Loktantra Mediatech Private Limited (“Khul Ke” “us”, “we” “our” and “Company”) is the author and publisher of the website/mobile application of the Company i.e. Khul Ke. For the purposes of this Privacy Policy, “user(s)” or “you” refers to the viewer/ user of the Services.

The Company is involved in providing and facilitating the usage of various digital services including but not limited to use of the Company’s website, email notifications, mobile application, social/ professional media platforms, widgets, ads and other covered services (collectively, the “Services”). Availing these Services will enable you to share any information in the form of text, messages, link, graphics, photos, audio, videos, or host live events, discussions, sessions, meetings by using the Company’s platforms or mobile application (collectively referred to as “Content”). By using these Services, you agree to be bound by this privacy policy of the Company (“Privacy Policy”).

We respect the privacy of everyone who uses our Services. We require certain information to provide our Services to you, for example you must have an account in order to upload or share Content on any of our platforms. When you choose to share the information with us, we collect and use it to operate our Services.

The confidentiality and protection of your personal information is paramount to us. This Privacy Policy details out how we gather information, process and use personal information shared by you with us. Please read this Privacy Policy before using the Services or sharing any personal information or data.

All the users are advised to read this document carefully prior to usage of the Services. If you do not agree to the terms of the Privacy Policy, please do not use or access the Services.

What information do we collect?

If you choose to create an account on any of our platforms, you must provide us with some personal data to enable us to provide our Services to you. This includes the following information:

(a) Your first and last name, username, password and an email address or phone number. Your username is always public. If you choose to create a business account, you must also provide us with your business category, organization and if you choose to then any additional information, including postal address, email address, and phone number, all of which will always be public.

(b) You may choose to share your preferred language for the usage of the Services, profile picture and any other information that you may choose to include in your profile/ bio.

(c) You may opt to share phone numbers from your address book or even add them manually in order to connect with people you know and/ or further to invite them to join any of our Services and you make revoke the same

(d) We may collect the Content that you share on any of our platforms including payment details, audio/visuals and direct messages, in accordance with applicable laws. Only if there are user reports or automated system flags indicate a violation of the Community Guidelines, do we look at the matter in these Contents.

(e) Any live Content is recorded temporarily while it is live. These are subsequently deleted unless there is a report by a user or our automated systems flag a violation of Community Guidelines while the Content is active. In such circumstances, we encrypt and retain the Content for the purpose of investigation of such incident and delete it once the investigation is complete, as per the applicable laws.

(f) We never record any data from muted speakers/moderators/users and listeners/audience members.

(g) We collect information regarding your usage, connections and interests including information about your interests (if you have added them) and how you use our platforms including the content you share, features you use, people or accounts you interact and connect with, and the time, frequency, and duration of your use. We collect this information solely for the purposes of enhancing your experience on our platforms and to provide you with better services and content ; free or promotional

(h) We may collect communications that we exchange with users when users contact us with queries or feedback, including feedback about interacting or engaging with other users. (i) We may collect information such as payment and transactional data including name, payment card information, bank account number, billing information, and your transaction history. This information is collected by our payment provider - [●], and [●] does not have access to payment card numbers. In addition to our Privacy Policy and our Terms of Service, services agreement and privacy policy of [●] govern the processing of information related to your payments or purchases.

(j) We collect information provided by any social media company in case you interact with any of our pages or connect your other social media accounts. When you connect your social network accounts, the platform can verify your identity and gain access to limited information about those accounts, such as the number of connections you have. We may receive information from social networking accounts based on your privacy settings with each company, so please review their privacy and data practices.

(k) We collect information about your computer, desktop or mobile devices, including its Internet Protocol (IP) address (and derived location), name and operating system, browser type and settings, telecommunications provider, operating system, date and time of platform use, interactions with the platform, and the time, frequency, and duration of those interactions. When you join any of our platforms, you can optionally choose to allow us to access your device's call log data to verify your phone number (as an alternative to text message-based verification). We will have access to your call log data only once.

How we use your information?

(a) We utilise personal information to provide our Services, including to:

(i) Invite you to our platforms;

(ii) Operate the platforms and our business;

(iii) Provide our Services to you;

(iv) Maintain and enhance the platforms and its features;

(v) Create and maintain your account;

(vi) Facilitate network connections;

(vii) Recommend events, users to follow and topics that might be of interest to you, which can be free, promotional or subscription based;

(viii) Notify you when one of your contacts has joined any of our platforms that you use;

(ix) Process your transactions with other users or with us;

(x) Communicate with you about our platforms by sending you push notifications with announcements, updates, security alerts, and support and administrative messages, if you have enabled that functionality; and

(xi) Provide support for the platforms and respond to your requests, questions and feedback.

(b) We may send you direct marketing communications as permitted by law, including, but not limited to, notifying you of feature releases and special events. You can unsubscribe from our email marketing correspondence by following the instructions in the section below under "Opt out of marketing communications”, provided in such emails. Although we may send you transactional emails periodically even after you have opted out of direct marketing.

(c) We may create and utilise de-identifiable data for commercial objectives, such as analysing the effectiveness of our platforms, improving and adding features to it, and analysing the general behaviour and characteristics of our users or other commercial purposes

(d) We employ third-party analytics providers to automatically log information about your devices and how you interact with our platforms. The gathered information is utilised to troubleshoot and avoid errors, analyse data, and develop new features.

(e) We may use personal information to:

(i) Protect our, your, or others’ rights, privacy, safety or property (including by making and defending legal claims);

(ii) Enforce the Terms and Conditions that govern our platforms;

(iii) Investigate violations of Community Guidelines;

(iv) Audit our internal processes for compliance with legal and contractual requirements and internal policies;

(v) Prevent, identify, investigate and deter fraudulent, harmful, unauthorized, unethical or illegal activity, including cyberattacks and identity theft; and

(vi) Comply with applicable laws, lawful requests, and legal process, such as to respond to inquiries or requests from government authorities.

Non-personal information

(i) Information sent by your devices to our platforms, may be automatically collected. This information typically includes the domain name (the site after the @ in your e-mail address). It may also contain your username (the name before the @ in your e-mail address). Other examples of information collected by our server include the Internet Protocol (IP) address used to connect to the internet, operating system and platform, the average time spent on our platforms, pages viewed, information searched for, access times, websites or applications visited before and after a visitor visits our platforms, and other relevant statistics. The amount of information sent depends on the settings of your browser, check your privacy settings on your browsers

(ii) We use the information which we automatically receive from your device to see which pages you visit within our website or mobile application. This is helpful to understand how our users use our Services. We use this information in the aggregate to measure the use of our Services and to administer and improve our Services. This statistical data is interpreted by the Company in its continuing effort to present the Content that users are seeking in a format they find most helpful.

Public Information

(i) Certain activities/information on our platforms is public, including your profile information, your time zone and language, when you created your account, and your Contents and certain information about your Contents like the date, time, and application. You also may choose to publish your location in your Contents or your profile. The lists you create, people you follow and who follow you, and Contents you like, or share are also public. If you like, reply, or otherwise publicly engage with an advertisement on our platforms, that advertiser might thereby learn information about you associated with the advertisement with which you engaged such as characteristics of the audience the advertisement was intended to reach. Any like, comments, or other content you contribute to another account’s broadcast will remain part of that broadcast for as long as it remains on system. Content posted about you by other people who use our platforms may also be public. For example, other people may tag you in photos or videos (if your settings allow) or mention you in a text that they upload.

(ii) You are responsible for your Content and other information you provide through our Services, and you should think carefully about what you make public, especially if it is private or sensitive information.

Personalizing based on your Inferred Identity / personality

When you log onto our platforms on a browser or device, we will associate that browser or device with your account for purposes such as authentication, security, and personalization. Subject to your settings, we may also associate your account with browsers or devices other than those you use to log onto our platforms (or associate your logged-out device or browser with other browsers or devices). When you provide other information to us, including an email address, we associate that information with your account. Subject to your settings, we may also use this information in order to infer other information about your inferred personality, for example by associating your account with hashes of email addresses that share common components with the email address you have provided to us. We do this to operate and personalize our Services. For example, if you visit websites with sports content on your laptop, we may show you sports-related ads/ information, if the email address associated with your account shares components with another email address, such as shared first name, last name, or initials, we may later match advertisements to you from advertisers that were trying to reach email addresses containing those components. If you do not wish to receive personalized ads or content then you may opt-out of the above by unchecking the “personalization” tab in the setting menu of your account.

Sharing your information with third parties

(a) We may share your personal information with organisations and individuals that provide services on our behalf or assist us in operating our platforms or our business (such as hosting, analytics, customer support, email and SMS delivery).

(b) We may share your personal information with professional advisors, such as lawyers, auditors, bankers, and insurers, where necessary in the course of the professional services that they render to us.

(c) We may share your personal information with law enforcement, government authorities, and private parties as required by law or in response to a valid legal request:

(i) Protect our, your, or others’ rights, privacy, safety, or property (including by making and defending legal claims);

(ii) Enforce the Terms and Conditions that govern our platforms; and

(iii) Protect, investigate and deter against fraudulent, harmful, unauthorized, unethical, or illegal activity.

(d) We may share your personal information with acquirers and other relevant parties in connection with a corporate divestiture, merger, consolidation, acquisition, reorganisation, sale, or other disposition of all or any portion of our business or assets, or equity interests in the Company or our affiliates (or negotiations for such transactions) (including, in connection with a bankruptcy or similar proceedings). We will provide notice before your personal data is transferred and becomes subject to a different privacy policy in case of a business transaction.

(e) We provide advertisers with reports about the kinds of people seeing their ads and how their ads are performing, but we don't share information that personally identifies you (information such as your name or email address that by itself can be used to contact you or identifies who you are) unless you give us permission.

Content sharing by users on our platforms

(a) When you create your account on any of our platforms, you agree to share certain aspects of your profile with us and users’ community on our platforms. Your profile picture, bio, name, username, the handles of social media accounts you connect to, the list of users you follow and those who follow you, the date you joined our platform, the friend who nominated you, and the rooms in which you participate are all included in this information. (b) When you share any information or post any Content, other users of our platforms or other social media accounts with whom you have an affiliation may receive notifications regarding actions you perform on the platform, depending on your privacy settings. You can also choose to allow other platform users to record your discussions. (c) If you connect your social media accounts on any of our platforms with your other accounts (for example, gmail or [●]), our platforms will notify those companies that you have given them permission to view your profile information and relationships associated with those accounts. (d) Your privacy and safety settings let you decide:

· Whether the Content that you share are publicly available on our platforms;

· Whether others can tag you in a photo; when available

· Whether you will be able to receive direct messages from any user on our platforms;

· Whether others can find you based on your email or phone number;

· Whether you sync your address book with our platform;

· Whether you wish to see any sensitive content on our platforms;

· Whether you want to block or mute other users.

Accessing or Rectifying Data/ Settings by users

(a) We will provide you with the ability to access, rectify, port and erase your data. You can ask us to update or correct your information by contacting us. You can also request that your account be deleted or that the contact phone numbers you previously shared with us be removed. Please be aware that we will need to authenticate your authority to edit, modify, or delete your account, and that certain activity created prior to deletion may be stored by us and shared with third parties as described in this Privacy Policy.

(b) At any time, you can disconnect your social media accounts that you had previously linked to our platform, directly from the platform.

(c) You can unsubscribe from marketing-related emails by following the unsubscribe or opt-out instructions included in the communications we send to you.

(d) We may send push notifications or alerts to your mobile device from time to time if you opt-in to receive them within the app. By adjusting your device settings, altering the push notification settings inside the app, or removing the app, you can turn off push notifications and alerts at any time.

Information Retention

(a) We store data until it is no longer necessary to provide our services to you or for as long as you have an account with any of our platforms, whichever is earlier. Your personal data will be stored for a reasonable period of time following account deletion in accordance with applicable lawsWe temporarily record audio/ visuals in a room while it is still operational. If a user reports a violation of Community Guidelines while the room is open, we keep the audio/visual to investigate the incident and then remove it after the inquiry is complete. We may remove the information by anonymizing it so that it can no longer be linked to a specific user.

(b) When determining the appropriate retention period for your personal data, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal requirements.

Information placed on Device - Cookies

(a) We may store some information such as cookies on your device when you access our Services. “Cookies” are text files containing small amounts of information which we download onto your device when you visit our website or mobile application for record-keeping purposes. We can recognize these cookies on subsequent visits and they allow us to remember your preferences and generally improve your experience of the website and mobile application.

(b) A few important things you should know about our use of Cookies:

(i) We use both session and persistent Cookies. Session Cookies are temporary Cookies that are used to remember you during the course of your visit on the website/mobile application and which expire when you close the website/mobile application. Persistent Cookies are used to remember your preferences within the website/mobile application and remain on your system even after you close the website/mobile application. These persistent cookies are used to analyze your behavior to establish visit patterns so that we can improvise the website/mobile application functionality for you;

(ii) You are always free to decline Cookies or alter your Cookies settings for our website/mobile application specifically, although doing so may interfere with your use of our website/mobile application. Please note that the website/mobile application automatically accepts the Cookies and therefore, if you do not wish to use the Cookies, please actively delete or block the Cookies;

(iii) We encode and protect our Cookies so that only we can interpret the information stored in them;

Other apps and websites

Our platforms may contain links to third-party websites and other online services. Our material may also be embedded in web pages or other online services that are not affiliated with us. These links and integrations are not an endorsement of any third party or an indication that we are associated with them. We have no control over third-party websites or online services, and we are not liable for their behaviour.

Commitment to Information Security

You use our platforms at your own risk. We utilise commercially reasonable technical, administrative, and organisational safeguards to protect personal information from loss, misuse, and unauthorised access, disclosure, modification, or destruction, both online and offline. No internet or e-mail communication, information shared online, however, is ever completely secure or error-free. Communications transmitted to or from us may not be secure. As a result, you should use extreme caution when determining what information, you send to us via the internet. Please keep this in mind whenever you provide us personal information via the internet.

Changes to this Privacy Policy

We retain the right to make changes to this Privacy Policy at any time. If we make significant changes to this Privacy Policy, we'll let you know by changing the date and publishing it on our platforms. If required by law, we will also notify you of such changes in a way we feel is reasonably likely to reach you, such as via email or any other method. Any changes to this Privacy Policy will take effect when we upload the updated version (or as otherwise indicated at the time of posting). In any circumstances, your continued use of our platforms after the effective date of any changed Privacy Policy signifies your acknowledgment of the changes. Khul Ke complies with the Google API Services User Data Policy, including Limited Use requirements. For details, refer to Google policy:  Google API Services User Data Policy.

Transfer of Personal Data

Your information, including Personal Data, is processed at the Company's operating offices and in any other places where the parties involved in the processing are located. This means that this information may be transferred to — and maintained on — computers located outside of Your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is treated securely and in accordance with this Privacy Policy and no transfer of Your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of Your data and other personal information.EU Data Subject Rights

If you are a resident of the European Economic Area (EEA) and are accessing our Services then you may be regulated by the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of natural persons with regard to the processing of personal data and on the free movement of such data and repealing Directive 95/46/EC (General Data Protection Regulation) (GDPR). You may reach out to us at: [●] with a subject line “GDPR compliance”. We respond to all requests we receive from individuals wishing to exercise their data protection rights in accordance with applicable data protection laws. Any transfer of data generated from EU citizens shall be subject to the data transfer compliances outlined in GDPR.

Contacting Us

Questions, comments and requests regarding this Privacy Policy should be addressed to  support@khulke.com. You may also contact us on:  support@khulke.com. (Monday-Friday, 9am to 5 pm India Standard Time).

Contact information of Grievance Officer:

If you have any grievance or complaint with respect to the Services, including any discrepancies and grievances with respect to processing of information, you can contact our Grievance Officer at : Email: support@khulke.com.