1. Introduction SUMMARY: We are committed to transparency. This document explains our practices concerning your Personal Information and applies to all kootumb users. Welcome to the kootumb website available at kootumb ( ”kootumb”, “we”, “us” and/or ”Service” ) is committed to transparency and has created this Privacy Policy (“ Policy”) to provide you with all tools necessary to understand how we collect, use and protect your Personal Information. We treat User’s privacy very seriously and make it a high priority to ensure the security and confidentiality of the personal data you provide us when you visit our Website or use our Service. We highly encourage everyone to review this Policy carefully, as it contains important information about users’ rights and obligations. Please also review ourCommunity guidelines & Terms of use, which governs your use of the Service. 2. Definitions It will be helpful for you if we explain the terms that you may encounter reading this document. A. ‘Content’ is information, materials and other content, including, but not limited to, video, sounds, text, and designs. B. ‘Visitor’ refers to any individual Internet browser that may view any portion of the Site, particularly public portions of the site that do not require registration. C. ‘User’ refers to any Visitor or registered user of kootumb, namely a person that seeks to use and engage with kootumb Content D. ‘Personal Information’ is information that can identify a natural person alone or in combination with other information, e.g. name, email address, online identifiers, etc. E. ‘Non-Personal Information’ – refers to information that is not considered ‘Personal’ under applicable law, such as anonymous session management cookies or information about your device. F. ‘Data Subject’ refers to any User whose information is being processed. ‘Processed’ means stored, used, shared, etc. G. ‘Profile’ is the section of our app where you can edit the Personal Information that is displayed publicly. 3. Information we collect SUMMARY: In order for our Service to work, we need to collect certain Information from you. This Information may include Personal Information, such as your name, but also some non-identifiable information, such as session storage properties, metadata and basic information about your device. kootumb collects or receives information from users in different ways. We ask you to provide basic Personal Information during the registration process, such as your name and email address. Your Internet browser or device on which you are using our app collects certain information as well, such as your device/browser information and IP address. Once you register, your name and additional information that you choose to include in your profile is public and is visible to all Users of the Service. This information may include: • the profile picture you upload; • your name; • location (provided optionally by Users, kootumb does not collect it automatically); • ther information that you decide to include in the “Bio” section of your Profile. 3.1. Usage Information kootumb will inevitably collect some usage information automatically when you visit and/or use the Service and store it in log files. This information refers mainly to the technical information about your use of the Service through your internet browser or mobile device and is necessary for the correct technical functioning of the Service. We use this information to administer the Service and improve the Site and our Services to our users’ needs. This information may include, but is not limited to: • Usage information – refers to the information that is uploaded to the Service and stored in log files. It relates to how you use the Service. When you use a mobile device to access our Service, we may access, collect, and/or monitor one or more “device identifiers”. These are small data files stored on or associated with your mobile device, which uniquely identify your mobile device. However, we only collect and store those identifiers for session management. After a User finishes a session, the device identifiers are deleted from our logs. • Services Metadata – Metadata is usually technical information that is associated with your use of the Service or any Content you post. For example, metadata can describe how, when and by whom a piece of user Content was posted and how that Content is formatted. kootumb processes metadata for the least amount of time possible and only enough for the application to function properly. The content you post is stripped off of metadata during the initial stage of processing. • Session management cookies – we use this mechanism to store session information for a particular user. When a User logs into the Service, his/her session ID will be stored on the server until he logs out. A session is initiated when a User logs onto the Service and is terminated when he or she logs out. The User’s Session ID is a random string of numbers and is non-identifiable on its own. The User’s Session ID is ‘assigned’ to the User and each time the User logs into the service, he/she retrieves that assigned key. 3.2. Communications Information We enable Users to communicate with each other through the commenting functionality under posts. We advise not to disclose any personal information, and especially any sensitive personal information such as health/genetic information, racial/religious/ethnic background, etc. in comments. 3.3. Information that you should not provide to us We do not require any kind of sensitive information, such as health/genetic information, racial/religious or ethnic backgrounds, etc. 4. How we collect information SUMMARY: We obtain information about you when you voluntarily give it to us. We use different methods to collect Personal Information from and about you, for example: • Direct disclosure – occurs when you register to the Service or fill in the forms in your Profile with Personal Information. It also happens when you disclose Personal Information through post/phone/email correspondence. • Automated technologies – As you interact with our Service, we may automatically collect certain technical Information about your device, information about your behaviour on the Service, etc. This is explained in more detail in part 3.1. of this Policy. 5. How we use the Personal Information collected SUMMARY: We use the information collected to ensure the proper functioning of our Service, maintain security, and/or comply with our legal obligations. kootumb will use your Personal Information only when it is allowed to by applicable law and in a manner that is consistent with this Policy. We use your Personal Information for the following purposes: 5.1. Providing and maintaining the best version of the Service Enabling the Service to function most effectively lies in our legitimate interest. kootumb uses the Personal and non-Personal Information to: • Create and update your account. • Maintain your Profile and make it visible to other users. • Enable you to contact us and for us to respond to you. • Contact you with administrative communication when it is necessary, for example when we update our policies. 5.2. Maintaining the appropriate level of safety and security kootumb is committed to keeping the Service safe and secure. We may use your non-identifiable information to: • Perform internal operations necessary to provide our services, including to troubleshoot software bugs and operational problems; • to conduct basic data analysis, testing, and research. 5.3. Communicating relevant information to you In the future, kootumb may use Personal Information it collects to inform you about services, studies, surveys and news. Users have the right to object to this type of use of your Personal Information, see section 8.1. of this Policy for more information. Before we introduce such type of processing, every User will be informed about it and will have the choice to opt-in to such processing. 5.4. Complying with our legal obligations We may process your information in a way that is necessary for compliance with a legal obligation we may encounter. Apart from the domestic/international regulations, this may include the need to comply with applicable court orders, legal requirements, legal proceedings, document requests, and industry standards and our policies. 6. How we share your information SUMMARY: Part of the Personal Information that you share with us is also shared with the community of our Users. You can decide which Personal Information will be displayed on your Profile by making changes in the ‘Edit Profile’ tab of the kootumb app. 6.1. We display information on your Profile We are a social network and due to this fact, we need to display some basic information about you publicly. You can always decide which Personal Information is being displayed by making changes in the ‘Edit Profile’ section. Data minimization is important for us and we collect and display only the bare minimum of the information necessary for the proper functioning of our Service. 6.2. We share information with kootumb’s service providers kootumb needs to provide certain information to service providers in order to ensure the proper functioning of the Service. Every time we share any Personal Information with a third party, we make sure that it’s done lawfully and in compliance with all the applicable regulations, such as the GDPR. We also make sure that the entities we share your information with adhere to the applicable law and offers appropriate safeguards to the information we disclose. kootumb shares only the information that is relevant for the purpose we are sharing it. We regulate our relationships with third parties with appropriate contracts and we take all commercially reasonable steps to ensure full information security. Currently, kootumb shares User’s Personal Information with Amazon Web Services , the service that hosts the application on the Internet .
6.3. We disclose the information if legally required to do so kootumb must share information with government agencies as required by law in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. 7. Information retention and deletion SUMMARY: We store your Personal Information for as long as you are a registered user. After deleting the account, your Personal Information is erased from our databases. kootumb must retain your Personal Information for the period when you are a registered User to ensure the proper functioning of our Service. You may request deletion of your account at any time by clicking the button at the bottom of the ‘Account Settings’ page within the kootumb app. If you delete your profile, the entire account information will be permanently deleted from our system when you confirm your wish to delete your account. 8. Users and the GDPR SUMMARY: As a User of kootumb, the GDPR grants you a number of rights concerning the use, storage and processing of your Personal Information. The General Data Protection Regulation (the ‘GDPR’) is an EU legislation that grants certain rights to Data Subjects. Those rights apply to all the Users of kootumb worldwide. 8.1. Your rights under the GDPR For as long as we are in possession of your information, you have the following rights: • Right of access – you may ask us whether we are processing your information andyou have the right to request a copy of the information we hold about you. • Right of rectification – you have the right to correct inaccurate or incomplete information about you; you also have the ability to do so yourself in the ‘Settings’ section of your Profile. • Right to be forgotten – in most circumstances, you can ask for the information that we hold about you to be erased from our system. • Right to restriction of processing – where certain conditions apply, you can ask us to ‘block’ the processing of your information. • Right to data portability – you have the right to have the data we hold about you transferred to another organisation and to receive the information in a structured, commonly used format. This functionality is under development – in themeanwhile you can contact us at kootumb.com@gmail.com to request your data. • Right to object – the GDPR gives you the right to object to certain types of processing, such as direct marketing. Currently, we are not using your Personal Information for any marketing purposes and we do not foresee such use in the future. • Right to object to automated processing (including profiling) – This right provides the data subject with the ability to object to a decision based on purely automated processing. Like with the right to object, we are not processing your Personal Data for such type of automated decision-making and we are not anticipating such use in the future. If you wish to exercise any of those rights, contact us at relevant kootumb email address or through our Slack communication channel that can be accessed through the “Useful links” tab in the Service’s menu in the lower right corner of the app. You can also contact kootumb through the “Support & Feedback” tab in the app’s menu. If you have any concerns about how kootumb processes your Personal Information, you have the right to lodge a complaint with a suitable data protection authority. Here you can find a list of data protection authorities in Europe. If you wish to learn more about the GDPR and your rights, the Information Commissioner’s Office website is a reliable source. 8.2. Grounds for processing The GDPR requires every organisation that processes information about EU users to do so on the basis of specific legal grounds. kootumb processes information on the basis of the following grounds: Legitimate interest - It is necessary to provide the Service’s features Our main ground for processing is our interest in delivering you the best Service possible. kootumb collects and uses certain information in order for the Service to fulfil its functions. Certain information about the user is necessary to create and maintain your account. Contract - processing is necessary to fulfil our contractual obligations towards you By signing up to the Service, you enter into a legally binding contract with kootumb, established in the terms of use link. Although it might sound very business-like, entering into a contract by signing up to a website is extremely common on the Internet and necessary for you to use the Service. Through creating an account and accepting the Terms of Use, you provide certain Personal Information for us to process. 9. International Data Transfers SUMMARY: kootumb is a company registered in the India but outsources its hosting services from a company that processes information in USA/ India. We use Amazon Web Services for the purposes of hosting our Service. We transfer the data to an AWS server in USA/ India. We take appropriate safeguards for international data transfers, all the data is encrypted and sent through a secure TLS connection with AWS servers. 10. Security SUMMARY: We utilize a variety of industry-standard safeguards to keep your Information safe, such as secure coding, privacy by design/default, two-step authentication, encryption, two step-authentication, TLS connections, and 3-layer access. kootumb takes information security very seriously. Sustainability, privacy and security are paramount values in our organisation. We work hard to protect the Personal Information you give us from loss, misuse, or unauthorized access. We utilize a variety of safeguards to protect the Personal Information submitted to us, both during transmission and once it is received. kootumb implements a number of safeguards to ensure that our systems are secure. kootumb performs code reviews and security and privacy testing on every new feature. kootumb utilises automated package vulnerability scanners – which scan the system for known vulnerabilities and automatically prepare and implement a patch which will fix the vulnerability. kootumb also implements security monitoring, which monitors strange activities and detects suspicious traffic. kootumb enforces a multi-layer approach to the service’s security. Accessing managerial part of the service requires a complex authentication. Every layer has access to different data and privileges. From the mid-layer downwards, there’s IP domain restriction, self-signed certificates and IP white listing/restriction. On top of the before-mentioned safeguards, kootumb also uses multi-factor authentication for development and management systems. 11. Children’s Privacy SUMMARY: We do not intentionally gather Personal Information from persons under the age of 16. If you are under the age of 12, please do not submit any Personal Information through the Service. kootumb does not collect or process Personal Information pertaining to a child, where a child under the GDPR is defined as an individual below the age of 12 years old. 12. Contact Us You can direct any questions regarding this Privacy Policy to kootumb by sending an email to kootumb.com@gmail.com, or by post to: kootumb Atish Complex, Sinhgad road Pune 11051
Please include your name and email address in email requests, and your name and postal address in mail requests.