Kuul Privacy Policy
The Mongolian version is the official one. If the two differ, the Mongolian text applies.
This policy explains what personal data Kuul collects, why, who sees it, how long we keep it, and what you can do about it. It follows Mongolia's Law on Personal Data Protection (2021).
1. Who is responsible
The people who run Kuul, from Ulaanbaatar, decide how your data is used and are responsible for it. For anything about your data, email hello@kuul.mn.
2. What we collect
| What | Details | Why | How long we keep it |
|---|---|---|---|
| Account | School email, display name, birth date, school, faculty, year, study level, language | Signing in, confirming you're a student, showing the right classes, age rules | Until you delete your account, plus 30 days |
| Profile | Bio | Showing other students who you are | Until you change it or delete your account |
| Timetable | Your classes, classes you add yourself, notes, colours, which entries are private | Your timetable, joining your class chats, "who's free" with friends | While your account exists |
| Friends | Friend requests, friends, people you blocked | Friends, sharing timetables, blocking | While your account exists |
| Chats | Messages, photos, reactions, the chats you're in | Delivering messages, moderation | 24 months after sending, also after you delete your account (then shown as "Deleted user"). The text and file of a message you delete are cleared within 30 days. Notifications: 90 days |
| Campus | Alerts and confirmations, lost and found posts and claims, keyword watches. A lost and found post can include private details such as the name on a found card | Campus alerts, returning lost items | Lost and found: deleted with your account. Alerts: kept without your name |
| Reports | Reports you file, reports about you, moderation decisions | Keeping Kuul safe | 2 years after the report is settled |
| Location | Your location at the moment you shake your phone | Finding the other phone in shake-to-befriend | About 18 seconds in server memory. Never saved, never shown to anyone |
| Device and technical | A random device ID, platform, app version, IP address, sign-in times | Security, stopping abuse, fixing bugs | Sign-in codes and their IP: 1 day. Server logs: 90 days |
| Consents | Which consents you gave or withdrew, when, and which version of these terms you accepted | Proving what you agreed to | While your account exists |
| Waitlist | The email address you leave on kuul.mn, and when you left it. No account needed | One email to confirm, and one when Kuul opens. Nothing else | Until you leave the list (deleted at once), and no longer than 30 days after the launch email |
We don't collect your gender, phone number, contacts, school portal password, or location history.
Timetables also include lecturers' names, taken from schools' public timetables. A lecturer, or anyone else whose data appears in Kuul, can ask us to remove it at hello@kuul.mn.
3. Why we can use it: your consent
3.1. We use your data because you consent to it. We ask separately for each purpose, and every box starts unticked:
- Core (required for an account): your account, timetable, friends, chats and campus features, as described in this policy.
- Data stored abroad (required while our server is outside Mongolia): see section 7.
- A parent's or guardian's agreement (required if you are 16 or 17): see section 11.
- Push notifications (optional).
- Waitlist (on kuul.mn, no account needed): leaving your email address there is your consent to the two emails in section 2. Every one of them has a link to leave the list.
- No usage statistics. We don't collect usage statistics or analytics. If we ever want to, we'll update this policy and ask you first.
3.2. You can turn push notifications off at any time in Settings or in your phone's settings. The other consents are what Kuul needs to work, so you withdraw them by deleting your account (Settings → Delete account). Withdrawing stops future use and doesn't undo use before that.
4. What we don't do
- We don't sell your personal data.
- We don't use your messages for ads.
- We don't ask for your school portal password.
- We don't collect ID cards, selfies or any biometric data.
- We don't track where you go, and we remove location data from the photos you upload.
- Schools and partners only ever get totals that can't identify anyone.
5. Who sees what
| Data | Who can see it |
|---|---|
| Profile: name, school, faculty, year, bio, verified badge | Other Kuul users who search for your name |
| Email, birth date | No other user. Kuul staff only where the job needs it (section 5.1) |
| Timetable | Your friends, by default. In Settings you can show them busy times only, or nobody. Private entries are never shown |
| Class chat membership | Everyone in that class chat. You join automatically when you add the class, so members can see who takes it |
| Messages | The people in that chat |
| Direct messages | Only possible between friends |
| Alerts | The students it's for: your school, faculty or class. Confirmed school-wide alerts can also be read without an account. Your name shows only if you choose. People who confirm show as initials |
| Lost and found posts | Anyone, even without an account. You can post anonymously. Private details (such as the name on a found card) are shown only to you and Kuul staff |
| Photos in chats, alerts and lost and found | Anyone who has the photo's link. The links are long and random |
5.1. Kuul staff see only what their job needs. They read a message only when it has been reported, by a student or automatically by our filter. They don't browse your chats. Moderators see email addresses partly hidden. We log staff actions.
5.2. We give data to government bodies only when the law or a court order requires it. We tell you, unless the law forbids it.
6. Phone permissions
Kuul asks for each permission the first time a feature needs it. Saying no only turns off that feature.
| Permission | Used for |
|---|---|
| Photos | Choosing a photo for a chat, a group or a lost and found post |
| Camera | Taking a photo to send in a chat. The camera opens only when you tap its button |
| Location (while using the app) | Shake-to-befriend only, to tell which nearby phone shook at the same moment. iPhone may offer "Always", but Kuul never uses location in the background |
| Motion sensor | Detecting the shake. The readings never leave your phone |
| Notifications | Telling you about friend requests, messages, confirmed alerts and lost and found matches. You can turn each type off in Settings |
7. Service providers and data stored abroad
7.1. Our server is in Japan, so your data is stored outside Mongolia. Mongolian law allows this only with your consent, so sign-up asks for it with its own box, and Kuul can't be used without it. Please read this section before you tick it.
| Provider | Country | What they get | Why |
|---|---|---|---|
| Oracle Cloud | Japan (Tokyo) | Everything in this policy | Hosting our server, database and photos |
| Zoho (ZeptoMail) | USA | Your email address, and the sign-in code or the waitlist email | Sending sign-in and waitlist emails |
| Apple Push Notification service | USA | The notification's title and text, and a token for your phone | Delivering push notifications to iPhone |
| Apple App Store, Google Play | USA | What the stores collect when you download the app, under their own policies | Distributing the app |
7.2. We don't use advertising, analytics or crash reporting services. Push notifications on Android (Google) and text messages (SMS) are not used yet. Before we add any new provider, we update this list and ask for your consent again.
7.3. Our agreements with providers limit them to the purpose above and forbid them from using your data for themselves. We remain responsible to you for what they do with it.
8. How long we keep data
8.1. The table in section 2 lists how long we keep each kind of data.
8.2. When you delete your account, your name, bio and photo are removed at once and you're signed out everywhere. After 30 days we delete the account and everything tied to it: your profile, timetable, friends, blocks, chat memberships, consents, notifications, verification records, uploaded files and lost and found posts.
8.3. Some things stay without your name, because they're part of other people's records or we need them for safety:
- messages you sent to others, shown as sent by "Deleted user"
- alerts you posted
- reports you filed
- logs of staff actions
8.4. Every night we back up the database and uploaded photos, encrypted, to separate storage at our cloud provider in Japan. Backups are kept 30 days, so anything deleted is gone from them within 30 days after that.
9. Security
- All traffic between the app and our server is encrypted (HTTPS).
- There are no passwords to steal. Sign-in codes expire after 5 minutes, allow 3 tries, and are stored only as a hash.
- Sessions rotate. If an old session key is reused, we sign that session out on every device.
- On your phone, Kuul keeps your session in the system's secure storage (Keychain on iPhone, Keystore on Android).
- Staff access depends on their role, and we log what they do.
- Rate limits slow down anyone trying to guess codes or scrape data.
If personal data leaks, we tell the people affected and the National Human Rights Commission as the law requires. Our own target is to tell you within 72 hours of finding out.
10. Your rights
You can:
- Ask what data we hold about you and who we shared it with.
- Get a copy of your data as a JSON file, free, within 7 days.
- Correct your data. You can edit your name and bio in the app. For anything else, such as your school, email us.
- Delete messages and posts, or your whole account (Settings → Delete account).
- Withdraw a consent in Settings.
- Ask a person to review an automated decision. The keyword filter can hold a message automatically, but a person reviews it, and only a person can suspend an account.
- Complain to the National Human Rights Commission of Mongolia, or go to court.
Email hello@kuul.mn for anything that isn't in the app. We reply within 10 working days.
11. Age limit
11.1. You must be at least 16 to use Kuul. We ask for your birth date at sign-up and turn away anyone younger. Your birth date is never shown to anyone.
11.2. If you are 16 or 17, show this policy and the Terms to a parent or guardian. If they agree, tick the box that says so on the consent screen. Users under 18 are matched by shake-to-befriend and friend suggestions only with other users under 18, and adults can find them in people search only if they go to the same school.
11.3. A parent or guardian can withdraw their agreement at hello@kuul.mn; we then close the account. If you think someone under 16 is using Kuul, email us and we will close the account and delete its data.
12. Changes to this policy
We'll tell you in the app at least 14 days before a change takes effect. If we want to use your data in a new way or share it with a new provider, we ask for your consent first.