This is a translation of the Brazilian Portuguese original. If the versions differ, the Portuguese version prevails.

Privacy Policy

Last updated: November 1, 2026 · Version 1.0

1. Who we are

This Policy explains how Eagle Fire Digital LTDA, Brazilian company number (CNPJ) 54.995.320/0001-58 (“TwoBible”, “we”) processes personal data in TwoBible: Couples Devotional. We are the controller of your data under Brazil’s General Data Protection Law (LGPD, Law No. 13,709/2018).

Support: suporte@twobible.com.

2. Data Protection Officer (DPO)

Our Data Protection Officer (DPO; “encarregado” under the LGPD) is Eagle Fire Digital LTDA itself. Contact: suporte@twobible.com (write “Personal data” in the subject line). Requests are handled in Portuguese.

Contact the Data Protection Officer to exercise your rights (section 13), ask questions about this Policy or report a security problem.

3. What this Policy covers

• the TwoBible website and quiz;
• the TwoBible app for iPhone and Android;
• the emails we send;
• the links that open in the browser for people who don’t have an account: invitations, gestures, “A Word for someone”, the gentle invitation to a spouse who doesn’t believe, and joining an Agreement or Before the Yes by link (section 7). People who receive these links don’t pay and don’t need the app.

4. Data we process

4.1 In the website quiz

Life stage (single, dating, engaged, married, widowed or divorced), gender, age range, your name and your partner’s name, your faith journey, your reasons and current struggles, where your relationship stands (including whether you feel afraid in your relationship), whether you have children, how long ago you lost your spouse (if you are widowed), what you have been praying for most, and your email. Your answers about faith and relationships are sensitive data (section 5).

4.2 When you buy

Name, email, country, chosen plan and transaction identifiers. Card, Pix, Apple Pay and Google Pay payments are processed by Stripe; we don’t receive or store your card number.

4.3 In your app account

Email, name, what you want to be called, gender, life stage, preferred Bible version, language, reminder time and time zone. If you sign in with Google or Apple, we use the email that provider sends us.

4.4 What you write and send

Devotional answers, journal and prayer requests, letters (including voice recordings), love coupons, date invites, album photos, quiz answers, Counselor chats, Agreements and Before the Yes conversations.

4.5 Connections

Who your account is linked with (spouse, prayer partner and groups), invitations (which include the invited person’s name), the couple’s stage and dates such as your wedding date.

4.6 Subscription and credits

Plan, billing period, free trial, receipts, credit balance and credit history. Your balance and your history are yours alone: not even your partner sees them.

4.7 Technical data

Tokens for sending notifications, access logs (IP address, date and time), app usage events, error reports and, on the website, cookies and pixels according to your choice (section 10).

4.8 Support

The messages you exchange with our support team.

5. Sensitive data

Under the LGPD (Art. 5(II) and Art. 11), the following are sensitive personal data in TwoBible: your religious beliefs and faith journey, your answers about your relationship, and health topics you choose to share (such as grief or infertility).

• Specific and prominent consent. We ask for your consent in a separate field, apart from the Terms of Use and not pre-checked, before the faith and relationship questions in the quiz and at sign-up in the app. Because TwoBible’s content is itself about faith (devotional answers, journal, prayer requests, Counselor chats and Agreements), this consent also covers what you write in the app. We use this data only to provide the service you asked for: building your plan, choosing the day’s devotional, tracks, verses and notifications, and replying in the Counselor.
• You can withdraw your consent at any time, in the app’s Settings or by emailing the Data Protection Officer. Because the app is made of this content, withdrawing means deleting your answers or deleting your account (section 13): without this data, TwoBible can’t work for you. Processing done before you withdraw remains valid.
• Never for ads. This data is not used for advertising and is never sent to the Meta Pixel, the TikTok Pixel or Google Analytics. The quiz’s web addresses (URLs) don’t carry your answers.
• Protecting life. The app automatically analyzes free text (answers, journal, letters, Counselor chats and Agreements) for signs of violence or crisis. When it finds them, it opens the help screen. This processing is based on the protection of life (Art. 11(II)(e)), costs nothing and does not notify your partner.
• Encryption. The most sensitive content, such as your journal and Agreements, is stored encrypted.

6. What we use data for, and on what legal basis

7. How the couple connection works

Each person has their own account, with their own email. When an invitation is accepted, the two accounts become a couple (or a pair of prayer partners, or a group).

What your partner sees

• your answers to 👥 questions, only after they have answered too (this rule is enforced on the server);
• whether you’ve done the day’s devotional, and when;
• your “I prayed for you” taps, with the time, and your ❤️;
• the prayer requests you chose to share;
• gestures you send, the photos in the challenges album, the results of games for two (including what you answer about yourself in “Who Knows the Other Better”), the stage, stage-change requests and the couple’s dates;
• the invitation to an Agreement and the version prepared for them; in Before the Yes done together, the shared summary;
• the couple’s streak and House on the Rock.

What your partner never sees

• your answers to 🔒 questions;
• your journal, unless you choose to share it;
• your Counselor chats;
• your balance, your credit history and how much a gesture cost;
• the words on your side of an Agreement;
• whether you answered that you don’t feel safe to talk;
• “Just mine” requests and the “Praying for [spouse]” section, in the mode for people walking alone in faith.

Notifications

They only say what happened (“Lucas finished today’s devotional”), never the content.

Unlinking and deleting your account

• Unlinking is in Settings and asks for confirmation. Each of you keeps your own journal, answers and credits; the couple’s streak and house are archived, and neither of you can edit what was archived; the other person no longer receives any events. The plan stays with whoever paid: if you weren’t the one who subscribed, your subscriber access ends with the connection. A new connection starts from scratch.
• Deleting your account: your partner is told that the connection has ended, without details, and your answers disappear from their side.

Prayer partner

Prayer partners share the question of the week (the other person’s answer appears after you answer, as with couples), the pair’s streak if you both want it, “I prayed for you” and the requests you choose to share. Journals, devotional answers and credits are not shared.

Groups

Members only see who did the day’s devotional, never the answers. Prayer requests appear in the group only if you choose. Taking part in Hard Seasons tracks isn’t shown to the group. Joining a church group also reveals your faith to its members.

People who join by link, without an account

People who open an invitation, a gesture or “A Word for someone” only see the content and don’t need to sign up. People who join an Agreement or Before the Yes by link write their own answers: these are processed with the consent requested in that link, sent to the AI provider to prepare the result (section 8), kept for 90 days and can be deleted on request by emailing the Data Protection Officer. These two features are only for people 18 and older.

Other people’s data

Your partner’s name appears in the app’s text (for example, “Praying for Rafael” or “You and Rafael”). If you tell us that your spouse doesn’t share your faith, that information stays only in your account, to tailor your content, and your spouse never sees it. When you write about your spouse, your family or a friend, share only what’s necessary.

8. Counselor and other artificial intelligence features

• What is sent to the artificial intelligence provider we contract with: your message, the recent context of the conversation and the profile data needed to reply, such as your stage and names.
• What for: generating the responses of the Counselor, the Agreement, Root (a 7-day plan when the same topic comes up in 3 Agreements), Truce (offered when the Counselor notices an argument in the conversation), Before the Yes, Custom Study and “Help me write” in Letters. We use the provider in a configuration where it does not use your data to train models and deletes the data after its technical retention period.
• Agreement: each of you writes your side privately. The AI reads both sides to prepare a version for each of you, and neither of you reads the other’s words.
• “Help me write” (Letter): uses only answers you have both already seen.
• Crisis: the automatic reading of free text looks for signs of violence or crisis and opens the help screen (section 5).
• Audio (“Listen”): generated from the app’s editorial content, without any of your data.
• Always identified: the Counselor appears in the app as an AI feature.
• You can request a review of decisions made solely on the basis of automated processing (LGPD, Art. 20) by emailing the Data Protection Officer.

9. Who we share data with (processors and service providers)

We share data only with service providers that help us deliver the service, each for the purpose below. We don’t sell personal data.

We may also share data when the law requires it or by order of a competent authority.

10. Website cookies and pixels

Advertising pixels (Meta Pixel, TikTok Pixel) and Google Analytics run only on the website, never in the app. The TwoBible app contains no advertising pixels or ad-tracking SDKs.

When you first open the website, we show a notice with three options of the same size: Accept, Decline and Preferences. Declining keeps only essential cookies. You can change your choice at any time under “Cookie preferences” in the footer.

11. International transfers

Some providers process data outside Brazil. We do this only in the cases allowed by Article 33 of the LGPD, in particular under the standard contractual clauses approved by Brazil’s National Data Protection Authority (ANPD) (Resolution CD/ANPD No. 19/2024) or another valid mechanism. Between Brazil and the European Union, the 2026 mutual adequacy decision applies. When the provider allows it, we prefer regions in Brazil or the European Union.

12. How long we keep data

13. Your rights and how to exercise them

Under the LGPD (Art. 18), you can request:

• confirmation that we process your data;
• access to your data;
• correction of incomplete, inaccurate or outdated data;
• anonymization, blocking or deletion of data that is unnecessary, excessive or processed in breach of the law;
• portability of your data to another provider;
• deletion of data processed with your consent;
• information about who we share your data with;
• information about your option not to give consent and what happens if you don’t;
• withdrawal of consent;
• review of decisions made solely on the basis of automated processing (Art. 20).

How to make a request

• In the app, under Settings: “Export my data”, “Delete my answers” and “Delete account”.
• By email to the Data Protection Officer: suporte@twobible.com. We may ask you to confirm your identity before we respond.
• Deadlines: confirmation and access in simplified form, immediately; the full statement, within 15 days (Art. 19).
• Complaints: you can also file a complaint with Brazil’s National Data Protection Authority (ANPD) at gov.br/anpd.

14. Children and teens

• TwoBible is for people aged 13 and older. It isn’t made for children.
• From 13 to 17, use requires the consent of a parent or guardian, and purchases are made by an adult.
• Agreement and Before the Yes are only for people 18 and older.
• For anyone under 18, we don’t carry out profiling for advertising and we don’t send profile-based conversion events to ad pixels, in line with Brazil’s Digital Statute of Children and Adolescents (Estatuto Digital da Criança e do Adolescente, Law No. 15,211/2025).
• Parents and guardians can contact the Data Protection Officer (suporte@twobible.com) to keep track of the minor’s data or ask for it to be deleted. If we learn that someone under 13 has created an account, we delete their data.

15. Security

• Each record can only be read by those the rules allow (row-level access control in the database).
• Revealing answers, counting streaks and charging credits happen on the server, never only on your phone.
• Encrypted connections, and sensitive content (journal and Agreements) encrypted in storage.
• We collect only what’s necessary and don’t store card data.
• If there is a security incident with significant risk, we notify you and the ANPD, as the law requires (Art. 48).

16. Communications

• Service emails: purchase confirmation, a reminder the day before your free trial ends, a notice before each annual renewal, receipts and security notices. As long as you have a subscription, these keep coming.
• News and updates emails: only with your consent, and you can unsubscribe whenever you want.
• App notifications: you choose the types and quiet hours in Settings.

17. Changes to this Policy

If we change anything significant, we’ll let you know by email or in the app before the change takes effect. The date of the last update is at the top, and we keep previous versions.

18. Contact

Eagle Fire Digital LTDA, Brazilian company number (CNPJ) 54.995.320/0001-58

Support and Data Protection Officer: suporte@twobible.com

19. Annex A: European Union, European Economic Area and United Kingdom

• The legal bases under the General Data Protection Regulation (GDPR) are the equivalents of those in section 6: contract (Art. 6(1)(b)), legal obligation (Art. 6(1)(c)), legitimate interest (Art. 6(1)(f)) and consent (Art. 6(1)(a)). For religious data, we ask for explicit consent (Art. 9(2)(a)).
• Representative in the European Union (Art. 27): will be named here before we offer the service to residents of the European Union.
• In some countries, the minimum age to consent on your own is higher than 13; in those cases, your country’s age applies.
• You have the rights of access, rectification, erasure, restriction, portability and objection, and you can lodge a complaint with your country’s data protection authority (in Portugal, the CNPD).

20. Annex B: United States

• We don’t sell personal data. The ad pixels on the website may be considered “sharing” under some state laws; that’s why they only work with your consent.
• Religious belief is treated as sensitive personal information.
• We don’t accept accounts from children under 13 (COPPA).
• Requests from residents of California and other states: suporte@twobible.com.

Back to contents