Bombinate Technologies Pvt. Ltd.

(Company, we, our, us) takes your privacy very

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

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

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

Scope

● This Privacy Policy applies to the Services, Application, or any online

application or service that refers to or links to this Privacy Policy. This
Privacy Policy applies regardless of whether you have downloaded or
accessed or used the Application from your mobile telephone or
handheld device or any other computer resource to access our
Services.

2. Koo is a public, microblogging platform. The users acknowledge and

understand that any content (including their user handle, profile picture and

published posts/ Koos) created by the users, is publicly available and

searchable by anyone around the world. It is advised that Users do not post

any personal (or sensitive) information on the Application. You should be

careful of what you are posting on the Application, as the updates will

reflect in your feed and will be visible to other Users of the Application, or

anyone else who accesses our Services, depending upon the privacy

setting specifically chosen by you for your account.

3. You acknowledge and agree that by providing public Content on Koo,

you are authorizing and advising us to disclose that information on the

Application and allow for wide circulation. When you are using hashtags,

our APIs, and that of other third-party service providers will also have

access to such information. We do not govern the operations of these

entities, and you may be required to adhere to their policies, hence, we

urge you to refer to their policies and familiarize yourself with the same,

prior to engaging with such third-party platforms.

2. Information We Collect

● At the time of registration: When you choose to register on the

Application, we will seek certain identifiers which qualify as personal
data (as defined at law), and some of these identifiers will have to be
mandatorily collected, and some will have to be collected only upon
your discretion, and consent.
● The information which you provide to us, mandatorily are:
 ● Mobile number and/or E-mail address: For creation of a
unique profile, identification, authentication via OTP and any
communications from us or on our behalf or by any third
parties engaged by us to provide the Service.
● Username or e-mail address or profile photo: If you sign
up/sign in to your Koo account using a One-Tap/Single Sign
On (SSO) from any supported third party service which
allows authentication of your identity and allows you to share
personal information with us (such as your name or email or
profile photo) to pre-populate signup/sign into the Koo
platform.
● The information which you may choose to additionally provide, are:
● Name: for purposes of displaying on your profile;
● User handle preference: for the purposes of identification on
the Application;
● Date of Birth: for the purposes of identification and/or
displaying on your profile;
● Gender: for the purposes of displaying on your profile;
● Profile Picture: for the purposes of displaying on your profile;
● Location: for the purposes of customising your experience
on the Application;
● The language that you wish to communicate in: for the
purposes of posting content on Koo;
● Language preference: for the purposes of customisation of
the Content, and other services offered to you;
● Professional details: for the purposes of displaying on your
profile and for customisation of the Content, and oth8er
services offered to you;
● Description of Self: for the purposes of displaying on your
profile;
● Relationship Status: for the purposes of displaying on your
profile;
● Access to information on your device to optimize your use
and access of the Services. You can restrict the access
granted to the Application, from the device settings. No
device permission will be taken from you without your explicit
consent.’
 ● Banking information: for the purposes of redeeming any
rewards or conducting any transactions on the Koo platform,
as may be allowed under relevant laws.
● At the time of profile verification – In order to verify your profile, we
may collect the following information from you:
● Mobile number;
● Email ID;
● Government-issued identification document(s). We will ask
you for this information only when you seek to become an
authenticated profile on the Application, while using our
Services, and such information is not disclosed to the public.
● In you log into to your Koo account using a One-Tap/Single
Sign On (SSO) from any supported third party service which
allows authentication of your identity and allows you to share
personal information, then we collect your name or email or
profile photo as approved by you to pre-populate signup/sign
into the Koo platform.

Information to Third Party Service – In addition, if you authorise us to do so,

we may grant/link third party services with Koo (eg. Facebook, Twitter,

Instagram, UPI, Google, Gpay etc) etc.). On your authorization, we may

grant such third parties access to some or all (depending on the permission

you give) of your information through our own API for use in connection

with their services. You have the ability to control what information you

share with these third parties through our API, but please note that any

information you share with third parties will be governed by their privacy

policies and we do not assume any responsibility for such third party’s use

of\ your information.

Information from your use of our Services – When you use our Services,

we may collect the following information automatically:

● Content of the Koos (text, images, graphics, audio, visuals,

etc.);
● Users you follow on the Application;
● Users who follow you on Application;
● People who have visited your profile and vice versa;
● Information on your browser’s user agent string and server
logs, including your IP address, information in the cookies
and activity on the Application ;
● URL information, time stamp, visit information, your browsing
history on the Application;
● Device information, such as make, model and operating
system of the device used for browsing the Application;
● Date of download and/or reinstall of the App;
● Events related to your actions (follows, reactions to Koos,
time spent, how often and when you visit the Application,
etc);
● Users who send you chat requests and have chatted with
you;
● The Unique Device Identifier on the Application; and
● Language.
● Locational information as permitted by you in your mobile
device settings.We do not collect any further information
which is not specifically communicated to you as per this
Privacy Policy.

You have the ability and choice of restricting certain kinds of information

from being collected by adjusting your phone and device settings. Please

refer to your phone and device user manuals for more information.
Surveys – We may collect additional information at other times, including

but not limited to, when you provide feedback(s), modify your content or

email preferences, respond to surveys, provide comments, or communicate

with us. This information may include your name, e-mail id, mobile number,

location, etc. and only such information that you may choose to specifically

provide to us.

Cookies – We use cookies and similar technologies which are necessary to

its functioning. Some of these cookies are essential for us to provide you

with the Services on the App. We, or our third-party service providers, may

use cookies, mobile app analytics and similar technologies to track visitor

activity and collect data on the App. We may combine this data with other

personal data we have collected from users.

3. Why We Collect This Information

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

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

4. When We Share Your Information

● We may share any information with our trusted partners or third

parties who provide us with infrastructure support services, for
meeting the obligations agreed to between you and us. We may also
share aggregated, non-personally identifiable information publicly
and with our partners, like publishers, advertisers or connected sites
to show trends about the general use of our Services. We will seek
your consent prior to using or sharing your personal information for
any other purpose, if so, identified at a later stage.
● We may also use your information to perform analytics and conduct
customer research, to determine your interest, for identifying content
that generates sales and to analyse traffic patterns.
● We also use your information to market to you as per the laws of your
country, and to the extent permissible.
● You have the ability to allow us to share your information to third
parties so that you can avail their services. You may disable or limit
such sharing at any time.

5. Disclosure Of Information

● We may also disclose your Personal Information only:

 ● As required by law, such as to comply with a judicial order,
executive orders, requirement by a law enforcement
authority, or by other legal processes.
● When your desired products and services can only be
provided if your personal information is disclosed.
● When we believe, in good faith, that disclosure is necessary
to protect our rights, protect your safety or the safety of
others, or, investigate fraud or crime;
● If we (or our affiliates) are involved in a merger, acquisition,
or sale of all or substantially all of its assets or equity. Such
information shall be disaggregated to the extent possible and
shall be subject to execution of appropriate non disclosure
agreements and binding privacy undertakings.
● We will never rent or sell your personally identifiable information to
others.

6. User Rights On Koo

● We want to ensure that you are fully empowered on the Koo platform
and are completely aware of the rights that you are entitled to in the
course of using our platform. You have a number of rights in relation
to the information we hold about you.
● Access – The right to access the information we hold about
you, and to obtain details of the processing. You also have
the right to access a list of all the third parties that have your
Personal Information through us.
● Rectification – The right to seek, correct, update and modify
the information available with us, to ensure accuracy.
● Cancellation – The right to seek to cancel or erase, free of
charge, your personal data when it is inadequate, excessive,
or unnecessary. This shall be subject to lawful processing
measures and any legal prescriptions.
● Objection – The right to withdraw your consent to our
continued processing of the information, at any point of time,
subject only to any legitimate reason for continued
processing in certain circumstances.
 ● Portability – The right to seek from us your personal data to
be provided to another service provider, in a
machine-readable format that we use at the time the request
was made.
You may exercise any of these rights by filling out the
request form at our Reporting and Redressal page.This shall
be subject to the legal requirements, and our internal
procedure.

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

● In relation to other Personal Information, we store them for certain

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

8. Opting Out

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

9. The Security Of Your Information

● Your personal data is maintained by us in electronic form. We shall

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

10. GDPR Compliance

● The Application may be accessed and used by residents of the

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

11. Overseas Transfer

● Your information may be transferred to and stored in locations

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

12. Children

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

14. Personal Data Of Others

● We make periodical changes to the Privacy Policy. Any significant

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

15. Grievance Redressal Mechanism

● Any discrepancies or grievances with regard to content and or

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

For any concerns or requests about your personal data, you may
also write to us at data.protection@kooapp.com or fill this form.

16. Our Contact Details

● Bombinate Technologies Private Limited,

849, 11th Main, 2nd Cross, HAL 2nd Stage, Indiranagar, Bangalore,
Karnataka – 560008