B2B Privacy Policy

By Koo App
October 19, 2022

This policy is effective from 14 June 2022

1. WHY THIS POLICY? 

• Koo is operated by Bombinate Technologies Private Limited (“BTPL”), a company incorporated under the provisions of the Companies Act, 2013. Its registered office is at 849, 11th Main, HAL 2nd Stage, Indiranagar, Bangalore, Karnataka 560008. 
• This Privacy Policy (“Policy”) applies to all corporations, companies, consultants, contractors, suppliers, service providers, advertisers and other business partners (“B2B Parties”) that render services to BTPL. In other words, this Policy governs BTPL’s ‘B2B relations’.
• This Policy articulates the data protection standards BTPL expects B2B Parties to deploy while collecting, processing and storing information on behalf of BTPL or from their use of the Application.
• By contracting with BTPL, you acknowledge you have read and understood this policy. If you do not agree with the terms of this policy, do not proceed with executing the agreement with BTPL. Negotiated amendments, if any, will be captured as an exception in the agreement between you BTPL.
• Words and expressions not defined in this document shall have the meanings assigned under applicable law. 

2. WHAT DATA RELATING TO A B2B PARTY(/IES) IS COLLECTED BY BTPL?

By contracting with BTPL, B2B Parties specifically allow BTPL to collect, store, transmit, distribute, disclose, share, use, retain, dispose, destroy and process B2B Parties’ data, in any form, whether manual or electronic, pursuant to the agreement between BTPL and B2B Parties for all or any of the following purposes: 

• To perform obligations under an agreement;
• To perform vendor background verification;
• To respond to government requests as required under applicable laws;
• To include in marketing and promotional advisories;
• To use in research, profiling and data analytics to improve performance.

3. WHEN WILL BTPL SHARE ITS DATA WITH B2B PARTIES?

• To operate and run Koo, BTPL may share data with B2B Parties so that features are enabled on Koo, to discharge contractual obligations or any other obligations under applicable law.
• This Policy covers the treatment of any data that BTPL may share with B2B Parties. For more information on how BTPL treats its users’ personal data, please refer to BTPL’s Privacy Policy. B2B Parties must comply with the standards set out in the Privacy Policy.
• This Policy complements BTPL’s Privacy Policy regarding processing information and must be read in conjunction with the Social Media Charter, Community Guidelines ,Terms of Service and Brand Guidelines.

4. WHY WILL BTPL SHARE DATA WITH B2B PARTIES?

Data may be shared with B2B Parties in order to operate the Koo App. The types of data shared depends on the services rendered by the contracted B2B Parties. The following is an illustrative, and not an exhaustive list, of the purposes for which data is shared:

• For Content Moderation

BTPL may share User Generated Content in accordance with the Koo’s Terms of Service, Privacy Policy and Community Guidelines with B2B Parties. 

• For Product Development and Data Analytics

BTPL may share data with B2B Parties on the product’s operation, data on the product’s interaction with users or for statistical purposes to improve the quality of the platform. 

• For Cyber Security

BTPL may share data with B2B Parties to conduct security audits and other activities to secure the social network.

• For Employment and Administration

BTPL may share data with B2B Parties to assist the administration and human resources at BTPL.

• For Branding and Marketing 

BTPL may share data with B2B Parties to conduct marketing campaigns, promotional activities or any other branding exercise. 

• For Advertising

BTPL may share data with B2B Parties to show trends of general use of Koo App by its users and to show its users advertisements based on their preferences. No personally identifiable of any user will be shared with B2B Parties.

5. HOW SHOULD B2B PARTIES STORE AND PROCESS DATA RECEIVED FROM BTPL? 

• B2B Parties agree and acknowledge that data received from BTPL shall only be stored for a period that is necessary to discharge your contractual obligations under the agreement with BTPL.
• As a social media platform, confidentiality and integrity of data are of vital importance. Access to data provided by BTPL shall be restricted to contracted B2B Parties and their employees or agents on a need to know basis. B2B Parties shall ensure that the data provided by BTPL must not be misused, damaged, modified or unauthorisedly accessed or disclosed and must be protected using best industry standards in compliance with applicable aws. 
• B2B Parties acknowledge and agree that data received from BTPL will be processed solely to perform contractual obligations or meet legal requirements under applicable law.
• B2B Parties acknowledge and agree that data stored and processed will be handled in accordance with the requirements of the Information Technology Act, 2000 and Rules made thereunder. 

6. WHAT ARE THE EXPECTED SECURITY STANDARDS B2B PARTIES MUST FOLLOW?  

• Regardless of the type of data and territory where data is received and processed, B2B Parties acknowledge and agree that data received from BTPL is confidential and shall deploy the highest standards of data protection at a technical and organisational level to protect the confidentiality, accuracy and integrity of the data received. Such measures shall take into account the concrete risks resulting from the processing of personal data as well as up-to-date security standards and procedures. 
• B2B Parties acknowledge and agree to protect the data received from BTPL against accidental, unauthorised, unlawful access, use, modification, disclosure, loss, destruction or damage. 
• In the event BTPL transfers its users’ personal data, B2B Parties agree and acknowledge to store such data by pseudonymising/encrypting/ limiting access or by deploying the best industry practices to maintain the confidentiality and integrity of the data transferred by BTPL to B2B Parties. 
• In the event of any real or suspected adverse event that is likely to compromise the confidentiality and integrity of the data transferred by BTPL, B2B Parties shall notify BTPL within 6 hours of the occurrence of the real or suspected adverse event and provide further notifications as prescribed under the Information Technology Act 2000 and the Rules made thereunder. 
• B2B Parties acknowledge and agree that BTPL retains the right to suspend access to the data transferred if it believes that the suspension is necessary to preserve the security, integrity and confidentiality of the transferred data.

7. HOW ARE B2B PARTIES EXPECTED TO PROTECT USERS’ PERSONAL DATA? 

• B2B Parties acknowledges that it has reviewed the BTPL’s Privacy Policy available at www.kooapp.com/privacypolicy  and agrees to comply with the same and applicable laws while processing any personal data during the course of performance of any agreement with BTPL. In addition to the above, B2B Parties will:
  • Process personal data (as defined under the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011) solely for the purpose of, and only to the extent necessary for, the performance of the services under the agreement with BTPL and in accordance with Koo’s Privacy Policy and other applicable laws.
  • Not: (a) sell or disclose the personal data to any third party for the commercial benefit of B2B Parties or any entity; or (b) retain, use, disclose or otherwise process the personal data outside of the direct business relationship between the B2B Parties and BTPL (c) Transfer (and will not permit its subcontractors to transfer) any personal data unless the transfer is strictly necessary for the provision of this agreement (d) Transfer any personal data to a subcontractor without ensuring that the subcontractor has signed same/similar obligations relating to personal data.
  • Provide reasonable assistance, information, and cooperation to BTPL to ensure compliance with obligations under applicable data protection, privacy and data security laws, including with respect to requests from data protection authorities or responding to requests from individuals to exercise their rights relating to personal data about them. 
  • Provide notice to BTPL within six (6) hours of discovery of any event involving any actual, suspected, potential, or threatened compromise of the confidentiality, integrity, or availability of personal data.
  • Implement and maintain, appropriate technical and organizational measures in relation to its processing of personal data so as to ensure an appropriate level of security in accordance with applicable law. Ensure that its employees, agents and subcontractors authorized to process personal data have committed themselves to confidentiality and protection of personal data.
  • Upon the termination or expiration of the Agreement with BTPL, securely destroy or return to BTPL as directed, all personal data processed by B2B Parties and by its sub-contractor in connection with performance of the Services under the agreement with BTPL. 

8. CHANGES TO THIS POLICY 

• This Policy is effective from the date mentioned in the title of this document and will be modified each time is necessary without prior or future notice of the changes. 
• The newer version will enter into force when published on the website and it will be marked accordingly.

9. CONTACT US

If you have any questions or concerns regarding this policy, please do not hesitate to write to legal@kooapp.com