Privacy Policy (US)

By Koo App
March 7, 2024

Privacy Policy – November 30, 2022

Bombinate Technologies Pvt. Ltd. (Company, we, our, us) takes your privacy very seriously. This Privacy Policy (Privacy Policy) describes the usage of information provided or disclosed to the Company, which may be inclusive of your personal data, and also brings to your notice the rights which are afforded to you as per the terms of this Privacy Policy. This Privacy Policy must be read in conjunction with the Terms of Service and the Community Guidelines.

Our Privacy Policy is in accordance with the applicable laws in the jurisdictions we offer our Services in. All capitalized terms that have not been specifically defined herein shall have the same meaning as provided under the Terms of Service.

By accessing, downloading, or using the website or the allied mobile application, Koo App (Application) you agree to be governed by this Privacy Policy.

1. Scope

1. This Privacy Policy applies to the Services, Application, or any online application or service that refers to or links to this Privacy Policy. This Privacy Policy applies regardless of whether you have downloaded or accessed or used the Application from your mobile telephone or handheld device or any other computer resource to access our Services.
2. Koo is a public, microblogging platform. The users acknowledge and understand that any content (including their user handle, profile picture and published posts/ Koos) created by the users, is publicly available and searchable by anyone around the world. It is advised that the Users do not post any personal (or sensitive) personal data in a Koo. You should be careful of what you are posting on the Application, for the updates will be reflected in your feed and will be visible to other Users of the Application, or anyone else who accesses our Services, depending upon the privacy setting specifically chosen by you for your account.
3. You acknowledge and agree that by providing public Content on Koo, you are authorizing and advising us to disclose that information on the Application and allow for wide circulation. When you are using hashtags, our APIs, and that of other third-party service providers will also have access to such information. We do not govern the operations of these entities, and you may be required to adhere to their policies, hence, we urge you to refer to their policies and familiarize yourself with the same, prior to engaging with such third-party platforms.

2. Information We Collect

1. At the time of registration: When you choose to register on the Application, we will seek certain identifiers which qualify as personal data (as defined at law), and some of these identifiers will have to be mandatorily collected, and some will have to be collected only upon your discretion, and consent.
2. The information which you provide to us, mandatorily are:
   1. Mobile number and/or E-mail address: For creation of a unique profile, identification, authentication via OTP and any communications from us or on our behalf or by any third parties engaged by us to provide the Service.
   2. Username or e-mail address or profile photo: If you sign up/sign in to your Koo account using a One-Tap/Single Sign On (SSO) from any supported third party service which allows authentication of your identity and allows you to share personal information with us (such as your name or email or profile photo) to pre-populate signup/sign into the Koo platform. 

1. The information which you may choose to additionally provide, are:
   1. Name: for purposes of displaying on your profile;
   2. User handle preference: for the purposes of identification on the Application;
   3. Date of Birth: for the purposes of identification and/or displaying on your profile;
   4. Gender: for the purposes of displaying on your profile;
   5. Profile Picture: for the purposes of displaying on your profile;
   6. Location: for the purposes of customizing your experience on the Application;
   7. The language that you wish to communicate in: for the purposes of posting content on Koo;
   8. Language preference: for the purposes of customisation of the Content, and other services offered to you;
   9. Professional details: for the purposes of displaying on your profile and for customisation of the Content, and oth8er services offered to you;
   10. Description of Self: for the purposes of displaying on your profile;
   11. Relationship Status: for the purposes of displaying on your profile;
   12. Access to information on your device to optimize your use and access of the Services. You can restrict the access granted to the Application, from the device settings. No device permission will be taken from you without your explicit consent.’
   13. Banking information: for the purposes of redeeming any rewards or conducting any transactions on the Koo platform, as may be allowed under relevant laws.  

1. At the time of profile verification – Depending on which jurisdiction you are in, in order to verify your profile, we will collect information from you for verification of your identity. Information that we collect may include:
   1. Mobile number;
   2. Driving license;
   3. Any other identification document(s) issued by government authorities.
      We seek this information from you only when you seek to become an authenticated profile on the Application, while using our Services, and such information is not disclosed to the public.

1. Third Party Service Information – When you choose to link third party services with Koo (including other social media platforms like Facebook, Twitter, Instagram, etc.) we will collect your user ID (or equivalent) for such third-party services as well as any information that you may choose to share from that third party service with us.
2. Information from your use of our Services – When you use our Services, we collect the following information automatically:
   1. Content of the Koos (text, images, graphics, audio, visuals, etc.);
   2. Users you follow on the Application;
   3. Users who follow you on Application;
   4. People who have visited your profile and vice versa;
   5. Information on your browser and server logs, including your IP address, information in the cookies and your browsing history;
   6. URL information, time stamp, visit information, your browsing history;
   7. Device information;
   8. Date of download and/or reinstall of the App;
   9. Events related to your actions (follows, reactions to Koos, time spent, how often and when you visit the Application etc.);
   10. Users who send you chat requests and have chatted with you;
   11. The Unique Device Identifier on the Application; and
   12. Language
       We do not collect any further information which is not specifically communicated to you as per this Privacy Policy.
3. Surveys – We may collect additional information at other times, including but not limited to, when you provide feedback(s), modify your content or email preferences, respond to surveys, provide comments, or communicate with us. This information may include your name, e-mail id, mobile number, location, etc. and only such information that you may choose to specifically provide to us.
4. Cookies – We use cookies and similar technologies which are necessary to its functioning. Some of these cookies are essential for us to provide you with the Services on the App. We, or our third-party service providers, may use cookies, mobile app analytics and similar technologies to track visitor activity and collect data on the App. We may combine this data with other personal data we have collected from users.

3. Why We Collect This Information

We collect information to provide the Services and for the purposes as outlined below:

1. To help us identify you when you log onto the Application and when you register an account with us, and, to validate, authorize and map a specific profile with an authorized user;
2. To enhance the quality of the Services that we provide and improve your experience during browsing;
3. For providing location-based services, as and where, requested by you;
4. For the performance of a contractual and legal obligation;
5. To communicate with you;
6. To provide you with news, special offers, general information about other products and services along with marketing information and surveys, as agreed to by you;
7. To provide and process service requests initiated by you.

4. When We Share Your Information

1. We may share any information with our trusted partners or third parties who provide us with infrastructure support services, for meeting the obligations agreed to between you and us. We may also share aggregated, non-personally identifiable information publicly and with our partners, like publishers, advertisers or connected sites to show trends about the general use of our Services. We will seek your consent prior to using or sharing your personal data for any other purpose, if so, identified at a later stage.
2. We may also use your information to perform analytics and conduct customer research, to determine your interest, for identifying content that generate sales and to analyze traffic patterns.
3. We also use your information to market products and/or services to you as per the laws of your country, and to the extent permissible.

5. Disclosure Of Information

1. We may also disclose your personal data only:
   1. As required by law, such as to comply with a judicial order, executive orders, requirement by a law enforcement authority, or by other legal processes.
   2. When your desired products and services can only be provided if your personal data is disclosed.
   3. When we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, or, investigate fraud or crime;
   4. If we (or our affiliates) are involved in a merger, acquisition, or sale of all or substantially all of its assets or equity.
2. We will never rent or sell your personally identifiable information to others.

6. User Rights On Koo

We want to ensure that you are fully empowered on our platform and are completely aware of the rights that you are entitled to in the course of using our platform. You have a number of rights in relation to the personal data we hold about you.

1. Access. The right to access your personal information we hold about you, and to obtain details of the processing. You also have the right to access a list of all the third parties that have your personal data through us.
2. Rectification. The right to seek, correct, update and modify your personal data available with us, to ensure accuracy.
3. Cancellation. The right to seek to cancel or erase, free of charge, your personal information when it is inadequate, excessive, or unnecessary. This shall be subject to the lawful processing measures.
4. Objection. The right to restrict or withdraw your consent to, our continued processing of your personal data , at any point of time, subject only to any legitimate reason for continued processing in certain circumstances.
5. Portability. The right to seek from us your personal data to be provided to another service provider, in a machine-readable format.
   You may exercise any of these rights by writing to us at redressal@kooapp.com This shall be subject to the legal requirements, and our internal procedure.

7. How Long Will Your Personal Data Be Stored With Us?

1. In relation to other personal data, we store them for certain pre-determined periods based on the basis of (i) statutory and legal requirements; (ii) industry guidelines, (iii) deidentified or pseudonymized data sets to be used in an aggregated format for scientific, statistical or historical purposes.
2. We retain the information which we have collected for a period no longer than is necessary, and as may be required in law. If we need to retain your personal data for a longer period, we will inform you prior to the extension of the storage period and seek your explicit consent to extend the retention period. We will delete your information whenever you request us to do so. However, we may archive and/or retain some information for legal purposes. Any other information which is processed by us for analytical purposes, will only be processed in an aggregated or non-identifiable basis.

8. Opting Out

1. You can always opt out of our Services or choose not to disclose information to us at any time. However, keep in mind that some information may be needed to register with us or to take advantage of some of our special features. By providing limited information, or by availing the opt-out provision, you may not be able to access full functionalities of our Services and Application, and some features may be disabled for your access.
2. We reserve the right to continue to keep a copy of any of your personal data if required by law. We may use any aggregated/anonymized data derived from your account, in a matter which shall not infringe upon your privacy.

9. The Security Of Your Information

1. Your personal data is maintained by us in electronic form. We shall take all necessary precautions to protect your personal data and implement reasonable security practices and measures including certain managerial, technical, operational and physical security control measures that are commensurate with respect to the information being collected and the nature of our business. Specifically, we will ensure that the security infrastructure put in place by us to safeguard your personal data against loss, unauthorized access, destruction, use, processing, storage, modification or de-anonymization, will at all times be adherent to the best industry standards.
2. We restrict access to personal data to Company employees, contractors, and agents who need that information in order to process it. Anyone with this access is subject to strict contractual confidentiality obligations and may be disciplined or terminated if they fail to meet these obligations.

10. The GDPR Compliance

The Application may be accessed and used by residents of the European Economic Area (EEA), who would be regulated by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (GDPR). EU citizens may reach out to us at: redressal@kooapp.com with a subject line “GDPR compliance”. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Any transfer of data generated from EU citizens shall be subject to the data transfer compliances outlined in GDPR.

11. Overseas Transfer

1. Your information may be transferred to and stored in locations outside laws of the territory in which the Company is registered and where the Application is registered on the app stores. We will do this only when the destination jurisdiction has an adequate and appropriate level of protection and where the transfer is lawful, and only when the same is required for us to meet our contractual and statutory obligations, and only where the laws of your country allow us to do so. For completeness, the information which may be transferred outside is such information which may be sent to foreign jurisdictions as per the applicable laws.
2. When we transfer your personal data from your home country (country, state and city in which you are present) to the alternate country (another country, state and city), we will comply with our legal and regulatory obligations in relation to your personal data, including having a lawful basis for transferring personal data and putting appropriate safeguards in place to ensure an adequate level of protection for the personal data. We will also ensure that the recipient in alternate country is obliged to protect your personal data at a standard of protection comparable to the protection under applicable laws.
3. Our lawful basis for such transfer will be either on the basis of content or one of the safeguards permissible by laws.
4. For transfer of data outside the EEA, we will follow adequate safeguards mandated under the GDPR. We ensure an adequate level of protection for the rights of data subjects based on the adequacy of the receiving country’s data protection laws, contractual obligations placed on the recipient of the data (model contractual clauses).

12. Children

1. You must have attained the age of majority to be able to use and access our Services. If you are a minor in your jurisdiction, your registration and use of our Services must be with the supervision of an adult.
2. As a parent or legal guardian, please do not allow your minors under your care to submit personal data to us. In the event that such personal data of a minor is disclosed to us, you hereby consent to the processing of the minor’s personal data and accept and agree to be bound by this Privacy Policy and take responsibility for his or her actions.

13. Personal Data Of Others

In some situations, you may provide personal data of other individuals (family, friends, likewise) to us. If you provide us with such personal data, you represent and warrant that you have obtained their consent for their personal data to be collected, used and disclosed as set out in this Privacy Policy.

14. Changes To This Privacy Policy

We make periodical changes to the Privacy Policy. Any significant changes we may make to our Privacy Policy in the future will be promptly notified to Users by posting the relevant terms in a prominent position on the webpage. The new terms may be displayed on the webpage, and you will be required to read and accept them to continue your use of the Services.

15. Grievance Redressal Mechanism

Any discrepancies or grievances with regard to content and or comment or breach of this Agreement shall be taken up with the designated Grievance Officer as mentioned below via in writing or through email signed with the electronic signature to redressal@kooapp.com (“Grievance Officer”) Mr. Rahul Satyakam, Grievance Officer
849, 11th Main, 2nd Cross, HAL 2nd Stage, Indiranagar, Bangalore, Karnataka – 560008.

16. Our Contact Details

Bombinate Technologies Private Limited, 849, 11th Main, 2nd Cross, HAL 2nd Stage, Indiranagar, Bangalore, Karnataka – 560008.