Last Modified: 2 December 2022
- WHY WE COLLECT YOUR DATA
- HOW IS INFORMATION COLLECTED BY US
- HOW WE USE AND SHARE INFORMATION
- MANAGING PREFERENCES OR WITHDRAWING CONSENT
- DATA RETENTION
- DATA SECURITY
- THIRD PARTY SITES
- INTERNATIONAL TRANSFERS
- CHANGES TO THIS POLICY
- CONTACT US
WHY WE COLLECT YOUR DATA
- We collect data, as mentioned in this policy, to ensure only eligible members join the Platform and to provide you with our services and optional features to help you have a better experience for ensuring only safe content is made available to you.
HOW IS INFORMATION COLLECTED BY USThere are three ways and means by which your data reaches us:
- INFORMATION YOU PROVIDE
The following is the information we collect from you when you specifically share it with us. By agreeing to these terms, you hereby give us express consent to collect this information from you, store and share it in terms of this policy. You can withdraw or modify your consent at any time as per the terms of Clause 4 of this policy, though note that you might not be able to some features that requires collection or use of that personal information.
- Personal Identifiable Information (PII)
When you create an account, you need to set up a username and password and share with us your email ID and phone number. If you do not provide this data you may not be able to create your account and/ or use various services of the coto Platform. We will be storing these details on our servers.
- Facial Biometric Data
Since our platform is exclusively for women, you shall be required to do a facial scan subject to your prior consent. This is a mandatory feature of the Platform to ensure that only women or trans gender are allowed on the platform. In the event, your facial scan fails, we will provide you the option of joining the platform through verification of your government issued identity proof (like Aadhar card for Indian users). We will be storing your facial biometrics to revalidate your gender. Before performing a facial scan, you shall be required to expressly consent to giving access to your phone camera. By performing a facial scan you hereby expressly consent to collection of your facial scan analysis by us for verification and storage of such data in our servers for revalidation purposes. This consent can be withdrawn at any time by simply deleting your account. In the event your facial scan as well as ID verification fails, you can write to us at email@example.com to help you create your account with the Platform.
- Data provided for optional features
We shall seek your express consent for optional features on the platform like access to your camera, photo gallery, microphone, contacts to enable usage of optional features present today and other features that may eventually be added.
Contact list - We shall be storing and updating your contacts list on our servers for the purpose of enabling you to find your friends who already have their accounts created on the Platform and to build community with them, communicate with them using Direct Message services, etc. Learn more about how we use your contacts here.
TrueDepth APIs [for iOS users only] - We use TrueDepth API technologies (ARKit, with automatic estimation of the real-world directional lighting environment) to create AR effects within the App. The only use of this information is to provide valuable user features. None of the information collected by the TrueDepth API ever leaves the user's device. We do not share information with third parties, do not store or process in any other way the data which we accessed and used via TrueDepth API. For more information about TrueDepth API technologies you may visit https://support.apple.com/en-us/HT208108
Personal Identifiable Information, Facial Biometric Data and data collected through use of optional features are collectively referred to as Personal Data.
- Your Content
As we are a women’s community platform, you shall be engaging in community conversations in both private and public communities, creating, posting, and sharing content through user account including photos, videos, voice comments, blogs, files etc. (including drafts) in your account or with the communities you are a part of, send or receive messages directly to other users of the platform as a part of using the platform’s services (“Your content”). You may also describe about yourself in your user profile and describe about your community if you are the creator of any community. Additionally, you may give us access to your phone contacts and email address book for syncing with your profile on the coto Platform. We may have an access to users added as connections in your profile, communities you are a part of, moderation actions taken by you in each community basis the consent given by you for the same. You will always have an option to change the privacy settings on your profile and content on the Platform.
- Promotions and Events
You may have the opportunity to participate in promotional events or engagements, and as part of such events may be asked to provide your name, email address, mobile phone number, and other relevant contact information. We will use this information to assess the progress of the promotion, improve on the promotion and to plan future promotions and engagements. We will use your mailing address or other contact information provided for the promotion to deliver your prize, if applicable, and, if you opt-in, for our own marketing purposes, unless you opt-out. We may also share anonymised and aggregated data provided to us to other users to assist them with understanding the nature of their fans, communities, and users engaged with promotions.
- Customer support, complaint to moderation panel or grievance officer, feedback or other communications
When you contact us for customer support, or to report a post/ user/ community creator/ moderator or otherwise communicate with us, you may provide us with information related to your use of our Services, including copies of your messages, content under dispute, any other information you deem helpful, and how to contact you (e.g., an email address).
- Personal Identifiable Information (PII)
- INFORMATION WE COLLECT AUTOMATICALLY
The following is the kind of information we collect automatically once you create your account on the coto Platform and start using its services:
- Device and connection information
We collect information about the device you are using to access the services. This includes information like your device identifiers, IP address, operating system information, browser information, information about your device settings, such as your microphone and/or camera, advertising identifiers, network provider/ Wi-fi or other Internet Service Provider, signal strength, location, language and time zone, battery level and usage, memory etc.
- Usage information
We collect log and event information related to how and when you use our coto Platform, such as the pages, user profiles, and communities you visit and interact with, time, frequency, and duration of your activities and interactions, log files, and diagnostic, crash, website, and performance logs and reports.
- Cookie and Tracking Technologies
We may collect certain information using cookies and other technologies such as web beacons, device IDs, advertising IDs, geolocation, HTML5 local storage, Flash cookies, and IP addresses. We use these technologies to provide you with an improved user experience on our coto Platform, including to save your preferences for future visits to our coto Platform. We specifically use browser cookies for different purposes, including cookies that are strictly necessary for functionality and cookies that are used for personalization, performance/analytics, and advertising.If you disable cookies, adjust privacy settings on your device, restrict local storage, or otherwise limit these technologies, you may not be able to use some of our Site features.
- Device and connection information
- INFORMATION WE COLLECT FROM THIRD PARTIES
We may engage third parties to collect information from you relating to your engagement with our coto Platform, products and services, including your IP address, country from where you access our Services, cookie information, hardware and software information and other analytics and technical information. These parties include data analytics vendors and related companies. We may use this information to analyze the effectiveness of our products and services and to understand your preferences and interactions with our coto Platform, products and services. We may also combine this information with other data that we already have about you to build a better experience for you.
- INFORMATION YOU PROVIDE
HOW WE USE AND SHARE INFORMATIONWe use your information for various purposes, including:
- BENEFIT OF USERS
- We use your anonymised aggregated data to provide you with the our services. We also collect and store the posts, comments and messages you send and display them as you direct to moderate harmful content. We also use the information you provide to us to create and manage your account and recommend communities of your interest to you.
- We collect and store your facial biometric data to ensure the platform is accessible only by women and for revalidation so that no person other than you gains access to your account without your consent.
- We use your data to monitor for content moderation and take action against users and content that violate our Terms of Service, Community Guidelines, and other policies. This includes responding to user reports, detecting fraud and malware, and proactively scanning attachments and other content for illegal or harmful content.
- We also use certain data, which may include content reported to us and public posts, to develop and improve systems and models that can be automated to more swiftly detect, categorize, and take action against prohibited content or conduct.
- We use your information to provide, personalize and improve our services.
- We use your information to contact you in connection with your account, such as to verify or secure it. We may also use your information to contact you about important product or policy changes, or just to let you know about new products or features of the Platform we think you’ll like. You may opt-out of receiving our platform’s marketing communications. Where local law requires, we will obtain your consent before sending such communications.
- We use your anonymised aggregated data to investigate bugs or other issues.
- BUSINESS USE
- We use your anonymised aggregated data to track the fundamental metrics of our business, to perform financial reporting, to respond to regulatory obligations, and to debug issues.
- We use your anonymised aggregated data to help us understand how users interact with our services, what features or products users may want, or to otherwise understand and improve our services. This includes information about how you use our services and how communities and their channels are structured.
- We use certain anonymised aggregated data to assist in the delivery of our advertising, to measure the effectiveness of advertisements for our own products, and to improve such advertisements in the future. We share information with third party advertising networks and other advertising companies, to help us serve advertisements;
- We sometimes use third party ad networks and other advertising companies to serve advertisements on our coto Platform.
- LEGAL COMPLIANCES
- We retain and use your information in connection with potential legal claims when necessary and for compliance, regulatory, and auditing purposes. We specifically retain information where we are required by law or if we are compelled to do so by a court order or regulatory body.
- To effectuate a sale of assets, merger, acquisition, reorganisation, bankruptcy, or other transaction. In the event of such transaction, you grant us the right to assign the anonymised aggregated data.
- BENEFIT OF USERS
MANAGING PREFERENCES OR WITHDRAWING CONSENT
- You may at any time withdraw your consent with future effect and wYou may at any time withdraw your consent with future effect of sharing and storing of your Personal Data.
- If you do not want to provide Personal Data to us that we request from you, you can choose not to provide it. Depending on what the Personal Data is that you choose not to provide, we may not be able to provide certain services or products.
- We may send you our promotional communications if you opt-in to receive such communications. If you do not want to receive promotional communications, you can click on the “unsubscribe” link, or other mechanism to unsubscribe that is provided in all our promotional communications. Note that you may still receive transactional messages about your account or services or products that you have requested, even if you opt-out of promotional communications.
- We will retain your Facial Biometric Data for as long as you maintain an account with us. Upon deletion of your account, your Facial Biometric Data shall be deleted from our servers.
- For Indian users, post deletion of your account we shall retain your Personal Identifiable Information on our servers for a period of 180 days post deletion, excluding your facial biometrics, to comply with our legal obligations. For users outside India, on account deletion, all your Personal Identifiable Information shall be immediately deleted from our servers subject to applicable laws in your jurisdiction.
- Where permissible by law, we will also delete your Personal Identifiable Information upon your request. If you want to make a deletion request, or correct any Personal Data that you have provided to us, or have questions about our data retention practices, please email us at firstname.lastname@example.org.
- We implement appropriate technical and organizational safeguards to protect against unauthorized or unlawful processing of Personal Data and against accidental or unlawful destruction, loss, alteration, unauthorized disclosure of, or access to Personal Data. Please be advised, however, that we cannot fully eliminate security risks associated with the storage and transmission of Personal Data. By using the coto Platform or otherwise providing Personal Data to us, you agree that we can communicate with you electronically regarding security, privacy and administrative issues relating to your use of the Site. We may post a notice via the Site if a security breach occurs. We may also send an email to you at the email address you have provided to us in these circumstances. Depending on where you live, you may have a legal right to receive notice of a security breach in writing.
THIRD PARTY SITES
- Our Site may provide a link or otherwise provide access to third party sites, including social media sites and other third party services. We provide these links merely for your convenience. We have no control over, do not review, and are not responsible for third party sites, their content, or any goods or services available through the third party sites.
CONTACT USIf you have any questions, comments, concerns or complaints about how we handle your Personal Data and anonymised aggregated data, please contact us at email@example.com