Privacy Policy
1. Four facts that shape this policy
Yunoh is an adults-only (18+) live video platform. Members buy Coins and spend them on random 1:1 Sessions with Earners. Friends exchange text Messages outside a Session. Four facts shape what follows.
Sessions are never recorded. We do not record, store or replay the video or audio of a Session. Safety systems analyse it in flight and discard it. Only moderation artefacts — a flagged still frame, a classifier score, a timestamped event — may be kept. Users are prohibited from recording Sessions.
Messages are stored, because a Message has to exist for its recipient to read it. Message text, any image a Verified Earner sends, and their metadata are held by us, seen by a moderator only where a report or detection requires it, and deleted under section 11.
There are no profiles. A Member is shown nothing about an Earner except her live video — no name, age, country, language, bio or photograph. Matching is random, with no filters.
Age assurance happens before the camera — and, in the United Kingdom, before anything at all. No Earner appears until she has passed facial age estimation and a liveness check, and no UK User reaches the interactive service until the same check passes. The face is analysed by our vendor; what reaches us is a result and a token, not an image — see section 5.
2. Who is responsible for your data
The controller of your personal data is:
PXL NexQuantum Ltd Voukourestiou 25, Neptune House, 1st floor, Flat/Office 11, Zakaki, 3045 Limassol Republic of Cyprus Company registration number: HE 497211
PXL NexQuantum Ltd is a subsidiary of NexQuantum Holdings Ltd (British Virgin Islands). The Cyprus company decides why and how your data is processed, and is the entity you deal with. Because we are established in Cyprus, the General Data Protection Regulation (Regulation (EU) 2016/679) applies, with Cypriot data protection law, supervised by the Office of the Commissioner for Personal Data Protection.
If you are in the United Kingdom, the UK General Data Protection Regulation and the Data Protection Act 2018 apply to us as well, because we offer this service to people in the UK and, for every UK User, we run age assurance before the service opens. Everything in this policy applies to you in the same terms. Your supervisory authority is the
Information Commissioner's Office (www.ico.org.uk), and you may complain to it directly. Where personal data of UK Users is transferred outside the UK, we rely on UK adequacy regulations where they cover the recipient, and otherwise on the transfer mechanisms approved for UK transfers.
Data protection contact: privacy@yunoh.com, monitored by the team responsible for privacy compliance. This policy covers Guests, Members, Earners and Verified Earners alike.
3. The personal data we collect
| Category | What it includes, and why | Lawful basis (Art. 6) |
|---|---|---|
| Account data | Email address, hashed password, account role and status, country and language, registration date. To create and run your account, authenticate you, and contact you about it. | 6(1)(b) contract |
| Matching, friend connections and blocks | Presence in the matching pool; matches offered; whether an Earner accepted or declined; friend requests and connections; blocks. To pair two people at random, route a Member to the next match, run friend connections, and keep decline and block patterns as a safety signal. A Member is never told he was declined. | 6(1)(b); 6(1)(f) legitimate interests — safety and abuse prevention |
| Age-assurance data (Gate 1, and every UK User) | What we receive is a result, not a face: an over-18 outcome, a further-check outcome, a timestamp and a verification token. The facial image and any biometric template are captured and held by our age-assurance vendor, not by us. Where the estimate does not clear, the document route runs on the same basis. To confirm an Earner is an adult before she appears on camera, and — in the United Kingdom — to confirm every User is an adult before the service opens. | 6(1)(c) legal obligation; 6(1)(f). Art. 9 position in section 5 |
| Member and Guest age signals | Self-declaration of being 18 or over, and the age-related signal returned by a payment card. Guests are admitted on self-declaration alone; we state that gap plainly. | 6(1)(c); 6(1)(f) |
| KYC and AML data (Gate 2 — Verified Earners only) | Identity document data, selfie and liveness capture, address and proof of address, date and place of birth, nationality, tax information, payout details, sanctions and PEP screening results, and our decision. To verify identity before any withdrawal, screen for money laundering and sanctions, and meet payout and tax duties. | 6(1)(c) legal obligation; 6(1)(b) |
| Session metadata | Participants, start and end, duration, the point at which billing began — the first 10 seconds of a new match are free — Coins spent, the resulting accrual, Gifts, connection quality, and whether a Session ended early. No recording is included. To bill minutes accurately, calculate earnings, resolve disputes, detect fraud and keep financial records. | 6(1)(b); 6(1)(c) accounting; 6(1)(f) fraud prevention |
| Message content and metadata | The text of every Message; any image sent by a Verified Earner — only a Verified Earner may send an image, and a Member may not send one at all; sender, recipient, timestamps, delivery and read status, whether an image was blocked, and the screening output. Messages are free to both sides and consume no Coin, so they generate no billing data. To deliver Messages, screen text, scan every image before delivery, investigate reports and hear appeals. | 6(1)(b) delivery; 6(1)(f) safety and enforcement; 6(1)(c) illegal content and child safety |
| Transient Session audio | Live audio converted to text and translated in flight for subtitles. Processed in memory, then discarded. | 6(1)(b), where you enable the feature |
| Moderation artefacts | Classifier scores and labels; a single still frame or short text excerpt where a rule appears to have been broken; timestamp; the intervention applied; user reports; the outcome of any human review. To enforce the No-Nudity Standard, protect users from abuse and illegal content, detect child sexual abuse material, and defend claims. | 6(1)(c); 6(1)(f) |
| Payment, Wallet and payout data | The fact and amount of a Coin purchase, the bundle, currency (USD), date, a processor token, the last four digits and card brand where returned, billing country, refunds and chargebacks; and, for Earners, accrual history, withdrawal requests, payout method and status, and deductions. We do not store full card numbers or security codes — those sit with our PCI-DSS-compliant payment processor. | 6(1)(b); 6(1)(c) tax and accounting; 6(1)(f) fraud prevention |
| Device, technical and security data | IP address, approximate country or region derived from it, device and browser characteristics, session identifiers, crash logs, CDN security telemetry. Being web-first, we collect no mobile advertising identifier, no app SDK telemetry and no push token. To deliver and stabilise the service, resist attacks and account takeover, and detect ban evasion. | 6(1)(b); 6(1)(f) security and fraud prevention |
| Fraud and risk signals | Risk scores and flags, purchase and refund patterns, device associations, velocity checks, links between accounts. To prevent payment fraud, chargeback abuse, account sharing, ban evasion and abuse of Guest free minutes. | 6(1)(f); 6(1)(c) where AML rules apply |
| Support correspondence | Your messages to us, tickets, safety reports, complaints, our replies and attachments. To answer you, investigate, and keep an audit trail of decisions. | 6(1)(b); 6(1)(c) complaint handling; 6(1)(f) |
| Marketing and cookie preferences | Whether you opted in to marketing email and your engagement with it; your cookie choices, the date, and the policy version shown. See the Cookie Policy. | 6(1)(a) consent; 6(1)(f) for strictly necessary technologies |
Some data reaches us from third parties: age and identity results from our age-assurance vendor and from Persona; transaction results, tokens, partial card details and fraud indicators from our payment processor; moderation classifications from Hive AI; reports made about you by other users; and sanctions and politically-exposed-person sources used in AML screening.
We do not ask for data about your health, sexual orientation, religion, politics, trade union membership or racial or ethnic origin. If you volunteer it in a support message or a Message, we process it only so far as necessary to answer you or enforce our rules.
Where we rely on legitimate interests, we have carried out and recorded a balancing assessment. It covers the interest pursued — safety, fraud prevention, network security, enforcement, dispute resolution — whether the processing is necessary to achieve it, what you would reasonably expect, the effect on you, and the safeguards that reduce it: not recording Sessions, minimising what is kept, restricting access, and your right to object under section 12.
We do not sell personal data, ever, and we run no advertising cookies or pixels at launch.
4. Children
Yunoh is an 18+ service. It is not directed at children and we do not knowingly collect data from anyone under 18. If we learn that a user is under 18 we close the account immediately, end any Session, and withhold any Wallet balance — we cannot lawfully pay a minor. We then delete the data, keeping only what is needed to enforce the ban, prevent re-registration, or meet a legal obligation or a report to the authorities. If you believe a minor is using the Platform, tell us at support@yunoh.com and we will treat it as a priority.
5. Special-category data and Article 9
5.1 Facial age estimation and liveness (Gate 1, and every UK User) To decide whether a person is an adult, our age-assurance vendor analyses an image of the face. Where that produces a biometric template or measurement used to decide about a specific individual, it is biometric data and Article 9 GDPR applies to it.
Who holds what, which is the part that matters. The capture happens in the vendor's flow. The vendor returns to us an over-18 outcome, a further-check outcome, a timestamp and a verification token. We do not receive the facial image and we do not receive the biometric template. We do not build a facial-recognition database, match faces across users, or use any of this for identification, advertising or emotion inference. What we keep is the decision and the token.
That division is deliberate and it is written into the vendor contract. It means the biometric processing sits with the vendor, on our instructions and under a data-processing agreement, and that we hold a result rather than a face.
Who this applies to, which changed on 1 September 2026. Facial age estimation originally ran only on Earners, at Gate 1. It now also runs on every User in the United Kingdom, before any part of the interactive service opens, because UK law requires highly effective age assurance there and a self-declaration does not meet it. If you are in the UK, this section describes processing that concerns you whether or not you ever earn on Yunoh.
Our position on the Article 9 condition. Where explicit consent is relied on, it is sought by the vendor on a separate, unbundled screen explaining what is captured, by whom, why, for how long, and that you may refuse. We also consider the processing necessary for reasons of substantial public interest in keeping children off an adults-only service, which points to Article 9(2)(g) read with the applicable national law. Which condition properly carries it is not settled, and we would rather say so than pretend otherwise.
A document alternative exists. If you prefer not to be assessed by facial estimation, or the estimate does not clear, a government-issued identity document route is available. Every refusal is reviewed by a person.
If you refuse the capture, you cannot appear on camera as an Earner. Outside the United Kingdom you may still use the Platform as an ordinary User; in the United Kingdom you cannot, because the check is what opens the service.
5.2 Moderation artefacts, Messages and identity documents Moderation may incidentally capture material revealing special-category information — a still frame showing religious dress, or two friends writing about health or faith. We do not seek it, and use it only to deliver the Message and keep the Platform safe. Where it is retained we rely on Article 9(2)(g), and on Article 9(2)(f) where a legal claim is in play.
Identity documents at Gate 1 fallback and Gate 2 are not automatically special-category data, but are highly sensitive: encrypted at rest, restricted to trained reviewers, and kept only for the periods in section 11.
6. Automated decision-making, profiling and AI
We use automated systems in three places. All three are described in the User Agreement, in its section on AI on the Platform.
6.1 Age assurance. An automated system estimates age from a facial image against a conservative buffer — a person is treated as under-age unless the estimate clears approximately 25, against a legal threshold of 18. Many adults will not clear on the estimate alone. They are not refused; they go to government-ID fallback, where a trained reviewer decides. Every refusal is seen by a person.
6.2 Moderation. Real-time classifiers detect nudity, sexually explicit conduct, suspected minors, violence and other prohibited content, and can warn, blur, interrupt or end a Session. They also screen Message text and scan every image before delivery. Automated detection and intervention run continuously, at every hour. Human review runs on one staffed moderation shift with on-call escalation outside it; child safety is escalated immediately at any hour.
6.3 Fraud and risk scoring. Automated scoring may decline a Coin purchase, hold a withdrawal, or limit account features.
6.4 Your right to a human. Where a decision produces legal effects or similarly significantly affects you — an age-assurance refusal, a permanent ban, a withheld withdrawal — it does not stand on automation alone. You may obtain human intervention, express your point of view and contest the decision at support@yunoh.com or privacy@yunoh.com. Where an immediate automated intervention is necessary to prevent serious harm in a live Session, human review follows without undue delay.
6.5 AI systems and training. The systems in use are age estimation and liveness (our age-assurance vendor), moderation and image scanning (Hive AI), speech-to-text (Deepgram), translation (Azure OpenAI), identity verification (Persona) and fraud screening (our payment processor). You are told when you are interacting with an automated system. Yunoh does not use Session content, Messages or images to train AI models, and our contracts do not permit a vendor to use material processed for Yunoh to train, fine-tune or improve any model. Aggregated, anonymised statistics may be used to tune thresholds.
7. Who we share data with
Each processor below is engaged under a written data processing agreement meeting Article 28 GDPR, and acts only on our documented instructions.
| Processor | Role | Location |
|---|---|---|
| Hetzner | Hosting and infrastructure | Germany / Finland (EEA) |
| Cloudflare | CDN, DDoS protection, bot management, firewalling | Global edge, US-headquartered |
| Hive AI | Session moderation, Message screening, pre-delivery image scanning | United States |
| Deepgram | Speech-to-text for subtitles | United States |
| Azure OpenAI (Microsoft) | Translation and subtitles | EU region where available |
| Persona | Financial KYC and identity verification (Gate 2) | United States |
| a specialist age-assurance provider | Facial age estimation, liveness, ID fallback (Gate 1) | To be confirmed on contracting |
| a third-party PCI-DSS-compliant payment processor | Card acceptance, fraud screening, chargebacks; an independent controller for parts of its own compliance processing | United States / EU |
| Trembit LLP | Development partner; limited, logged, time-boxed production access for maintenance | Per its contracting entity |
| Email, ticketing and analytics | Transactional and support email, tickets, product analytics | See the Cookie Policy |
- providers
We also share with other users, but only what the Platform shows them, which is very little; with child-safety organisations and hotlines where child sexual abuse material or endangerment is detected or reported; with professional advisers under confidentiality; with law enforcement and courts under section 9; and with a buyer or successor if we sell or reorganise the business, when this policy continues to apply until you are told otherwise.
Tax authorities — Earners only, and you should know exactly what this means. EU rules require platforms to report the people who earn on them. If you are an Earner, we are required to give the Cyprus Tax Department an annual return identifying you — your name, address, date of birth, tax identification number and the account we pay you into — together with what we paid or credited you in each quarter of the year and any fees we charged. The Cyprus Tax Department then passes that return to the tax authority of the country where you are tax resident, under the EU's automatic exchange of information.
This is reporting, not deduction: we take nothing from your money, and your tax remains your own affair, as the Earner Agreement says. But it does mean the tax office where you live will be told what you earned here. We would rather you heard that from us at the outset than from a letter. We will send you a copy of everything we report about you, and section 13.4 of the Earner Agreement explains what happens if you do not give us the information the rules require. It applies only to Earners — a Member who buys Coins is never reported to anyone.
8. International transfers
Our core infrastructure sits in the EEA. Some processors above are outside it, principally in the United States. Where personal data leaves the EEA we rely on an adequacy decision of the European Commission where one covers the recipient; otherwise on the Commission's Standard Contractual Clauses, written into our data processing agreements, together with a documented transfer risk assessment. That assessment considers the law and practice of the destination country and the supplementary measures we apply — encryption in transit and at rest, strict access controls, data minimisation, and the fact that Sessions are never recorded. Ask at privacy@yunoh.com for the safeguards applied to a specific transfer.
One transfer works differently: the tax return in section 7. Where we report an Earner to the Cyprus Tax Department and it passes that return to the tax authority where she lives, the transfer is made because EU law requires it, between public authorities, under the automatic exchange of information. It does not rely on Standard Contractual Clauses and it
is not something we can decline, restrict or apply safeguards to. It is a legal obligation, and we tell you about it rather than ask you to agree to it.
9. Law enforcement and government requests
We disclose User data to a law enforcement agency, court, regulator or government body only where there is a valid legal basis and the request has been properly served. We do not disclose because a requester sounds official or the subject matter is serious. Requests go to support@yunoh.com marked "Law Enforcement Request", and must identify the issuing authority and named officer, the legal instrument relied on with a copy attached, the identifiers held, the data sought, and a date range. "All information held" is not a specification. We disclose the minimum that answers a valid request, we refuse or narrow one that is defective, overbroad or unverifiable, and we log every disclosure. The bases are Article 6(1)(c) for binding legal process, Article 6(1)(d) for emergencies, and Article 6(1)(f) for investigating crime or for legal claims. An order from a non-EU authority does not by itself compel a Cypriot company: Article 48 GDPR limits us, and the ordinary route is mutual legal assistance.
Emergencies. Where there is an imminent risk of death or serious physical injury, and the request is specific and from a verifiable law enforcement source, we may disclose without formal process. Where a child is at risk, we do not wait.
Notification. Our default is to tell you before we disclose, and to give you a copy of the request, so you can object. We will not notify where we are legally prohibited, where notice would create a serious risk to an active investigation or to anyone's safety, or where the request concerns child sexual exploitation or a child at risk.
10. Security and personal data breaches
We encrypt data in transit and sensitive data at rest, including identity documents, KYC records and stored Messages. Age-estimation images are held by the vendor, not by us; we hold the result and the verification token. Payments are tokenised, and full card data never touches our systems. Access is role-based and least-privilege: moderator access to Messages is driven by a report or a detection rather than free browsing, is logged at record level, and has no export path. We run Cloudflare in front of the Platform, review a processor's security before engaging it, and maintain an incident response procedure. No system is perfectly secure; if you believe your account has been compromised, contact support@yunoh.com and change your password.
If a personal data breach is likely to result in a risk to your rights and freedoms, we notify the Office of the Commissioner for Personal Data Protection without undue delay and, where feasible, within 72 hours of becoming aware of it. Where the risk to you is high, we also tell you directly, in plain language: what happened, the likely consequences, what we are doing, and what you should do. We record every breach, including those we need not report.
11. How long we keep data
| Data | Retention |
|---|---|
| Session video and audio; transient audio for subtitles | Not retained at all |
| Raw facial image for age estimation | Deleted immediately after the decision |
| Age-assurance decision record | 24 months from account closure |
| Identity documents used at Gate 1 fallback | 90 days from the decision |
| KYC and AML records (Verified Earners) | The statutory AML retention period after the end of the relationship |
| Account data | 12 months from account closure, then deleted or irreversibly anonymised |
| Matching, friend-connection and block records | Life of the connection or block, then 12 months |
| Ban and enforcement record | 5 years from closure; longer for child safety or illegal content |
| Session metadata; payment, Wallet and payout records | 7 years, aligned to accounting and tax rules |
| Message content and images, including an image blocked before delivery | 12 months from sending or the block |
| Moderation artefacts | 90 days where no action was taken; 24 months where an action followed; as required by law where illegal content or child safety is involved |
| Device, technical and security logs | 12 months, or until a live investigation closes |
| Fraud and risk scores | 24 months, or the life of an active restriction |
| Support correspondence | 3 years; 6 years for a complaint, safety report or potential claim |
| Consent records | Marketing: until withdrawn, plus 3 years. Cookies: 12 months, after which we ask again |
Where the law, a court order or a valid preservation request obliges us to keep data longer, we keep it for that period and no more. At the end of a period we delete or irreversibly anonymise it.
12. Your rights
Under the GDPR you have the right to:
- access your data, and be told the purposes, recipients, retention periods and sources (Art. 15);
- rectification of inaccurate or incomplete data (Art. 16);
- erasure where data is no longer necessary, where you withdraw consent, or where you object and we have no overriding grounds (Art. 17). It does not apply where we must keep data — AML records, tax records, a ban record — and a Message is also correspondence the other person received, so we will not delete it from their account on your request;
- restriction of processing while a dispute about accuracy or lawfulness is resolved (Art. 18);
- portability of the data you provided, and data generated by your use of the service, in a structured, commonly used, machine-readable format (Art. 20);
- object to processing based on our legitimate interests, including profiling; we stop unless we can show compelling grounds that override your interests. Your right to object to direct marketing is unconditional (Art. 21);
- withdraw consent at any time — to facial age estimation, marketing email or non-essential cookies — without affecting processing done before withdrawal (Art. 7(3)). Withdrawing it for age assurance means you cannot appear on camera as an Earner;
- human intervention in relation to automated decisions, as set out in section 6.
How to exercise them. Write to privacy@yunoh.com from the email address on your account, or use your account settings. We may need to verify your identity, and will ask for the minimum necessary. We respond without undue delay and within one month. If a request is complex, or you have made several, we may extend by up to two further months, telling you within the first month, with reasons. This is free.
Complaints. If you are unhappy with how we have handled your data, tell us first at privacy@yunoh.com. You may also complain to the Office of the Commissioner for Personal Data Protection of the Republic of Cyprus (www.dataprotection.gov.cy), or to the supervisory authority where you live or work, and you may seek a judicial remedy. If you are in the United Kingdom, that authority is the Information Commissioner's Office (www.ico.org.uk).
13. Cookies, and changes to this policy
The technologies we set on your device, and how to control them, are in the Cookie Policy. Non-essential ones are set only with your consent.
We may update this policy as the Platform, our vendors or the law change, and will change the "Last updated" date. Where a change is material — a new purpose, a new category of data, a processor with a materially different role, or a change to your rights — we will tell you in advance by email or in-product notice, and where it relies on consent we will ask again.
Contact
Data protection, data rights and access requests: privacy@yunoh.com Account, billing, safety reports, complaints, legal and compliance: support@yunoh.com General enquiries: info@yunoh.com
PXL NexQuantum Ltd Voukourestiou 25, Neptune House, 1st floor, Flat/Office 11, Zakaki, 3045 Limassol Republic of Cyprus Company registration number: HE 497211 Data protection contact: privacy@yunoh.com
Nothing in this policy removes or limits any right you have under mandatory local law.