Privacy Policy

October 2015

Your Privacy Is Important to Us

Keettoo is a leading predictive text application for smartphones, tablets and other mobile devices. It has been created with the aim of delivering a faster, error-free and personalized text input experience to users. Keettoo has an intelligent and intuitive feature that allows it to continuously learn and adapt to the user's writing style, vocabulary and vernacular. This makes it one of the most advanced text input applications in the market today. Keettoo has been developed by Talent Trove (India) Pvt. Ltd. (hereinafter, "TTIPL").


This privacy policy (hereinafter, "Privacy Policy") sets out basic principles adopted by Talent Trove (India) Pvt. Ltd for collecting, using, disclosing and protecting personal information consistent with Indian information security laws and associated regulations.


Scope and Content

You accept this Privacy Policy when you sign up for, access, or use Keettoo, its services, content, features, technologies or functions (collectively, "Services"). We may amend this Privacy Policy at any time by posting a revised version on our website, http://www.keettoo.com/. The revised version will be effective at the time we post it. In addition, if the revised version includes a substantial change, we will provide you with 30 days' prior notice by posting notice of the change on the "Policy Updates" page of our website. After this 30-day notice period, you will be considered as having expressly consented to all amendments to this Policy.


This Privacy Policy does not apply to the practices of companies that we do not own or control. Further, this Privacy Policy does not apply to: (a) information collected by third party websites, platforms and/or applications ("Third Party Sites") which we do not control; (b) information collected by Third Party Sites which you access via links using our Services; or (c) banners, sweepstakes and other advertisements or promotions on Third Party Sites that we may sponsor or participate in. These Third Party Sites may have their own privacy policies and terms and conditions. We assume no liability, in any manner whatsoever, for the contents of such privacy policies, and we encourage you to be informed in relation thereto.


About Keettoo and its Capabilities

Keettoo is supplied to end-users as a complete keyboard application or as a predictive engine that can be embedded into a customer's keyboard application, in the event the customer is an original equipment manufacturer. Keettoo can also be supplied to end-users directly as a third party droid/iOS application on Play store/App store. With Keettoo, users can access industry specific dictionaries from fields like Medicine, Telecom, IT, Finance, Law, Business etc.


We may collect certain types of information in order to provide you with the use of and access to our Services, and to help us personalize and improve your experience. At the outset, notwithstanding our capabilities, we avoid collecting personal information of users. For instance, we typically avoid collecting or storing data entered into password fields while using Keettoo. We also typically avoid storing or collecting the login credentials for your online profiles.


Without prejudice to the above, when you avail our Services, we may collect non-personal data (e.g. type of internet browser and operating system used, device model being used by you etc). We may use this data and share it with our worldwide affiliates to monitor the attractiveness of our Services and improve our performance or content.


At times, we may collect personal information (using a unique identifier or associating the unique identifier with Android/iOS platform advertising identifier) such as your location, your mobile device (including a unique identifier for your device,), your shopping habits and preferences such as your hobbies and interests. Such personal information is used by us to provide you with location-based services, such as advertising, search results and other personalized content (including language modelling). Most mobile devices allow you to control or disable location services in the device's settings menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.


Unless otherwise defined, the expression "personal information" as used in this Privacy Policy refers to such information, in whole or in part, which allows the provider thereof to be identified.


In certain specific (though rare) instances, we may collect "sensitive personal data or information" (as defined under applicable laws, in particular, the Rules framed under the Information Technology Act, 2000), such as your login credentials, that we believe is necessary for a lawful purpose connected with our function or activity necessary to deliver, promote or market our Services or to carry out our primary business functions and/or activities. Ordinarily, Keettoo will only collect such information about you when you provide it or you have consented to provide the information or where it is required by law. Where we collect sensitive personal information for a specific purpose, we will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons. In order to protect information from accidental or malicious destruction, when we delete information from our services we may not immediately delete residual copies from our servers or remove information from our backup systems.


Keettoo will not collect, use or disclose your personal information without your consent, whether explicit or otherwise. By using our Services, you are consenting to Keettoo for collecting, using and disclosing your personal information in accordance with this Privacy Policy.


We may ask you to provide additional consent if we need to use your personal information for purposes not covered by this Privacy Policy. If you provide additional consent, then, notwithstanding anything contained in this Privacy Policy, the terms of such additional consent (as mutually agreed) shall prevail over this Privacy Policy to the extent of any inconsistency.


Certain Android/ iOS platforms through which Keettoo can be accessed may grant you the option of resetting your identifier, such that a fresh identifier may be generated. By using our Services, you are consenting to Keettoo using the information already collected by it through your previous identifier, such that you may be provided with personalized services on your fresh identifier.


How We Protect and Store Personal Information

We store and process your personal information on our servers in the Singapore region, and elsewhere in the world where our facilities may, in future, be located.


We protect your personal information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. We take all reasonable precautions to keep your personal information secure and require any third parties that handle or process your personal information for us to do the same. Access to your ersonal information is restricted to prevent unauthorized access, modification or misuse and is only permitted among our employees and agents on a need-to-know basis.


How We Use the Personal Information We Collect

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information primarily to enhance our prediction technology which suggests the next word you are trying to type and to personalize your keyboard typing experience. We may also use your personal information to (a) suggest products or services (including those of relevant third parties) which we think may be of interest to you, or (b) offer you the opportunity to take part in competitions or promotions. You can opt out of receiving communications from us at any time. In order to do so, please send us an email at feedback@keettoo.com.


Information from third party sources

We may receive personal information about you from other sources if you have given permission for such information to be shared. This may include information from commercially available sources, such as public databases and data aggregators, and information from third parties. Any information disclosed in public areas or websites (YouTube, Twitter, etc.) will become public information. We cannot control the use of information disclosed in public forums, such as forums, bulletin boards, blogs, chat rooms, and networking functions of mobile-device applications. You should exercise caution when disclosing information in these public areas, and be careful how you disclose your personal information.


Further, by virtue of your use of telecommunication services while availing our Services, your communication data (e.g. Internet protocol address) or utilization data (e.g. information on the beginning, end and extent of each access, and information on the telecommunication services you accessed) are technically generated and could conceivably relate to personal information. We shall not be held accountable for such data, given that we do not use our recourses to collect such data. However, to the extent that there is a compelling necessity, the collection, processing and use of such data may occur and will be performed in accordance with the applicable data privacy protection legal framework.


Openness and Data Access

If you ask, we will inform you about how your personal data is processed and the rights and remedies you have under this Privacy Policy. You may inquire as to the nature of the personal data stored or processed about you by Keettoo. You will be provided access as is required by applicable laws. If any data is inaccurate or incomplete, you may request that the data be amended..


Who Do We Share Your Personal Information With

Typically, we do not share your personal information with anyone outside of the TTIPL group. However, we may share your personal information with trusted third parties.


We may share your personal information with (a) our advertising, marketing and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions, (b) third parties required to deliver a product or service to you either through us or directly, without such product or service being necessarily delivered through our platform, and (c) law enforcement or government authorities where they have followed due legal process to request us to disclose the information. You can opt out of receiving communications from such third parties at any time. In order to do so, please send us an email at feedback@keettoo.com.


We may also share your personal information with companies, organizations or individuals outside of the TTIPL group if we believe that disclosure of the information is necessary for legal reasons. If we do share your personal information with a third party, we shall make reasonable endeavours to ensure that they keep your information secure, take all reasonable steps to protect it from misuse and only use it in a manner consistent with this Privacy Policy and applicable data protection laws and regulations.


TTIPL does not sell personal information, except to an entity to which it divests all or a portion of its business, or otherwise in connection with a merger, consolidation, change in control, reorganization or liquidation of all or a portion of its business or undertaking.


Your Privacy Rights & Who To Contact

If you have any questions, comments or concerns about how we handle your personal information or if you do not wish that we collect your personal information, then you may contact us by clicking the 'Contact Us' link on our website. Alternatively, please send us an email at feedback@keettoo.com. We have a designated grievance officer, to address any grievance or discrepancy in relation to processing of personal information, as required under applicable laws.


You have the right to tell us if you (a) do not want to be contacted in the future by us, (b) would like a copy of the personal information which we hold about you, (c) would like us to correct or update your personal information in our records, (d) wish to report any isuse of your personal information. To assist us in dealing with your request, please provide your full name and details.


Governing Law and Jurisdiction

This agreement is governed by the laws of the Republic of India. This agreement is deemed to have been signed and executed in New Delhi, India and you expressly submit yourself to the exclusive jurisdiction of the Indian laws and the Courts in New Delhi, India only, in respect of any disputes arising in any manner out of or relating to our Services. You expressly waive any objection of whatsoever nature to Indian jurisdiction and agree not to raise any objection or take any plea as to Indian jurisdiction on the ground of forum inconvenient, delay, expense, hardship or otherwise howsoever.

June 2016

YOUR PRIVACY IS IMPORTANT TO US

Keettoo is a leading predictive text application for smartphones, tablets and other mobile devices. It has been created with the aim of delivering a faster, error-free and personalized text input experience to users. Keettoo has an intelligent and intuitive feature that allows it to continuously learn and adapt to the user's writing style, vocabulary and vernacular. This makes it one of the most advanced text input applications in the market today. Keettoo has been developed by KSC Software Pvt. Ltd. (hereinafter, "KSC").


This privacy policy (hereinafter, "Privacy Policy") sets out basic principles adopted by KSC Software Pvt. Ltd for collecting, using, disclosing and protecting personal information consistent with Indian information security laws and associated regulations.

SCOPE AND CONTENT

You accept this Privacy Policy when you sign up for, access, or use Keettoo, its services, content, features, technologies or functions (collectively, "Services"). We may amend this Privacy Policy at any time by posting a revised version on our website, http://www.keettoo.com/. The revised version will be effective at the time we post it. In addition, if the revised version includes a substantial change, we will provide you with 30 days' prior notice by posting notice of the change on the "Policy Updates" page of our website. After this 30-day notice period, you will be considered as having expressly consented to all amendments to this Policy.


This Privacy Policy does not apply to the practices of companies that we do not own or control. Further, this Privacy Policy does not apply to: (a) information collected by third party websites, platforms and/or applications ("Third Party Sites") which we do not control; (b) information collected by Third Party Sites which you access via links using our Services; or (c) banners, sweepstakes and other advertisements or promotions on Third Party Sites that we may sponsor or participate in. These Third Party Sites may have their own privacy policies and terms and conditions. We assume no liability, in any manner whatsoever, for the contents of such privacy policies, and we encourage you to be informed in relation thereto.

ABOUT KEETTOO AND ITS CAPABILITIES

Keettoo is supplied to end-users as a complete keyboard application or as a predictive engine that can be embedded into a customer's keyboard application, in the event the customer is an original equipment manufacturer. Keettoo can also be supplied to end-users directly as a third party Android/iOS application on Play store/App store. With Keettoo, users can access industry specific dictionaries from fields like Medicine, Telecom, IT, Finance, Law, Business etc.


We may collect certain types of information in order to provide you with the use of and access to our Services, and to help us personalize and improve your experience. At the outset, notwithstanding our capabilities, we avoid collecting personal information of users. For instance, we typically avoid collecting or storing data entered into password fields while using Keettoo. We also typically avoid storing or collecting the login credentials for your online profiles.


Without prejudice to the above, when you avail our Services, we may collect non-personal data (e.g. type of internet browser and operating system used, device model being used by you etc). We may use this data and share it with our worldwide affiliates to monitor the attractiveness of our Services and improve our performance or content.


At times, we may collect personal information (using a unique identifier or associating the unique identifier with Android/iOS platform advertising identifier) such as your location, your mobile device (including a unique identifier for your device,), your shopping habits and preferences such as your hobbies and interests. Such personal information is used by us to provide you with location-based services, such as advertising, search results and other personalized content (including language modelling). Most mobile devices allow you to control or disable location services in the device's settings menu. If you have questions about how to disable your device's location services, we recommend you contact your mobile service carrier or the manufacture of your particular device.


Unless otherwise defined, the expression "personal information" as used in this Privacy Policy refers to such information, in whole or in part, which allows the provider thereof to be identified.


In certain specific (though rare) instances, we may collect "sensitive personal data or information" (as defined under applicable laws, in particular, the Rules framed under the Information Technology Act, 2000), such as your login credentials, that we believe is necessary for a lawful purpose connected with our function or activity necessary to deliver, promote or market our Services or to carry out our primary business functions and/or activities. Ordinarily, Keettoo will only collect such information about you when you provide it or you have consented to provide the information or where it is required by law. Where we collect sensitive personal information for a specific purpose, we will not keep it for longer than is necessary to fulfil that purpose, unless we have to keep it for legitimate business or legal reasons. In order to protect information from accidental or malicious destruction, when we delete information from our services we may not immediately delete residual copies from our servers or remove information from our backup systems.


Keettoo will not collect, use or disclose your personal information without your consent, whether explicit or otherwise. By using our Services, you are consenting to Keettoo for collecting, using and disclosing your personal information in accordance with this Privacy Policy.


We may ask you to provide additional consent if we need to use your personal information for purposes not covered by this Privacy Policy. If you provide additional consent, then, notwithstanding anything contained in this Privacy Policy, the terms of such additional consent (as mutually agreed) shall prevail over this Privacy Policy to the extent of any inconsistency.


Certain Android/ iOS platforms through which Keettoo can be accessed may grant you the option of resetting your identifier, such that a fresh identifier may be generated. By using our Services, you are consenting to Keettoo using the information already collected by it through your previous identifier, such that you may be provided with personalized services on your fresh identifier.

HOW WE PROTECT AND STORE PERSONAL INFORMATION

We store and process your personal information on our servers in the Singapore region, and elsewhere in the world where our facilities may, in future, be located.


We protect your personal information using physical, technical, and administrative security measures to reduce the risks of loss, misuse, unauthorized access, disclosure and alteration. We take all reasonable precautions to keep your personal information secure and require any third parties that handle or process your personal information for us to do the same. Access to your personal information is restricted to prevent unauthorized access, modification or misuse and is only permitted among our employees and agents on a need-to-know basis.


HOW WE USE THE PERSONAL INFORMATION WE COLLECT

Our primary purpose in collecting personal information is to provide you with a secure, smooth, efficient, and customized experience. We may use your personal information primarily to enhance our predictive technology, which suggests the next word you are trying to type and to personalize your keyboard typing experience. We may also use your personal information to (a) suggest products or services (including those of relevant third parties) which we think may be of interest to you, or (b) offer you the opportunity to take part in competitions or promotions. You can opt out of receiving communications from us at any time. In order to do so, please send us an email at contact@keettoo.com

INFORMATION FROM THIRD PARTY SOURCES

We may receive personal information about you from other sources if you have given permission for such information to be shared. This may include information from commercially available sources, such as public databases and data aggregators, and information from third parties. Any information disclosed in public areas or websites (YouTube, Twitter, etc.) will become public information. We cannot control the use of information disclosed in public forums, such as forums, bulletin boards, blogs, chat rooms, and networking functions of mobile-device applications. You should exercise caution when disclosing information in these public areas, and be careful how you disclose your personal information.


Further, by virtue of your use of telecommunication services while availing our Services, your communication data (e.g. Internet protocol address) or utilization data (e.g. information on the beginning, end and extent of each access, and information about the telecommunication services you accessed) are technically generated and could conceivably relate to personal information. We shall not be held accountable for such data, given that we do not use our recourses to collect such data. However, to the extent that there is a compelling necessity, the collection, processing and use of such data may occur and will be performed in accordance with the applicable data privacy protection legal framework.


OPENNESS AND DATA ACCESS

If you ask, we will inform you about how your personal data is processed and the rights and remedies you have under this Privacy Policy. You may inquire as to the nature of the personal data stored or processed about you by Keettoo. You will be provided access as is required by applicable laws. If any data is inaccurate or incomplete, you may request that the data be amended..

WHO DO WE SHARE YOUR PERSONAL INFORMATION WITH

Typically, we do not share your personal information with anyone outside of the KSC group. However, we may share your personal information with trusted third parties.


We may share your personal information with (a) our advertising, marketing and promotional agencies to help us deliver and analyze the effectiveness of our advertising campaigns and promotions, (b) third parties required to deliver a product or service to you either through us or directly, without such product or service being necessarily delivered through our platform, and (c) law enforcement or government authorities where they have followed due legal process to request us to disclose the information. You can opt out of receiving communications from such third parties at any time. In order to do so, please send us an email at contact@keettoo.com.


We may also share your personal information with companies, organizations or individuals outside of the KSC group if we believe that disclosure of the information is necessary for legal reasons. If we do share your personal information with a third party, we shall make reasonable endeavours to ensure that they keep your information secure, take all reasonable steps to protect it from misuse and only use it in a manner consistent with this Privacy Policy and applicable data protection laws and regulations.


KSC does not sell personal information, except to an entity to which it divests all or a portion of its business, or otherwise in connection with a merger, consolidation, change in control, reorganization or liquidation of all or a portion of its business or undertaking.

YOUR PRIVACY RIGHTS & WHO TO CONTACT

If you have any questions, comments or concerns about how we handle your personal information or if you do not wish that we collect your personal information, then you may contact us by clicking the 'Contact Us' link on our website. Alternatively, please send us an email at contact@keettoo.com. We have a designated grievance officer, to address any grievance or discrepancy in relation to processing of personal information, as required under applicable laws.


You have the right to tell us if you (a) do not want to be contacted in the future by us, (b) would like a copy of the personal information which we hold about you, (c) would like us to correct or update your personal information in our records, (d) wish to report any isuse of your personal information. To assist us in dealing with your request, please provide your full name and details.

GOVERNING LAW AND JURISDICTION

This agreement is governed by the laws of the Republic of India. This agreement is deemed to have been signed and executed in New Delhi, India and you expressly submit yourself to the exclusive jurisdiction of the Indian laws and the Courts in New Delhi, India only, in respect of any disputes arising in any manner out of or relating to our Services. You expressly waive any objection of whatsoever nature to Indian jurisdiction and agree not to raise any objection or take any plea as to Indian jurisdiction on the ground of forum inconvenient, delay, expense, hardship or otherwise howsoever.

INFORMATION WE COLLECT

We collect information in the following ways:


Information you give us. For example, when you sign up we’ll ask for personal information, like your name, email address, telephone number or credit card to store with your account.


Information we get from your use of our services. We collect information about the services that you use and how you use them, like when you watch a video or view and interact with our ads and content. This information includes: Device information


We collect device-specific information (such as your hardware model, operating system version, unique device identifiers, and mobile network information including phone number). We may associate your device identifiers or phone number with your Keettoo Account. Log information


When you use our services or view content provided by Keettoo, we automatically collect and store certain information in server logs. This includes:

Details of how you used our service, such as your search queries.


Telephony log information like your phone number, calling-party number, forwarding numbers, time and date of calls, duration of calls, SMS routing information and types of calls.


Internet protocol address.


Device event information such as crashes, system activity, hardware settings, browser type, browser language, the date and time of your request and referral URL.


Cookies that may uniquely identify your browser.


Location information


When you use Keettoo services, we may collect and process information about your actual location. We use various technologies to determine location, including IP address, GPS, and other sensors that may, for example, provide Keettoo with information on nearby devices, Wi-Fi access points and cell towers.


Unique application numbers


Certain services include a unique application number. This number and information about your installation (for example, the operating system type and application version number) may be sent to Keettoo when you install or uninstall that service or when that service periodically contacts our servers, such as for automatic updates.


Local storage


We may collect and store information (including personal information) locally on your device using mechanisms such as browser web storage (including HTML 5) and application data caches.

Accessing and updating your personal information

Whenever you use our services, we aim to provide you with access to your personal information. If that information is wrong, we strive to give you ways to update it quickly or to delete it – unless we have to keep that information for legitimate business or legal purposes. When updating your personal information, we may ask you to verify your identity before we can act on your request.


We may reject requests that are unreasonably repetitive, require disproportionate technical effort (for example, developing a new system or fundamentally changing an existing practice), risk the privacy of others, or would be extremely impractical (for instance, requests concerning information residing on backup systems).


Where we can provide information access and correction, we will do so for free, except where it would require a disproportionate effort. We aim to maintain our services in a manner that protects information from accidental or malicious destruction. Because of this, after you delete information from our services, we may not immediately delete residual copies from our active servers and may not remove information from our backup systems.

INFORMATION WE SHARE

We do not share personal information with companies, organizations and individuals outside of Keettoo unless one of the following circumstances applies:


With your consent

We will share personal information with companies, organizations or individuals outside of Keettoo when we have your consent to do so. We require opt-in consent for the sharing of any sensitive personal information.


With domain administrators

If your Keettoo Account is managed for you, by a domain administrator then your domain administrator and resellers who provide user support to your organization will have access to your Keettoo Account information (including your email and other data). Your domain administrator may be able to:

View statistics regarding your account, like statistics regarding applications you install.
Change your account password.
Suspend or terminate your account access.
Access or retains information stored as part of your account.
Receive your account information in order to satisfy applicable law, regulation, legal process or enforceable governmental request.
Restrict your ability to delete or edit information or privacy settings.

Please refer to your domain administrator’s privacy policy for more information.

For external processing

We provide personal information to our affiliates or other trusted businesses or persons to process it for us, based on our instructions and in compliance with our Privacy Policy and any other appropriate confidentiality and security measures.

For legal reasons

We will share personal information with companies, organizations or individuals outside of Keettoo if we have a good-faith belief that access, use, preservation or disclosure of the information is reasonably necessary:

Meet any applicable law, regulation, legal process or enforceable governmental request.
Enforce applicable Terms of Service, including investigation of potential violations.
Detect, prevent, or otherwise address fraud, security or technical issues.
Protect against harm to the rights, property or safety of Keettoo, our users or the public as required or permitted by law.

We may share non-personally identifiable information publicly and with our partners – like publishers, advertisers or connected sites. For example, we may share information publicly to show trends about the general use of our services.


If Keettoo is involved in a merger, acquisition, or asset sale, we will continue to ensure the confidentiality of any personal information and give affected users notice before personal information is transferred or becomes subject to a different privacy policy.

COMPLIANCE AND COOPERATION WITH REGULATORY AUTHORITIES

We regularly review our compliance with our Privacy Policy. We also adhere to several self regulatory frameworks. When we receive formal written complaints, we will contact the person who made the complaint to follow up. We work with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that we cannot resolve with our users directly.

CHANGES

Our Privacy Policy may change from time to time. We will not reduce your rights under this Privacy Policy without your explicit consent. We will post any privacy policy changes on this page and, if the changes are significant, we will provide a more prominent notice (including, for certain services, email notification of privacy policy changes). We will also keep prior versions of this Privacy Policy in an archive for your review.