Privacy Policy

Global Privacy Policy &
Child Safety Standards Policy

Last modified: [2024-06-19]

Welcome to Koottu!

At Koottu, fostering meaningful connections is our passion. We understand that privacy is essential for building trust within our community. This Privacy Policy explains how We collect, use, and protect Your information when You use the Koottu mobile app (“App” or “Koottu App”).
This policy applies solely to Your use of the App. By using the App, You agree to the terms of this Privacy Policy. If You have any questions about this policy, please don’t hesitate to contact us.

Scope of this Privacy Policy

What This Policy Covers

This Privacy Policy applies solely to Your use of the App. It outlines how We collect, use, and disclose information You provide or that is collected when You use the App.

What This Policy Does Not Cover

This policy does not cover:

Information collected by third-party websites or apps that may link to or be accessible from the Koottu App.
Data collected by Us through other means, such as offline interactions.

We encourage You to review the privacy policies of any third-party services You access through the Koottu App.

Changes to This Policy

We may update this Privacy Policy from time to time. We will notify You of any changes by posting the new Privacy Policy within the App. Your continued use of the App following any changes constitutes Your acceptance of those changes.

INTERPRETATIONS AND DEFINITIONS

Interpretation

In this policy document, words with initial capitalization carry specific meanings under defined conditions. These definitions hold consistent significance throughout this policy, irrespective of whether they are expressed in singular or plural form.

Definitions

For the purpose of this Privacy Policy:

Account:A unique account created for You to access the Koottu App and its features.
App:Refers to the Koottu mobile application.
Company (referred to as either “the Company”, “We”, “Us” or “Our” in this Agreement) refers to Koottu Inc. For the purpose of the GDPR, the Company is the Data Controller.
Consumer(for the purpose of the CCPA, California Consumer Privacy Act), means a natural person who is a California resident. A resident, as defined in the law, includes (1) every individual who is in the USA for other than a temporary or transitory purpose, and (2) every individual who is domiciled in the USA who is outside the USA for a temporary or transitory purpose.
Cookies:Small files that are placed on Your Device by the App, containing details about Your use of the App.
Data Controller(for the purposes of the GDPR, General Data Protection Regulation), refers to the Company as the legal person which alone or jointly with others determines the purposes and means of the processing of Personal Data.
Device:Any device that can access the App, such as a Smartphone or tablet.
Personal Data:Any information that relates to an identified or identifiable individual. For the purposes of GDPR, Personal Data means any information relating to You such as a name, an identification number, location data, online identifier or to one or more factors specific to Your physical, physiological, genetic, mental, economic, cultural or social identity. For the purposes of the CCPA (if applicable), Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could reasonably be linked, directly or indirectly, with You.
Sale(for the purpose of the CCPA, California Consumer Privacy Act), means selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a Consumer’s personal information to another business or a third party for monetary or other valuable consideration.
Service Provider:Any natural or legal person who processes data on behalf of the Company. It refers to third-party companies or individuals employed by the Company to facilitate the App, to provide services related to the App, or to assist the Company in analyzing how the App is used. For the purpose of the GDPR, Service Providers are considered Data Processors.

Usage Data: Data collected automatically by the App, either generated by Your use of the App or from the App’s infrastructure itself (for example, the duration of a session).

What Data do We Collect

We are committed to transparency regarding the information we collect about You when You use Our App. This section outlines the different categories of data We gather:

Personal Data

Email Address
First and Last Name
Phone Number
Postal Address (including city, State/Province, and ZIP/Postal Code)

Location Data

In addition to the postal address, We also store Your location data, including Latitude/Longitude, Country, and City. This information helps Us provide location-based services within the App.

Usage Data

We automatically collect Usage Data to understand how You interact with the App and improve Your experience. This data includes:

● Device’s Internet Protocol (IP) address
● Operating System
● Device Model and Make
● Unique device identifiers (such as IDFV for iOS or Advertising ID for Android)
● App session duration
● Date and time of App use
● Pages or features visited within the App

Additional Information Collected

We collect certain information when You access the App through Your mobile device:

Mobile device type and unique ID
Mobile device IP address
Mobile operating system
Mobile browser type

Other Data We Collect:

Depending on Your interactions with the App, We may collect additional data categories, including:

Personal and Contact Details:When applicable, this may include Name, Title, Email Address, Phone Numbers, and Location.
Login Credentials:We store usernames for Your account login, but We do not collect or store Your passwords.
Audio-Visual Information:In some instances, the App may allow You to capture photos or videos Your use of these features constitutes Your consent to the collection of this data.
Queries, Comments, or Feedback:Any correspondence You submit through the App, such as feedback or questions, may also be collected.

We are committed to collecting only the data necessary to provide You with the best possible experience on the Koottu App. If You have any questions about the data We collect, please don’t hesitate to contact Us.

How Do We Collect Your Data?

We collect information about You in a variety of ways to provide a seamless and personalized experience on the Koottu App, improve our services, and ensure Your safety. We are committed to collecting Your data fairly and lawfully, and We will only use it for the purposes We have explained to You. Here’s a breakdown of how We gather data:

Information You Provide Directly

When You engage with the Koottu App, You may provide us with personal information in several ways:

Account Registration:When You create a Koottu account, We collect information such as Your name, phone number, email address, date of birth, and postal address. You may also choose to upload a profile picture.
Forms and Surveys:The App may offer forms or surveys where You can provide additional information, such as Your interests or preferences.
Customer Support:If You contact our customer support team, We may collect details about Your issue, device information, and communication preferences to resolve Your request effectively.
Online Purchases:If You make in-app purchases, We may collect payment information (e.g., credit card details) and billing addresses through secure payment gateways
Reporting and Reasons:When You report a user or provide reasons behind an action on the App, We may collect relevant information to investigate the issue and maintain a safe and secure environment

Automatic Data Collection

We use certain technologies to automatically collect data about Your interactions with the App:

Analytics Tools:We use tools like Firebase to collect data about App usage, user behavior, and performance metrics. This helps Us analyze trends, identify areas for improvement, and measure the effectiveness of Our features.

(We will have a separate section on Cookies and Similar Technologies.)

Information from Third Parties

In some instances, we may collect information about You from third-party sources:

Social Media Platforms:If You choose to connect Your social media account (e.g., Facebook or Google) with Koottu, We may collect information from Your public profile, such as Your name, profile picture, and email address. You will be able to control the information shared through Your social media privacy settings.
Business Partners:We may collaborate with business partners, such as joint marketing partners or vendors, who may provide us with limited user information relevant to our services.
Advertising Networks:We may receive information about Your interests and preferences from advertising networks to deliver targeted advertising on the App.

We do not collect any private information from publicly available sources at this time.

Mobile Device Data Collection

When Your use the Koottu App on Your mobile device, we may collect certain device-specific information:

Location Data:If You enable location services on Your device, We may collect Your location data to provide location-based features or tailored content (with Your consent).
Device Information:We may collect basic information about Your mobile device, such as its unique identifier, operating system, and mobile network information.

Other Data Collection Methods

Offline Data Collection:We may collect information offline, such as through paper forms or in-person interactions.
Third-Party Services:We may use third-party services to collect data, such as payment processors or customer support platforms.

We may collect data through other methods in the future, and We will update this policy accordingly. We are committed to transparency and will always inform You about the data We collect and how We use it. If You have any questions about our data collection practices, please don’t hesitate to contact us.

Cookies and Similar Technologies

What are Cookies?

Cookies are small text files that websites store on Your computer or mobile device when You visit them. They collect information about Your browsing activity, such as Your preferences, device details, and website interactions.

While traditional cookies are used on websites, the Koottu App utilizes different methods for storing data locally on Your device. These methods allow us to offer similar functionalities as cookies on a website.

We leverage two primary methods for data storage within the App:
●Shared Preferences: This is a built-in mechanism for storing key-value pairs of data. It allows us to save small amounts of data securely on Your device, such as login preferences or user settings.
●SQL Storage: The App may utilize a local SQL database for storing more complex data structures. This enables features like storing user profiles, offline data, or browsing history (if applicable).

How does this benefit You?

The data we store locally on Your device helps us:

Personalize Your experience:By remembering Your preferences (language, settings), we can tailor the App to Your needs.
Improve performance:By caching certain data locally, we can improve loading times and overall app responsiveness.
Enable offline functionality:Certain features within the App may function even without an internet connection, thanks to locally stored data.

How to manage your Data Storage?

You can manage the data stored by the Koottu App through Your device settings. The specific options may vary depending on Your device and operating system. Look for options related to app data management or storage.

Important to Note:

Disabling or clearing app data may reset Your preferences and require You to log in again.
Some functionalities within the App might be limited if You restrict data storage.

We are committed to using data storage responsibly and for the purposes outlined above. If you have any questions about how we manage data on Your device, please don’t hesitate to contact us.

How Do We Use Your Data?

WE DO NOT SELL YOUR INFORMATION TO ANY THIRD PARTY.
We understand that Your data is personal and precious. We respect Your privacy and are committed to using Your information responsibly and transparently. This section outlines the various ways We may use Your data to enhance Your experience and improve Our services:

Essential Functions

Providing and Maintaining Our Service: We use Your data to operate and manage Our platform, ensuring smooth functionality and access to all features. This includes monitoring usage patterns and identifying potential issues for improved performance.
Account Management: Your data allows Us to manage Your registered account, track preferences, and provide personalized experiences. This could involve remembering login details, language settings, and content You’ve interacted with.
Contract Fulfillment: If You purchase goods or services through our platform, we use Your data to fulfill the contract and ensure a smooth transaction process. This may involve processing payments, sending confirmation emails, and managing delivery or service provision.
Moderators: To monitor activity on the App and approve content.

Communication and Engagement

Updates and Information: We may use Your data to send You essential updates, security alerts, or informative communications about Our platform, services, or features. This ensures You stay informed and aware of important developments.
Personalized Offers and Recommendations: We analyze Your data to personalize content, offers, and recommendations tailored to Your interests and preferences. This might involve suggesting relevant articles, products, or services based on Your previous activity.
Customer Support: Your data helps Us address Your inquiries and requests efficiently. This includes responding to emails, phone calls, or any other communication channel You choose.
To contact You: We may use Your data to reach out to You by email, telephone calls, SMS, or other equivalent forms of electronic communication, such as a mobile application’s push notifications regarding updates or informative communications related to the functionalities, products or contracted services, including the security updates, when necessary or reasonable for their implementation.
News /Offers: We may use Your data to provide You with news, special offers and general information about other goods, services and events which we offer that are similar to those that You have already purchased or enquired about unless You have opted not to receive such information.

Please note that if You have agreed to receive marketing, You may always opt out at a later date. You have the right to stop us from contacting You for marketing purposes. If You no longer wish to be contacted for marketing purpose, You can send us an email to [email protected]

Even if You opt-out of receiving marketing communications, We may still communicate with You in connection with security and privacy issues, servicing Your account, fulfilling Your requests, or administering any promotion or any program in which You may have elected to participate.

Research and Improvement

Data Analysis:We use Your anonymized data for research and analytics purposes. This helps Us understand user behavior, identify trends, and measure the effectiveness of Our platform and marketing campaigns. This ultimately leads to improved service and features for all users.
Testing and Development:We may use Your data to test new technologies, features, and functionalities within Our platform. This allows Us to refine Our offerings and ensure they meet user needs and expectations.

Additional Purposes

Legal Compliance:Your data may be used to comply with legal requirements, regulations, or court orders as necessary. This helps Us maintain transparent and responsible data practices.
Protecting Users and Others:We may use Your data to prevent fraud, abuse, or other potential harm to Our users or the platform. This ensures a safe and secure environment for everyone.
Business Transfers:In case of mergers, acquisitions, or other business transfers, Your data may be transferred as part of the assets. We will ensure such transfers are conducted legally and ethically.
Service Providers:We engage certain trusted third-party companies (“Service Providers”) to perform functions and provide services to Us that enhance Your experience on the Koottu App. We may share Your Registration Information or personal data with these Service Providers, but only for the limited purposes of performing these functions and providing such services. This may include sharing data with:
- Payment Processing and Telecommunications Companies:To facilitate payments processing for premium services and other purchases made within the App.
- Billing Services:To allow users to purchase paid features within the Koottu App (e.g., Google Play).
- Authentication Services:To allow You to securely authenticate their accounts
- Social Media Providers:To allow You to create or connect their Koottu account with their accounts on social media platforms (e.g., Facebook, Instagram, or Spotify).
- Product Improvement and Market Research:To conduct customer surveys and market research through third-party platforms and agencies to improve Our App and services.
- IT Services:Some third-party software providers used to operate the Koottu App may process user data. For example, if a user contacts us via social media with a support inquiry, their inquiry may be processed by Our community management software provider.

We carefully vet all Service Providers before engaging them. We ensure they have adequate data protection and information security measures in place. We only share the minimum amount of data necessary for them to provide the specific service. Additionally, we take steps to ensure that the data shared is anonymized to the greatest extent possible.

Our Service Providers are also subject to strict contractual obligations, including data retention limitations. This ensures that Your data is protected and used only for the authorized purposes.

We are committed to working with reputable Service Providers who share Our commitment to user privacy.

Legal Basis for Processing Your Information

This section outlines the various legal grounds on which We may process Your data, in accordance with the applicable privacy laws including but not limited to the EU and UK Privacy laws. We always strive to strike a balance between Our legitimate interests and Your fundamental right to privacy.

Consent:

In some cases, We rely on Your explicit consent to process Your personal information. This may apply to situations including:

Marketing communications:We may send You marketing emails or messages about Our products and services with Your consent. You can withdraw Your consent at any time by following the unsubscribe instructions in the communication or by contacting Us.
Sharing Your data with third parties:We may share Your data with trusted third-party partners only with Your consent, such as for analytics purposes or to provide You with additional services.

Cookies and similar technologies: We use similar technologies to Cookies to personalize Your experience. To know more about how You can manage Your Data Storage preferences please refer to the Cookies and Similar Technologies section of the Policy.

Contractual Necessity:

We may process Your personal information when it is necessary for the performance of a contract with You, such as:

Providing our services:When You purchase or use Our services, We need to process Your information to fulfill Your order and manage Your account.
Employment contracts:We process the personal information of Our employees as necessary for the performance of their employment contract and related administrative purposes.

Legitimate Interests:

We may process Your personal information based on Our legitimate interests, provided that these interests do not override Your data protection rights. This may include:

Improving our services: We analyze Your usage data to understand how You interact with our App and services, so We can improve them and personalize Your experience.
Security and fraud prevention: We use Your data to protect against fraud, unauthorized access, and other security threats.
Marketing and analytics: We may use Your data for targeted advertising and marketing campaigns, but we will always give You the option to opt out of these communications.

Research and development: We may use Your anonymized data for research and development purposes to improve Our products and services.

Legal Obligations:

We may be required to process Your personal information by law, such as:

Complying with court orders or law enforcement requests: We may be required to disclose Your personal information to comply with a legal obligation, such as a court order or subpoena.
Reporting certain activities: We may be required to report certain activities, such as financial transactions, to government authorities.

Vital Interests:

In rare and exceptional circumstances, we may need to process Your personal information to protect Your vital interests or those of another person. This may include situations where:

Your life or health is at risk.
You are unable to give Your consent, and processing Your information is necessary to protect You.
We need to identify or trace someone who has caused harm to You or others.

We will only process Your data under this basis when it is strictly necessary and no other less intrusive alternatives are available. We will also carefully balance Your vital interests against Your data protection rights.

Public Interests:

We may also process Your personal information when it is necessary for a task carried out in the public interest or in the exercise of official authority vested in us. This may include situations where:

We are required to comply with a legal obligation, such as reporting criminal activity or preventing fraud.
We are carrying out a public function, such as providing healthcare or education services.
We are exercising regulatory or supervisory powers, such as investigating potential breaches of our terms of service.

Moderation Practices

We strive to create a safe and positive environment for all users on the Koottu App. To achieve this, we have implemented a combination of automated moderation systems and a dedicated moderation team.

Automated Systems: We utilize automated systems to identify and flag content that may violate our Community Guidelines (replacing “Terms and Conditions of Use” with a more user-friendly term). These systems analyze content for potential violations, such as hate speech, harassment, or spam.
Human Moderation: A team of trained moderators reviews flagged content and makes informed decisions based on our Community Guidelines. This ensures a nuanced approach to content moderation, considering context and intent.

If content is found to violate our Community Guidelines, we may take one or more of the following actions:

Issue a warning to the user.
Restrict user access to certain features or functionalities.
Temporarily or permanently suspend the user’s account.

We understand that mistakes can happen. If You believe Your account or content has been suspended or restricted in error, You have the right to appeal the decision. You can contact our support team through the App or by emailing us at [email protected]

Why We Process Your Data (Legal Basis)

European Union (EU), United Kingdom (UK) California data protection laws require us to be transparent about the legal basis for collecting and using Your information. This table outlines the purposes for which we process Your data and the corresponding legal basis for each.

Purpose	Data	Source	Legal Basis	CCPA Category
Provide the Koottu App services	Name, email address, phone number (optional)	You provide this information	Contractual Necessity	A, B
Facilitate connections on Koottu	Profile information (including photos, interests, etc.)	You provide this information	Contractual Necessity and Legitimate Interests (to facilitate connections)	B, C, H, I, J
Verify Your identity and prevent fraud	Phone number (optional), photo (for verification in some countries), geolocation and device information	You provide a phone number and photo (optional). We obtain geolocation and device information from Your device.	Legitimate Interests (security and fraud prevention)	A, B, C, E, F, G, H
Take payment for premium services (if applicable)	Payment card details	You provide this information	Contractual Necessity	B, D
Send marketing information (with Your consent)	Name, email address, postal address (optional)	You provide this information	Consent	A, B
Improve the Koottu App	Log and usage data (e.g., IP address, browsing activity), profile information	You interact with the App and provide profile information. We obtain log and usage data from Your device.	Legitimate Interests (app improvement)	A, F, H
Respond to Your inquiries	Email address, phone number (optional)	You provide this information	Legitimate Interests (customer service)	B, F
Investigate and block users for misuse	Username, registration details, profile information, message content, photos, usage data, device information	You provide registration details, profile information, messages, and photos. We obtain other information from Your device.	Legitimate Interests (security and maintaining app integrity)	A, B, C, F, H
Improve Your Koottu experience	Data about profile photo interactions (e.g., scrolling, voting)	We obtain this information from how You interact with the App	Legitimate Interests (user experience improvement)	-
Enable login with third-party accounts	Data from third-party accounts (e.g., Facebook)	We obtain this information from the third-party provider.	Legitimate Interests (facilitating access)	A, B, C, H
Block fraudulent transactions	Name, IP address, email address, phone number, cardholder name, payment details	You provide name, email address, phone number, and card details. We obtain Your IP address from Your device.	Legitimate Interests (fraud prevention)	A, B, D
Serve relevant ads on Koottu (limited by Your preferences)	Location (limited by Your preferences), age, gender, profile information (optional)	You provide age, gender, and profile information (optional). We obtain location data from Your device (limited by Your preferences).	Legitimate Interests (targeted advertising)	A, C, G

What Others Can See About You

At Koottu, we believe our Users are amazing, and we want to empower You to showcase that! The Koottu App is designed to facilitate connections and interactions between Users. However, it’s important to be mindful of what information You choose to share, as some aspects may be publicly viewable.

General Visibility:

By default, Your Koottu profile information, including photos and bio (if provided), is visible to other Users within the App. This allows them to discover You and potentially connect with You.
Remember, anything You post or submit on the App, including messages and comments, may be seen by other Users.

Sharing and Privacy Considerations:

We encourage Users to be cautious about posting sensitive information on their profiles. This includes details like religious beliefs, health information, or political views.
While some features allow You to add optional details like interests or badges that might reveal personal preferences, You are not obligated to use them.
Be mindful that photos You share can also disclose personal details about Your lifestyle or surroundings.
By uploading and choosing to share sensitive information on Your Koottu profile, You explicitly consent to Us processing this information and making it visible to other Users.

Sharing Beyond the App:

It’s important to understand that information You share on Koottu may be seen or shared by Users with others outside the App.
For example, a User might share Your profile information (e.g., screenshot) with a friend who isn’t a Koottu user. We have no control over how others use such shared information.

Third-Party Accounts:

If You connect Your Koottu account to a third-party account (e.g., Facebook, Instagram), certain information from that account may be visible on Your Koottu profile (refer to our section on “Third-Party Links” for more details).

Data Downloads (if applicable):

In some regions, local laws may require Us to provide Users with the ability to download their Koottu data, which could include conversation history. We have no control over how Users might share or use this downloaded information.

Protecting Your Privacy:

If You access the Koottu App on a shared device, remember to log out completely to prevent others from accessing Your account.

We encourage You to be mindful of the information You share on Koottu and to use the App’s features responsibly.

HOW DO WE STORE YOUR DATA?

We understand that Your data is personal and precious. We respect Your privacy and are committed to using Your information responsibly and transparently. This section outlines the various ways We may use Your data to enhance Your experience and improve Our services:

Global Infrastructure for Accessibility:

We want You to enjoy Our services from anywhere in the world. To make this possible, We leverage a robust cloud infrastructure provided by Amazon Web Services (AWS). AWS operates a global network of data centers strategically located across the globe, ensuring high availability and accessibility for your data. Our data is stored securely within these AWS data centers. While AWS manages the underlying infrastructure, We maintain complete ownership and control over Your data. We implement strict security measures and access controls to safeguard Your information. This approach allows us to deliver a fast, reliable, and secure experience for you, regardless of your location.

Data Location and Transfer:

Your information, including Personal Data, is processed at the Company’s operating offices and in any other places where the parties involved in the processing are located. It means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ from those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.

While We strive to store Your data within Your region whenever possible, some information may be transferred to and processed outside Your country of residence. This may happen for reasons such as:

Providing efficient services:Certain data processing tasks for specific functionalities may be best handled by servers located in different regions.
Data backup and disaster recovery:We maintain data backups in geographically diverse locations for redundancy and disaster recovery purposes.
Compliance with legal requirements:We may be required to transfer data to certain jurisdictions to comply with legal obligations, such as court orders or law enforcement requests.

For additional details on international transfer of data outside of Your country or region, based on Your residence, please refer to our region-specific Privacy Statements called out below.

Safeguarding Your Information:

Regardless of the location, we ensure Your data is protected by implementing robust security measures and legal safeguards. These include:

Secure data centers:We partner with trusted data center providers who offer state-of-the-art security measures to protect Your data from unauthorized access, loss, or misuse.
Data encryption:We encrypt Your data at rest and in transit, using industry-standard encryption protocols to ensure confidentiality.
Access controls:Only authorized personnel have access to Your Data, and strict access controls are in place to prevent unauthorized access or disclosure.
Contractual safeguards:For any data transferred outside Your region, We will implement valid and legally binding mechanisms to ensure an adequate level of protection for Your data. This may include:
- Standard contractual clauses approved by the European Commission for data transfers from the EEA to third countries.
- Binding corporate rules (BCRs) for data transfers within the same corporate group.
- Other approved data transfer mechanisms compliant with applicable data protection laws.

DISCLOSURE OF YOUR DATA

We understand that You trust Us with Your personal information, and We take that responsibility seriously. We only disclose Your data in limited circumstances, as outlined below:

Service Providers:

To provide You with the best possible experience, We may share Your personal information with trusted service providers who assist Us in operating and improving Our services. These providers may handle data such as:

Payment processing for purchases or subscriptions.
Technical support and infrastructure maintenance.
Email delivery and analytics.
Customer service and feedback management.

We carefully select and vet Our service providers and require them to comply with strict data privacy and security standards. We only share the minimum amount of information necessary for them to perform their specific tasks.

Business Transfers:

In the event of a merger, acquisition, or sale of assets, Your personal information may be transferred as part of the business transaction. We will ensure that any such transfer is conducted in accordance with applicable data protection laws and that Your privacy rights are protected. We will notify You of any such transfer and Your options regarding Your information.

Affiliates:

We may share Your personal information with our affiliated companies, who will treat Your data with the same care and respect as we do. These affiliates may include parent companies, subsidiaries, or joint venture partners. We will only share Your information with affiliates for legitimate business purposes, such as providing You with a wider range of products and services.

Legal Requirements:

We may be required to disclose Your personal information to comply with applicable laws or regulations, such as court orders, subpoenas, or requests from law enforcement agencies. We will only disclose Your information in good faith and as required by law.

Public Safety and Legal Protection:

We may disclose Your personal information to protect the safety of our users or the public, or to prevent or investigate illegal activity. This may include situations where we believe there is an imminent threat of harm to an individual or the public, or where we need to prevent fraud or abuse of our services.

With Your Consent:

We may disclose Your personal information for any other purpose with Your express consent. We will always request Your consent before sharing Your information for any purpose not covered in this Policy.

What are Your Data Protection Rights?

Depending on Your location and the applicable laws, You may have certain rights regarding Your data, including:

Right to information:You have the right to be informed about how we collect, use, and share Your personal information. This includes the purposes for processing, the categories of data we hold, and the recipients or categories of recipients with whom we share it.
Right to access:You have the right to request access to Your personal information and to receive a copy of it.
Right to rectification:You have the right to request the correction of inaccurate or incomplete personal information about You.
Right to erasure:In certain circumstances, You have the right to request the deletion of Your personal information. This may include situations where the data is no longer necessary for the purposes for which it was collected, You withdraw Your consent, or the processing is unlawful.
Right to object:You have the right to object to the processing of Your personal information for certain purposes, such as direct marketing or profiling.
Right to restrict processing:You have the right to request the restriction of the processing of Your personal information in certain circumstances, such as while we verify the accuracy of Your data or assess the legitimacy of our processing.
Right to data portability:In some cases, You have the right to receive Your personal information in a structured, commonly used, and machine-readable format and to transmit it to another controller without hindrance.
Right to complain:You have the right to lodge a complaint with a supervisory authority if You believe that Your data protection rights have been violated.

Please note that Your specific rights may vary depending on Your location and the applicable data protection laws. We may require certain information from You to verify Your identity and confirm Your right to exercise these rights. We will respond to Your requests within a reasonable timeframe, as defined by applicable laws.

For more detailed information about Your data protection rights in Your specific region, please refer to our region-specific Privacy Statements.

We encourage You to review Your rights and contact us [email protected] if You have any questions or concerns about Your data protection rights.

How Long We Keep Your Data

At Koottu, we take the retention of Your data seriously. We strive to balance the need to provide You with a high-quality app experience with our legal obligations to data security and privacy.

General Data Retention Periods

We retain Your data for as long as it’s necessary to:

Deliver and improve the Koottu App and its functionalities.
Fulfill our contractual obligations to You.
Comply with applicable legal requirements, such as data retention laws.

Specific Examples

Here are some specific examples of how long We may retain Your data:

Account Information:We retain Your account information for as long as Your account is active. If You deactivate Your account, We may retain certain data for a limited period to comply with legal or regulatory requirements, resolve disputes, enforce our agreements, or prevent fraud.
Usage Data:We may retain usage data, such as app activity logs, for a shorter period for analytics purposes. This helps Us understand how Users interact with the App and improve its overall functionality.
Device Information:We may retain device information, such as device type and operating system, for as long as it’s necessary to maintain the security and functionality of the App.

Account Deletion

When Your Account is deleted, we make sure it is no longer viewable in the App. For up to 30 days, it is still possible to restore Your Account if it was accidentally deleted. After this, We begin the process of deleting Your personal information from Our systems, unless:

●We must keep it to comply with applicable law (for instance, if You make purchases within the App, some personal data may be kept for tax and accounting purposes);
●We must keep it to evidence Our compliance with applicable law (for example, if an account is blocked, We keep some account information and a record of the behavior that led to the block – this information is retained for evidential purposes in case of queries or legal claims concerning the block);
●there is an outstanding issue, claim or dispute requiring Us to keep the relevant information until it is resolved; or
●The information must be kept for our legitimate business interests, such as fraud prevention and enhancing Users’ safety and security (for example, information may need to be kept to prevent a user who was banned for unsafe behavior or security incidents from opening a new account).

Warning: Even after You remove information from Your profile or delete Your Account, copies of that information may still be viewable and/or accessed to the extent such information has been previously shared with others, or copied or stored by others. We cannot control this, nor do we accept any liability for this.
If You have given third party applications or websites access to Your personal information, they may retain such information to the extent permitted under their terms of service or privacy policies.

Data Anonymization

Once Your data is no longer necessary for the purposes described above, We will either delete it or anonymize it. Anonymized data cannot be linked back to You and is used for statistical purposes to improve the Koottu App.

Your Control Over Your Data

You have the right to request access to Your data and to request its deletion. You can exercise these rights by contacting Us through the App or by emailing Us at [email protected] Please note that there may be circumstances where We are required by law to retain certain data, even after You request its deletion.

We are committed to being transparent about our data retention practices. If You have any questions, please don’t hesitate to contact Us.

Children’s Privacy

The Koottu App is not intended for children under the age of 18 (or such other age as defined by the laws of Your jurisdiction). We do not knowingly collect personally identifiable information from anyone under this age.

Protecting Children Online

We take protecting children’s privacy online very seriously. Here’s how We ensure this:

Age Restriction:We encourage parents and guardians to be mindful of their children’s online activities. The Koottu App requires users to be at least 18 years old (or such other age as defined by the laws of Your jurisdiction) to create an account.
Verification Measures:While We cannot guarantee that users will always provide their accurate age, We may employ various verification measures to discourage underage users from registering for the App.
Parental Controls:We encourage parents and guardians to utilize parental control features available on their devices to restrict their children’s access to certain apps and websites, including the Koottu App.

Reporting Concerns: If You believe a child under the age of 13 (or such other age as defined by the laws of Your jurisdiction) has provided Us with personal information, please contact Us immediately. We will take steps to remove such information from Our servers.

Our Moderation Practices

We are committed to providing a safe and positive environment for all users on the Koottu App. This includes protecting children from harmful content and interactions. Please refer to our “Moderation Practices” section for more information on the steps We take to moderate content and user behavior within the App.

We encourage parents and guardians to have open conversations with their children about online safety and responsible use of mobile apps.

If You have any questions about our practices regarding children’s privacy, please don’t hesitate to contact Us.

Links to Other Websites/Apps

The Koottu App may occasionally include links that direct You to external websites or apps that are not operated by Us. These links are provided for Your convenience and information only. When You click on a third-party link, You leave the Koottu App and navigate to the website or app controlled by that separate entity.

We are not responsible for the content, privacy practices, or security of any linked websites or apps.

We encourage You to review the privacy policies of any third-party websites or apps You visit to understand how they collect and use Your data.

Changes to This Privacy Policy

Our Privacy Policy may be updated periodically. We will notify You of any changes by posting the revised Privacy Policy on this page. Notification may also be provided via email and/or a prominent notice on our Service before the changes take effect. The “Last Updated” date at the top of this Privacy Policy will reflect the most recent modifications.

We encourage You to revisit this Privacy Policy periodically to stay informed about any changes.

Contact Us

If You have any questions or concerns regarding this Privacy Policy, or if You wish to exercise Your data subject rights, please feel free to contact Us through the following methods:

In-App Contact Form:You can reach Us directly through the contact form within the Koottu App settings.
Email:You can send Us an email at [email protected]

We value Your privacy and are committed to being transparent about our data practices. We will do our best to address any inquiries or concerns You may have in a timely manner.

Child Safety Standards Policy

Welcome to Koottu! Our community is built on the principles of kindness, inclusivity, and respect. At Koottu, we strive to create a safe and welcoming environment for all users. We believe that every member of our community deserves to feel secure and respected, and we are committed to fostering an atmosphere where everyone can connect and share without fear. Our platform is designed to promote positive interactions and meaningful connections, and we take our responsibility to protect our users very seriously.

Zero-Tolerance Policy

KOOTTU MAINTAINS AN ABSOLUTE ZERO-TOLERANCE STANCE AGAINST ANY MATERIAL THAT OBJECTIFIES, SEXUALLY EXPLOITS, OR PUTS CHILDREN AT RISK ON OUR PLATFORM. SHOULD WE DETECT SUCH CONTENT OR RECEIVE INFORMATION ABOUT IT, WE WILL PROMPTLY NOTIFY THE RELEVANT AUTHORITIES.

Commitment to Child Safety

At Koottu, we are unwavering in our dedication to preventing the distribution and consumption of child sexual abuse material (CSAM) on our platform. This encompasses all forms of media, including but not limited to text, images, videos, illustrations, and computer-generated content. We recognize the gravity of our responsibility to ensure that our platform remains a safe space, free from content that exploits or endangers children in any form, and we are fully committed to discouraging any attempts to search for, share, or engage with CSAM.

Any content that involves or depicts a child – whether real, fictional, or digitally rendered—or that in any way promotes or condones the sexual exploitation of minors is strictly prohibited. This is considered a serious breach of our Terms of Service. Additionally, written materials that references or implies child sexual abuse or exploitation are similarly forbidden and subject to immediate removal.

For the purposes of this policy, a child is defined as anyone under the age of eighteen (18) years. We maintain a zero-tolerance approach toward any violations, and we take prompt action to report any suspected instances of CSAM to the appropriate authorities for further investigation and legal action.

We strictly forbid the use of our platform to harm or exploit children in any manner. This includes, but is not limited to, using apps to engage in predatory behavior directed towards minors. Such conduct may involve, but is not limited to, the following:

Inappropriate contact or behavior aimed at a child: This includes any physical or virtual interaction that is inappropriate or harmful, such as touching, groping, or caressing.
Child grooming: The act of establishing a relationship or emotional connection with a child, either online or offline, with the intent to engage in sexual contact or the exchange of sexual images.
Sexualizationof minors: Any imagery or content that depicts, encourages, or promotes the sexual exploitation or abuse of children, or that portrays minors in a way that could lead to their sexual exploitation.
Sextortion: Using threats or blackmail against a child, often by leveraging real or alleged access to intimate images of the child, to exploit or coerce them.
Childtrafficking: The use of apps to facilitate the solicitation or advertisement of a child for purposes of commercial sexual exploitation.

We maintain a zero-tolerance policy towards these behaviors and will take immediate action to address any violations.

Support for Global Initiatives

Koottu actively endorses and supports global efforts aimed at combating child sexual exploitation and abuse in the digital realm. In particular, we align ourselves with the goals of the Voluntary Principles to Counter Online Child Sexual Exploitation and Abuse. This initiative, spearheaded by the Five Country Ministerial (5 Eyes) in collaboration with leading technology companies, seeks to address the growing challenges posed by the misuse of digital platforms for child exploitation.

We acknowledge that while technological advancements have brought about significant benefits, they have also been exploited by malicious actors. However, we are committed to implementing comprehensive, adaptable, and effective policies to counter these risks. By engaging in meaningful collaboration across sectors and contributing to global initiatives, we aim to play an active role in the collective fight to eliminate the spread of child sexual abuse and exploitation online.

Our mission is to create a safer digital environment, and we will continue to enhance our efforts to protect vulnerable individuals from harm while promoting awareness and responsible usage across our platform.

Guidelines

To uphold the safety and integrity of our community, particularly for children, Koottu has established strict guidelines regarding the types of content that are not permitted on our platform. We ask that you follow these rules when sharing any material:

DO NOT share any content (including visual, audio, or written material) that:

Involves or portrays a child in any manner.This includes any representation of a child, whether real, fictional, or animated.
Sexualizes a child.This includes any content that depicts a child (in any form, including illustrations or computer-generated images) in sexually explicit situations or suggestive behaviors.

This list is not exhaustive and serves as a guideline. For a comprehensive understanding, please refer to our Terms of Service, particularly the section labeled “Prohibited Uses.” Koottu retains the authority to assess the appropriateness of content and ensure compliance with our Terms of Service. We reserve the right to remove any content at our discretion and without prior notice if it is deemed inappropriate.

Enforcement

At Koottu, we are committed to maintaining a safe and secure platform for all users. We have established strict policies and operational mechanisms to address and swiftly act against any instance of child sexual abuse material (CSAM). Our approach is centered around manual moderation and user-reported incidents.

We rely primarily on our dedicated team of human moderators who regularly review and monitor content on our platform. Our moderators are trained to identify and address any violations of our policies, including the presence of CSAM. Additionally, we encourage our users to actively participate in maintaining the safety of our community by reporting any content that violates our Child Safety Standards Policy.

When we identify or are alerted to an actual or potential instance of CSAM on our platform, we take immediate action to remove the content and conduct a thorough investigation. Any material identified as CSAM is reported to the appropriate authorities. We also cooperate fully with law enforcement investigations and promptly respond to valid legal requests to assist in combating the dissemination of CSAM.

We are dedicated to creating a secure and respectful environment for all users, and your adherence to these guidelines is crucial in maintaining that commitment. Thank you for your cooperation.

How to Report Violations

At Koottu, we prioritize the safety and well-being of our community. We encourage all users to report any content that violates our policies, especially if it involves child sexual abuse material (CSAM) or any other form of inappropriate content. Here’s how you can help us maintain a safe environment:

Reporting Process

Flagging Content:

Using the Flagging Feature:If you encounter content that you believe violates our policies, you can use the flagging feature available on the platform. This feature is designed to be easily accessible and user-friendly.

Contacting Us Directly:

Email Us:If you prefer to report a violation directly, you can send an email to [email protected]. Please provide as much detail as possible about the content you are reporting, including the specific URL or location of the content on our platform.
Confidentiality:All reports and complaints submitted to Koottu are kept strictly confidential. We take the privacy of our users very seriously and ensure that your identity is protected.
Swift Action:Our team of dedicated human moderators reviews all flagged content and reports promptly. We work swiftly to handle the content appropriately, ensuring that any violations are addressed immediately.
Detailed Information: When reporting a violation, please provide as much detail as possible. This includes the specific URL or location of the content, a description of why you believe the content violates our policies, and any other relevant information.
Contact Information:While not required, providing your contact information can help us follow up with you if we need additional details.

Consequences for Violating This Policy

Koottu maintains an unwavering commitment to the safety and well-being of children. We have a zero-tolerance policy towards any content that involves a child or constitutes child sexual abuse material (CSAM). Any content that we identify or are made aware of that violates this policy will result in the immediate removal of the content and the permanent banning of the user who uploaded it. We take swift and decisive action to ensure that our platform remains a safe space for all users.

We report all instances of apparent CSAM to the appropriate authorities without delay. Our actions are guided by a strong sense of responsibility to protect children and uphold the integrity of our community.

Additional Resources and Support

If you believe a child is in imminent danger, it is crucial to contact your local law enforcement agency immediately. Time is of the essence in such situations, and immediate action can make a significant difference.

In addition to reporting to local authorities, you may also choose to reach out to organizations dedicated to combating child sexual exploitation and abuse. These organizations play a vital role in protecting children and can provide support and resources. Reports can be made anonymously, and they are an essential part of our collective effort to safeguard children.

We encourage you to take advantage of these resources and to report any suspicious activity or content that you encounter. Your vigilance and action can help prevent harm and protect vulnerable individuals.

International Association of Internet Hotlines

National Center for Missing and Exploited Children (NCMEC)

Canadian Centre for Child Protection

Internet Watch Foundation

Thank you for your cooperation and commitment to maintaining a safe and respectful community on Koottu.

The Team

Just like you, our team, is made up of people who tried different apps available for dating but weren’t fully satisfied and saw an amazing possibility for an app that is focused only on Malayalis.

Global Privacy Policy & Child Safety Standards Policy