Privacy Policy

1. Introduction

This is the Privacy Policy of Kisu, (“Kisu”, “us”, “we”, or “our”) which is incorporated into and is subject to our Terms of Use. If you do not agree with the terms of this Privacy Policy, please do not use the Service.

When you visit the Site or App we may collect data from you as described below. When you register and use your account with us we will collect data from you in order to provide the Services. The types of data we collect depends on how you use our App and Services.

2. Information we collect

When you visit and use our Site or App , install the App on your device, or register for an account with Kisu, some personally identifiable information about you is collected in order for us to be able to provide you with the Services. Further details about this are set out below.

2.1. Registration

When you install the Service on your device and/or register for an account with Kisu, personally and/or non-personally identifiable information about you may be collected. There are two types of Registration and Account Data; data:-

Information you provide (mandatory) - You will be asked to provide your gender, name or an alias and date of birth together with your mobile phone or email address. This is important to help us provide you with the connection and friends features in our Service.

Information you provide (optional) - You may also choose to provide other personally identifiable information such as your photos or videos of yourself, description of yourself and information about your interests. For example you can indicate your interests in your profile page. The provision of such information is entirely optional. If you register and log in using your Facebook, Apple or Google account, we may also collect additional information that you make available to us. For example, if you register with Kisu using your Facebook account (e.g., Facebook Connect), we may collect and store your Facebook ID and corresponding token on our servers for automatic log in and profile information and, if you give us your express consent, we will have access to and may collect certain information that you make available on Facebook (for example, your first and last names, email address, profile picture, birthdays). We will store it on our servers and use it to facilitate your use of the Service – for example - we may synchronize your Kisu account between different devices which you may use to access our Service.

We also use your contact information to market to you as your country’s laws allow – for example if there are new offerings for our Services or updates regarding changes to our Services and to help others find your account if your settings permit, including through third-party services and client applications. You can use your settings for email and mobile notifications to control notifications you receive from us. You can also unsubscribe from a notification by following the instructions contained within the notification.

In addition to the video calling features you can use our personal text messaging service as part of the Services in the App. When you communicate with others by sending or receiving text messages, we will store and process your communications and information related to them. This includes scanning for malicious content, detection of abuse and prohibited images, and use of reported issues. We also use information about whom you have communicated with and when (but not the content of those communications) to better understand the use of our Services, to protect the safety and integrity of our platform.

2.2. Log Data

We receive information when you view content on or otherwise interact with our services, which we refer to as “Log Data”.

For example, when you visit our websites, sign into our services, interact with our email notifications, use your account to authenticate to a third-party service, we may receive information about you. This Log Data includes information such as your IP address, browser type, operating system, configuration information made available by the Kisu app or desktop browser, the referring web page, pages visited, location, your mobile carrier, device information (including device and application IDs), search terms (including those not submitted as queries), and cookie information. We also receive Log Data when you click on, view, or interact with links or make connections on our Services and general information about your communications on Kisu such as the user you have communicated with and the date and duration of your communications ( but not the content of such communications, unless required for safety and security reasons) including when and if you install another application through our Services. We use Log Data to operate our Services and ensure their secure, reliable, and robust performance. The purpose for using Log Data is to protect the security of accounts and to determine what is popular on our services and importantly Log Data is used to enable you to make connection with new and former connections on Kisu. We also use this data to improve our Services and to improve the effectiveness of our own marketing. We also use metadata, which means information related to items to you have made available through Kisu, such as the date or location that you made a connection via the Kisu App.

We do not keep Log Data beyond 30 days.

2.3. Age

The Service is not directed at children or persons under the age of eighteen (18) and we do not knowingly collect personally identifiable information from children or persons under the age of eighteen (18) as part of the Service. We do however collect information regarding your age to ensure underage users are not part of our platform in order to maintain the security of our Services and use third parties to help us maintain the correct age profile for our App. If we become aware that we have inadvertently received or collected personally identifiable information from a user under the age of eighteen (18) as part of the Service, we will delete such information from our records. If you are under the age of eighteen (18), please do not use the Service.

3. Your User Profile

You can access, control and modify your the information you provide for your user profile on the App (your “Profile”) at anytime. This includes your Profile and profile pictures and videos, name, interests, personal bio, languages you speak and your birthday all of which can be shared with your Kisu contacts. So please ensure you only share what you want to include in your Profile. Your Profile will be made available to other users of the App who are connected to you. In addition, your Profile is discoverable by other App users, for example, through listing of App contacts in the App that will include your proximity to other users.

You may also choose to “block” any other Kisu user in your contact list in the App which will prevent them from discovering your Profile at any time. In addition, Kisu may pre-populate your Profile with certain information such as your name and Facebook profile picture, date of birth, email, gender, Facebook ID if you have logged into your account on the App using your Facebook account. You can delete and change your Profile information in the App as indicated below in Section 13 and in our Safety Centre.

4. Purpose and use of personal information

We adopt the data minimization principle when collecting and using your data and ensure that your data will only be used in accordance with the stated purposes below. We will only process your data in connection with the Service and for other related business purposes, including:

4.1 To provide you with the Service, including:

• to connect you with other users within the App;
• to enable you to share your Profile with other users on the App;
• to provide you with video and audio call functions of the App;
• to allow you to send images and videos through the App;
• to show you the names of persons you communicate with and to show your name to persons you communicate with on the App; and
• to provide you with certain features of the App that may be offered from time to time, such as our Premium Services (please see our Terms of Use),play games and share /play music during your video calls.
• to enable you to contact us
• oconnect with third parties for payment processing
• oto run analytics to provide you with better and relevant connections, provide you with additional offers and for the purpose of providing you with updates to our Services.

4.2 To help us administer and maintain your account and User Profile on the App, including:

• ocreating and updating your account;
• and delivering to you any administrative notices, alerts and communications relevant to your use of the App.
• To facilitate networking opportunities through the Service and provide you with location or interests information relating to other users of the App.
• We use the information we have to develop, test and improve our Services, including by conducting surveys, compiling research, statistics and analytics as well as habits and behaviours of users such as transactional history, online interactions, and testing and troubleshooting new products and features.
• To handle and process any payments for transactions carried out through the Service via third party providers.
• We use the information we have to send you marketing communications and notifications (including our Membership Loyalty Programme details); and communicate with you about our Services, and let you know about our policies and terms.
• We also use your information to respond to you when you contact us.

4.3 Promote safety, integrity and security.

• For audit, compliance, controls, security and other risk management purposes we use the information we have to verify accounts and activity, combat harmful conduct, detect and prevent other bad experiences, illegal behaviour, maintain the integrity of our Services, and promote safety and security. For example, we use a combination of automated detection technology and manual review of the data we have to investigate suspicious activity or violations of our Terms of Use and policies such as this Privacy Policy and enable you to report and contact us if you have any issues to raise.

4.4 For business management purposes, including data and record management:

• To establish, exercise and/or defend our legal rights.
• To comply with our legal, regulatory and reporting requirements to regulatory bodies.
• To ensure the safety of users through content moderation.
• In connection with a corporate transaction involving Kisu, such as the purchase or sale of a business unit, an acquisition, merger, sale of assets, or another similar event.
• To enable us to provide the Services and our contractual commitments to you.

4.5 Information across Our Services:

• We connect information about you and your activities on Kisu with our other Apps and Services provided by us to provide you with a broad engagement experience and to provide a more tailored and consistent experience with your use of the Services.

5. Data Access and Removal

You can always control what information you choose to share with us on the App (except for information which we have indicated as mandatory for you to provide). To do so, you can change your settings in the App or in your mobile device. Alternatively, you can remove the App from your mobile device entirely.

You can choose to remove your data anytime you want. If you ask us to delete your account, we will use commercially reasonable efforts to remove your data from our servers, subject to any applicable legal or other requirement to maintain certain records of your personally identifiable data. Please note that the deletion of your personally identifiable data from our database may result in us not being able to provide you with the Service.

6. Sharing with Third-Party Partners “Shared Information”

We provide information and content to affiliates, vendors and service providers who support our business, such as by providing technical infrastructure services, analyzing how our Services are used, providing customer service, security services, facilitating payments, music sharing or conducting surveys. Examples of where your information may be disclosed or transferred to other users, our affiliates or Third-Party Partners for any of the purposes mentioned above in order for the Services to be provided to you are:

• Your publicly visible information and Profile, which may include your Kisu ID, name, gender, region and photos, date of birth, interests, in-App music playlist etc;
• All the information you make available to other users or information about you that is made available by other Kisu users;
• Our parent company, subsidiaries, affiliates and/or branch offices who support the App or Site Services as well as the integration of your information with our other apps who deliver and perform the Services;
• Any of our member's agents, contractors including, IT companies who support our website and other business systems, back office service providers, payment service providers, data management and analytics service providers, and data cleansing service providers and subject to your consent direct marketing companies and mailing houses who help us manage our electronic and mailed communications;
• Any relevant third parties such as telecommunications operators, third party collection agencies, credit reference agencies, security agencies (including identification verification service providers), credit providers, banks, financial institutions (including any payment processors);
• Any professional advisors (including our legal advisors and auditors);
• Any regulatory authorities, law enforcement, courts and other governmental agencies;
• And any of our actual or proposed assignees or transferees of any part of our business or operations.

7. Parties with whom you may choose to share your User Content

Any information or content that you voluntarily disclose or post on the App, such as your User Content, becomes available to the public. Once you have shared such User Content or made it public, that User Content may be viewed and re-shared by others and it may not be possible to prevent the distribution of that Content once it becomes public.
Even if you remove any User Content (e.g. screenshots, etc.) that you created or posted on the App, copies of such User Content may remain accessible in the cached and archived pages of the App, or if other users or third parties have copied or saved such information.(e.g. from using Facebook, etc.)

Any personally identifiable information that you: (i) share in text messages, photos, videos or otherwise in or through the App with other users; or (ii) submit via live messaging on the App, can be viewed and used by others. Kisu is not responsible for any use or misuse of such information that you share or submit.

8. Retention of Your Data

We will keep your personal data only for so long as is necessary to fulfil the purposes outlined in this Privacy Policy, unless the law requires us to keep it for a longer period. Once we no longer need your personal data, we will either irreversibly anonymise or securely delete it from our servers.

9. Your Data Protection Rights

Kisu would like to make sure you are fully aware of all of your data protection rights. In particular, you are entitled to the following rights:

• Right of Access:

  You shall have the right to obtain from Kisu confirmation as to whether or not your personal information is being processed, and, where that is the case, you may request for a copy of your personal information.

• Right to Withdraw Consent:

  The provision of your consent shall give Kisu a lawful basis to process your personal information. You may also revoke your consent to processing.

• Right to Rectification:

  If you entered the incorrect age or gender, we can assist you. Please submit a report to us and we will handle your request.

• Right to Erasure:

  You shall have the right to ask for your personal information to be deleted in certain circumstances;

Please note that your right to erasure may be limited if the data are necessary for compliance with a legal obligation or for the establishment, exercise or defence of legal claims.

• Right to Restriction on Processing:

  You shall have the right to object to and ask for restrictions on the processing of your personal information in certain circumstances;

• Right to Data Portability:

  You shall have the right to receive the personal information you have provided to Kisu, in a structured, commonly used and machine-readable format and have the right to transmit those personal information from Kisu to another controller without hindrance from Kisu to which the personal information have been provided, where:-
  • the processing is based on your consent; and
  • the processing is carried out by automated means;

• Right to Objection:

  You shall have the right to object, on grounds relating to your particular situation, at any time to processing of your personal information.

  Kisu shall no longer process the personal information unless Kisu demonstrates compelling legitimate grounds for the processing which override your interests, rights and freedoms or for the establishment, exercise or defence of legal claims;

• Right to Complaint –

  You shall have the right to file a complaint with our Data Protection Officer (details of which are provided below) if you think that one or more of your rights have been infringed by Kisu.