Privacy Policy

PRIVACY POLICY DCZ Media Holdings LLC DesiCouplesZ Platform — desicouplesz.app

Effective Date: 10/9/2026

1. INTRODUCTION AND SCOPE

DCZ Media Holdings LLC ("DCZ," "Company," "we," "us," or "our") operates DesiCouplesZ, accessible at desicouplesz.app and desicouplesz.com, including all associated websites, subdomains, mobile applications, application programming interfaces, and related services (collectively, the "Platform"). This Privacy Policy ("Policy") governs the collection, use, disclosure, retention, and protection of information obtained from or relating to individuals who access or use the Platform ("User," "you," or "your").

This Policy applies to all Users of the Platform and to all information collected through the Platform, regardless of the device or method of access. This Policy does not apply to third-party websites, applications, services, or integrations that we do not own or control, even where such third parties are accessible through or integrated with the Platform.

BY ACCESSING, REGISTERING FOR, OR USING THE PLATFORM, YOU ACKNOWLEDGE THAT YOU ARE 18+ AGE, AND YOU HAVE READ, UNDERSTOOD, AND CONSENT TO THE PRACTICES DESCRIBED IN THIS POLICY. IF YOU DO NOT AGREE WITH ANY PROVISION OF THIS POLICY, YOU MUST IMMEDIATELY DISCONTINUE USE OF THE PLATFORM.

This Policy is incorporated by reference into our Terms of Service. In the event of any conflict between this Policy and the Terms of Service regarding the processing of personal information, this Policy shall control.

1. DEFINITIONS

"Personal Information" means any information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular individual or household.

"Processing" means any operation or set of operations performed on Personal Information, whether or not by automated means, including collection, recording, organization, structuring, storage, adaptation, alteration, retrieval, consultation, use, disclosure by transmission, dissemination, making available, alignment, combination, restriction, erasure, or destruction.

"Data Controller" means the entity that determines the purposes and means of Processing Personal Information.

"Data Processor" means an entity that Processes Personal Information on behalf of and under the instructions of a Data Controller.

"User-Generated Content" or "UGC" means any content, that a User uploads, posts, transmits, or otherwise makes available through the Platform.

1. OUR ROLE

DCZ Media Holdings LLC is the Data Controller for Personal Information collected through the Platform. In limited circumstances, we may act as a Data Processor when Processing information solely on behalf of and under the documented instructions of a business partner.

DCZ is an interactive computer service within the meaning of 47 U.S.C. § 230. We do not create, develop, or author User-Generated Content. Users are solely responsible for the content they upload, post, transmit, or share through the Platform.

1. INFORMATION WE COLLECT

4.1 Information You Provide Directly We collect Personal Information that you voluntarily provide, including:

Account Registration Data: Full name, display name, email address, password, date of birth, and account preferences.

Identity and Age Verification Data: Government-issued identification documents, biometric data, or other verification data submitted through our third-party age verification provider.

Profile Data: Photographs, videos, biographical information, interests, preferences, and any other information you choose to include in your profile.

Payment and Billing Data: Billing name, billing address, and payment method details. Full payment card numbers are processed by our third-party payment processors and are not stored on our servers.

Communications Data: Correspondence with our support, moderation, compliance, or privacy teams.

4.2 Information Collected Automatically When you access or use the Platform, we automatically collect:

Device and Connection Data: IP address, device type, hardware model, operating system, browser type and version, language settings, mobile network information, and unique device identifiers. We do not associate persistent device identifiers with personal information for advertising purposes.

Approximate Location Data: Derived from IP address or, where you enable location services, from your device.

Cookies and Similar Technologies: As described in Section 8.

4.3 Information From Third Parties We may receive information about you from:

Authentication Providers: If you sign in using a third-party credential, we receive the identifiers that provider shares (typically name and email address).

Age Verification Providers: Verification results and associated data from our third-party age verification provider.

Payment Processors and Fraud Prevention Services: Transaction confirmations, fraud signals, and risk assessments.

Advertising and Analytics Partners: Aggregated or pseudonymous data regarding your interaction with our marketing.

4.4 Sensitive Information We do not intentionally collect government identifiers, precise geo location, health data, or biometric identifiers except as necessary for age verification. If you voluntarily include sensitive information in your profile or UGC, you do so at your own risk.

1. AGE VERIFICATION AND PROFILE ACTIVATION

5.1 Mandatory Age Verification To comply with applicable law and to maintain the integrity of the Platform, all Users must complete age verification through our designated third-party verification provider before their profile becomes visible or accessible to other Users.

5.2 Verification Process The verification process involves the submission of government-issued identification or biometric data to our third-party verification provider. This provider acts as an independent Data Controller for the verification process and processes your data in accordance with its own privacy policy. Verification data is encrypted in transit and at rest.

5.3 Profile Activation Your profile will not be activated, visible, or accessible to other Users until:

Age verification is successfully completed; and

Your profile has been reviewed and approved by our moderation team.

Until both conditions are satisfied, you will not have access to core Platform features.

1. HOW WE USE YOUR INFORMATION

We Process Personal Information for the following purposes, each supported by a legal basis:

Purpose Legal Basis Creating, operating, and maintaining your account Performance of a contract Providing, securing, and improving the Platform Legitimate interests Processing payments and preventing fraud Contract; legal obligation; legitimate interests Verifying age and identity Legal obligation; vital interests Moderating content and enforcing our Terms of Service Legitimate interests; legal obligation Complying with lawful requests from authorities Legal obligation Sending service, security, and transactional notices Contract; legitimate interests Sending marketing communications Consent (where required by law) Detecting, investigating, and preventing CSAM, NCII, trafficking, and other illegal activity Legal obligation; vital interests; legitimate interests Conducting analytics and research to improve the Platform Legitimate interests We do not sell your Personal Information. We do not use your Personal Information to train, fine-tune, or otherwise develop any artificial intelligence or machine learning models.

1. AI-BASED CONTENT SCANNING AND MODERATION

7.1 Automated Scanning All User-Generated Content, and associated metadata, undergoes automated scanning by third-party artificial intelligence systems for the purpose of detecting and preventing prohibited content, including child sexual abuse material (CSAM), non-consensual intimate imagery (NCII), and other illegal or violative material.

7.2 Data Transmitted Uploaded media, associated metadata, and relevant account identifiers are transmitted to our AI scanning providers solely for the purpose of content detection and moderation.

7.3 Provider Obligations Our AI scanning providers act as Data Processors and are contractually prohibited from:

Using your data for any purpose other than performing scanning services on our behalf;

Retaining your data beyond the period necessary to perform the scanning services; and

Using your data to train, fine-tune, or develop any AI or machine learning models.

7.4 User Consent Before any media upload, you must provide explicit, separate consent to AI-based scanning. Users who decline such consent will not be permitted to upload media to the Platform.

7.5 Human Review All content flagged by automated systems is reviewed by trained compliance personnel before any removal, restriction, or account action is taken. We do not rely solely on automated decision-making for final content determinations.

7.6 No AI Training on User Data We do not use your Personal Information, including uploaded media, messages, or any other UGC, to train, fine-tune, or otherwise develop any artificial intelligence or machine learning models.

1. COOKIES AND SIMILAR TECHNOLOGIES

We and our partners use cookies, pixels, software development kits (SDKs), and local storage technologies to operate the Platform, remember your preferences, measure performance, and, where permitted, deliver relevant advertising.

You may control cookies through your browser settings and, where required by law, through our consent management interface. Disabling certain cookies may affect Platform functionality.

We honor Global Privacy Control (GPC) signals where required by applicable law.

1. HOW WE SHARE INFORMATION

We share Personal Information only as described below:

Service Providers: We share information with third-party service providers who perform functions on our behalf, including hosting, payment processing, analytics, customer support, security, and AI-based content scanning. These providers are contractually bound to use information only for the purposes we specify and in accordance with this Policy.

Age Verification Providers: We share information with our third-party age verification provider as necessary to complete the verification process.

Other Users: To the extent you choose to make information public or share it through the Platform, that information will be visible to other Users.

Legal Authorities: We disclose information when we receive valid legal process, when we believe disclosure is necessary to prevent imminent harm, or when we are required to report CSAM to the National Center for Missing & Exploited Children (NCMEC) or other authorities.

Successors: We may disclose information in connection with a merger, acquisition, financing, reorganization, or sale of assets, subject to this Policy.

With Your Consent: We may share information with third parties when you have provided your consent or at your direction.

We do not sell your Personal Information. We do not rent, release, disclose, disseminate, make available, transfer, or otherwise communicate your Personal Information to any third party for monetary or other valuable consideration, as those terms are defined under applicable law. We do not knowingly sell or share the Personal Information of consumers under 16 years of age.

1. USER-GENERATED MEDIA (PHOTOGRAPHS AND VIDEOS)

10.1 Ownership You retain all ownership rights in the photographs, videos, and other media you upload to the Platform.

10.2 License Grant By uploading media, you grant DCZ a worldwide, non-exclusive, royalty-free, sublicensable, transferable license to host, store, reproduce, adapt, transcode, create derivative works of (including thumbnails, previews, and format conversions), display, distribute, and make available your media solely in connection with operating, providing, securing, and promoting the Platform. This license terminates when you delete the media or your account, except:

Where the media was shared with others who have not deleted it;

Where retention is required by law; or

Where the media exists in backup systems for a limited period as described in Section 14.

10.3 Your Responsibilities You are solely responsible for the media you upload. You represent and warrant that:

You own or have all rights, licenses, consents, and releases necessary to upload the media;

Every identifiable person depicted has consented to the upload and to the uses described in this Policy;

No person depicted in sexually explicit media is under 18 years of age; and

The media does not infringe any third party's copyright, trademark, privacy, publicity, or other rights, and does not violate any law.

You agree to indemnify, defend, and hold harmless DCZ and its officers, directors, employees, and agents from any claim, loss, liability, or expense (including reasonable attorneys' fees) arising from your media or your breach of these representations.

10.4 Prohibited Media You may not upload:

CSAM or any sexual content involving minors;

Non-consensual intimate imagery (NCII), including "revenge porn" and AI-generated intimate imagery of real people;

Content promoting prostitution, escort services, or commercial sexual exploitation;

Content that infringes copyright or other intellectual property;

Content depicting violence, bestiality, or other material prohibited by our Terms of Service; or

Media depicting any person who has not consented to the upload.

10.5 No Monitoring Obligation We do not pre-screen user media and have no obligation to monitor it. We may, but are not required to, review, screen, remove, or restrict access to any media at our discretion. Our failure to act on any particular media does not constitute approval or endorsement.

10.6 Metadata Where technically feasible, we strip or suppress geolocation (EXIF) metadata from uploaded photographs. You should review metadata before uploading.

10.7 Biometric Analysis We do not perform facial recognition, voiceprint analysis, or other biometric processing on uploaded media except as necessary for age verification. If this changes, we will update this Policy and obtain any consents required by law.

1. CONTENT MODERATION AND PLATFORM SAFETY

11.1 Moderation Team DCZ maintains a dedicated moderation team that reviews User-Generated Content, including content flagged by automated systems, reported by Users, or identified through our safety operations. The moderation team is authorized to remove content, restrict features, suspend accounts, terminate accounts, and preserve or report evidence as required by law.

11.2 Compliance Team Access Logging Access to User data by compliance and moderation personnel is restricted to authorized individuals and limited to what is strictly necessary for content review, legal compliance, or security response. All such access is logged and subject to internal audit for a minimum retention period of twelve (12) months.

11.3 CSAM Compliance DCZ strictly prohibits CSAM. We comply with 18 U.S.C. § 2258A. Upon obtaining actual knowledge of CSAM on the Platform, we will:

Preserve the content and associated data;

Report to the NCMEC CyberTipline as soon as reasonably possible; and

Cooperate with law enforcement.

Accounts associated with CSAM will be terminated and barred from re-registration.

11.4 §2257 Records Where the Platform hosts sexually explicit content, DCZ complies with 18 U.S.C. § 2257 and its implementing regulations. We may require documentation establishing the age and identity of any person depicted before permitting upload, and may remove content pending verification.

11.5 FOSTA Compliance DCZ complies with FOSTA (18 U.S.C. § 2421A). We do not promote or facilitate prostitution, escort services, or sex trafficking. Users are strictly prohibited from using the Platform to advertise, solicit, or promote any such activity. Violations result in immediate removal and account termination, and may be reported to law enforcement.

11.6 NCII Takedown If you believe intimate imagery of you has been posted without your consent, contact support@desicouplesz.app. We will act promptly to remove the content and preserve related data, in accordance with applicable law including the federal TAKE IT DOWN Act and state NCII statutes.

11.7 Reporting and Appeals Report content: support@desicouplesz.app

Copyright (DMCA): DMCA@desicouplesz.app

Appeals: Users whose content was removed may appeal to support@desicouplesz.app. Appeals are reviewed by a different moderator than the one who took the original action.

1. DMCA PROCEDURE (17 U.S.C. § 512)

If you believe your copyrighted work has been used on the Platform without authorization, send a notice to our Designated Copyright Agent at DMCA@desicouplesz.app containing:

Your physical or electronic signature;

Identification of the copyrighted work;

Identification of the allegedly infringing material and its location on the Platform;

Your name, address, telephone number, and email;

A statement of good-faith belief that the use is not authorized; and

A statement under penalty of perjury that the notice is accurate and that you are the owner or authorized agent.

We will remove or disable access to the material and notify the uploader, who may submit a counter-notification under § 512(g). We maintain and enforce a repeat-infringer termination policy.

1. DATA DELETION

You may request deletion of your Personal Information at any time by:

Logging into your account and selecting the account deletion option;

Emailing support@desicouplesz.app; or

Completing the GDPR User Rights form on the Platform.

Upon receipt of a valid deletion request, your account will be deactivated. Majority data deletion will occur upon your consent. Complete data deletion will occur within seven (7) days, subject to the retention exceptions described in Section 14.

If you fail to make payment for any premium plan, DCZ will remove all paid features and return you to the Free/Trial Plan. Please see Section 7.5 of our Terms of Service for User inactivity under the Free Plan.

Notwithstanding the foregoing, DCZ may retain data beyond the periods described above where required by law, where necessary to comply with legal obligations, to respond to valid legal process, to resolve disputes, to enforce our agreements, to prevent fraud or abuse, or where data has been flagged for moderation review or is subject to an ongoing investigation. Data subject to a law enforcement preservation request will be retained until the request is released or as required by law.

1. DATA RETENTION

We retain Personal Information only as long as necessary for the purposes described in this Policy, or as required by law.

Category Retention Period Basis Account and profile data Until account deletion + 7 days Restoration window; backup lifecycle Content you posted Until deleted by you, or account deletion + 7 days Contract; legitimate interests Flagged / reported content Until review concludes, even after account deletion Legal obligation; legitimate interests Age verification data As required by verification provider's policy and applicable law Legal obligation Billing and tax records As required by tax and accounting law (typically 7 years) Legal obligation Access logs and IP data Up to 12 months Security; fraud prevention; legal obligation Moderation and compliance access logs Minimum 12 months Legal obligation; abuse prevention Law-enforcement preservation Until the request is released Legal obligation Where we cannot delete data (for example, because it resides in encrypted incremental backups), we isolate it from active use until deletion becomes possible. Our backups fully recycle within seven (7) days.

If your account is deactivated or terminated, some content may remain visible to other Users — for example, forum posts or shared media — to preserve the continuity of discussions and shared experiences.

1. SECURITY

We maintain administrative, technical, and physical safeguards designed to protect Personal Information, including:

Encryption of data in transit (TLS 1.3) and at rest (AES-256);

Access controls and least-privilege provisioning;

Regular security assessments and monitoring; and

Employee training on data protection.

Access to User data by employees and contractors is limited to what is strictly necessary for diagnosis, support, moderation, and legal compliance. All such access is logged.

No system is perfectly secure. We cannot guarantee absolute security of information transmitted over the Internet or stored on our systems. If we become aware of a breach affecting your Personal Information, we will notify you and the relevant authorities as required by law.

1. INTERNATIONAL DATA TRANSFERS

We are based in the United States. If you access the Platform from outside the United States, your information will be transferred to, stored in, and processed in the United States. For transfers of EEA, UK, or Swiss personal data, we rely on the European Commission's Standard Contractual Clauses, the UK International Data Transfer Addendum, and, where applicable, supplementary technical and organizational measures.

1. YOUR PRIVACY RIGHTS

Depending on your jurisdiction, you may have the following rights:

Right to Know: The right to know what Personal Information we hold about you.

Right to Access: The right to receive a copy of your Personal Information.

Right to Correct: The right to correct inaccurate Personal Information.

Right to Delete: The right to request deletion of your Personal Information, subject to legal retention obligations.

Right to Portability: The right to receive your Personal Information in a machine-readable format.

Right to Restrict or Object: The right to restrict or object to certain Processing.

Right to Withdraw Consent: The right to withdraw consent at any time where Processing is based on consent.

Right to Opt Out: The right to opt out of targeted advertising or profiling where applicable.

Right to Lodge a Complaint: The right to lodge a complaint with your local supervisory authority.

How to Exercise Your Rights Submit a request through the form on desicouplesz.app or desicouplesz.com, or email privacy@desicouplesz.app. We will respond within 30 days unless a longer period is permitted by law. To protect your account, we may require government-issued identification or a secondary verification method before fulfilling a request.

You may also:

Modify or delete your profile by logging in;

Request deletion, portability, correction, or objection via privacy@desicouplesz.app

Authorized Agents You may designate an authorized agent to submit requests on your behalf. We may require proof of authorization and may still contact you directly to verify identity.

Appeals If we deny your request, you may appeal by replying to our decision or emailing privacy@desicouplesz.app. We will respond to appeals in writing.

1. CHILDREN'S PRIVACY

The Platform is for adults only. We do not knowingly collect Personal Information from anyone under 18 years of age (or the age of majority in your jurisdiction, if higher). If we learn that we have collected information from a minor, we will delete it promptly. If you believe a minor has provided us information, contact privacy@desicouplesz.app.

1. THIRD-PARTY SERVICES

The Platform may link to or integrate with third-party services. Their privacy practices are governed by their own policies, not this one. We encourage you to review them before use. We are not responsible for the content or privacy practices of third parties.

1. CHANGES TO THIS POLICY

We may update this Policy from time to time. Material changes will be announced on the Platform and, where required, by email. Continued use of the Platform after the effective date constitutes acceptance of the updated Policy. The "Last Revised" date at the top indicates the current version.

1. LIMITATION OF LIABILITY AND DISCLAIMERS

TO THE MAXIMUM EXTENT PERMITTED BY LAW, DCZ PROVIDES THE PLATFORM "AS IS" AND "AS AVAILABLE," AND DISCLAIMS ALL WARRANTIES, EXPRESS OR IMPLIED. DCZ IS NOT LIABLE FOR ANY INDIRECT, INCIDENTAL, SPECIAL, CONSEQUENTIAL, OR PUNITIVE DAMAGES, OR FOR ANY LOSS OF DATA, PROFITS, OR GOODWILL, ARISING FROM YOUR USE OF THE PLATFORM OR FROM UNAUTHORIZED ACCESS TO YOUR INFORMATION, EXCEPT WHERE SUCH LIMITATIONS ARE PROHIBITED BY LAW.

Nothing in this Policy limits our obligations under applicable data protection law, including GDPR Articles 82 (right to compensation) and 33–34 (breach notification).

1. DISPUTE RESOLUTION

Any dispute arising out of or relating to this Policy will be resolved by binding individual arbitration in [Insert Venue], under the rules of [Insert Arbitration Body], except where prohibited by law. You and DCZ each waive the right to a jury trial and to participate in a class action. You may opt out of arbitration within 30 days of first accepting this Policy by written notice to support@desicouplesz.app.

Nothing in this section prevents you from filing a complaint with a data protection authority.

1. CONTACT INFORMATION

Purpose Contact General support support@desicouplesz.app Privacy requests and DPO privacy@desicouplesz.app Copyright / DMCA DMCA@desicouplesz.app Data Protection Officer DCZ Media Holdings LLC privacy@desicouplesz.app