Privacy Policy

1. Who is responsible

The controller of your personal data is LEOMAS, s. r. o., Begóniová 20547/38C, 821 07 Bratislava–Vrakuňa, Slovak Republic, company ID (IČO) 44 047 789, VAT ID SK2022589646, which runs Nuune. Contact: privacy@nuune.app. Data protection officer: Michaela Nguyen, dpo@nuune.app.

2. What we collect, why, and for how long

2.1 Your account

• What: Email address, name, and either a password (held by our sign-in provider Clerk as a hash, never by us) or your Apple or Google sign-in. Anything you add to your profile, such as your relationship status.
• Why: To create your account, sign you in and run Nuune for you.
• Legal basis: Performing our contract with you (GDPR Art. 6(1)(b)).
• How long: Until you delete your account.

2.2 What you write and say in Nuune

• What: Messages in solo and shared chats, journal entries, check-ins, voice recordings and their transcripts if you use voice, voice notes you send your partner, deals and exercise answers, questionnaires you fill in (for example about your personality or how you handle conflict), and what Nuune works out from them: reflections, summaries, suggested deals, emotion and sentiment scores, relationship health scores and patterns. This can reveal your health, feelings or sex life, which the law treats as special categories of data.
• Why: To mediate, reflect, suggest exercises and deals, and show you your progress.
• Legal basis: Your explicit consent (GDPR Art. 9(2)(a)), which the app asks for before its AI does anything, and our contract with you. You can withdraw consent in the app under Profile, Privacy; Nuune's AI features then stop.
• How long: Until you delete it or your account. When you delete your account, your messages in shared chats are erased too; your partner keeps their own.

2.3 Tone of voice (emotion recognition)

• What: If you turn on voice, Hume AI analyses the tone of your voice to detect emotional states during voice conversations.
• Why: To notice when a conversation is heating up and respond with more care.
• Legal basis: Your explicit consent (GDPR Art. 9(2)(a)), asked the first time you record; nothing is sent to Hume before you agree. EU AI Act Art. 50 notice: this is an emotion recognition system. In the EU and EEA it switches off on 2 December 2027 unless it meets the AI Act's requirements for high-risk systems by then.
• How long: With your conversation (2.2). Hume may keep data under its own terms; see its privacy policy linked in section 3.

2.4 Safety check

• What: An automated check of chat messages and journal entries for signs that someone may be at risk of harming themselves or others. When it finds them, Nuune shows crisis resources, and a flag is stored with up to the last 200 characters of the message that raised it. Flags that are not closed in the app can be seen by authorized staff who review them.
• Why: To respond to someone who may be in danger.
• Legal basis: Part of the service you consent to in 2.2 (GDPR Art. 9(2)(a)); in an emergency, protecting someone's life (Art. 6(1)(d) and Art. 9(2)(c)).
• How long: Until you delete your account.

2.5 Your partner

• What: When you link with your partner, we store their name and email address with your account so the two accounts can be connected, and which chats and journal entries you choose to share.
• Why: To connect your accounts and let you talk and make deals together.
• Legal basis: Our contract with each of you.
• How long: Until either of you removes the link or deletes their account.

2.6 Location

Nuune is not available in some places (see Terms, section 2.4), so we process three kinds of location information, and no others. We never track where you go.

• Approximate location of your connection: the country and, in the US, the state that your IP address points to, checked when you open Nuune, when it contacts our AI and when the website loads. It is used to apply the rules for that place and is stored only as part of the records below and the waitlist (2.13).
• Where you live: the country, and in the US the state, that you tell us, when you told us, and the region your connection showed at that moment. Kept with your account until you delete it.
• A one-time location check, only if you ask for it: if your connection places you in a state where Nuune is not available and you choose to confirm where you are, your phone sends its position to our server once. We use it to work out which state you are in, then discard it; it is never stored or logged. We keep the outcome, the state, the rounded distance to the nearest state where Nuune is not available, the accuracy your phone reported and the time. The app only asks for location permission while it is open.

Legal basis: complying with the laws of the places where we operate (GDPR Art. 6(1)(c)) and our legitimate interest in doing so (Art. 6(1)(f)); the location check because you ask for it.

2.7 Your consents

• What: What you agreed to or declined, which version of the wording you saw, when, and the country and state you were in. If you agree in the app before making an account, we keep this, and where you told us you live, against a keyed hash of your phone's random ID (2.8), and move it to your account when you make one on that phone.
• Why: To show we have your consent, and to ask again when the wording changes.
• Legal basis: Our legal obligation to be able to prove consent (GDPR Art. 7(1) and Art. 6(1)(c)).
• How long: Until you delete your account. Kept against a phone that never makes an account: one year, then deleted automatically.

2.8 Free messages, and the app before you make an account

• What: You can send ten messages in the app before choosing a plan, even before you make an account. To count them per phone as well as per account, the app keeps a random ID in your phone's secure storage. Our server stores only a keyed hash of that ID and the number of free messages used on the phone and on your account. Before you make an account, your conversation is kept only on your phone; our server passes each message to Anthropic for the reply and stores none of it. If you then make an account on that phone, the conversation is saved to your account (2.2), so you can carry on in it.
• Why: So you can try Nuune before signing up, and so the ten free messages cannot be claimed again by making a new account on the same phone.
• Legal basis: For the messages, your explicit consent, asked before the first one (GDPR Art. 9(2)(a)); for the count, our legitimate interest in preventing abuse of the free messages (Art. 6(1)(f)).
• How long: Your account's count until you delete your account. The phone's count for two years after it was last used, then it is deleted automatically.

2.9 Payments

• What: Your plan, its status and dates. For each payment, the date, the amount, the period it covers and its reference at Stripe, and a note if we refunded it, so that we can answer your questions about a payment. Payments are processed by Clerk and Stripe; we never see or store your card number.
• Why: To bill you, give you access to what you pay for, and answer questions about a payment.
• Legal basis: Our contract with you, and our obligations under tax and accounting law (GDPR Art. 6(1)(b) and (c)).
• How long: Our list of your payments until you delete your account, and it is part of your data export. Clerk and Stripe keep the accounting records for as long as Slovak law requires (currently 10 years).

2.10 Keeping Nuune working and secure

• What: Error and crash reports (sent to Sentry, with your account ID but never the text of your messages), error logs in our database, server logs kept by our hosting provider (IP address, time and the request made), and, if you allow notifications, your phone's push token, your notification settings (which kinds you want, quiet hours, your phone's time zone) and an Activity list: for each thing a notification was sent about, the kind of event, your partner's first name, and the time. A notification, and the Activity list, show a first name and what kind of thing happened, never what was written.
• Why: To find and fix problems, keep the service secure, stop abuse, and send the notifications you asked for.
• Legal basis: Our legitimate interest in a working, secure service (GDPR Art. 6(1)(f)); notifications because you allowed them.
• How long: Server logs for the short time our hosting provider keeps them; error reports and error logs for up to 90 days; push tokens and notification settings until you turn notifications off or delete your account; the Activity list for 60 days. The Activity list and your notification settings are part of your data export.

2.11 Usage data, only if you agree

• What: Counts per day of which screens and features are used, how many times the app is opened, and how long those visits last added together, with the phone type (iOS or Android) and the app version. Nothing else is in a count: no account ID, no device ID, no text, so a count does not say who it came from. While you use the app, it sends short lists of the screens and features you opened; our server adds them up into numbers and stores only those numbers, each day's row with the time it was first created. With only a few users, a day's numbers for one phone type could still point at one person. Like every request, the one that carries them shows your sign-in; our server uses it to check that you agreed and to limit abuse, and does not store it with the counts. It also shows up in our hosting provider's server logs like any other request (2.10), but what it contains is not logged. We use no third-party analytics or advertising tools.
• Why: To understand what helps and improve Nuune.
• Legal basis: Your consent (GDPR Art. 6(1)(a)). It is off until you turn it on, and you can turn it off in Profile, Privacy. Your phone then stops sending and drops what it had not yet sent.
• How long: The added-up counts for 400 days (a little over 13 months), then they are deleted automatically. Because they are not linked to your account, they are not part of your data export, and deleting your account or turning this off does not remove counts already added.

2.12 Research, only if you agree

If you opt in, once a week we create a summary for you under a code instead of your identity: the number of conversations and messages, average sentiment and its trend over the week, engagement, the type of session, and how many of those conversations raised a safety flag (a number only). It never contains your words, name, email, your partner's identity or payment details. The code is made from your account ID with a secret key that only we hold, so researchers cannot link it to you, but we could; that makes it pseudonymous data, which the law still treats as personal data. Approved researchers can query these summaries through our research API under an agreement that forbids trying to identify anyone.

• Legal basis: your explicit consent (GDPR Art. 9(2)(a)).
• How long: when you withdraw, we stop adding summaries. Past summaries are deleted when you delete your account, or when you ask us at privacy@nuune.app, within one month. See also our research ethics page.

2.13 The website

• The home page sets no cookies and loads nothing from other companies; even its fonts come from our own server. It stores nothing in your browser unless you send a message in the demo.
• The demo on the home page sends what you type to Anthropic to write a reply, only after you tick the box that appears when you click into it, agreeing to this; by sending, you also confirm that you are 18 or older and accept our Terms. We do not store your messages. Legal basis for them: your consent (GDPR Art. 6(1)(a) and Art. 9(2)(a)), which you can withdraw by simply not sending more. To give each browser ten messages, the page keeps a random token in your browser's local storage once you send your first message, and we keep a keyed hash of it with a count for up to a year. To stop anyone from starting over again and again, we also count demo messages per network (a keyed hash of your IPv4 address, or of the first half of an IPv6 address) per day, and delete that count within a year. Legal basis for the counts: our legitimate interest in limiting abuse and cost (GDPR Art. 6(1)(f)). Please do not type anything you would not want an AI to read.
• The waitlist: if you leave your email, we keep it with the date, the button you used, the country your connection pointed to and, if you came through one of our links (a short link from a social profile, a podcast or a promotion), which kind of link it was, in our own database. We use it only to tell you when Nuune is available, and we share it with no one. Legal basis: your consent (GDPR Art. 6(1)(a)). It is deleted once we have told you, or earlier if you ask.
• Sign-in and account pages load Clerk, our sign-in provider, which sets cookies that record whether you are signed in. When a page breaks, an error report goes to Sentry, with cookies and addresses removed. This page and the other information pages load neither. See our Cookie Policy.
• Server logs as in 2.10.

2.14 How you found Nuune

• What: Your answer to one question when you sign up (how you found Nuune), if you answer it; the question can be skipped. On Android, also the name of the campaign of the link that led to the download, as Google Play passes it to the app when it first starts, if the link had one. Only a choice from our own short list is kept, never the raw text of a link, and no advertising ID.
• Why: To know where to keep talking about Nuune, and where not to.
• Legal basis: Our legitimate interest in understanding how people find us (GDPR Art. 6(1)(f)). You choose whether to answer, and it has no effect on what Nuune does for you.
• How long: With your account: it is part of your data export and is deleted when you delete your account. It is shared with no one.

3. Who processes your data for us

We use these companies to run Nuune. They process data only on our instructions and under data processing terms. We never sell your data, never share it for advertising, and never give it to data brokers.

• Anthropic (United States): the AI model that writes Nuune's replies, including the demo's. It receives your messages. Its commercial terms do not allow it to train its models on them. Privacy policy
• Hume AI (United States): tone of voice, only if you turn voice on. Privacy policy
• Convex (United States): our database, where your account data, conversations and journal are stored.
• Clerk (United States): sign-in and account management, and billing together with Stripe. Privacy policy
• Vercel (United States): hosting for our website and servers.
• Sentry (United States): error and crash reports, without message text.
• Expo (United States): delivery of push notifications to your phone through Apple or Google. The text of a notification, a first name and a general line, passes through them.
• Apple and Google: only if you choose to sign in with them.

Apart from them, your partner sees what you share with them, approved researchers see pseudonymous summaries if you opt in (2.12), and we disclose data to authorities only when the law requires it.

4. Transfers outside the EU

The companies above are in the United States. We transfer data to them under the European Commission's Standard Contractual Clauses, or under the EU–US Data Privacy Framework where the company is certified under it. You can ask us for a copy of the safeguards at privacy@nuune.app.

5. Security

• Your data is encrypted in transit (TLS) and at rest by our database provider.
• Private messages are readable only by their author, which our database enforces.
• Within our team, access to production data is limited to the people who need it.

Nuune is not end-to-end encrypted, and we want to be clear about why. Nuune works by having an AI read what you write and reply to it. That is only possible if our systems and Anthropic can read your messages. Any service that reads your conversations and still claims end-to-end encryption is promising something it cannot deliver. No system is perfectly secure; if a breach puts you at risk, we will tell you as the law requires.

6. Automated processing

Nuune's replies, reflections, deal suggestions, scores, the safety check and tone of voice analysis are produced automatically. None of them makes a decision about you with legal or similarly significant effects in the sense of GDPR Art. 22. Nuune is an AI, not a person, a therapist or a counselor.

7. Your rights

Wherever you live, you can:

• download your data, and delete your account and everything in it, in the app under Profile, Privacy;
• withdraw any consent in the app under Profile, Privacy, without affecting what happened before;
• ask us at privacy@nuune.app for anything else below.

In the EU, EEA, UK and Switzerland

You have the right to access your data, correct it, have it erased, restrict its processing, receive it in a portable format, object to processing based on our legitimate interests, and withdraw consent. We answer within one month. You can also complain to a data protection authority, in particular where you live or work. Ours is the Úrad na ochranu osobných údajov Slovenskej republiky, Hraničná 12, 820 07 Bratislava 27, dataprotection.gov.sk.

In the United States

Depending on your state, you have the right to know what personal data we hold about you and get a copy, to have it corrected or deleted, and to opt out of its sale, of targeted advertising and of profiling with significant effects. We do not sell personal data, do not share it for targeted advertising, and do not do such profiling. We use sensitive data only to provide Nuune. Write to privacy@nuune.app; an authorized agent may write for you. We answer within 45 days and never treat you differently for using these rights. If we refuse a request, you can appeal by replying to our answer.

• Where Nuune is not available: Illinois, Maine, Nevada, Rhode Island, Tennessee and Vermont (see our Terms, section 2.4).
• California, New York, Utah, Oregon, Washington and Nebraska: laws there require clear notice that you are talking to an AI, protections for minors, and a protocol when someone may be at risk. Nuune tells everyone it is an AI before they start and repeats it, is for adults only, and shows crisis lines when a conversation suggests danger.
• Utah: we show no advertising in Nuune, never use what you type to target advertising, and do not sell or share what you tell Nuune.
• Washington and other states with consumer health data laws: see our Consumer Health Data Privacy Policy.

8. Age

Nuune is for adults, 18 and older. We do not knowingly collect data from anyone younger; if we learn that we have, we delete it.

9. How long we keep data, at a glance

• Account, conversations, journal, deals, consents, location records and safety flags: until you delete them or your account.
• Deleted data can remain in our database provider's backups for up to 30 days before it is overwritten.
• Free message count for a phone: two years after it was last used. Consents given on a phone that never makes an account: one year.
• Demo and waitlist counters, kept against keyed hashes of a browser token or a network address: deleted within a year.
• Waitlist email: until we have told you Nuune is available, or until you ask.
• How you found Nuune (your answer, and on Android the campaign of the link): with your account.
• Error reports and error logs: up to 90 days. Accounting records: as long as Slovak law requires (currently 10 years).
• Usage counts (screens, features, app opens and visit length per day, with phone type and app version; no account or device ID, only if you agree): 400 days, a little over 13 months.
• Research summaries: until you delete your account or ask us to delete them.

10. Changes

We will tell you in the app or by email before a change that matters takes effect. If a change affects something you consented to, we will ask for your consent again. The date at the top shows the latest version.