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Privacy Policy

Last updated: 10 July 2026 Effective date: 10 July 2026

Welcome to QRooms.

This Privacy Policy (the “Privacy Policy”) describes how PT Era Reka Aplikasi, a limited liability company duly established under the laws of the Republic of Indonesia (“QRooms,” “we,” “us,” “our,” or the “Company”), collects, obtains, accesses, uses, stores, discloses, shares, rectifies, updates, deletes, and otherwise processes Users’ Personal Data in connection with the access to and use of the QRooms mobile application, official website, and any features, functions, content, and services provided by QRooms (collectively, the “Services”).

This Privacy Policy forms an integral and inseparable part of the QRooms Terms and Conditions. Capitalized terms used but not otherwise defined in this Privacy Policy shall have the meanings ascribed to them in the Terms and Conditions.

By creating an Account, accessing, or using the Services, you acknowledge that you have read, understood, and agreed to the processing of your Personal Data as described in this Privacy Policy.

If you do not agree with any part of this Privacy Policy, you must immediately cease accessing and using the Services.

QRooms processes Personal Data in accordance with the applicable laws and regulations of the Republic of Indonesia, including, without limitation, Law No. 27 of 2022 on Personal Data Protection, as amended, supplemented, or replaced from time to time, together with its implementing regulations.

1. DEFINITIONS

Unless otherwise specified in these Privacy Policy, the following terms shall have the meanings set forth below:

  1. “Account” means an account registered by a User to access and use the QRooms Services.

  2. “Personal Data” means any data concerning an individual who is identified or can be identified, whether independently or in combination with other information, directly or indirectly, through electronic or non-electronic systems, as defined under the applicable personal data protection laws and regulations.

  3. “Privacy Policy” means this document, including any amendments, updates, or revisions made from time to time.

  4. “Services” means the QRooms mobile application together with all features, functions, content, systems, software, websites, and other services provided by PT Era Reka Aplikasi from time to time.

  5. “User” means any individual who accesses, registers an Account, or uses the Services in any capacity, including as a player, Venue administrator, tournament organizer, referee, cashier, or any other role made available through the Services.

  6. “Processing of Personal Data” means any operation performed on Personal Data, including obtaining, collecting, accessing, using, storing, rectifying, updating, disclosing, transferring, deleting, destroying, or any other processing activity permitted under applicable laws and regulations.

  7. “Terms and Conditions” means the QRooms Terms and Conditions, including any amendments, updates, or revisions made by QRooms from time to time.

  8. “Venue” means any billiards or pool playing venue used in connection with Matches through the Services, whether operated by a Venue Partner or otherwise supported by QRooms.

  9. “Venue Partner” means any billiards or pool venue that collaborates with QRooms in connection with certain features of the Services, including, without limitation, Check-in, Identity Verification, tournament administration, or Settlement confirmation.

  10. “Identity Verification” means the face-to-face identity verification process conducted in accordance with the Terms and Conditions.

  11. “Day” means a calendar day, unless expressly stated otherwise in the Terms and Conditions.

2. PERSONAL DATA WE COLLECT

In providing the Services, QRooms collects and processes only Personal Data that is relevant, adequate, and necessary to provide, operate, develop, secure, and comply with legal obligations relating to the Services.

The Personal Data that we may collect includes the following:

  1. Account Information:

When a User creates or updates an Account, we may collect the following information, including:

- full name;
- display name;
- nickname;
- email address;
- telephone number (if provided);
- year of birth;
- gender;
- profile photo or avatar;
- preferred Venue or pool hall; and
- any other account information voluntarily provided by the User.

2. Match and Gameplay Data:

While you use the Services, we may process information relating to your gameplay activities, including, without limitation:

- Match results;
- Match scores;
- gameplay statistics;
- Match history;
- QRating;
- Leaderboard rankings;
- achievements;
- Tournament participation;
- Check-in records; and
- other information generated through your use of gameplay-related features within the Services.

3. Settlement Data:

For purposes of confirming Match results, we may process information including:

- Settlement status;
- Settlement timestamp;
- the identity of the individual confirming the Settlement;
- the identities of the players participating in the Match; and
- any other information necessary to confirm the Match result.

For purposes of this Privacy Policy, Settlement refers solely to the Match result confirmation process as described in the Terms and Conditions and does not constitute a payment process, fund transfer, or financial transaction of any kind.

  1. Identity Verification Data:

If a User elects to use the Identity Verification feature, we may process:

- Identity Verification status;
- verification results;
- full name;
- display name;
- nickname;
- Gender;
- year of birth; and
- profile photo.

QRooms does not photograph, scan, upload, copy, transmit, or retain images of any government-issued identity document presented during the Identity Verification process.

Identity Verification is performed through a visual inspection conducted by an authorized Venue Partner representative, as described in the Terms and Conditions.

  1. Device and Technical Data:

We may automatically collect technical information generated through your use of the Services, including:

- device type;
- device model;
- operating system;
- application version;
- IP address;
- device identifier;
- activity logs;
- crash reports;
- timestamps;
- usage analytics; and
- other technical information necessary for the security and operation of the Services.

To maintain the security, stability, and integrity of the Services, QRooms may maintain system activity logs, including access times, IP addresses, devices used, authentication activities, security events, and other technical information necessary for audits, security incident investigations, abuse prevention, and system maintenance.

  1. Location Data:

Where you grant the necessary permissions, QRooms may process limited location information to support certain features of the Services, including detecting your presence at a Venue to facilitate automatic Check-in and Check-out.

QRooms does not continuously retain location history or share your precise location with other Users.

  1. Communications:

We may process information provided when a User:

- contacts customer support;
- sends emails;
- submits complaints;
- reports abuse;
- provides suggestions or feedback; or
- otherwise communicates with QRooms.

8. Device Permissions:

In providing the Services, QRooms may request permission to access certain device features, including:

- camera;
- photo gallery;
- notifications;
- location services; and
- other permissions necessary to enable specific features of the Services.

Users may revoke such permissions at any time through their device settings. However, revoking such permissions may limit or disable certain functionalities of the Services.

  1. Data We Do Not Collect:

QRooms does not intentionally collect or retain:

- images or copies of government-issued identity documents;
- biometric data;
- health data;
- bank account information;
- credit card information or payment instrument data;
- continuous location history;
- Users' contact lists; or
- any other data that is not necessary for providing the Services.

10. Users are responsible for ensuring that all Personal Data provided to QRooms is accurate, complete, current, and up to date. Users shall promptly update their Personal Data whenever there is any change to information previously provided to QRooms.

3. PURPOSES OF PROCESSING PERSONAL DATA

  1. QRooms processes Users’ Personal Data solely for lawful, specific, and legitimate purposes in accordance with applicable laws and regulations.

  2. We may process Personal Data to:

    • provide, operate, maintain, and improve the Services;

    • create, manage, secure, recover, and verify User Accounts;

    • administer Matches, Settlement, Tournaments, Leaderboards, QRating, and other community features;

    • conduct Identity Verification;

    • display public information in accordance with Users’ privacy settings and the Services;

    • detect, prevent, investigate, and address suspected fraud, system manipulation, suspicious activities, Account abuse, security incidents, and violations of the Terms and Conditions;

    • develop features, improve the quality of the Services, conduct usage analytics, system testing, security audits, incident recovery, and product development;

    • provide customer support and respond to Users’ inquiries, complaints, and requests;

    • send notifications relating to Account security, changes to the Services, amendments to this Privacy Policy, and other important information;

    • comply with applicable laws and regulations, court orders, and requests from competent governmental authorities;

    • protect the rights, legitimate interests, security, and integrity of QRooms, Users, Venue Partners, and other parties; and

    • any other purpose permitted under applicable laws or based on the User’s consent where required by law.

  3. Certain Personal Data processing activities are carried out automatically through electronic systems, including, without limitation, QRating calculations, Leaderboard generation, abnormal activity detection, Account abuse prevention, system security management, and other automated functions necessary for the operation of the Services.

  4. QRooms does not sell Users’ Personal Data to any third party and does not use Personal Data for cross-application advertising or cross-app advertising purposes.

  1. QRooms processes Personal Data based on one or more lawful grounds for processing in accordance with applicable laws and regulations.

  2. The basis for processing as referred to in Paragraph (4.1) may include:

    • the User’s consent;
    • the performance of a contract between the User and QRooms, including the Terms and Conditions;
    • compliance with legal obligations applicable to QRooms;
    • the protection of the vital interests of the User or another individual, where permitted by applicable law;
    • the performance of duties carried out in the public interest where required under applicable laws and regulations; and/or
    • the legitimate interests of QRooms or a third party, provided that such interests do not override the User’s rights and freedoms under applicable data protection laws.

5. PUBLICLY AVAILABLE INFORMATION

  1. Certain User information may be displayed to other Users through the Services as part of the community features, QRating system, Leaderboards, Matches, and other social features available within the Services.

  2. Information that may be displayed to other Users includes, among others:

    • the User’s display name or nickname;
    • the User’s uploaded profile photo;
    • QRating and gameplay statistics;
    • Match history for Matches that have completed the Settlement process;
    • achievements, badges, or other recognitions earned through the Services;
    • Tournament participation information and results; and
    • any other information that, under the design and settings of the Services, is intended to be visible to the User community.

  3. Users who have successfully completed the Identity Verification process may appear on the public Leaderboard using their display name or other identity information permitted under this Privacy Policy.

  4. Users who have not completed the Identity Verification process may be displayed using an anonymous identity, user code, or any other identifier designated by QRooms, and shall not appear on the verified public Leaderboard.

  5. Users acknowledge and understand that information designated as publicly available within the Services may be viewed, accessed, or shared by other Users in accordance with the functionality of the Services.

  6. The Services may provide features enabling Users to share or export certain publicly available information, including, without limitation, Leaderboard rankings, gameplay statistics, or achievements, in image format or other formats made available by QRooms.

  7. Venue Partners, Venue administrators, Tournament organizers, referees, and cashiers may access User data only to the extent necessary to perform the functions, responsibilities, or operational activities of the Venue or Tournament under their administration.

  8. Users may configure the visibility of certain information through the privacy settings available within the Services. Notwithstanding the foregoing, information forming part of QRooms’ competitive ecosystem, including Match results that have completed Settlement, QRating, and gameplay statistics, may continue to be displayed where reasonably necessary to preserve the integrity of the QRating system and Leaderboards.

6. DISCLOSURE OF PERSONAL DATA TO THIRD PARTIES

  1. QRooms does not sell, trade, or rent Users’ Personal Data to any third party.

  2. In operating the Services, QRooms may disclose Personal Data to third parties where necessary for the provision of the Services or based on another lawful basis for processing in accordance with applicable laws and regulations.

  3. The third parties referred to in Paragraph (6.2) may include:

    • providers of cloud computing services, database services, authentication services, and technology infrastructure used to operate the Services;

    • providers of email services, communication services, analytics services, security monitoring services, and other technical service providers;

    • application distribution platform providers, including the Apple App Store and Google Play Store;

    • Venue Partners, Tournament organizers, Venue administrators, referees, or cashiers, to the extent necessary for the administration of Matches, Tournaments, Settlement, or Identity Verification;

    • professional advisers, auditors, consultants, and other service providers who are subject to confidentiality obligations; and

    • government authorities, law enforcement agencies, regulators, or other parties where disclosure is required under applicable laws and regulations, pursuant to a court order, or in response to a lawful request.

  4. QRooms requires every third party receiving Personal Data to maintain the confidentiality and security of such Personal Data in accordance with applicable laws and to process the Personal Data solely for the purposes for which it was disclosed.

  5. Wherever reasonably practicable, QRooms shall disclose only the minimum Personal Data necessary (data minimization) for the relevant lawful processing purpose.

7. CROSS-BORDER TRANSFER OF PERSONAL DATA

  1. In providing the Services, Users’ Personal Data may be processed, stored, or accessed through servers or facilities located outside the territory of the Republic of Indonesia where the technology service providers engaged by QRooms operate internationally.

  2. Where Personal Data is transferred outside the territory of the Republic of Indonesia, QRooms shall conduct such transfer in accordance with applicable laws and regulations, including the Indonesian Personal Data Protection Law and its implementing regulations.

  3. QRooms shall implement reasonable measures to ensure that recipients of Personal Data outside the Republic of Indonesia provide an adequate level of protection for Personal Data through contractual, technical, organizational, or other safeguards required under applicable law.

8. COOKIES AND SIMILAR TECHNOLOGIES

  1. In providing the Services, QRooms may use cookies, software development kits (SDKs), local storage, authentication tokens, device identifiers, session identifiers, and other similar technologies to support the functionality and security of the Services.

  2. The technologies referred to in Paragraph (8.1) may be used for purposes including:

    • maintaining Users’ login sessions;
    • remembering Users’ preferences;
    • enhancing Account security;
    • preventing misuse of the Services;
    • analyzing the use of the Services; and
    • improving the performance and stability of the Services.

  3. Users acknowledge and understand that disabling certain of these technologies may cause some features of the Services to function improperly or become unavailable.

9. RETENTION AND DELETION OF PERSONAL DATA

  1. QRooms retains Personal Data only for as long as necessary to fulfill the purposes of collection and processing described in this Privacy Policy, for as long as the User continues to use the Services, or for such longer period as required or permitted under applicable laws and regulations.

  2. If a User deletes their Account, QRooms will delete, anonymize, or de-identify the User’s Personal Data within a reasonable period in accordance with QRooms’ internal data retention policy, unless continued retention is required or permitted by applicable law.

  3. QRooms may continue to retain certain Personal Data after an Account has been deleted where such retention is necessary to:

    • comply with legal obligations;
    • satisfy tax, accounting, auditing, or other regulatory compliance requirements;
    • resolve disputes, claims, or legal proceedings;
    • prevent fraud, abuse of the Services, system manipulation, or security incidents;
    • enforce the Terms and Conditions and QRooms’ legal rights; or
    • fulfill any other purpose permitted under applicable laws and regulations.

  4. As part of QRooms’ disaster recovery and business continuity measures, backup copies of Personal Data may continue to be retained for a limited period in accordance with QRooms’ internal retention policy. Such backup data will remain subject to the same security standards and will be deleted or anonymized in accordance with applicable procedures.

  5. Data that has been anonymized, aggregated, or otherwise processed so that it can no longer be used to identify an individual User shall no longer constitute Personal Data and may be used by QRooms for statistical analysis, research, product development, improvement of the QRating algorithm, business analytics, and other lawful purposes in accordance with applicable laws and regulations.

  6. Upon expiration of the applicable retention period, QRooms will securely delete or anonymize Personal Data in accordance with its internal procedures and applicable laws and regulations.

10. DATA SUBJECT RIGHTS

  1. To the extent provided under applicable laws and regulations, including Law No. 27 of 2022 on Personal Data Protection and its implementing regulations, you, as a Data Subject, have the right to:

    • obtain information regarding the identity of the party requesting your Personal Data, the legal basis for the processing, the purpose of the request and use of your Personal Data, and the accountability of the requesting party;

    • access and obtain a copy of the Personal Data processed by QRooms;

    • complete, update, and/or rectify inaccurate, incomplete, or outdated Personal Data;

    • terminate the processing of, delete, and/or destroy your Personal Data in accordance with applicable laws and regulations;

    • withdraw your consent to the processing of Personal Data where such processing is based on your consent;

    • object to decisions based solely on automated processing that produce legal effects or similarly significant effects concerning you, where applicable;

    • request the postponement or restriction of the processing of your Personal Data under certain circumstances as permitted by applicable law;

    • obtain your Personal Data in a structured, commonly used, and machine-readable format, where technically feasible; and

    • lodge a complaint with the competent authority if you believe that the processing of your Personal Data violates applicable laws and regulations.

  2. To exercise any of the rights referred to in Paragraph (10.1), you may contact QRooms via support@qrooms.app or through any other mechanism made available within the Services.

  3. QRooms may request additional information or documentation to verify your identity before processing any request relating to your Personal Data in order to protect the security of your Account and Personal Data.

  4. QRooms will respond to verified requests within a reasonable period, taking into account the complexity of the request and the requirements of applicable laws and regulations.

  5. You may delete your Account through the features available within the Services or through any other mechanism provided by QRooms. Deletion of your Account does not automatically result in the deletion of all Personal Data where continued retention is required or permitted under applicable law, as further described in this Privacy Policy.

  6. QRooms may refuse, in whole or in part, a request to exercise Data Subject rights where:

    • the request conflicts with applicable laws and regulations;
    • granting the request would adversely affect the rights of another person;
    • the processing is necessary for law enforcement purposes;
    • the processing is necessary to maintain the security or integrity of QRooms’ systems; or
    • there is another legal basis permitting such refusal.

11. CHILDREN’S PRIVACY

  1. The Services are intended for Users who are at least 13 (thirteen) years of age, as provided in the Terms and Conditions.

  2. Users who are between 13 (thirteen) and 17 (seventeen) years of age must obtain the consent, supervision, or involvement of a parent or lawful guardian in accordance with applicable laws and regulations.

  3. QRooms does not knowingly collect or process Personal Data from children under 13 (thirteen) years of age.

  4. If QRooms becomes aware that Personal Data relating to a child below such age has been collected without a valid legal basis, QRooms reserves the right to take any action it deems necessary, including deleting the relevant Personal Data and disabling the associated Account in accordance with applicable law.

  5. If you believe that a child has unlawfully provided Personal Data to QRooms, you may contact us at support@qrooms.app.

12. PERSONAL DATA SECURITY

  1. QRooms implements reasonable technical and organizational measures to protect Personal Data against unauthorized access, unlawful use, loss, alteration, disclosure, or destruction, taking into account the nature of the Personal Data, the risks associated with the processing, technological developments, and applicable laws and regulations.

  2. The measures referred to in Paragraph (12.1) may include, among others:

    • the use of encryption during data transmission through secure protocols;
    • user authentication mechanisms;
    • role-based access controls;
    • system activity logging (audit logs);
    • security monitoring; and
    • other technical measures deemed necessary to maintain the security of the Services.

  3. Although QRooms endeavors to implement reasonable security standards, no method of transmitting data over electronic networks or storing electronic data can guarantee absolute security. Accordingly, Users remain responsible for maintaining the confidentiality of their Account credentials and for taking reasonable measures to protect the security of their Accounts.

  4. In the event of a Personal Data breach that is required to be notified under applicable laws and regulations, QRooms will provide notification to the relevant authorities and/or the affected Data Subjects in accordance with the procedures and timeframes prescribed by applicable law.

13. ACCOUNT RECOVERY

  1. If a User loses access to their Account, the User may utilize the Account recovery mechanism made available through the Services.

  2. Account recovery may be completed through the email address registered with the Account or through any other authentication mechanism provided by QRooms or the authentication service provider engaged by QRooms.

  3. To protect the security of Accounts and Personal Data, QRooms reserves the right to request additional information or documentation reasonably deemed necessary to verify ownership of the Account before restoring access to the User.

  4. Users acknowledge and understand that QRooms will never request a password, One-Time Password (OTP), authentication code, or any other security credentials via email, text message, telephone, or any other communication channel.

  5. Users are responsible for promptly notifying QRooms if they become aware of or suspect any unauthorized access to their Accounts.

14. PROHIBITION ON USE FOR GAMBLING

  1. QRooms is a skill-based billiards/pool community and competition platform that provides Match recording, the QRating system, Leaderboards, Check-in functionality, and other supporting features.

  2. QRooms is not a gambling platform, betting operator, payment service provider, or a facility for conducting or facilitating gambling activities in any form.

  3. QRooms does not receive, hold, manage, retain, transfer, or process any funds relating to wagers, stakes, bets, or any other form of gambling between Users.

  4. Any use of the Services for gambling purposes or for any activity that violates applicable laws and regulations constitutes a violation of the QRooms Terms and Conditions and may result in the restriction, suspension, or termination of the User’s Account in accordance with the Terms and Conditions.

  5. Further provisions regarding the prohibition on using the Services for gambling are set out in the QRooms Terms and Conditions, which form an integral and inseparable part of this Privacy Policy.

15. CHANGES TO THIS PRIVACY POLICY

  1. QRooms reserves the right to amend, update, or supplement this Privacy Policy from time to time to reflect developments in the Services, technological advancements, operational requirements, changes in applicable laws and regulations, or other legitimate business reasons.

  2. If any material changes are made to the manner in which QRooms processes Personal Data, QRooms will notify Users through the Services, email, or any other communication channel reasonably determined by QRooms, and will update the “Last Updated” date set out in this Privacy Policy.

  3. Any amendments to this Privacy Policy shall become effective on the effective date specified in the relevant notice or, if no effective date is specified, upon publication through the Services.

  4. By continuing to access or use the Services after such amendments become effective, Users are deemed to have read, understood, and agreed to the revised Privacy Policy, to the extent permitted by applicable laws and regulations.

16. MISCELLANEOUS

  1. This Privacy Policy forms an integral and inseparable part of the QRooms Terms and Conditions. In the event of any inconsistency between this Privacy Policy and the Terms and Conditions with respect to the processing of Personal Data, the provisions of this Privacy Policy shall prevail to the extent they relate to the protection and processing of Personal Data.

  2. If any provision of this Privacy Policy is held to be invalid, unlawful, or unenforceable pursuant to a final court judgment, applicable laws or regulations, or a decision of a competent authority, the remaining provisions of this Privacy Policy shall remain in full force and effect to the fullest extent permitted by applicable law.

  3. Any failure or delay by QRooms in exercising or enforcing any right, power, or remedy under this Privacy Policy shall not constitute a waiver of such right, power, or remedy, nor of any other rights, powers, or remedies.

  4. In the event of a merger, consolidation, acquisition, corporate restructuring, business transfer, sale of all or a substantial portion of assets, change of control, or any similar corporate transaction, Users’ Personal Data may be transferred to the successor entity or other parties involved in such transaction, provided that such transfer is carried out in accordance with applicable laws and regulations and that an equivalent standard of Personal Data protection as set out in this Privacy Policy continues to be applied.

  5. QRooms may engage service providers, affiliates, contractors, or other third parties to assist in providing the Services, provided that such parties process Personal Data on behalf of QRooms in accordance with QRooms’ instructions, are subject to appropriate confidentiality obligations, and implement Personal Data protection measures consistent with applicable laws and regulations.

  6. Any matters not specifically governed by this Privacy Policy shall be subject to the QRooms Terms and Conditions and the applicable laws and regulations of the Republic of Indonesia.

  7. This Privacy Policy may be made available in the Indonesian language and/or other languages. In the event of any inconsistency or discrepancy between the Indonesian version and any other language version, the Indonesian version shall prevail to the extent not prohibited by applicable laws and regulations.

17. CONTACT

  1. If you have any questions, requests, complaints, or wish to exercise your rights as a Data Subject under this Privacy Policy or applicable laws and regulations, you may contact QRooms at:

PT Era Reka Aplikasi

Email : support@qrooms.app

Website : https://qrooms.app

  1. QRooms will use reasonable efforts to respond to all communications received within a reasonable period, taking into account the nature and complexity of the matter and the requirements of applicable laws and regulations.