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
We collect personal data to enable communication, identification, and optimize Your experience on the App. This may include the following information You provide when registering for an account or interacting with the App's features:

• 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 Date 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 Your 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 Your 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 please click here or alternatively, 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 than 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.

California Privacy Notice

This California Privacy Notice supplements the Koottu App Privacy Policy and applies to California residents. It explains how We collect, use, and share Your personal information, and Your rights under the California Consumer Privacy Act (CCPA) and California Privacy Rights Act (CPRA).

Personal Information We Collect:
We collect various categories of personal information about California residents, as described in the table within our main Privacy Policy. This information is collected for the purposes outlined in the table, which aligns with CCPA categories.

Sharing with Third Parties:
We may share Your personal information with certain third-party service providers to operate the Koottu App and deliver our services. Please refer to the "Service Providers" section in our main Privacy Policy for more details.

Your California Rights
As a California resident, You have the following rights regarding Your personal information:

• Right to Know: You can request to know the categories and specific pieces of personal information We collect, use, and disclose about You.
• Right to Access: You can request a copy of the personal information We maintain about You.
• Right to Delete: You can request that We delete Your personal information, subject to certain exceptions.
• Right to Opt-Out of Sale: We do not currently sell Your personal information as defined by the CCPA. However, You have the right to request to opt-out of any future sale (as defined by the CCPA).
• Right to Portability: You can request to receive Your personal information in a portable and readily useable format.
• Right to Correct: You can request that We correct inaccurate personal information We maintain about You.
• Right to Limit Use: You can request to limit our use of Your personal information for certain purposes.
• Right to Non-Discrimination: You cannot be discriminated against for exercising Your CCPA rights.

Exercising Your Rights
To exercise Your rights under the CCPA, You can submit a request through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Shine the Light Law
California's Shine the Light Law allows California residents to request information about Our disclosure of their personal information to third parties for their direct marketing purposes. We do not currently share personal information with third parties for their own direct marketing purposes. However, You can contact Us at [email protected] if You have any questions.

This California Privacy Notice is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for EU/EEA residents

This section supplements the Koottu App Privacy Policy and applies to users residing in the European Union (EU) or European Economic Area (EEA). It explains how We collect, use, and share Your personal information, and Your rights under the General Data Protection Regulation (GDPR).

Data Privacy in the EU/EEA
We comply with the data privacy principles and regulations of the GDPR when processing Your personal information within the EU/EEA region.

Cross-Border Data Transfers
Koottu, operated by Koottu Inc., is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside the EU/EEA. In such cases, We ensure a level of data protection equivalent to GDPR standards through one of the following methods:

• European Commission Adequacy Decisions: We may transfer data to countries deemed adequate by the European Commission for data protection.
• Standard Contractual Clauses: We may use standard contractual clauses approved by the EU Commission to ensure adequate data protection by third-party service providers outside the EU/EEA.

We take all necessary steps to ensure the confidentiality and security of Your personal information during transfers.

Your Rights Under GDPR
As a data subject in the EU/EEA, You have the following rights:

• Right to Information: You have the right to be informed when Your personal data is collected and used.
• Right of Access: You can request a copy of the personal information we hold about You.
• Right to Rectification: You can request that We correct any inaccurate personal information We hold about You.
• Right to Erasure: You can request deletion of Your personal information, subject to certain exceptions.
• Right to Object: You can object to the processing of Your personal information for specific purposes.
• Right to Data Portability: You can request to receive Your personal information in a portable format for transfer to another data controller.
• Right to Restriction of Processing: You can request to restrict the processing of Your personal information in certain situations.
• Right to Automated Decision-Making: You have the right to be informed about automated decision-making processes that may affect You.

Exercising Your Rights
You can exercise Your rights under the GDPR by contacting us through the Koottu App by emailing us at [email protected]

We will verify Your request and respond within the timeframe required by law.

EU Representative
Pursuant to Article 27 of the General Data Protection Regulation (GDPR), We have appointed DataRep as its GDPR representative in the EU. If You usually reside in an EU Member State You can contact DataRep regarding matters pertaining to the GDPR: [email protected]

Privacy Notice for UK residents

This section supplements the Koottu App Privacy Policy and applies to users residing in the United Kingdom (UK). It explains how We collect, use, and share Your personal information, and Your rights under the UK General Data Protection Regulation (UK GDPR).

Data Privacy in the UK
We comply with the data privacy principles and regulations of the UK GDPR when processing Your personal information within the UK.

Cross-Border Data Transfers
Koottu, operated by Koottu Inc., is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside the UK. In such cases, We ensure a level of data protection equivalent to UK GDPR standards through one of the following methods:

• UK Adequacy Decisions: We may transfer data to countries deemed adequate for data protection by the UK Secretary of State.
• Standard Contractual Clauses: We may use standard contractual clauses approved by the UK Information Commissioner's Office (ICO) to ensure adequate data protection by third-party service providers outside the UK.

We take all necessary steps to ensure the confidentiality and security of Your personal information during transfers.

Your Rights Under UK GDPR
As a data subject in the UK, You have the following rights:

• Right of Access: You can request a copy of the personal information We hold about You through a Data Subject Access Request (DSAR).
• Right to be Informed: You have the right to be informed about how We process Your personal data.
• Right to Rectification: You can request that We correct any inaccurate personal information We hold about You.
• Right to Erasure: You can request deletion of Your personal information, subject to certain exceptions.
• Right to Object: You can object to the processing of Your personal information for specific purposes.
• Right to Data Portability: You can request to receive Your personal information in a structured format for transfer to another data controller.
• Right to Restriction of Processing: You can request to restrict the processing of Your personal information in certain situations.
• Right to Not Be Subject to Automated Decision-Making: You have the right to be informed about automated decision-making processes that may affect You.

Exercising Your Rights
You can exercise Your rights under the UK GDPR by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Dubai residents

This section supplements the Koottu App Privacy Policy and applies to users residing in the Dubai International Financial Centre (DIFC). It explains how We collect, use, and share Your personal information, and Your rights under the DIFC Data Protection Law and the Data Protection Regulations.

Data Privacy in Dubai (DIFC)
We comply with the data privacy principles and regulations of the DIFC Data Protection Law and the Data Protection Regulations when processing Your personal information within the DIFC.

Cross-Border Data Transfers
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Dubai. In such cases, We ensure an adequate level of data protection equivalent to DIFC standards through one of the following methods:

• Contractual Safeguards: We use contractual or other means to ensure that third-party service providers outside Dubai provide an adequate level of protection for Your personal information.

We take all necessary steps to ensure the confidentiality and security of Your personal information during transfers.

Your Rights as a Data Subject in Dubai (DIFC)
As a Data Subject in the DIFC, You have the following rights:

• Right to be Informed: You have the right to be informed about the use or disclosure of Your personal data.
• Right of Access: You can request access to Your personal data and receive an electronic copy upon request.
• Right to Rectification: You can request that We rectify any inaccurate personal information We hold about You, unless it is not feasible to do so on technical grounds.
• Right to Erasure: You can request the erasure of Your personal data.
• Right to Object: You can object to the processing of Your personal information for specific purposes.
• Right to Data Portability: You have the right to request to receive Your personal information in a structured format for transfer to another data controller.
• Right to Restrict Processing: You have the right to request restriction of processing of Your personal information where applicable.
• Right to Restrict Processing: You have the right to request restriction of processing of Your personal information where applicable.

Exercising Your Rights
You can exercise Your rights under the DIFC Data Protection Law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Canada residents

This section supplements the Koottu App Privacy Policy and applies to users residing in Canada. It explains how We collect, use, and share Your personal information, and Your rights under the Personal Information Protection and Electronic Documents Act (PIPEDA).

Data Privacy in Canada
We comply with the data privacy principles and regulations of PIPEDA when processing Your personal information within Canada.

Cross-Border Data Transfers
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Canada. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in Canada
As a Data Subject in Canada, You have the following rights:

• Right of Access: You can request access to the personal information We collect about You.
• Right to Know: You have the right to know the purposes for which Your personal information is collected by Us.
• Right to Withdraw Consent: You can withdraw consent to the processing of Your personal information.
• Right to Data Accuracy: You have the right to have Your personal data be accurate, complete, up-to-date, and relevant to the purpose for which it is collected.
• Right to Rectification: You can request that We rectify any inaccurate personal information We hold about You.
• Right to Erasure: You have the right to request that Your personal information that is no longer required be deleted or made anonymous.
• Right to Data Portability: You have the right to receive or send Your personal information to another organization.
• Right to Lodge a Complaint: You have the right to lodge a complaint regarding the manner in which Your personal information is being processed.

Exercising Your Rights
You can exercise Your rights under PIPEDA by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Hong Kong residents

This section supplements the Koottu App Privacy Policy and applies to users residing in Hong Kong. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws.

Data Privacy in Hong Kong
We comply with the applicable data privacy principles and regulations of when processing Your personal information within Hong Kong.

Cross-Border Data Transfers
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Hong Kong. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in Hong Kong
As a Data Subject in Hong Kong, You have the following rights:

• The right to be informed about the purpose for which Your data will be collected.
• The right to access Your personal information.
• The right to data portability of Your personal data.
• The right to object against use of Your personal data against direct marketing.
• The right to request correction of Your personal data.

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Philippines residents

This section supplements the Koottu App Privacy Policy and applies to users residing in the Philippines. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws including Data Protection Act, 2012.

Data Privacy in Philippines
We comply with the applicable data privacy principles and regulations when processing Your personal information within the Philippines.

Cross-Border Data Transfers
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside the Philippines. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in Philippines
As a Data Subject in Philippines, You have the following rights:

• The right to be informed when Your personal data is being processed.
• The right to reasonably access matters relating to the processing of Your personal data such as, among others, the identity of the Personal Information Controllers (“Data Controllers”) or Personal Information Processors (PIPs) that will be given access to Your personal data.
• The right to rectification or the right to dispute the inaccuracy or error in Your personal data and have the Data Controllers correct it within a reasonable period of time.
• The right to suspend, withdraw, or order the blocking, removal, or destruction of Your personal data from the Data Controllers filing system.
• The right to object to the processing of Your personal data, including processing for direct marketing, automated processing, or profiling.
• The right to obtain from the Data Controllers a copy of Your personal data in an electronic or structured format that is commonly used and allows for further use.
• The right not to be subject to automated decision making.
• The right to be indemnified for damages sustained due to inaccurate, incomplete, outdated, false, unlawfully obtained, or unauthorized use of personal data. In addition, You also have the right to lodge a complaint before the National Privacy Commission.

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for South Africa residents

This section supplements the Koottu App Privacy Policy and applies to users residing in South Africa. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws.

Data Privacy in South Africa
We comply with the applicable data privacy principles and regulations when processing Your personal information within South Africa.

Cross-Border Data Transfers
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Hong South Africa. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in South Africa
As a Data Subject in South Africa , You have the following rights:

• The right to be informed about the collection of Your personal information.
• The right to access Your personal information held by the responsible parties.
• The right to request for the correction of Your personal information.
• The right to request the deletion of Your personal information.
• Your right to opt-out of the direct marketing communication.
• Your right to not be a part of automated decision making.

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Singapore residents

This section supplements the Koottu App Privacy Policy and applies to users residing in Singapore. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws including Data Protection Act, 2012 (commonly known as 'PDPA’) and the Personal Data Protection Amendment Act, 2020 (‘the Amendment Act’)..

Data Privacy in Singapore
We comply with the applicable data privacy principles and regulations when processing Your personal information within Singapore.

Cross-Border Data Transfers
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Singapore. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in Singapore
As a Data Subject in Singapore , You have the following rights:

• The right to be informed about the purpose for which We intend to collect, use or disclose Your personal data.
• The right to access the personal information that we collect about You.
• The right to be notified about a data breach that is likely to cause You significant harm.
• The right to withdraw consent from the collection, use and disclosure of Your personal data.
• The right to request correction of Your inaccurate data.
• The right to have Your personal data which is no longer required being ceased from our retention.

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Mexico residents

This section supplements the Koottu App Privacy Policy and applies to users residing in Mexico. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws including the Federal Law on Protection of Personal Data Held by Private Parties (FLPPDPP).

Data Privacy in Mexico
We comply with the applicable data privacy principles and regulations when processing Your personal information within Mexico.

Cross-Border Transfer of Personal Information
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Mexico. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in Mexico
As a Data Subject in Mexico , You have the following rights:

• The right to access Your personal data that is being processed.
• The right to rectification of incomplete, inaccurate data.
• The right to cancellation of personal data, which results in a period of blocking after which the data may be deleted.
• The right to oppose the processing of Your personal data for legitimate reasons

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Malaysia residents

This section supplements the Koottu App Privacy Policy and applies to users residing in Malaysia. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws including the Personal Data Protection Act 2010 ('PDPA').

Data Privacy in Malaysia
We comply with the applicable data privacy principles and regulations when processing Your personal information within Malaysia.

Cross-Border Transfer of Personal Information
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Malaysia. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in Malaysia
As a Data Subject in Malaysia , You have the following rights:

• The right to be informed about the processing of Your personal data.
• The right to access Your personal data that is being processed.
• The right to correct the personal data, if it is inaccurate, incomplete,misleading, or outdated, subject to certain conditions.
• The right to opt-out of the processing of Your personal data.

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Brazil residents

This section supplements the Koottu App Privacy Policy and applies to users residing in Brazil. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws including the General Personal Data Protection Law ('LGPD').

Data Privacy in Brazil
We comply with the applicable data privacy principles and regulations when processing Your personal information within Brazil.

Cross-Border Transfer of Personal Information
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Brazil. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in Brazil
As a Data Subject in Brazil , You have the following rights:

• The right to be informed about the processing of Your personal data.
• The right to access Your personal data that is being processed.
• The right to have correction of Your personal data which is incomplete, inaccurate, or out-of-date data.
• The right to request erasure of Your personal data.
• The right to portability of Your personal data by expressly making a request for the same.
• The right to request the blocking of Your unnecessary or excessive data which is not processed in compliance with applicable laws.
• Your right to request for review of decisions based on automated processing..

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Japan residents

This section supplements the Koottu App Privacy Policy and applies to users residing in Brazil. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws including Act on the Protection of Personal Information(‘APPI’) and the Act on the Use of Numbers to Identify a Specific Individual in the Administrative Procedure (‘My Number Act’).

Data Privacy in Japan
We comply with the applicable data privacy principles and regulations when processing Your personal information within Japan.

Cross-Border Transfer of Personal Information
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Japan. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Your Data Subject Rights in Japan
As a Data Subject in Japan , You have the following rights:

• The right to be informed about the handling of Your personal information.
• The right to have Your personal data revised, corrected, amended, or deleted their personal data.
• The right to request deletion of Your personal data.
• The right to request the controller to cease using Your personal data if no longer needed.

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.

Privacy Notice for Australia residents

This section supplements the Koottu App Privacy Policy and applies to users residing in Australia. It explains how We collect, use, and share Your personal information, and Your rights under the applicable laws including the Data Privacy Principles and Regulations of the Privacy Act and its Australian Privacy Principles ('APPs')

Data Privacy in Australia
We comply with the applicable data privacy principles and regulations when processing Your personal information within Australia.

Cross-Border Transfer of Personal Information
Koottu, operated by Koottu Inc, is the data controller responsible for Your personal information. We may transfer Your data to third-party service providers located outside Australia. In such cases, We ensure an adequate level of data protection equivalent to applicable standards.

Direct marketing materials
We may send You direct marketing communications and information about our products and services that we consider may be of interest to You. These communications may be sent in various forms, including SMS, and email, in accordance with applicable marketing laws, such as the Spam Act 2003 (Cth). If You indicate a preference for a method of communication, we will endeavor to use that method whenever practical to do so. In addition, at any time You may opt-out of receiving marketing communications from us by contacting us or by using opt-out facilities provided in the marketing communications and we will then ensure that Your name is removed from our mailing list.

Accessing Your Personal Information
You can request access to any personal information We hold about You at any time by contacting Us through the Koottu App by emailing Us at [email protected].

If We hold information that You are entitled to access, We will try to provide You with suitable means of accessing it (for example, by mailing or emailing it to You). We may charge You a reasonable fee to cover Our administrative and other reasonable costs in providing the information to You. We will not charge You for simply making the request and will not charge for making any corrections to Your personal information.

Exceptions to Access
There may be instances where We cannot grant You access to the personal information We hold. For example, We may need to refuse access if granting access would:

• Interfere with the privacy of others.
• Result in a breach of confidentiality.

If We refuse Your request for access, We will provide You with written reasons for the refusal.

Updating Your Personal Information
If You believe that personal information We hold about You is incorrect, incomplete, or inaccurate, You can request that We amend it. We will consider if the information requires amendment. If We do not agree that there are grounds for amendment, We will add a note to the personal information stating that You disagree with it.

Your Data Subject Rights in Australia =
As a Data Subject in Australia, You have the following rights:

• The right to be informed about the collection of Your personal data.
• The right to access Your personal information held by us.
• The right to seek correction of Your personal information.
• The right to request not to receive direct marketing and to not have Your personal information disclosed or used for direct marketing is covered.
• Your right to deal anonymously with us, unless impracticable or required by law

Exercising Your Rights
You can exercise Your rights under the law by contacting Us through the Koottu App by emailing Us at [email protected]

We will verify Your request and respond within the timeframe required by law.

Please note: This section is intended to supplement Our main Privacy Policy. For more information on how We handle Your personal information, please refer to the complete Privacy Policy.