Nira Privacy Policy

Last Updated: May 5, 2026

Effective Date: May 5, 2026

1. Introduction

CogCloud ("we," "us," "our," or "the Platform") operates the Nira mobile application and the website qisuanai.com (collectively, "Nira" or "the Service"). We are committed to protecting your privacy and personal data. This Privacy Policy explains how we collect, use, store, and share your personal information, and what rights you have regarding that information.

This Privacy Policy applies to all Nira users globally and complies with:

EU General Data Protection Regulation (GDPR)
U.S. Children's Online Privacy Protection Act (COPPA)
Singapore Personal Data Protection Act (PDPA)
Indonesia Electronic Information and Transactions Law (UU ITE)
Vietnam Law on Children
U.S. TAKE IT DOWN Act
EU Artificial Intelligence Act (EU AI Act)

2. Information We Collect

2.1 Information You Provide

Information Type	Purpose	Required
Email address	Account registration and login	Yes
Date of birth	Age verification and legal compliance	Yes
Voice recordings	AI voice call functionality	Optional (during use)
Photo (front-facing)	Exclusive Avatar image generation	Optional (when creating Exclusive Avatar)
Chat logs	Exclusive Avatar personality customization	Optional (when creating Exclusive Avatar)
Voice samples (3–10 seconds)	Exclusive Avatar voice cloning	Optional (when creating Exclusive Avatar)

2.2 Information Collected Automatically

Information Type	Purpose
Device information (model, OS version)	Compatibility optimization, crash reporting
IP address	Region detection, compliance routing
Usage logs (feature frequency, call duration)	Service improvement
QS transaction records	Billing and account management

2.3 Information We Do NOT Collect

We do not store audio/video call content. Real-person video calls use end-to-end encryption (WebRTC standard). Call data is discarded immediately after the call ends. The Platform does not record, store, or enable playback.
We do not collect precise location data. Only IP-based country/region detection is used to determine applicable law.

3. Biometric Data (Special Provisions)

3.1 Definition

For purposes of this Privacy Policy, "biometric data" includes:

Your uploaded facial photo
Your provided voice sample
Facial feature vectors and voiceprint models extracted during Exclusive Avatar creation

3.2 Legal Basis

Under Article 9 of the GDPR, biometric data constitutes a "special category of personal data." Our legal basis for processing your biometric data is: Your explicit consent (GDPR Article 9(2)(a))

3.3 Usage Limitations

Biometric data is used solely to generate your Exclusive Avatar
It is not used for any other commercial purpose
It is not used for public model training
It is not shared with any third party
It is not publicly displayed

3.4 Retention Period

Raw materials (photos, chat logs, voice samples): Automatically and permanently deleted within 7 days after Exclusive Avatar distillation is complete
Generated Exclusive Avatar data: Retained until you actively delete it. Once deleted, it is immediately cleared and irrecoverable

3.5 Local .nira File Storage and Encryption

Exclusive Avatar personality data is stored locally on your device in an encrypted .nira file format
Encryption uses AES-256-GCM with a three-component key distribution (device keychain + server token + device fingerprint)
Raw distillation materials are never uploaded to Nira servers—only the cleaned, encrypted persona file is transmitted
The .nira file is device-bound; copying to another device renders it unreadable

4. Data Storage

All user personal data is stored in Singapore (Alibaba Cloud Singapore node). We do not transfer user data to any other jurisdiction for storage purposes.

5. Your Rights

Under applicable data protection laws, you have the following rights:

Right	Description	How to Exercise
Right of Access	Obtain a copy of your personal data	In-app: Settings → Export Data
Right to Rectification	Correct inaccurate personal data	In-app: Settings → Edit Profile
Right to Erasure (Right to be Forgotten)	Delete your account and all personal data	In-app: Settings → Delete Account
Right to Restriction of Processing	Restrict how we process your data	Contact privacy@qisuanai.com
Right to Data Portability	Export your data in a structured format	In-app: Settings → Export Data
Right to Withdraw Consent	Withdraw consent for biometric data at any time	In-app: Settings → Exclusive Avatar → Delete
Right to Lodge a Complaint	File a complaint with a supervisory authority	Contact your local data protection authority

Response Timeline

Account deletion: Personal data deleted within 7 days
Biometric consent withdrawal: Related data deleted within 7 days
Data export request: Copy provided within 30 days
Access request: Responded to within 30 days

6. Children and Minor Protection

6.1 Age Thresholds

Age	Permissions
Under 15	Registration prohibited
15–17	Registration requires dynamic guardian verification; Minor Mode applies
18 and above	Full functionality available

6.2 Minor Mode Restrictions

Users aged 15–17 who complete guardian verification:

✅ Allowed: AI text chat, AI voice calls
❌ Not allowed: Digital human video calls, Exclusive Avatar, Real-person video calls

6.3 Dynamic Guardian Verification

The Platform uses a dynamic knowledge-based verification system to confirm the identity of the guardian:

The minor user provides the guardian's email address
The Platform sends a verification request to the guardian's email
The guardian must correctly answer at least 2 out of 3 randomly generated dynamic questions based on publicly available data associated with the guardian's email
Upon passing, the guardian sets a 6-digit PIN and communicates it to the minor user
The minor user enters the PIN to complete registration

Anti-spoofing measures:

3 incorrect answers → 30-minute lockout
5 cumulative incorrect answers → 24-hour lockout
The guardian's email and verification timestamp are recorded for audit purposes

6.4 Guardian Rights

Guardians may:

Request to review the minor user's activity logs
Request closure of the minor user's account
Dispute QS consumption by the minor user
Withdraw consent at any time (account will be closed upon withdrawal)

Contact: guardian@qisuanai.com

7. Data Security

We implement the following technical and organizational measures:

Encryption in transit: TLS 1.3 (HTTPS)
End-to-end encryption: WebRTC DTLS-SRTP for real-person video calls
Access control: Only the CTO and Data Protection Officer may access full system logs
Log anonymization: Personally identifiable information is automatically redacted in logs
Regular audits: Security audits conducted quarterly

8. AI-Generated Content Labeling

In compliance with the EU AI Act and U.S. Deepfake regulations:

All text, voice, and video content generated by Exclusive Avatars is labeled as "AI-Generated / Digital Avatar"
Users may view content labeling information in Settings
AI-generated content may not be used to mislead others or impersonate real persons

9. Third-Party Services

Nira uses the following third-party services:

Service	Purpose	Privacy Policy
Firebase (Google)	User authentication	Firebase Privacy Policy
Stripe	Payment processing	Stripe Privacy Policy
Hive Moderation	Content moderation	Hive Privacy Policy
Cloudflare	CDN	Cloudflare Privacy Policy

10. Cookies and Tracking

Nira does not use third-party advertising or tracking cookies. We use only the following essential local storage:

Authentication token (expires in 7 days)
Language preference
Theme preference

11. Policy Updates

We may update this Privacy Policy from time to time. For material changes, we will:

Notify you via an in-app pop-up
Notify you via your registered email
Update the "Last Updated" date at the top of this page

Continued use of the Service constitutes acceptance of the updated Privacy Policy.

12. Contact Us

Matter	Contact
Privacy inquiries	privacy@qisuanai.com
Data Protection Officer (DPO)	dpo@qisuanai.com
Guardian-related matters	guardian@qisuanai.com
Report violations	report@qisuanai.com

Company Information:
CogCloud
Operational address: Singapore
Website: https://qisuanai.com