Privacy Policy

PT Genius Growth Indonesia ("GeniusGrowth.ai", "we"), part of the Genius Growth Holdings Inc. group, is the personal data controller for the Services described in our Terms and Conditions, including GG.AI, GG Universe, GG Learning Centre, 100English, GG School LMS, GG Parent and Teman AI.

We process personal data in line with Law No. 27 of 2022 on Personal Data Protection (UU PDP), Indonesia's electronic systems and child protection regulations, and, where they apply to users outside Indonesia, other privacy laws such as the US Children's Online Privacy Protection Act (COPPA).

When a school or learning centre gives its students accounts, it may also be a controller of the data it enters or sees, under its own agreement with us.

What we collect depends on the product and features you use:

• Account data: name, username, email address, phone number (if you sign in with it), password (stored encrypted), date of birth or age, profile photo, study level, learning goals, school or group, referral code, and the consents you gave.
• Sign-in data from Google or Apple when you choose to sign in with them.
• Learning data: chats with AI tutors and teachers, questions, answers, quiz and test results, notes, uploaded files and images, study plans, progress, streaks, points and the learning profile our AI builds from your activity (for example your preferences and skill levels), plus progress and talent reports.
• Voice data: recordings and transcripts when you use voice chat, live voice, translation, the audio summarizer or recorded classes.
• Wellbeing data you choose to share, such as mood tracker and journal entries and support chat messages. We treat this as sensitive.
• Social data: friends, blocks, group and forum messages and content you share with other users.
• Purchase data: plans, coins and packages bought, invoices and payment status. Card and e-wallet details are entered with our payment partners; we receive only limited details such as the payment method and transaction reference.
• Earnings data for affiliates, creators and teachers: commissions, downlines, and the bank or e-wallet account for payouts.
• Delivery data, such as a name, address and phone number, when you claim a physical reward.
• Device and usage data: device model, operating system, app version, language, push notification token, approximate location or city if you allow it, log data, and app analytics.

We do not show third party advertising in our apps, and we do not sell personal data.

We use personal data, based on your consent, our contract with you, our legal obligations or our legitimate interests as allowed by UU PDP, to:

• create and secure your account and verify age and parental consent;
• provide AI tutoring, voice, quizzes, reports, groups, classes and other features, and personalize learning to your level and goals;
• let parents, teachers or schools you or your parent connected see progress and reports;
• process payments, coins, rewards, commissions and payouts, and keep financial records;
• keep the Services safe: moderate content, detect fraud and abuse, and respond to reports;
• measure and improve the quality of our Services and AI, using de-identified or aggregated data where possible;
• send service messages and, if you agree, news and offers you can switch off at any time;
• meet legal obligations and respond to lawful requests from authorities.

We do not use children's data for profiling for commercial purposes or for targeted advertising, and we do not use it to train AI models without the consent required by law.

Many of our users are children. For users under 18 we rely on the consent of a parent or guardian, given directly or through the child's school or learning centre, and we may ask for confirmation.

Parents and guardians can ask to see, correct or delete their child's data, withdraw consent, or close the child's account at any time by contacting us. We may need to confirm that you are the child's parent or guardian.

We keep features that let children contact other users limited and moderated, and we may switch them off for younger users.

We share personal data only as needed for the purposes above, with:

• Service providers who process data on our behalf: cloud hosting and storage, Google Firebase (sign-in, file storage, notifications, analytics), AI model providers such as Google (Gemini) and Alibaba Cloud (Qwen) that process prompts, voice and text to generate responses, translation services, and customer support tools.
• Payment partners: Apple App Store, Google Play, Midtrans, Prismalink and the banks and e-wallets you choose.
• People you choose to share with: friends, group members, teachers, parents or schools you connect, and other users who see content you post.
• Your school, learning centre or organization, if it provided your account.
• Companies in the Genius Growth group that help run the Services.
• Authorities, courts or other parties when required by law or to protect the rights and safety of users and the public.
• A buyer or successor if our business is merged or transferred, under the same protections.

Our providers may only use the data to provide their service to us and must protect it.

Your data is stored on servers we operate or rent and on our providers' servers. Some of these are outside Indonesia, in other countries in Asia and in the United States, especially when AI models process a request.

When we transfer personal data abroad, we do so as allowed by UU PDP: to countries or providers with adequate protection, under contracts with appropriate safeguards, or with your consent.

We keep personal data while your account is active and as long as needed for the purposes in this policy. When you delete your account, we delete or anonymize your personal data within a reasonable period, except data we must keep by law (for example financial and tax records) or to resolve disputes and prevent abuse. Copies in backups are removed on their normal cycle.

Under UU PDP you, or your parent or guardian, have the right to:

• get information about how we process your data;
• access and get a copy of your data;
• correct or update inaccurate data;
• delete your data or close your account;
• withdraw consent you gave;
• object to automated decisions that significantly affect you;
• restrict or pause processing in certain cases;
• complain about how we handle your data.

You can delete your account in the app under Settings, Delete account, or make any request on the Request your data page or at contact@geniusgrowth.ai. We will verify your identity and respond within the period set by law. Withdrawing consent may mean some features stop working.

We protect data with encryption in transit, access controls, monitoring and regular reviews. No system is completely secure, so please use a strong password and never share one-time codes. If a data breach affects your personal data, we will notify you and the authorities as required by law.

We will update this policy when our Services or the law change. For important changes we will tell you in the app or by email before they take effect and ask for your consent again where the law requires.

For questions or requests about personal data, contact our data protection team at contact@geniusgrowth.ai, WhatsApp +1 (562) 645-0511, or write to PT Genius Growth Indonesia, Gedung Jaya Lantai 5 Unit A.6, Jl. M.H. Thamrin No. 12, Kebon Sirih, Menteng, Jakarta Pusat, DKI Jakarta, Indonesia.