Privacy Policy

Last updated: July 20, 2026

Quuque ("we", "us") is committed to protecting your personal information. This Privacy Policy explains what data we collect, how we use it, and your rights. By using the Platform, you agree to this policy.

1. Data Controller

The data controller responsible for your personal data is: PT. Oxis Onix Zilo Menara Laswi Residence No 87 P, Jalan Raya Laswi Baleendah, Kabupaten Bandung, Jawa Barat, Indonesia Email: admin@quuque.com If you are located in the European Economic Area (EEA), our Data Protection Officer (DPO) can be contacted at dpo@quuque.com.

2. Data We Collect

2.1. Account & Profile Data When you register: name, email address, phone number, date of birth, profile photo, and country. 2.2. KYP (Know Your Professional) Data For creators undergoing professional verification: professional licenses, diplomas, certificates, and government-issued ID documents. 2.3. Content & Activity Data Videos, voice notes, images, and documents you upload; comments you post; Coaching Class questions and answers; tip and gift transactions; view history; search queries. 2.4. Payment & Wallet Data Coin top-up transactions and Gem earnings. We do not store full credit card numbers. Payment gateway partners handle card data under PCI-DSS. 2.5. Communication Data Direct messages (DM), ChatQuu group messages, and call metadata (duration, participants). End-to-end encryption for DM is planned for a future release. 2.6. Device & Technical Data IP address, device type, OS version, browser type, app version, device ID, push notification tokens, and crash/error logs. 2.7. Usage & Analytics Data Pages viewed, features used, video watch time, tap events, and engagement patterns. This data powers our feed ranking and recommendation logic. 2.8. AI Processing Data Audio and video comments uploaded to the Platform may be transcribed and semantically analyzed by the Gemini API to generate content recommendations. See Section 6 for details.

3. How We Use Your Data

We use your data to: • Operate and improve the Platform (account management, content delivery, HLS video streaming). • Process payments and wallet transactions. • Review submitted creator credentials (KYP) and enforce platform compliance. • Personalize your feed using our two-tier recommendation engine (entertainment vector + urgency escalation vector). • Send you transactional notifications (tips received, coaching payments, DM messages, call alerts). • Detect and prevent fraud, abuse, and policy violations. • Fulfill legal and regulatory obligations. • Conduct analytics to improve product features and fix bugs. • Serve contextual advertising (Track 1 ad interstitials).

4. Legal Basis for Processing (GDPR / applicable law)

• Contract performance: processing necessary to provide the services you requested (account, wallet, Coaching Sessions). • Legitimate interests: fraud detection, platform security, product improvement. • Consent: marketing communications and personalized advertising (you may withdraw consent at any time). • Legal obligation: KYP verification, tax reporting, regulatory compliance.

5. Data Sharing & Third Parties

We share your data with: 5.1. Payment Processors: Midtrans (web payments); Apple App Store, Google Play Store (in-app purchases); RevenueCat SDK (IAP management). These process payment data under their own privacy policies. 5.2. Cloud & Infrastructure: Oracle Cloud Infrastructure (servers); MinIO / Cloudflare (media storage and CDN). 5.3. AI Services: Google Gemini API, used as a fallback transcription engine for auto-generated video captions when our primary on-device speech-to-text engine cannot complete a portion. Gemini processes content per Google's data processing terms. 5.4. Real-Time Communications: LiveKit (WebRTC server for Coaching Sessions and live coaching). Media streams are processed by LiveKit under their terms. 5.5. Push Notifications: Firebase Cloud Messaging (FCM) by Google. 5.6. Analytics & Monitoring: Sentry (error monitoring); our own in-house analytics systems (page views, feature usage, and video/earnings performance) to improve the Platform. 5.7. Legal Authorities: We may disclose data if required by law or court order. We do not sell your personal data to third-party advertisers.

6. AI & Automated Processing

Video you upload to the Platform is automatically transcribed to generate closed captions, primarily by an on-device speech-to-text engine; the Google Gemini API is used only as a fallback for the portions our primary engine cannot process (see §5.3). AI processing is fully automated. It does not constitute a significant decision about you individually and does not produce legal effects.

7. Data Retention

• Account data: retained while your account is active and for 90 days after deletion. • Wallet ledgers (TransactionLedger, GemLedger): retained for 7 years for financial compliance. • KYP documents: retained for 5 years from submission per regulatory requirements. • Video content: deleted from storage within 30 days of account deletion or content removal. • Chat messages: retained for 2 years; deleted sooner on user request subject to legal hold exceptions.

8. International Data Transfers

Your data may be transferred to and processed in countries other than your own, including Singapore, where our production servers are located. Where required, we use Standard Contractual Clauses (SCCs) approved by the European Commission to protect data transferred outside the EEA.

9. Your Rights

Depending on your jurisdiction, you may have the right to: • Access: request a copy of the personal data we hold about you. • Correction: request correction of inaccurate data. • Deletion: request deletion of your data ("right to be forgotten"). • Portability: receive your data in a machine-readable format. • Restriction: ask us to pause processing in certain circumstances. • Objection: object to processing based on legitimate interests or for direct marketing. • Withdraw consent: for processing based on your consent, at any time. To exercise any of these rights, email admin@quuque.com. We will respond within 30 days. You may also lodge a complaint with your local data protection authority.

10. Cookies & Tracking

The Quuque web portal uses cookies and similar technologies for: • Authentication and session management (strictly necessary). • Analytics and performance monitoring (with your consent). • Advertising measurement (with your consent). The mobile app uses equivalent device-level identifiers (Advertising ID / IDFA). You can reset or opt out of ad tracking in your device settings. iOS users will be prompted for App Tracking Transparency (ATT) consent on first launch. This site is protected by reCAPTCHA and the Google Privacy Policy and Terms of Service apply. We use invisible reCAPTCHA during phone number verification to prevent SMS abuse.

11. Security

We implement industry-standard security measures including: • TLS/HTTPS encryption for all data in transit. • At-rest encryption for stored media and database backups. • JWT with refresh token rotation and blacklisting for session management. • Atomic wallet operations with row-level locking to prevent tampering. • Firebase Admin SDK for social authentication token verification. No security measure is 100% foolproof. In the event of a data breach affecting your rights, we will notify you within 72 hours of becoming aware.

12. Children's Privacy

Quuque is not intended for users under 17 years old. We do not knowingly collect personal data from minors. If you believe a minor has registered, contact us at admin@quuque.com and we will promptly delete the account.

13. Changes to This Policy

We may update this Privacy Policy from time to time. Material changes will be communicated via in-app notification or email at least 14 days before taking effect. The latest version is always available in the app under Profile → Privacy Policy, and at quuque.com/privacy.

Privacy Contact

For privacy-related requests or questions, contact our Privacy team:

admin@quuque.com