PRIVACY POLICY

Suka

Effective Date: March 24, 2026

Welcome to Suka (the "App", "Platform", "we", "us", or "our"). Suka is a mobile application dedicated to authentic, real-person live streaming experiences. We are committed to safeguarding the privacy and personal data of every individual who accesses or uses our services. This Privacy Policy explains in detail how we collect, use, store, share, and protect your information when you interact with Suka, including our website, mobile applications, and any related services (collectively, the "Services").

By downloading, installing, registering for, or using Suka, you acknowledge that you have read, understood, and agree to the terms set forth in this Privacy Policy. If you do not agree with any part of this policy, please do not access or use the Services.

This Privacy Policy is intended to comply with applicable data protection laws and regulations worldwide, including but not limited to the General Data Protection Regulation (GDPR), the California Consumer Privacy Act (CCPA), the California Privacy Rights Act (CPRA), the Brazilian General Data Protection Law (LGPD), and other relevant legislation. We encourage you to read this document carefully.

1. Definitions and Interpretation

In this Privacy Policy, the following terms carry the meanings assigned below unless the context clearly indicates otherwise:

2. Information We Collect

We collect information through various channels when you interact with Suka. The categories of information we collect are described below.

2.1 Account and Registration Information

When you create an account on Suka, we collect information you voluntarily provide, including your display name, email address, phone number, date of birth, gender, and profile photograph. If you choose to register or sign in through a third-party social media account (such as Apple, Google, or Facebook), we may receive certain profile information from that provider in accordance with their policies and your privacy settings.

2.2 Identity Verification Data

To maintain the authenticity and safety of our live streaming community, we may require identity verification. This may include government-issued identification documents, facial recognition data for liveness checks, and selfie photographs submitted during the verification process. This data is used strictly for verification purposes and is handled with heightened security measures.

2.3 Device and Technical Information

We automatically collect technical information about your device and how you access the App, including your device model, operating system version, unique device identifiers (such as IDFA, GAID, or UUID), IP address, browser type, mobile carrier, time zone settings, language preferences, screen resolution, and hardware specifications.

2.4 Location Data

With your explicit consent, we may collect precise or approximate geolocation data from your mobile device. This information enables us to offer location-based features, recommend nearby content creators, and comply with regional regulatory requirements. You may revoke location permissions at any time through your device settings, though some features may become unavailable as a result.

2.5 Usage and Behavioral Data

We collect information about how you use Suka, including pages visited, features accessed, live streams watched or participated in, duration of sessions, interaction patterns (such as likes, follows, gifts, and messages), search queries, and navigation paths within the App. This data helps us understand user behavior and improve the overall experience.

2.6 Communication and Messaging Data

When you use Suka's messaging features, we collect the content of messages exchanged between users, along with metadata such as timestamps, sender and recipient identifiers, and message delivery status. We may also collect information from communications you have with our customer support team.

2.7 Financial and Transaction Data

If you make purchases or engage in monetary transactions on the Platform (such as purchasing virtual gifts or subscribing to premium features), we collect transaction records, purchase history, payment method details (processed securely through third-party payment providers), and billing information. We do not store complete credit card numbers on our servers.

2.8 User-Generated Content

We collect and store content you create and share on Suka, including live stream recordings, uploaded photos and videos, profile descriptions, comments, and any other materials you publish or broadcast through the Platform.

2.9 Cookies and Tracking Technologies

We use cookies, web beacons, pixel tags, software development kits (SDKs), and similar tracking technologies to collect information about your interactions with our Services. These technologies help us authenticate users, remember preferences, analyze traffic patterns, measure advertising effectiveness, and deliver personalized content.

3. Legal Bases for Processing Personal Data

We process your Personal Data under the following legal bases, as applicable under relevant data protection legislation:

4. How We Use Your Information

The information we collect is used for the following purposes:

4.1 Providing and Operating the Services

We use your information to create and manage your account, facilitate live streaming sessions, enable social interactions between users, process transactions, and deliver core platform functionality.

4.2 Personalization and Content Recommendations

We analyze your usage patterns, preferences, and behavioral data to personalize your experience, including recommending content creators, curating your discovery feed, and tailoring notifications to your interests. Our recommendation algorithms consider factors such as viewing history, engagement patterns, language preferences, and geographic proximity.

4.3 Safety, Security, and Fraud Prevention

We use information to detect, investigate, and prevent fraudulent activities, unauthorized access, spam, abuse, and violations of our Terms of Service. This includes automated systems that monitor content and behavior patterns to protect the safety of our community.

4.4 Communication

We use your contact information to send you service-related communications, including account verification messages, security alerts, transaction confirmations, policy updates, and customer support responses. With your consent, we may also send promotional communications, which you can opt out of at any time.

4.5 Analytics and Service Improvement

We use aggregated and de-identified data to conduct research, analyze trends, evaluate feature performance, troubleshoot technical issues, and develop new products and services. These analytics help us make data-driven decisions to enhance the quality and reliability of Suka.

4.6 Advertising and Marketing

We may use your information to deliver relevant advertisements within the App and across third-party platforms. This may include interest-based advertising informed by your usage behavior and preferences. You can manage your advertising preferences through the App settings or through your device's operating system privacy controls.

4.7 Legal and Regulatory Compliance

We use your information as necessary to comply with applicable laws, regulations, legal processes, or governmental requests, including responding to court orders, subpoenas, and regulatory investigations.

5. Information Sharing and Disclosure

We do not sell your Personal Data to third parties. However, we may share your information in the following circumstances:

5.1 Service Providers and Partners

We share information with trusted third-party service providers who assist us in operating the Platform, including cloud hosting providers, payment processors, analytics services, content delivery networks, identity verification vendors, and customer support tools. These providers are contractually obligated to use your data only for the purposes we specify and to implement appropriate security measures.

5.2 Other Users and the Public

Certain information you provide is visible to other users by design, including your display name, profile photo, bio, live stream content, and public activity on the Platform. Information shared during live streams may be viewed by a broad audience in real time. Please exercise caution when sharing personal information in public or semi-public contexts.

5.3 Legal Requirements and Law Enforcement

We may disclose your information if required to do so by law or if we believe in good faith that such disclosure is necessary to comply with legal obligations, enforce our Terms of Service, protect the safety or rights of Suka, its users, or the public, or respond to a lawful government request.

5.4 Business Transfers

In the event of a merger, acquisition, reorganization, bankruptcy, or other similar corporate event, your Personal Data may be transferred to the acquiring entity or successor organization. We will provide notice before your data is transferred and becomes subject to a different privacy policy.

5.5 With Your Consent

We may share your information with third parties when you explicitly provide your consent or direct us to do so, such as when you connect your Suka account with external services or participate in co-branded promotions.

5.6 Aggregated and De-Identified Data

We may share aggregated, anonymized, or de-identified information with partners, advertisers, and researchers for purposes such as market analysis, academic research, and industry benchmarking. This information cannot reasonably be used to identify any individual.

6. Data Retention

We retain your Personal Data only for as long as reasonably necessary to fulfill the purposes for which it was collected, including to satisfy legal, regulatory, accounting, or reporting requirements. The specific retention period depends on the nature of the data and the purpose of processing.

Account information is retained for the duration of your active account and for a reasonable period thereafter (typically up to 36 months) to allow for account reactivation, dispute resolution, and compliance with legal obligations. Transaction records may be retained for longer periods as required by applicable financial regulations. When data is no longer required, it is securely deleted or anonymized in accordance with our data destruction procedures.

7. International Data Transfers

Suka operates globally, and your information may be transferred to, stored in, and processed in countries other than your country of residence. These countries may have data protection laws that differ from the laws of your jurisdiction. When we transfer data internationally, we implement appropriate safeguards to ensure your data remains protected, including:

By using Suka, you acknowledge and consent to the transfer of your information to jurisdictions outside your own, subject to the safeguards described herein.

8. Data Security

We implement a comprehensive range of technical, organizational, and administrative security measures designed to protect your Personal Data against unauthorized access, alteration, disclosure, destruction, or loss. These measures include:

While we strive to protect your information, no method of electronic transmission or storage is completely secure. We cannot guarantee absolute security, but we are committed to maintaining the highest practicable standards.

9. Your Rights and Choices

Depending on your jurisdiction, you may be entitled to exercise the following rights regarding your Personal Data:

9.1 Right of Access

You have the right to request a copy of the Personal Data we hold about you. We will provide this information in a commonly used, machine-readable format within the timeframe required by applicable law.

9.2 Right to Rectification

You have the right to request correction of inaccurate or incomplete Personal Data. You may update most of your account information directly through the App settings.

9.3 Right to Erasure (Right to Be Forgotten)

You may request the deletion of your Personal Data, subject to certain exceptions required by law (such as data retention for legal compliance or dispute resolution). Upon receiving a valid erasure request, we will delete or anonymize your data within a reasonable timeframe and confirm completion.

9.4 Right to Data Portability

Where technically feasible and required by law, you may request that we export your Personal Data in a structured, commonly used, and machine-readable format for transfer to another service provider.

9.5 Right to Restrict Processing

You may request that we limit the processing of your Personal Data in certain circumstances, such as while we verify the accuracy of your data or assess the validity of an objection to processing.

9.6 Right to Object

You have the right to object to the processing of your Personal Data for certain purposes, including direct marketing and processing based on legitimate interests. We will cease such processing unless we can demonstrate compelling legitimate grounds.

9.7 Right to Withdraw Consent

Where processing is based on consent, you may withdraw your consent at any time. Withdrawal of consent does not affect the lawfulness of processing conducted prior to the withdrawal.

9.8 Right to Lodge a Complaint

If you believe that your data protection rights have been infringed, you have the right to lodge a complaint with the relevant supervisory authority in your jurisdiction.

To exercise any of these rights, please contact us at service@suka.blog. We will respond to your request within the timeframe required by applicable law, typically within 30 calendar days.

10. Children's Privacy and Protection of Minors

Suka is intended exclusively for individuals who are 18 years of age or older. We do not knowingly collect, solicit, or process Personal Data from anyone under the age of 18. If you are under 18 years old, you are not permitted to use the Platform under any circumstances.

10.1 Age Verification Measures

We implement age verification mechanisms during the registration process to prevent individuals under 18 from accessing the Platform. These mechanisms may include date-of-birth verification, identity document checks, and other age-gating techniques. We continuously work to strengthen these safeguards.

10.2 Parental and Guardian Notice

If a parent, legal guardian, or any responsible adult becomes aware that a minor under the age of 18 has provided us with Personal Data or has created an account on Suka, they should immediately contact us at service@suka.blog. Upon verification, we will promptly delete the minor's account and all associated Personal Data from our systems.

10.3 Child Sexual Abuse and Exploitation (CSAE)

Suka maintains a zero-tolerance policy toward Child Sexual Abuse and Exploitation (CSAE) in all its forms. We are deeply committed to the protection of children and strictly prohibit any content, behavior, or activity that involves, depicts, promotes, glorifies, or facilitates the sexual abuse, exploitation, or endangerment of minors. This prohibition includes, but is not limited to:

We employ a combination of automated detection tools (including hash-matching technologies such as PhotoDNA and perceptual hashing), human review teams, and machine-learning classifiers to proactively identify and remove CSAE content. All confirmed instances are reported to the National Center for Missing & Exploited Children (NCMEC) and other relevant law enforcement agencies in accordance with applicable legal obligations. Accounts found to engage in CSAE-related activity are immediately and permanently terminated without prior notice.

10.4 Cooperation with Law Enforcement

We fully cooperate with law enforcement agencies and child protection organizations worldwide in their efforts to investigate and combat child exploitation. We may proactively refer suspected CSAE cases to the appropriate authorities even where not expressly required by law.

11. User-Generated Content (UGC)

11.1 Collection and Storage of UGC

When you create, upload, publish, or broadcast content through Suka, including live streams, photos, videos, text posts, and comments, we collect and store that content on our servers. UGC may be retained for the duration of your account and for a reasonable period following account deletion to address any pending disputes, appeals, or legal obligations.

11.2 Use and Display of UGC

UGC you share publicly on Suka may be displayed to other users, featured in promotional materials, or used to improve our content recommendation systems. By posting content on the Platform, you grant Suka a non-exclusive, worldwide, royalty-free, sublicensable, and transferable license to use, reproduce, distribute, prepare derivative works of, display, and perform your content in connection with the Services, as further described in our Terms of Service.

11.3 Content Moderation and Enforcement

We employ both automated tools and human moderators to review UGC for compliance with our Community Guidelines and Terms of Service. Content that is found to violate our policies, including content that is illegal, abusive, sexually explicit, hateful, misleading, or otherwise harmful, may be removed, restricted, or flagged without prior notice. Users who repeatedly violate our content policies may face account suspension or permanent ban.

11.4 Copyright and Intellectual Property

Suka respects intellectual property rights and complies with applicable copyright laws, including the Digital Millennium Copyright Act (DMCA). If you believe that your copyrighted work has been used on our Platform without authorization, you may submit a copyright infringement notice to us. We will investigate all valid claims and take appropriate action, which may include removing the infringing content and disabling the accounts of repeat infringers.

11.5 Deletion of UGC

You may delete your own UGC at any time through the App. Please note that copies of deleted content may persist in our backup systems for a limited period and that content previously shared with or saved by other users may remain accessible. We are not responsible for content that has been redistributed by third parties.

12. Cookies, Tracking Technologies, and Automated Decision-Making

We use cookies and similar technologies to enhance your experience and gather usage data. You may manage your cookie preferences through your browser or device settings. We categorize our cookies as follows:

We may also engage in automated decision-making, including profiling, to personalize your content feed and detect potential policy violations. You have the right to request human review of any automated decision that significantly affects you.

13. Third-Party Links, SDKs, and Integrations

Suka may contain links to external websites, embed third-party SDKs, or integrate with third-party services (such as payment gateways, social login providers, analytics platforms, and advertising networks). These third parties have their own privacy policies, and we are not responsible for their data practices. We encourage you to review the privacy policies of any third-party service you interact with through our Platform.

We may integrate third-party SDKs that collect data on our behalf or for their own purposes, including crash reporting tools, attribution services, and advertising measurement platforms. A list of major SDK partners and their privacy policies may be available in our App or upon request.

14. Push Notifications and Communication Preferences

With your permission, we may send push notifications to your device to alert you about live stream activities, messages, promotions, and account-related updates. You may manage or disable push notifications at any time through your device settings or within the App. Disabling push notifications will not affect your ability to use the core Services, though you may miss time-sensitive alerts.

15. Do Not Track Signals

Some browsers offer a "Do Not Track" (DNT) feature that signals to websites and services that you do not wish to be tracked. There is no universally accepted standard for how to respond to DNT signals. At this time, Suka does not respond to DNT browser signals. However, you can manage your privacy preferences through the tools and options described in this Privacy Policy.

16. California Privacy Rights (CCPA/CPRA)

If you are a California resident, you have additional rights under the California Consumer Privacy Act (CCPA), as amended by the California Privacy Rights Act (CPRA):

We do not sell Personal Data as defined under the CCPA. To submit a request, please contact us at service@suka.blog or use the in-app privacy request feature.

17. Rights for Users in the European Economic Area (EEA), United Kingdom, and Switzerland

If you are located in the EEA, United Kingdom, or Switzerland, you benefit from the data protection rights afforded under the GDPR and equivalent local legislation. In addition to the rights described in Section 9, you may contact our designated Data Protection Officer or representative for the EEA/UK by emailing service@suka.blog. You also have the right to lodge a complaint with your local Data Protection Authority (DPA).

18. Biometric Data

In connection with identity verification and safety features, we may collect biometric data, including facial geometry data derived from photographs or live selfie captures. Biometric data is collected only with your explicit consent and is used solely for verification, fraud prevention, and platform safety. We do not sell biometric data. Biometric data is retained only for as long as necessary to fulfill the purpose for which it was collected and is securely deleted thereafter, in compliance with applicable biometric privacy laws such as the Illinois Biometric Information Privacy Act (BIPA).

19. Virtual Currency, Gifts, and Creator Monetization

Suka enables users to purchase virtual currency, send virtual gifts to content creators during live streams, and participate in monetization programs. We collect and retain records of these transactions, including amounts, timestamps, involved parties, and payment methods. This data is used to facilitate transactions, calculate creator earnings, prevent fraud, and comply with tax and financial reporting obligations. Transaction records are retained for the period required by applicable financial regulations.

20. Live Streaming Specific Provisions

Live streaming on Suka involves the real-time transmission of audio and video content. During a live stream, viewers and hosts may share personal information verbally or visually. We advise all users to exercise caution and refrain from disclosing sensitive personal details during live broadcasts.

We may record and temporarily store live stream sessions for content moderation, safety review, and quality assurance purposes. Recorded streams are subject to automated and manual review to ensure compliance with our Community Guidelines. Users will be notified through the App interface when recording is in effect.

21. Use of Artificial Intelligence and Machine Learning

Suka uses artificial intelligence (AI) and machine learning technologies to enhance various aspects of the Services, including content moderation, content recommendation, fraud detection, user matching, and safety monitoring. AI-driven systems process data such as behavioral signals, content features, and usage patterns to make predictions and automated decisions.

We are committed to responsible AI practices and regularly review our automated systems for accuracy, fairness, and potential bias. Users have the right to request information about the logic involved in automated decision-making processes that significantly affect them, and to request human review of such decisions.

22. Data Breach Notification

In the event of a data breach that is likely to result in a risk to your rights and freedoms, we will notify affected users and the relevant supervisory authorities without undue delay and, where feasible, within 72 hours of becoming aware of the breach. Notification will include a description of the nature of the breach, the categories and approximate number of individuals affected, the likely consequences, and the measures taken or proposed to address the breach and mitigate its effects.

23. Account Deletion and Data Upon Termination

You may request deletion of your Suka account at any time through the App settings or by contacting us at service@suka.blog. Upon account deletion:

24. Accessibility and Language

We strive to make this Privacy Policy accessible and understandable to users from diverse backgrounds and jurisdictions. If you require this policy in a language other than English or need assistance understanding any provision, please contact us at service@suka.blog and we will make reasonable efforts to accommodate your request.

25. Governing Law and Dispute Resolution

This Privacy Policy shall be governed by and construed in accordance with the laws of the jurisdiction in which Suka is incorporated, without regard to its conflict of laws principles. Any disputes arising from or relating to this Privacy Policy shall be resolved through binding arbitration or in the competent courts of the relevant jurisdiction, as specified in our Terms of Service. Nothing in this section limits your right to bring proceedings before a court in your country of habitual residence where permitted by law.

26. Severability

If any provision of this Privacy Policy is found to be invalid, unlawful, or unenforceable by a court of competent jurisdiction, that provision shall be severed from the remaining terms, which shall continue in full force and effect. The invalid provision shall be replaced with a valid provision that most closely reflects the original intent.

27. Changes and Updates to This Privacy Policy

We reserve the right to modify, amend, or update this Privacy Policy at any time to reflect changes in our data practices, legal requirements, or business operations. When we make material changes:

We encourage you to review this Privacy Policy periodically to stay informed about how we protect your information. Your continued use of the Services after the effective date of any update constitutes your acceptance of the revised Privacy Policy.

28. Contact Us

If you have any questions, concerns, or requests regarding this Privacy Policy or our data practices, please do not hesitate to reach out to us through the following channels:

Email: service@suka.blog

In-App: Navigate to Settings > Help & Support > Privacy Inquiry

We will make every reasonable effort to respond to your inquiry within 30 calendar days. For data protection inquiries from the European Economic Area, United Kingdom, or Switzerland, please include "GDPR Request" in your subject line to ensure priority handling.

Thank you for trusting Suka with your personal information. We are dedicated to maintaining the highest standards of privacy and transparency as we build a platform centered on authentic human connection.