Kulfy Privacy Policy

This Privacy Policy describes the policies and procedures of Kulfy, Inc. ("we", "our" or "us") on the collection, use and disclosure of your information in connection with your use of www.kulfyapp.com (the "Site"), our mobile applications, and the services, features, or content we offer (collectively with the Site, the "Services"). We receive information about you from various sources, including: (i) if you register for an account on the Services, through your user account (your “Account”); (ii) your use of the Services generally; and (iii) from third party websites and services. When you use the Services, you are consenting to the collection, transfer, manipulation, storage, disclosure and other uses of your information as described in this Privacy Policy.

What Does This Privacy Policy Cover?

This Privacy Policy covers the treatment of personally identifiable information ("Personal Data") gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Data that our business partners share with us or that we share with our business partners.

This Privacy Policy covers the treatment of personally identifiable information ("Personal Data") gathered when you are using or accessing the Services. This Privacy Policy also covers our treatment of any Personal Data that our business partners share with us or that we share with our business partners.

This Privacy Policy does not apply to the practices of third parties that we do not own or control, including but not limited to any third party websites, services and applications (each a "Third Party Service") that you elect to access through the Service or to individuals that we do not manage or employ. While we attempt to facilitate access only to those Third Party Services that share our respect for your privacy, we cannot take responsibility for the content or privacy policies of those Third Party Services. We encourage you to carefully review the privacy policies of any Third Party Services you access.

What Information Do We Collect From You?

We collect Personal Data about you when you provide such information directly to us, when third parties such as our business partners or service providers provide us with Personal Data about you, or when Personal Data about you is automatically collected in connection with your use of our Services. The information we gather enables us to personalize, improve, understand and continue to operate the Services. In connection with certain aspects of the Services, we may request, collect and/or display some of your Personal Data. Below explains in greater detail the types of information that we collect from our users.

Information You Provide to Us

Account Information:

If you create an Account, you will provide information that could be Personal Data, such as your email address and a password. You may also choose to provide additional Personal Data, including your contact name, information about yourself, basic demographic information including age and gender identity, a description of your channel, and links to your website or social media profiles.

Additionally, if you register for or access the Services using a Third Party Service (such as your social media account login credentials), we may receive Personal Data that you have made available to share through such Third Party Service, which may include, without limitation, your user ID, email, name, and image. You acknowledge that this information may be personal to you, and by creating an Account and providing Personal Data to us, you allow others, including us, to identify you and therefore may not be anonymous. We may use your contact information to send you information about our Services.

Content:

Some features of the Services allow you to provide content to the Services, including Personal Data if you so choose. User contributions include, but are not limited to, GIFs, videos, written comments, links, and pictures. All content submitted by you to the Services may be retained by us indefinitely, even after you terminate your Account or your access to the Services is terminated. We may continue to disclose such content to third parties in a manner that does not reveal Personal Data, as described in this Privacy Policy.

Information From Others

As mentioned above, you may be able to register for or access the Services using a Third Party Service, such as your social media account (e.g. Facebook, Twitter, etc.). Occasionally, you can also use your Account on our Services to interact with your accounts on these other services. For example, you may be able to access posting and sharing tools on the Services that allow you to post information to your social networks outside of the Services (“Share”). By using these tools, you acknowledge that some information (such as your IP address) from your account on the applicable Third Party Service may be transmitted into your Account with us, in accordance with the policies and your account privacy settings selected through that Third Party Service, and that such information and content is covered by this Privacy Policy. Furthermore, if a tool, such as the Share tool, is operated by a Third Party Service, the Third Party Service that operates the tool may collect information about your browser or online activity, which would be subject to the Third Party Service’s privacy policy and your account settings selected through that Third Party Service. When you use these tools, some of your information from the Services may be shared with the Third Party Service and others. Therefore, we encourage you to read the privacy policies and other policies of any Third Party Services, including without limitation any applicable social networks, that you use in connection with the Services. Additionally, we may collect and receive your applicable Third Party Service login credentials in connection with providing you with the Services, but only if you expressly provide us with such information. We will only use such login information as set forth in this Privacy Policy or as otherwise expressly authorized by you.

Information Collected Automatically

We automatically receive and record information from your web browser or device when you interact with the Services, including your IP address, device ID and cookie information. This information is used for fighting spam/malware and also to facilitate collection of data concerning your interaction with the Services (e.g., what links you have clicked on). Your IP address may be used to send you geographically-targeted advertisements. Generally, the Services automatically collect usage information, such as the number and frequency of visitors to the Site and the Services. We may use this data in aggregate form, for example, as a statistical measure or in other anonymous forms, but not in a manner that would identify you personally. This type of aggregate data enables us and third parties authorized by us to figure out how often individuals use parts of the Services so that we can analyze and improve them.

Information Collected Using Cookies

• Cookies are pieces of text that may be provided to your computer or device through your web browser when you access a website. Your browser stores cookies in a manner associated with each website you visit. We may use cookies to enable our servers to recognize your web browser and tell us how and when you visit the Site and otherwise use the Services.
• Our cookies do not, by themselves, contain Personal Data. However, we may match cookies with your Personal Data to identify you, and we may use cookies to identify that your web browser has accessed aspects of the Services and may associate that information with your Account if you have one.
• We may allow third party web analytics service providers to use cookies or similar technologies to collect information about your use of the Services. We use Google Analytics, a service provided by Google, Inc. (“Google”) to help us understand how users use the Services and to enhance your experience when you use the Services. For more information on Google’s privacy practices, please go to https://policies.google.com/technologies/partner-sites and to opt out of data recording and analysis by Google Analytics on the Services, please visit https://tools.google.com/dlpage/gaoptout.
• Most browsers have an option for turning off the cookie feature, which will prevent your browser from accepting new cookies, as well as (depending on the sophistication of your browser software) allowing you to decide on acceptance of each new cookie in a variety of ways. We strongly recommend that you leave cookies active, because they enable you to take advantage of the most attractive features of the Services.
• This Privacy Policy covers our use of cookies only and does not cover the use of cookies by third parties. We do not control when or how third parties place cookies on your computer or device. For example, third party websites to which a link points may set cookies on your computer or device.

Information Related to Advertising and the Use of Web Beacons

To support and enhance the Services, we may serve advertisements through the Services. These advertisements are sometimes targeted and served to particular users, including using your IP address to send you geographically-targeted advertisements, and may come from third party companies called "ad networks." Ad networks include third party ad servers, ad agencies, ad technology vendors and research firms. We may also receive anonymized user data from our Agents (defined below), so we can learn and make enhancements to offer you a better experience. Some of these entities may use cookies, web beacons and other technologies to collect information about your use of the Services and other websites, including your IP address, web browser, pages viewed, time spent on pages, links clicked and conversion information. This information may be used by us and others to, among other things, tailor the Services to you (for example, by providing search results in your preferred language), analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Services and other websites and better understand your online activity. Advertisements served through the Services may be targeted to users who fit a certain general profile category and may be based on anonymized information inferred from information provided to us by a user, including Personal Data (e.g., gender or age), may be based on the Services usage patterns of particular users, or may be based on your activity on Third Party Services. We do not provide Personal Data to any ad networks for use outside of the Services. To increase the effectiveness of ad delivery, we may deliver a file (known as a "web beacon") from an ad network to you through the Services. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve targeted advertisements to you when you visit other websites. Because your web browser must request these advertisements and web beacons from the ad network's servers, these companies can view, edit or set their own cookies, just as if you had requested a web page from their site. We may also collect advertising identifiers from your mobile device. Advertising identifiers are resettable identifiers unique to your mobile device, and which are used in connection with advertising delivered to your mobile device. The IDFA (developed by Apple, Inc. for the iPhone) and Google Ad ID (developed by Google for Android) are examples of advertising identifiers.

Aggregate Information

We collect statistical information about how both unregistered and registered users, collectively, use the Services ("Aggregate Information"). Some of this information is derived from Personal Data. This statistical information is not Personal Data and cannot be tied back to you, your Account, or your web browser.

Personal Data of Children

As noted in the Terms of Service, we do not knowingly collect or solicit Personal Data from anyone under the age of 13. If you are under 13, please do not attempt to register for the Services or send any Personal Data about yourself to us. If we learn that we have collected Personal Data from a child under age 13, we will delete that information as quickly as possible. If you believe that a child under 13 may have provided us Personal Data, please contact us at namaste@kulfyapp.com.

How, and With Whom, Is My Information Shared?

The Services are designed to help you share information with others. As a result, some of the information generated through the Services is shared publicly or with Third Party Services. Below further describes the ways in which we may share your information.

Public Information About You and Your Activity on the Services

User profile and channel information that you choose to provide, including your username, contact name, GIFs you upload, information about yourself, a description of your channel, and links to your website or social media profiles, may be displayed to other users to facilitate user interaction within the Services. We will not directly reveal user email addresses to other users.

Some of your activity on and through the Services is public by default. This may include, but is not limited to, content you have posted publicly on the Site or otherwise through the Services. Registered users may have some of this information associated with their Accounts. Unregistered users will not have this association, but information concerning their use of the Services (such as what pages they have visited) may be tracked anonymously through the use of cookies and stored by us.

Please remember that if you choose to provide Personal Data using certain public features of the Services, then that information is governed by the privacy settings of those particular features and may be publicly available. Individuals reading such information may use or disclose it to other individuals or entities without our control and without your knowledge, and search engines may index that information. We therefore urge you to think carefully about including any specific information you may deem private in content that you create or information that you submit through the Services.

Information Shared Through Third Party Services

You may access other Third Party Services through the Services, for example by clicking on links to those Third Party Services from within our Services. We are not responsible for the privacy policies and/or practices of these Third Party Services, and you are responsible for reading and understanding those Third Party Services' privacy policies. This Privacy Policy only governs information collected on the Services.

Information Shared In Connection with Related Services

While we collect and store IP address and device ID information, that information is not made public. We do at times, however, share this information with our partners, service providers and other persons with whom we conduct business, and as otherwise specified in this Privacy Policy.

We also share Aggregate Information with our partners, service providers and other persons with whom we conduct business. We share this type of statistical data so that our partners can understand how and how often people use our Services and their services or websites, which facilitates improving both their services and how our Services interface with them. In addition, these third parties may share with us non-private, aggregated or otherwise non Personal Information about you that they have independently developed or acquired.

Information Shared with Our Agents

We employ and contract with people and other entities that perform certain tasks on our behalf and who are under our control (our "Agents"). We may need to share Personal Data with our Agents in order to provide products or services to you. Unless we tell you differently, our Agents do not have any right to use Personal Data or other information we share with them beyond what is necessary to assist us. You hereby consent to our sharing of Personal Data with our Agents.

Information Disclosed Pursuant to a Change in Control or Sale

In some cases, we may choose to buy or sell assets. In these types of transactions, user information is typically one of the transferred business assets. Moreover, if we, or substantially all of our assets, were acquired, or if we go out of business or enter bankruptcy, user information would be one of the assets that is transferred or acquired by a third party. You acknowledge that such transfers may occur, and that any acquirer of us or our assets may continue to use your Personal Data as set forth in this policy.

Information Disclosed for Our Protection and the Protection of Others

We also reserve the right to access, read, preserve, and disclose any information as we reasonably believe is necessary to (i) satisfy any applicable law, regulation, legal process or governmental request, (ii) enforce this Privacy Policy and our Terms of Service, including investigation of potential violations hereof, (iii) detect, prevent, or otherwise address fraud, security or technical issues, (iv) respond to user support requests, or (v) protect our rights, property or safety, our users and the public. This includes exchanging information with other companies and organizations for fraud protection and spam/malware prevention.

Information We Share With Your Consent

Except as set forth herein, you will be notified when your Personal Data may be shared with third parties, and will be able to prevent the sharing of this information.

What Choices Do I Have Regarding My Information?

Access and Control Your Personal Data

• If you are a registered user, you can access information associated with your Account by logging into the Services. Registered and unregistered users can access and delete cookies through their web browser settings.
• You can use many of the features of the Services without registering, thereby limiting the type of information that we collect.
• You can always opt not to disclose certain information to us, but please note that such information may be needed to take advantage of some of our features.
• You can opt-out of certain cookies and tracking technologies by following the steps set forth in the section titled “Information Collected Using Cookies” above.
• Your browser may offer you a “Do Not Track” or “DNT” option, which allows you to signal to operators of websites, and web applications, and services that you do not wish such operators to track certain of your online activities over time and across different websites.

California Privacy Rights: Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 416 West 13th Street, Suite 207, New York, NY 10014.

Opt-Out of Targeted Advertising

• Through the Digital Advertising Alliance (“DAA”) and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of and greater control over ads that are customized based on their online behavior across different websites. To make choices about interest-based ads from participating third parties, please visit the DAA’s or NAI’s consumer opt out pages, which are located at http://www.networkadvertising.org/choices/ or www.aboutads.info/choices.
• Reset your mobile device’s advertising identifier or set it to opt out of targeted advertising.
• iOS: You can opt-out of targeted advertising by choosing “Limit Ad Tracking” in your device’s settings menu.
• Android: You can reset your advertising ID at any time from the Ads section under Settings on your device, or you can also opt-out of targeting advertising in this same section.

We want you to know that by opting-out of targeted advertising does not mean that you will no longer receive advertising, but just that the advertising that you do receive will not be customized to you and may feel less relevant to you.

Delete Your Account

Should you ever decide to delete your Account, you may do so by emailing namaste@kulfyapp.com. Please note that we will need to verify that you have the authority to delete the Account. If you terminate your Account, any association between your Account and information we store will no longer be accessible through your Account. However, given the nature of sharing on the Services, any public activity on your Account prior to deletion will remain stored on our servers and may remain accessible to the public.

How Long Do We Retain Your Personal Data?

We retain Personal Data about you for as long as you have an open account with us or as otherwise necessary to provide you Services. In some cases we retain Personal Data for longer, if doing so is necessary to comply with our legal obligations, resolve disputes or collect fees owed, or is otherwise permitted or required by applicable law, rule or regulation. Afterwards, we retain some information in a depersonalized or aggregated form but not in a way that would identify you personally.

Is the Information About Me Secure?

Your Account information will be protected by a password for your privacy and security. You need to prevent unauthorized access to your Account and Personal Data by selecting and protecting your password appropriately and limiting access to your computer and browser by signing off after you have finished accessing your Account.

We seek to protect Account information to ensure that it is kept private; however, we cannot guarantee the security of any Account information. We store all of our information, including your IP address information, using industry-standard techniques. We do not guarantee or warrant that such techniques will prevent unauthorized access to information about you that we store, Personal Data or otherwise. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security of user information at any time.

What Happens When There Are Changes to this Privacy Policy?

We may amend this Privacy Policy from time to time. Use of information we collect now is subject to the Privacy Policy in effect at the time such information is collected. If we make changes in the way we collect or use information, we will notify you by posting an announcement on the Services or sending you an email. A user is bound by any changes to the Privacy Policy when he or she uses the Services after such changes have been first posted.

What If I Have Questions or Concerns?

If you have any questions or concerns regarding privacy using the Services, please send us a detailed message to namaste@kulfyapp.com. We will make every effort to resolve your concerns.

Effective Date: July 10, 2018