Last Updated 01.12.2023
Kurero (Plus App Holdings Limited) takes your privacy, security & data protection very seriously.
If there is anything in this document you don’t understand, or if you want to ask any questions, please feel free to contact us.
When you use any Kurero Services, the data you provide to Kurero, is processed in order for us to provide you with useful, quality, reliable & safe services.
Plus App Holdings Limited, trading as Kurero is registered at: 39 Alma Road, St Albans, Hertfordshire, United Kingdom, AL13AT
Company Registration number: 13851886
In this document, Plus App Holdings Limited may be referred to as “we”, “us”, “our”, and “Kurero”.
Kurero collects personal data for various purposes (detailed under each type of data listed below) and including for Legal Obligations:
Kurero uses personal data to fulfil our contractual obligations that exist between us and yourself. Where we request personal data be provided to enter into, or meet the terms of any such contract, you will be required to provide the relevant personal data or we will not be able to deliver the goods or services you want. In such cases the lawful basis of us processing the personal data is that it is necessary for the performance of a contract.
The types of data & personal data that we may process and collect either directly from yourself or from other sources, are listed below:
(i) Name & Username - As part of your account creation you can chose what you would like your name and username to
be known as in Kurero. Both these are public on your profile.
(ii) Date of Birth - so that we can keep users of different ages safe by only allowing access to certain features to certain
age groups.
(iii) Telephone - so that you can secure your account by registering and logging in with a secure OTP message.
(vi) Contacts (if permission granted) are needed if you would like to find your friends within Kurero or to invite your friends
(vii) Location (only precise location if permission granted) - general location data is shared from your operating system
(viii) Preferences such as any settings chosen in the app are needed if you would like to customise your Kurero experience
(iv) Any profile information, such as your bio, any website links, profile photo you upload are shown publicly
(x) Usage information
- Content of anything you post in Kurero
- Interactions including all reactions, follows, friendships, any links interacted with, time spent viewing different content
and parts of the app.
- DMs, content and metadata related to encrypted messages
- content of any emails you send us
(xi) Purchases & Payments - information relating to any purchases and subscriptions made, such as expiry dates of
subscriptions
(xii) Device information - your phone provider will share details of the type of device you are using and the OS.
There are quite a three main ways in which the data we process is used (these are detailed below) and different types of data may be used for either one or many of these different purposes. For example, information about someone's age may be used in conjunction with information about someone else's use of the app so that we can keep under 16's safe from receiving DMs from people they don't know.
To operate the Kurero app service, data needs to be processed in order to provide a quality and personalised experience. In terms of personalisation, this is determined both by your specific preference settings chosen and also by algorithmic logic that uses information on your previous interactions in the app in order to show you more relevant content in order to give you better experience.
These algorithms are constantly being updated & improved. We will also soon be opensourcing our algorithms as well as offering you more choices on your algorithmic preferences, including the algorithms that you can set for your own communities.
We use relevant data for the safety and security of all our customers and all users of Kurero services. We also have certain legal obligations to use data in a way that complies with applicable laws to keep people safe. This includes verifying your identity, authenticating your account, and defending against fraud, unauthorised use, and illegal activity. We also use the information to evaluate and affect the safety and quality of content on Kurero - this includes investigating and enforcing our policies and and terms, as well as applicable law.
We use the information we collect to communicate with you about our products and services, including about product updates and changes to our policies and terms. If you have agreed to also receive marketing messages from us, you may receive these from time to time too.
We use information you share with us, or that we collect to conduct research, surveys, product testing, and troubleshooting to help us operate and improve our products and services.
We also use information to measure and analyse the effectiveness of our products and services, so we can better understand how you use them in order to make them better.
You are in control of your own data.
There are several rights granted to you immediately upon providing us with your personal information, see seven listed rights below. We’d like you to know that at Kurero we take your rights seriously and will always conduct ourselves in a way that is considerate of our responsibility to serve your legal rights.
This grants you the right to confirm whether or not your personal data is being processed, and to be provided with relevant details of what those processing operations are and what personal data of yours is being processed. If you would like access to the personal data we have about you, we ask that you contact us on customerservice@kurero.co .
If you notice that the data we have about you is inaccurate or incomplete, you may request we rectify the mistake. We will make every effort to respond to requests of this type immediately.
Otherwise known as the ‘right to be forgotten’, this gives you the right to request your personal data be deleted. This is not an absolute right; if you were to request that we erase your personal data, we would erase as much of that data as we could but may have to retain some information if it is necessary.
Where we have received a request for personal data to be erased, if it is necessary for us to retain some of that information we shall ensure that the remaining data is used only when and where it is absolutely necessary.
You have the right to withdraw any consent you have previously issued for processing your data. Sometimes these updates can be made directly in your account settings in Kurero. For any other restriction or withdrawal of service requests please email customerservice@kurero.co .
You can access, correct, or modify the information you provided to us by editing your profile and adjusting your account settings.
To protect your privacy and maintain security, we take steps to verify your identity before granting you access to your personal information or complying with a deletion, portability, or other related request. We may, in certain situations, reject your request for access, correction, or portability, for example, we may reject access where you are unable to verify your identity.
The right to object is a basic freedom all democracies enjoy. If you wish to object to the way we use, or have used, your personal data you may do so freely.
We will always try to maintain the highest standards and encourage the confidence our customers have in us as an organisation. To achieve this, we request that any complaints be first brought to our attention so we can properly investigate matters. If you would like to complain about Kurero to a regulatory body, you may do so by contacting your local data protection supervisory authority.
You have the right not to be subject to a decision based solely on automated means, if the decision produces legal effects concerning you or significantly affects you in a similar way.
If another users reports your content or profile, there could be restrictions made on your content or profile for everyone's safety whilst a human investigation is underway. If you would like to discuss any report or restriction please contact us on customerservice@kurero.co .
The Kurero Privacy Policy https://www.kurero.co/privacy describes how we handle the information you provide to us when you use Kurero and Services. Your use of Kurero & Services confirms that you consent to the collection and use of this information (as detailed in the privacy policy), including the transfer of this information to the United States, United Kingdom, Ireland, and/or other countries for storage, processing and use by us and our affiliates.
We may preserve, use, share, or disclose your information if we believe that it is reasonably necessary to:
- comply with a law, regulation, legal process or governmental request;
- protect the safety of any person, protect the safety or integrity of our platform, including to help prevent spam, abuse,
or malicious actors on our services;
- explain why we have removed content or accounts from our services (e.g., for a violation of our Community Guidelines)
- address fraud, security, or technical issues; or
- protect our rights or property, or the rights or property of those who use our services.
We may share your information with service providers that perform functions and provide services on our behalf, including service providers that host our various blogs and wikis; service providers that help us understand the use of our services; and those that provide fraud detection services.
We may share, sell, or transfer information about you in connection with a merger, acquisition, reorganisation, sale of assets, or bankruptcy. This Privacy Policy will apply to your personal information that is shared with (before and after the close of any transaction) or transferred to the new entity.
We keep different types of information for different periods of time:
- We keep your profile information and content for the duration of your account.
- We generally keep other personally identifiable data we collect when you use our products and services for a
maximum of 18 months.
- Remember public content can exist elsewhere even after you remove it from Kurero.
- For example, search engines and other third parties may retain copies of your posts longer, based upon their own
privacy policies, even after they are deleted or expire on Kurero.
Where you violate our Rules and your account is suspended, we may keep the identifiers you used to create the
account (i.e., email address or phone number) indefinitely to prevent repeat policy offenders from creating new
accounts.
- We may keep certain information longer than our policies specify in order to comply with legal requirements and for
safety and security reasons.
We provide Kurero to people all over the world and provide many of the same privacy tools and controls to all of our users regardless of where they live. However, your experience may be slightly different than users in other countries to ensure Kurero respects local requirements.
Just as you use Kurero to seamlessly participate in global conversations with people in countries all over the world, Kurero must move information across borders and to different countries around the world to support the safe and reliable service you depend on. For example, if you live in Europe and are having a conversation with someone in the United States, information has to move between those countries to provide that experience – it’s what you expect from us.
We also use data centers and cloud providers, and engage located in many parts of the world to help us provide our services. Before we move data between countries we look at the risks that may be presented to the data and rely on Standard Contractual Clauses (SCCs), where applicable, to ensure your data rights are protected. To request a copy of the SCCs, please contact us at customerservice@kurero.co . If data will be shared with a third party, we require them to maintain the same protections over your data that we provide directly.
We will never sell your personal data.
In the future, when our full web3 solution is rolled out, we may assist you to sell your own data but only if you chose to.
Our services are not directed to children, and you may not use our services if you are under the age of 13. You must also be old enough to consent to the processing of your personal data in your country (in some countries we may allow your parent or guardian to do so on your behalf).
The most current version will always be found here at https://www.kurero.co/privacy . This Privacy Policy governs our processing of your personal data and we may revise this Privacy Policy from time to time as needed. I
f we do revise this Privacy Policy and make changes that are determined by us to be material, we will provide you notice and an opportunity to review the revised Privacy Policy before you continue to use Kurero.
The Kurero Privacy Policy is written in English but is made available in multiple languages through translations. Kurero strives to make the translations as accurate as possible to the original English version. However, in case of any discrepancies or inconsistencies, the English language version of the Kurero Privacy Policy shall take precedence. You acknowledge that English shall be the language of reference for interpreting and constructing the terms of the Kurero Privacy Policy.
It is worth just dropping a quick note to inform you that Kurero has been founded upon many great web3 ambitions, to further improve the ease of your ability to own, control & profit from your own data. We have employed an expert web3 research & development team who are actively working on a cutting edge innovative solution to upgrade our service and roll out these improvements to you safely & securely in phases over the coming years. However, for now, we are still utilsing many web2 systems until our PhD researchers figure out the best way to provide the same high quality service on web3 systems without compromising on customer experience, safety & security.
Plus App Holdings Limited, 39 Alma Road, St Albans, Hertfordshire, United Kingdom, AL1 3AT
customerservice@kurero.co
Effective as of: 1st December 2023
Copyright © 2022 Plus App Holdings Limited