the current named list of providers, email privacy@closerapp.us.

6.3 For legal reasons

We may disclose information when we have a good-faith belief that disclosure is necessary to (a) comply with applicable law, lawful subpoenas, court orders, or other legal process; (b) enforce our Terms of Service; (c) detect, prevent, or address fraud, security incidents, or technical issues; or (d) protect the rights, property, or safety of datasamy, our users, or the public — including, in serious cases, by reporting credible threats of harm to law enforcement.

6.4 In a corporate transaction

If datasamy is involved in a merger, acquisition, financing, reorganization, bankruptcy, or sale of assets, your information may be transferred as part of that transaction. If that happens, we will give you notice before your information becomes subject to a materially different privacy policy.

6.5 With your consent

We may share information for any other purpose disclosed to you and to which you consent.

6.6 We do not sell or share for cross-context behavioral advertising

We do not sell your personal information for money, and we do not share it for cross-context behavioral advertising, as those terms are defined under the California Consumer Privacy Act ("CCPA"). We have not done so in the preceding twelve months.

7. International data transfers

datasamy is a United States company and our service providers operate primarily in the United States. If you access the Service from outside the United States, your information will be transferred to, stored, and processed in the United States and in other countries where our service providers maintain facilities. These countries may have data protection laws that differ from the laws of your country.

Where required, we rely on appropriate safeguards for cross-border transfers, including the European Commission's Standard Contractual Clauses and the UK International Data Transfer Addendum, supplemented by additional measures where needed.

8. How long we keep your information

We keep your information only as long as we need it for the purposes described in this Privacy Policy.

• Account information, relationship context, activity content, discussions, streak state — retained while your account is active.
• Session tokens — expire approximately ninety (90) days after creation and are deleted during normal rotation.
• Invite codes — expire and are deleted forty-eight (48) hours after creation.
• Crash diagnostics — retained per our diagnostics provider's standard retention schedule (typically thirty (30) to ninety (90) days).
• Product analytics events — retained per our configured retention window, currently up to twelve (12) months.
• Support correspondence — retained for up to two (2) years after the matter is resolved.
• Information we are required by law to retain — retained for the period required by the relevant law (for example, tax records).

When you delete your account (see Section 10), we immediately mark the account as deleted, revoke your sessions, and unpair your couple. We then purge your personal identifiers and activity content from our active systems within thirty (30) days, except where we are required to retain specific records to comply with law, resolve disputes, or enforce our Terms of Service. Backup copies are overwritten in the ordinary course within approximately ninety (90) days.

9. How we protect your information

We take reasonable and appropriate technical and organizational measures to protect your information against loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction:

• Encryption in transit — TLS 1.2 or higher for all network communication between the app and our servers.
• Encryption at rest — database encryption provided by our managed Postgres host.
• Access controls — credentials and API keys stored in a managed secret store; only authorized services and personnel can access production systems.
• Token hygiene — server-side session tokens with a fixed time-to-live that can be revoked.
• Backups — encrypted backups, retained on a rolling basis.

No system is perfectly secure. We cannot guarantee that your information will never be accessed by unauthorized parties, and you use the Service at your own risk. If you believe your account has been compromised, email us at security@closerapp.us.

10. Your choices and rights

You always have the following choices, no matter where you live:

• Access and update. Most of your data is visible and editable in the app under Settings. If you need anything more, email privacy@closerapp.us.
• Delete your account. You can delete your account at any time from Settings → Delete account. Deletion revokes your sessions, unpairs your couple, and starts the purge process described in Section 8.
• Notification preferences. Toggle push categories on or off in Settings → Notifications or in your device's system notification settings.
• Opt out of analytics and crash reporting. Once available, you will be able to opt out of product analytics and crash reporting independently in Settings → Privacy. Until that toggle ships, email privacy@closerapp.us and we will disable analytics for your account on request.

10.1 California residents (CCPA / CPRA)

If you are a California resident, you have the following rights with respect to your personal information, subject to limited exceptions:

• Right to know — what categories and specific pieces of personal information we have collected about you, where we got it, the business or commercial purposes for which we collect it, and the categories of third parties with whom we share it. The disclosures in Sections 3, 4, and 6 cover this.
• Right to delete — request that we delete personal information we collected from you.
• Right to correct — request that we correct inaccurate personal information.
• Right to opt out of sale or sharing — we do not sell or share your personal information for cross-context behavioral advertising, so there is nothing to opt out of, but we honor this right by default.
• Right to limit use of sensitive personal information — to the extent we process sensitive personal information, we use it only for the purposes permitted under California law without your additional consent.
• Right to non-discrimination — we will not deny you the Service, charge you a different price, or provide a different level of quality because you exercised any of these rights.

To exercise these rights, email privacy@closerapp.us from the email address associated with your account, or use the in-app Delete account flow. We will verify your request by matching the information you provide with the information associated with your account. If you use an authorized agent, we will require written permission from you and verification of the agent's identity. We will respond within forty-five (45) days. If we need more time, we will let you know.

10.2 EEA, United Kingdom, and Swiss residents (GDPR / UK GDPR)

If you are in the EEA, the United Kingdom, or Switzerland, you have the rights of access, rectification, erasure, restriction of processing, objection to processing, data portability, and the right not to be subject to automated decision-making that produces legal or similarly significant effects. You also have the right to withdraw consent at any time where we rely on consent, and the right to lodge a complaint with your local supervisory authority. To exercise these rights, email privacy@closerapp.us.

10.3 Other US states

Residents of Colorado, Connecticut, Virginia, Utah, Texas, Oregon, Montana, and other states that have enacted comprehensive consumer-privacy laws may have similar rights of access, deletion, correction, portability, and opt-out. To exercise your rights, email privacy@closerapp.us.

10.4 Do Not Track and global privacy signals

Because Closer is delivered primarily as a mobile application, browser-level "Do Not Track" signals do not apply. On our website, we will treat a recognized Global Privacy Control ("GPC") signal as a valid request to opt out of any sale or sharing of personal information, to the extent that selling or sharing is taking place (it is not, today).

11. Children's privacy

Closer is not directed to children under the age of 13. You must be at least 13 years old to use the Service. We do not knowingly collect personal information from children under 13. If you are a parent or guardian and believe that your child under 13 has provided us with personal information, email privacy@closerapp.us and we will delete the account and the associated information promptly.

12. Third-party content and links

The Service may contain links to third-party websites, services, or resources, including the websites of our service providers. We are not responsible for the content, privacy practices, or terms of those third parties. Following links is at your own risk, and the third party's privacy policy will govern any information collected through its site or service.

13. Changes to this Privacy Policy

We may update this Privacy Policy from time to time. If we make material changes, we will notify you in-app, by email, or by another reasonable means before the changes take effect, and we will update the "Effective date" at the top of this page. We will obtain your consent to material changes where the law requires it. Continued use of the Service after the effective date of an updated policy constitutes acceptance of the updated policy.

14. Contact us

If you have any questions or concerns about this Privacy Policy or our handling of your personal information, please contact us:

datasamy, Inc. Attn: Privacy 2261 Market Street, #10168 San Francisco, CA 94114 United States

Privacy questions: privacy@closerapp.us Security reports: security@closerapp.us General support: support@closerapp.us

Appendix A — App Store privacy label mapping

The table below maps the disclosures in this Privacy Policy to Apple's App Store "App Privacy" categories (also referenced by Google Play's Data safety section). It is provided for transparency and for our submission filings; the substantive rules are in Sections 3, 4, and 6 above.

Tracking, as Apple defines it: None. We do not link Closer data with third-party data for the purpose of advertising or advertising measurement, and we do not share Closer data with data brokers.