We value your privacy. The contents hereof shall constitute Kogo Tech Labs Private Limited’s privacy policy in relation to our services on the KOGO mobile application, the website or any third party platforms through which KOGO is provided (together, "KOGO") ("Privacy Policy"). This Privacy Policy informs you of your choices and our practices regarding any Information you provide to us or that you generate in using KOGO.
The use of our services (being the KOGO mobile app, the KOGO GPS device, the website or any third party platforms through which KOGO is provided) (together, "KOGO") involve the processing of your Information. It is important for you to understand how this happens and how you may control it. Please read this Privacy Policy carefully.
By using KOGO, you agree to the processing of your Information in accordance with this Privacy Policy.
When you use certain features you will be asked to agree to the processing of your Information in certain ways.You can find information on how to control your preferences and the use of your Information via your account here. For certain Information you may withdraw your agreement to the processing of that Information in accordance with this Privacy Policy.
If you do not agree with this Privacy Policy, you must not use KOGO. You shall have the right to withdraw any or all of your consent at any point in time, post which you shall not be able to use KOGO further.
In this Privacy Policy, "we", "our" or "us" refers to: Kogo Tech labs Pvt. Ltd., An Indian company located at 840, Ground Floor, Chirag Delhi, New Delhi - 110 017, India.
Contact
If you have any questions or complaints regarding this Privacy Policy or the use of your Personal Information, please contact our Data Protection Officer Mr. Prashant Verma via email at prashant@kogo.ai or via postal mail at 840, Ground Floor, Chirag Delhi, New Delhi - 110 030, India (Attention: Data Protection Officer : Prashant Verma).
If you wish to make any complaints regarding this Privacy Policy or its implementation by us, please contact us via the above contact details. Please note that if you are a resident in the European Union you have the right to lodge a complaint with your country’s data protection authority.
SCOPE AND APPLICATION OF THIS PRIVACY POLICY
This Privacy Policy applies to KOGO, as well as any services accessible on the KOGO platform that state that this Privacy Policy applies to the use of such service (for example, users that follow or use Official Accounts, Mini Programs and KOGO Login for third-party apps). Those KOGO services may have further privacy-related terms that you must agree to if you use those services. Any capitalised terms used in this Privacy Policy have the same meaning as the equivalent defined terms in the KOGO Terms & Conditions, unless they are defined otherwise in this Privacy Policy.
Please note that this Privacy Policy does not apply to Information that you choose to disclose or submit to:
Services other than of KOGO (other products or services not being ours but supplied or operated by us or our affiliates), that do not expressly state that this Privacy Policy applies; b) any third party services (including any third party websites) that you may access through KOGO; or
Any third party services (including any third party websites) that you may access through KOGO; or
Companies or organisations that advertise products or services on KOGO.
If you are using KOGO on behalf of a company, partnership, association, government or any other organisation (your "Organisation"), you agree to notify your Organisation’s relevant individual owners, shareholders, directors, officers, managers, employees and other relevant individuals whose Personal Information we collect or you provide to us from time to time ("Connected Persons") of the collection of their Personal Information, and you agree to obtain your Connected Persons’ consent to the processing of their Personal Information in accordance with this Privacy Policy as required by applicable laws and regulations. When this Privacy Policy refers to "you" or "your" this includes you and any Connected Persons. If you or any Connected Persons would like to request your personal Information be removed from our database, please contact us at prashant@kogo.ai.
CHANGES TO THIS PRIVACY POLICY
We may from time to time revise or add specific instructions, policies and terms to this Privacy Policy. These instructions, policies and terms form part of this Privacy Policy.
Whenever we make any changes to this Privacy Policy that are important for you to know about, we will post the updated Privacy Policy at this link and notify you via KOGO or other means before the change becomes effective. Your continued use of KOGO will be taken as consent to the changes made to this Privacy Policy.
TYPES OF INFORMATION WE PROCESS
We process different categories of information and data in providing KOGO. These are set out below:
"Location Data" is information that is derived from your KOGO Device, GPS, WiFi, compass, accelerometer, IP address, or public posts that contain location information. You will disclose certain location information to us and to other KOGO users:
When you use certain location-based features and when you share your location with other KOGO users; and
When you access KOGO, as we derive location information from your IP address, device, or internet service to prevent multiple or fraudulent log-ins to your account.
"Log Data" is information that we automatically collect when you use KOGO, whether through the use of cookies, web beacons, log files or scripts including:
Technical information, such as your mobile carrier-related information, configuration information made available by your web browser or other programs you use to access KOGO, your IP address and your device’s version and IMEI number;
Information about what you have searched for and looked at while using KOGO, such as web search terms used, social media profiles visited, and details of other information and content accessed or requested by you in using KOGO;
General information about communications on the platform, such as the identity of a user that you have communicated with and the time, data and duration of your communications (but not the content of such communications, except where you are communicating with an Official Account or our support services team); and
Metadata, which means information related to items you have made available through KOGO, such as the date, time or location that a shared photograph or video was taken or posted.
"Non-Personal Information" is any information that is not reasonably practicable to directly or indirectly identify you.
"Personal Information" is any information, or combination of information, that relates to you, that can be used (directly or indirectly) to identify you. We set out examples of Personal Information (and how we collect such Personal Information) below.
"Shared Information" is information about you or relating to you that is voluntarily shared by you on KOGO. Shared Information may include postings that you make on KOGO (including your public profile, the lists you create, and photos, videos and voice recordings as accessed with your prior consent through your device’s camera and/or microphone sensor), any postings from others that you re-post and Location Data and Log Data associated with such postings. Shared Information also includes information about you (including Location Data and Log Data) that others who are using KOGO share about you.
References to "Information" in this Privacy Policy mean both Personal Information and Non- Personal Information.
PURPOSES FOR WHICH THE INFORMATION COLLECTED IS USED
We collect your Information for various purposes, including the following:
To register you as an user of KOGO, and other linked services through KOGO;
To respond to your inquiries;
To respond to problems and issues faced by you in using KOGO;
To provide Information about products and services of KOGO;
To personalise your experience of KOGO;
To process a payment, your financial Information as relevant;
To administer KOGO properly, improve services, content, products etc.;
To conduct internal reviews and data analysis, statistical studies, performance measures, research studies etc. as required for management of KOGO;
To protect the integrity of KOGO; and
To respond to judicial process and provide Information to law enforcement agencies or in connection with an investigation on matters related to public safety, as permitted by law.
Above uses may be collectively referred to as"Purpose(s)"
HOW WE PROCESS YOUR INFORMATION
The following lists what Personal Information we collect, how we use it (and the legal basis for processing that Personal Information under EU law to the extent applicable):
Registration Data and Log-in Data. Your name, user alias, mobile phone number, password, gender, and IP address:
To set up and log-in to a user account on KOGO;
To notify you about changes to KOGO;
To facilitate communication;
To provide you with user support;
To enforce our terms, conditions, and policies;
To place VoIP calls using KOGO;
To communicate with you;
To provide personalised help and instructions;
To better understand how you access and use KOGO;
To develop new and improve existing services;
To provide language and location customisation;
To protect any rights, property or safety of ours, our affiliate companies, or other users of KOGO; and
To administer KOGO and for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, account management, and survey purposes.
User Profile Search Data. Record of search inquiries:
To provide quick access to previous searches.
Shared Information - Profile Data. Any Information that you include in your publicly- visible KOGO profile, which may include your profile ID, name, and photo:
To administer the KOGO platform in accordance with your instructions and requests;
To provide personalised help and instructions;
To provide language and location customisation;
To develop new and improve existing services;
To better understand how you access and use KOGO; and
To maintain your KOGO account in accordance with your instructions and requests.
Shared Information – Profile Media. This comprises all of the Information you make available to other users via KOGO, comprising: KOGO Moments & Posts and responding to other users’ KOGO Moments & Posts; and Information made available by another user about you via their use of KOGO – for example, any Shared Information that others using KOGO make available about you via KOGO Moments and communications they make to you and others using KOGO:
Chat Data. Content of communications between you and another user or group of users. This is permanently stored on our servers and is sent to devices via subscriptions that it can be distributed to the users you have chosen to send communications to:
To facilitate delivery of communication to another user.
Contacts List. Your on-device contact list:
To connect you with other KOGO users using the "Recommended Friends" function.
Log Data:
To better understand how you access and use KOGO;
To administer KOGO; and
for internal operations, including troubleshooting, data analysis, testing, research, security, fraud-detection, and account management.
Location Information.
for security, fraud-detection and account management (such as to ensure there are not multiple log-ins or suspicious log-ins on your account);
To provide you with location-based services that you choose to use:
Share Location (when you elect to share your location within a chat with other users);
Moments/Point of Interest (geo-tagging a place in a Moments post);
Go Cards (when you elect to use this feature KOGO uses your accelerometer and gyroscope, geo-location);
Official Accounts (if you elect to disclose your location to an Official Account, that Information will be shared with the Official Account);
Mini Program (if you choose to disclose your location to a Mini Program, or choose to find Mini Programs Nearby);
People Nearby, Live Trips, GoCards (these are location-based services that you can choose to use to disclose your general location for a limited period of time (and you can choose to clear such location data at any time);
Active Recommendations (if you access this feature, we use your location to optimize locally relevant content for you); and
Search (if you perform an external search using KOGO, the service uses your location to provide you with locally relevant Information); and
To provide language and location customisation.
Credit card Information: We process this data in accordance with our obligations under applicable law.
In some regions, credit card Information is collected and the card Information verified via a third-party payment processing service for the purpose of verifying parental or guardian consent to use KOGO by an underage minor. This Information is not permanently stored to KOGO's servers and is immediately disposed after a verification request has been performed by the third-party payment processing service.
Customer Support Information. Any Information that you provide to our customer support team:
To investigate your support issue.
Device Data. Media stored on your device:
To facilitate the sharing of such media using KOGO.
Surveys. If you choose to participate in a survey, we may request certain Personal Information from you. We may use a third party service provider to conduct these surveys and this will be notified to you prior to you completing the survey:
To better understand how you access and use KOGO;
To provide personalised help and instructions;
To develop new and improve existing services; and
To improve KOGO and respond to customer requests and preferences.
Contest Information. Any Information that you provide to us in submitting an entry to a contest offered on KOGO.
To facilitate your participation in the contest; and
To award prizes, if applicable.
Pseudonymised and Aggregated Data. We pseudonymise and aggregate certain Personal Information to improve our services:
Analysis of what features or actions are taken within the app in order to improve app experience;
Fraud detection and account safety analysis;
User demographic analysis on items such as region, phone model, operating system platform, system language, and KOGO version in order to better understand how our users are using KOGO’ and
Web and account traffic statistics of what content and services are used when users access third-party services on the KOGO Open Platform as a method for informing third-party service providers basic analysis of how their service is being used by KOGO users.
Cookies. We further explain such collection in "Tracking Technologies": to facilitate log-in and account verification; and
To assess effectiveness of and improve advertising and other marketing and promotional activities.
Some features of KOGO are only available to users in certain jurisdictions. For these features we collect additional information as follows:
Additional Registration Data – Verified Account. nationality, date of birth, residential address, copy of residential address proof, copy of personal identification document (for example passport, identification card, home return permit, etc.), personal identification document number, occupation, and source of funds.
Availability: This feature is only available to users with mobile numbers issued in certain jurisdictions (such as Hong Kong)
If you choose to apply for account verification (in order to unlock additional payment and fund settlement features in KOGO), we use this information to:
To verify your identity; and
To facilitate payment and funds settlement.
Payments Information. Your credit card number, expiry, CVC and cardholder name. Please note that where a payment is processed by a third party payment service provider, we do not collect or store any Personal Information, though we may receive summary Information about transactions.
Availability: This feature is only available to users with mobile numbers issued in certain jurisdictions (such as Hong Kong)
To facilitate your purchases within KOGO; and
to validate your real name to facilitate the creation of your KOGO Pay account.
Personal Information within
If any of your Personal Information comprises your Content (as defined in the KOGO Terms of Service), we and our affiliate companies may (subject to this Privacy Policy) use such Personal Information in accordance with the "Your Content" section of the KOGO Terms of Service.
SHARING OF YOUR PERSONAL INFORMATION
We do not sell or rent your Personal Information to third parties for their marketing purposes without your explicit consent but may use it for our internal study and analysis purposes such as consumer behavior, your preferences, popularity of the service(s), product, etc. We may also make anonymous or aggregate personal information and disclose such data only in a non- personally identifiable manner. Such Information shall not identify you individually. We understand clearly that you and your Information is one of our most important assets. We store and process your Information on computers that are protected by physical as well as technological security devices. Of course, data transmission over the internet is inherently insecure, and we do not warrant / guaranty the security of data sent over the internet.
We will not transfer your Personal Information to any other third parties except as specified below, or in circumstances where you consent to such transfer.
We share your Information with selected recipients who have a legal basis and valid jurisdiction to request such data. These categories of recipients include:
Government, public, regulatory, judicial and law enforcement bodies or authorities: where we are required to comply with applicable laws or regulation, a court order, subpoena or other legal process, or otherwise have a legal basis to respond to a request for data from such bodies, and the requesting entity has valid jurisdiction to obtain your personal Information;
Related group companies: we may share your Personal Information within our group of companies, for the purpose of:
Providing KOGO to you, assisting us in carrying out the purposes set out under the "How We Collect and Process Your Information" section above, and carrying out our obligations and enforcing our rights under the KOGO Terms of Service or this Privacy Policy;
In the event of an internal restructuring of our or our affiliates businesses, or the sale of KOGO or any of its assets to a third party, the entity that consequently operates KOGO may be a different entity to us and we will transfer your Information accordingly so that your service can continue; and
Third party service providers: service providers supplying services to support, improve, or advertise through our services. These include communication service providers who send SMSs on our behalf, VoIP providers for connection to traditional telephony services card processing and verification, and payment services. We also use service providers to help speed up content delivery to you in your region using acceleration points and content delivery networks; Any third party (selected by us) with whom we share user data will provide the same or equal protection of user data as stated in the this Privacy Policy. KOGO Official Accounts and Mini Program operators, other services via which you choose to use KOGO Login for third-party apps, if you elect to follow or use the relevant Official Account / Mini Program/ KOGO Login for third-parties.
KOGO Official Accounts and Mini Program operators, other services via which you choose to use KOGO Login for third-party apps, if you elect to follow or use the relevant Official Account / Mini Program/ KOGO Login for third-parties.
EXTENT AND STATUS OF SHARED INFORMATION
KOGO enables certain Information to be shared publicly with your KOGO contacts and other users of KOGO("Shared Information"). At any time you can hide your profile from public view and search by unchecking "allow find by phone number, KOGO ID" in your account settings. This means that other users of KOGO will not be able to find you. We refer to this type of Information above as Shared Information. Shared Information will remain publicly- available for so long as you or a user that has shared such information retains it. Even after you delete Shared Information, it may still be separately cached, copied, or stored by, or remain public through, other users or third parties who are not affiliated with and not controlled by us.
Where you have requested that we erase your Personal Information that we have made public and there are grounds for erasure, we will use reasonable steps try to tell others that are displaying the Personal Information or providing links to the Personal Information to erase it too.
Please consider carefully what you post and communicate through KOGO. In some instances, you may control what access the wider public has to your Shared Information via the privacy settings in KOGO.
COMMUNICATIONS FROM US
We may from time to time send you service-related announcements when we consider it necessary to do so (such as when we temporarily suspend KOGO for maintenance, or security, privacy, or administrative-related communications). We send these to your email address or via SMS. You may not opt-out of these service-related announcements, which are not promotional in nature and used solely to protect your account and keep you informed of important changes to KOGO.
SENSITIVE PERSONAL INFORMATION
In some jurisdictions, certain types of Personal Information, such as information about your race or ethnic origin, religious or philosophical views or personal health, is characterised as "sensitive" and is subject to stricter regulation than other types of Personal Information. Please note that content and information that you input to KOGO, such as photographs or information about your school, relationship status or social activities, may reveal your sensitive Personal Information to others.
Before communicating any Personal Information of a sensitive nature within KOGO, please consider whether it is appropriate to do so.
By posting any Personal Information of a sensitive nature within KOGO, you are consenting to such Information being available within the controls you have selected (for example, available to the audience of users you select as being capable of viewing your post or profile Information).
SOCIAL MEDIA SHARING
Sharing Your KOGO Data outside of KOGO
We provide other KOGO-related features that allow you to disclose Shared Information to audiences outside of your KOGO network – for example, publicly accessible blogs and forums, or certain social media features within KOGO (such as "plug-ins" (which create a direct link between two websites) and "widgets" (which are interactive Mini Programs that provide third party services within KOGO)) allow you to re-post and disclosure Shared Information. Any Information you distribute using such features may be read, collected, and used by third parties that are not controlled by KOGO.
Accessing and Importing Information using KOGO
KOGO allows you to link your KOGO services with select third party social media services, and import certain content and information from such third party services. For example:
You may share content on, or login to, KOGO using services provided by third parties. These third party services will authenticate your identity and provide you with the option of sharing certain Personal Information with us. They may also give you the option to post information from your third party service account to KOGO as Shared Information.
You may login to KOGO using other sign-in services such as a Social Media login. These sign- in services will authenticate your identity and provide you the option to share certain Personal Information with us for account registration and login purposes, such as your name and email address; and
˝ KOGO may (whether in advertisements or otherwise within KOGO) provide you with links or features that allow you to access third party services or websites (or access within KOGO content that is hosted on those third party services or websites). For example, you may be able to access videos hosted by a third party without leaving the KOGO application.
Third party social media platforms are hosted by the relevant third party. KOGO services are hosted by us. Third parties that provide third party services may collect your Information (including your Personal Information and Log Data), and set cookies on your computer, or device to enable such features to function properly.
Your use of any third party services (whether social media services or otherwise), including any Personal Information you provide to such third parties and their collection and use of your Personal Information, are subject to the relevant third party’s own terms of services and privacy policies and not the KOGO Terms of Service or this Privacy Policy, so please review those third party terms and conditions; and privacy policies carefully.
This Privacy Policy only applies to any Information collected by us, and does not apply to any services offered by or information practices of any third parties. If you choose to use third party services or features that are made available within KOGO (for example, you choose to follow an Official Account or use a Mini Program), then we will share certain information with that third party to allow you to use that third party service. The Information we share with such a third party is described to you at the time you first use that service or feature, and that third party will provide the same or equal protection of user data as stated in the this Privacy Policy. You can control which third parties have access to this Information in your account. You can withdraw your agreement to the sharing of that Information at any time by following the instructions set out in the Kogo help centre or by sending an email to the Data Protection Officer at prashant@kogo.ai. Please note however that if you ask us not to share that Information with the third party, you may no longer be able to use that service or feature. We are not responsible for any third party use of any Information provided by you to them.
AGE RESTRICTIONS
KOGO is not intended for Children. Children under the age of 18 years must not use KOGO for any purpose without first obtaining parental/ guardian's consent to this Privacy Policy (both for themselves and on your behalf). We do not knowingly collect Personal Information from any children under the age of 18 years without such consent. Please contact our Data Protection Officer if you believe we have any Personal Information from any children under the age of 18 years without such parental/guardian consent – we will promptly investigate (and remove) such Personal Information.
LOCATION OF YOUR PERSONAL INFORMATION
The Personal Information that we collect from you will be transferred to, stored at, or processed in:
NOIDA, Uttar Pradesh, India (which was found to have an adequate level of protection for Personal Information ); and Singapore
Our engineering, technical support, and other teams that support the supply of KOGO to you are based in our offices around the world (including India & Singapore) and may have incidental access to certain of your data in order to provide the service (for example, in order to fix technical issues that you report). We rely on the European Commission’s model contracts for the transfer of personal data to such third countries (i.e., the standard contractual clauses), pursuant to Decision 2001/497/EC (in the case of transfers to a controller) and Decision 2004/915/EC (in the case of transfers to a processor).
SECURITY OF YOUR PERSONAL INFORMATION
We use a variety of security technologies and procedures for the purpose of preventing loss, misuse, unauthorised access, or disclosure of Information – for example, we use encryption technology to protect certain sensitive Information (such as Location Data) provided by you to us.
Please be aware that despite our efforts, no data security measures can guarantee 100% security at all times. We do not warrant or guarantee the security of KOGO or any information you provide to us through KOGO.
If you use KOGO, you are responsible for maintaining the confidentiality of your account and for restricting access to your phone, laptop etc. and you agree to accept responsibility for all activities that occur under your account. You agree to take due care in protecting your username and phone, laptop etc. against misuse by others and promptly notify us about any misuse. If we have any reason to believe that there is likely to be a breach of security or misuse of KOGO, we may require you to create a new account and/or suspend your existing account without any liability to KOGO.
PERIOD OF USE OF YOUR PERSONAL INFORMATION
We will retain your Personal Information as set out below, except where we are otherwise required to retain such data in accordance with law. Should you or we terminate your account for any reason, we will take steps to ensure that your Personal Information is no longer available through KOGO, or otherwise used by us, within a reasonable period of time (subject to technical limitations) after such account termination.
Registration data: Your name, user alias, password, gender, IP address
Until such time as you instruct KOGO to delete your account or you have not logged in for 180 days. Your account will be permanently deleted within 60 days of both verification of account ownership and the account deletion request.
Registration data: Facebook account used to register account
Until such time as you instruct KOGO to delete your account or you have not logged in for 180 days. Your account will be permanently deleted within 60 days of both verification of account ownership and the account deletion request. Subsequent to account deletion, aggregated registration data is retained for spam prevention and systems security purposes.
Login data
Information is retained for a period of 6 months from the date of such log in.
User profile search data
Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier.
Profile data (viewable by friends)
Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).
Profile data - profile photo (viewable by all users)
Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services for a period up to 60 days).
Profile data - profile name (viewable by all users)
Information is retained for a period of up to 60 days after requesting removal, amending your information, or when your account is deleted, whichever is earlier.
Additional account security
Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).
Chat – non-persistent and semi-persistent communication between users
Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).
Media such as images, video, audio, and files
Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).
Contacts list
Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier.
Location-based services and Location-based media
Data is retained for a period of 24 hours from the time of the relevant interaction and then cached.
Moments and Favorites -- data and media
Until you request removal or amendment of the Personal Information or your account is deleted, whichever is earlier (however, the data may be available if cached on third party services).
Provision of third party products and services (i.e. if you are a provider of an Official Account or Mini Program)
Until such time as you instruct KOGO to delete your account. Your account will be permanently deleted within 60 days of both verification of account ownership and the account deletion request. Please note that the information disclosed to the third party is controlled by them. We will use reasonable efforts to seek that they delete such information when we do.
Information provided to an Official Account / Mini Program
Until such time as you instruct KOGO to delete your account or you withdraw your permission / unfollow such third party. Please note that the information disclosed to the third party is controlled by them. We will use reasonable efforts to seek that they delete such information when we do.
Information provided to customer service
Until such time as you instruct KOGO to delete your account or you withdraw your permission / unfollow such third party. Please note that the information disclosed to the third party is controlled by them. We will use reasonable efforts to seek that they delete such information when we do.
Metadata / Log Data
Data is retained for 3 months from the date of log in and then permanently deleted.
Device Data
Until such time as you instruct KOGO to delete your account. Your account will be permanently deleted within 60 days of the account deletion request.
Social Connect Information
Until such time as you instruct KOGO to delete your account or unbind your social account from your KOGO account. Your account will be permanently deleted within 60 days of the account deletion request.
Cookies
Data is retained for 6 months from the date of log in and then permanently deleted.