Welcome to Kumu!

Kumu Privacy Policy (v3.0)

At kumu, as part of our commitment to create a safe space, we are working our best to ensure that your privacy is respected and your Personal Data is protected. 

Thus, we want you to take a moment and understand what data we obtain about you and our data privacy practices and policies, so you can make an informed decision and exercise meaningful control over your data.

This Privacy Policy will take effect on 20 Nov 2023. For the old version (v2.0) of the policy click here.

HIGHLIGHTS 

You should read our Privacy Policy in its entirety, but here are a few key points we hope you will take away:

• kumu is accessible to the general public from anywhere in the world except in a few countries where the service is unavailable in order for kumu to comply with the law or its company policy.
• When you livestream, create a profile, follow a streamer, give virtual gifts, participate in campaigns or post a clip on kumu that are public or intended to be public in nature, individuals that use kumu will access this information and may have the ability to acquire, use, or reveal such information to others. Furthermore, several of our Services (as defined below) are intended to offer others with information on user behavior, such as virtual gifting or a follow to a streamer. We advise you to keep this in mind when using kumu. However, we also provide non-public communication channels on kumu, such as private streaming and chat.
• When you participate in campaigns sponsored by our Business Partners (i.e. any company or individual which transacts business with Kumu, including but not limited to advertisers and merchants), we may share your Personal Data with them in accordance with the terms and conditions of the campaigns. For example, if you participate in DTI (Philippines) registered campaigns of a Business Partner, we may share your information with DTI (Philippines) as part our legal obligation and with the Business Partner as part of our contractual obligation.
• When you purchase products from our Business Partners, we may share your Personal Data with them to fulfill your orders and to third party service providers for the delivery of your ordered products.
• We collect certain Personal Data (e.g. information regarding the device you’re using, IP address, etc.) from you when you use kumu, even if you’re simply browsing livestreams. We use this information to keep the platform safe and to offer you more relevant content, suggested users and advertisements.
• We want to hear from you if you have any concerns regarding this Privacy Policy, how we collect or use your Personal Data, or anything else relating to our policies or practices at kumu. You are welcome to contact us at any time using the contact details set out at the end of the Privacy Policy.

APPLICABILITY +

This Privacy Policy is applicable to the collection and use of Personal Data by KumuMedia International Pte. Ltd. (“kumu,” “we,” “us,” or “our”). It describes kumu’s practices regarding the collection, use, disclosure, sale and other processing of Personal Data when you:

• Use kumu products and services (e.g. websites, applications, or services supplied, owned, or operated by kumu) which we refer to collectively in this Privacy Policy as our “Services,” or
• Otherwise, communicate with us

Kumu acts as the “controller” of your Personal Data for the activities described in this Privacy Policy. That means kumu is the legal entity deciding why and how your Personal Data is collected and used.

EXTERNAL PARTY SITES

Our Services may contain links to other websites [and apps] that we do not operate, which may have privacy policies that differ from our own. If you click on a third party link, you may be directed to that third party’s website [or app landing page]. We strongly advise you to review the privacy policy of every third party site and/or app that you visit. We have no control over and assume no responsibility for the content, privacy policies or practices of any third party sites, apps or services.

WHAT PERSONAL DATA DO WE COLLECT

CATEGORIES AND SOURCES +

For purposes of this Privacy Policy, “Personal Data” means any data that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household. This implies that Personal Data includes information that directly identifies you, such as your name, as well as information that can reasonably be used to identify you, such as your device number in certain circumstances. Personal data does not include aggregated data (which does not identify a particular individual).

We may collect the following categories of Personal Data from you when you [download our app], create an account, stream through our Services, participate in our campaigns and challenges, post klips, use our chat services, purchase coins and share virtual gifts through our Services, contact us (including via social media), participate in our surveys and events, purchase a product in our kumu shop, or otherwise interact with us by using our Services.

USER-PROVIDED PERSONAL DATA

• Personal identifiers. Name, email address, physical address, phone number, [social media account names], registered devices, gender, in-game username (for gaming tournaments and competitions) and age
• Payment Information. Information about billing address and payment method, such as bank account information, credit, debit, or other payment card information
• Transaction Information. Data about purchases and use of services or transactions facilitated by kumu, including purchases made through the Services
• Usage Information. Audio, videos, images, and other information uploaded, viewed ,shared and downloaded on and from the Services; interactions and exchanges with other users (e.g. chat, stream, etc.)
• Government ID Data. We may request a government-issued ID in some instances, such as for verification of your identity, or as required by law
• Other Information You Provide to Us. The content of your kumu correspondence, including exchanges with our customer support (including social media)
• Inferences Drawn From your Data. Inferences we make based upon your interests and viewing preferences

SENSITIVE INFORMATION

Sensitive Personal information are those personal data revealing racial or ethnic origin, political opinions, religious or philosophical beliefs; trade-union membership; genetic data, biometric data processed solely to identify a human being; health-related data; data concerning a person’s sex life or sexual orientation.

When necessary, with your consent or as otherwise permitted by applicable law, we may also process the following categories of sensitive information:

• financial data
• biometric data
• social security numbers or other government identifiers

PAYMENT DATA

We may collect data necessary to process your payment if you make purchases, such as your payment instrument number, and the security code associated with your payment instrument.

SOCIAL MEDIA LOG-IN DATA

We may provide you with the option to register with us using your existing social media account details, like your Facebook, Twitter, or other social media account. If you choose to register this way, we will collect the information described herein.

APPLICATION DATA

When you use our mobile application(s), we may also collect the following information if you choose to provide us access and permission:

• Geolocation Information. We may request access or permission to track location-based information from your mobile device, either continuously or while you are using our mobile application(s), to provide certain location-based services. If you wish to change our access or permissions, you may do so in your device’s settings.
• Mobile Device Access. We may request access or permission to certain features from your mobile device, including your mobile device’s camera,contacts, microphone, bluetooth, calendar, reminders, sms messages, social media accounts, storage, and other features. If you wish to change our accessor permissions, you may do so in your device’s settings.
• Push Notifications. We may request to send you push notifications regarding your account or certain features of the application(s). If you wish to opt out from receiving these types of communications, you may turn them off in your device’s settings.

The above information is primarily needed to maintain the security and operation of our application(s), for troubleshooting, and for our internal analytics, and reporting purposes.

AUTOMATICALLY-COLLECTED DATA

When you use our Services, we use cookies and other technologies to automatically collect, record, store and otherwise process the following types of Personal Data:

• Usage Data. Data about your activities on and use of our Services, such as app launches inside our Services, browser history, product engagement, IP address or other unique identifiers, and other information regarding your interaction with our Services and our advertisements
• Device Information. Data that can be used to identify your device, such as the device ID, or information about the device, such as the browser type

We use Google Analytics to evaluate the use of our website. Google Analytics uses cookies and other identifiers to collect information, such as how often users visit a website, what pages they visit when they do so, and what other websites they visited prior to visiting a website. To learn more about how Google Analytics collects Personal Data, review Google’s Privacy Policy.

To learn more about cookies, please check our cookie policy here

INFORMATION FROM OTHER SOURCES

kumu may receive Personal Data about you from other individuals, from businesses or third parties acting at your direction, from our Business Partners such as social media platforms with which you interact, and from third parties that work with us to provide our products and services and assist us with security and fraud prevention and improving our Services.

For instance, we may acquire your Personal Data from social media networks (such as Facebook). By accessing or connecting our Services through social media, you authorize kumu to collect, retain, and otherwise process such Personal Data in accordance with this Privacy Policy and our Terms of Use.

HOW KUMU USES YOUR PERSONAL DATA +

Kumu processes the following types of Personal Data for the following purposes and in reliance on the following legal bases: 

You have a right to object to the processing of your personal information where that processing is carried out for our legitimate interests. Please note however that we may not be able to fulfill this request in all instances. You are able to request a copy of the legitimate interest assessment carried out by us.

Where we need to collect the above mentioned categories of Personal Data by virtue of a legal obligation or in light of a contract entered or to be entered into with you, and you do not provide this Personal Data when requested, we may not be able to comply with our legal obligations, provide you with a service or perform the contract we have or are trying to enter into with you. In such a case, we may have to terminate our relationship with you.

KUMU’S SHARING OF PERSONAL DATA +

 We may disclose your personal information with our service providers pursuant to a written contract between us and each service provider. 

 We may use your personal information for our own business purposes, such as for undertaking internal research for technological development and demonstration. This is not considered to be “selling” your personal information.

 We may share or disclose your Personal Data to the following:

VENDORS, CONSULTANTS & OTHER THIRD-PARTY SERVICE PROVIDERS

We disclose Personal Data to service providers who perform services for us or on our behalf and may require access to such information to do that work. We have contracts in place with our third parties, which are designed to help safeguard your personal information. This means that they cannot do anything with your personal information unless we have instructed them to do it. They will also not share your personal information with any organization apart from us. They also commit to protect the data they hold on our behalf and to retain it for the period we instruct. The categories of third parties we may share personal information with are as follows:

• Ad Networks
• Affiliate Marketing Programs
• Cloud Computing Services
• Communication & Collaboration Tools
• Data Analytics Services
• Data Storage Service Providers
• Finance & Accounting Tools
• Payment Processors
• Performance Monitoring Tools
• Product Engineering & Design Tools
• Sales & Marketing Tools
• Social Networks
• Testing Tools
• User Account Registration & Authentication Services
• Website Hosting Service Providers

BUSINESS TRANSFERS

We may share or transfer your information in connection with, or during negotiations of, any merger, sale of company assets, financing,or acquisition of all or a portion of our business to another company.

WHEN WE USE GOOGLE MAPS PLATFORM APIs

We may share your information with certain Google Maps Platform APIs (e.g., Google Maps API, Places API).

OTHER USERS

When you share personal information (for example, by posting comments, contributions, or other content to the Services) or otherwise interact with public areas of the app, such personal information may be viewed by all users and may be publicly made available outside the Services in perpetuity. If you interact with other users of our applications and register for our Services through a social network (such as Facebook), your contacts on the social network will see your name, profile photo, and descriptions of your activity. Similarly, other users will be able to view descriptions of your activity,communicate with you within our Services, and view your profile.

BUSINESS PARTNERS

Campaigns, Contests and Gaming Tournament partners. When you participate in campaigns, challenges and competitions sponsored by our partners, we may disclose your personal data to them in accordance with the terms and conditions of the said campaign, challenge or competition.

We may also share aggregated, anonymized data with our Business Partners and advertising clients, such as user segment statistics.

OFFER WALL

Our application(s) may display a third-party hosted “offer wall.”Such an offer wall allows third-party advertisers to offer virtual currency, gifts,or other items to users in return for the acceptance and completion of an advertisement offer. Such an offer wall may appear in our application(s) and be displayed to you based on certain data, such as your geographic area or demographic information. When you click on an offer wall, you will be brought to an external website belonging to other persons and will leave our application(s). A unique identifier, such as your user ID, will be shared with the offer wall provider in order to prevent fraud and properly credit your account with the relevant reward.

LAW AND PUBLIC INTEREST

We may disclose your Personal Data if we believe it is reasonably necessary to comply with law, regulation, legal process, or governmental requests such as court orders, subpoenas, or warrants in the manner allowed by law.

We may also disclose Personal Data when we believe, in good faith, that disclosure is appropriate or reasonably necessary to protect kumu from fraudulent, abusive, or unlawful uses; to investigate and defend ourselves against third-party claims or allegations; to protect the security or integrity of kumu; or to protect the rights, property, or safety of kumu, our users, or others.

AFFILIATES AND CHANGE OF OWNERSHIP

We may also disclose your Personal Data to kumu affiliates (companies controlled by, controlling, or under common control with kumu) and subsidiaries that are either subject to this Privacy Policy or implement standards that are at least as protective as those specified in this Privacy Policy.

Your Personal Data may also be transferred as part of a bankruptcy, merger, acquisition, reorganization, or sale of kumu assets if we are involved in such a transaction, including any evaluation of such a transaction.

HOW DOES KUMU HANDLE YOUR SOCIAL MEDIA LOGINS? +

Our application(s) offer you the ability to register and log in using your third-party social media account details (like your Facebook or Twitter logins). When you choose to do this, we will receive certain profile information about you from your social media provider. The profile information we receive may vary depending on the social media provider concerned, but will often include your name, email address, friends list, and profile picture, as well as other information you choose to make public on such a social media platform.

We will use the information we receive only for the purposes that are described in this privacy notice or that are otherwise made clear to you on the relevant Services. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party social media provider. We recommend that you review their privacy notice to understand how they collect, use, and share your personal information, and how you can set your privacy preferences on their sites and apps.

HOW DOES KUMU OPERATE AND TRANSFER PERSONAL DATA GLOBALLY +

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

kumu will take all steps reasonably necessary to ensure that your data is transferred securely and in accordance with this Privacy Policy, and applicable laws, and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including with respect to the security of your Personal Data.

HOW LONG KUMU STORES YOUR PERSONAL DATA +

kumu will retain your Personal Data only for as long as is necessary for the purposes set out in this Privacy Policy or as required or permitted by applicable laws. We will retain and use your Personal Data to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our contractual agreements and policies.

We will cease to retain your Personal Data, or remove the means by which the data can be associated with you, as soon as it is reasonable to assume that such retention no longer serves the purpose for which the Personal Data was collected, and is no longer necessary for legal or business purposes.

HOW KUMU SECURES YOUR PERSONAL DATA +

To safeguard your Personal Data from unauthorized access, collection, use, disclosure, copying, modification, disposal or similar risks, we have put in place reasonable and appropriate administrative, physical and technical measures.

You should be aware, however, that no method of transmission over the Internet or method of electronic storage is completely secure. Data security incidents and breaches can occur due to a variety of factors that cannot reasonably be prevented; therefore, our safeguards may not always be adequate to prevent all breaches of security.

YOUR PRIVACY RIGHTS AND MANAGING YOUR PERSONAL DATA +

RESIDENTS OF UNITED STATES OF AMERICA

Residents of California, Colorado, Connecticut, and/or Virginia are granted specific rights regarding access to your personal information.

Categories of Personal Information Collected in the Past Twelve (12) Months

Sensitive information may be used, or disclosed to a service provider or contractor,for additional, specified purposes. You have the right to limit the use or disclosure of your sensitive personal information.

We may also collect other personal information outside of these categories through instances where you interact with us in person, online, or by phone or mail in the context of:

• Receiving help through our customer support channels;
• Participation in customer surveys or contests; and
• Facilitation in the delivery of our Services and to respond to your inquiries.

CALIFORNIA RESIDENTS

California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits our users who are California residents to request and obtain from us, once a year and free of charge, information about categories of personal information (if any)we disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with which we shared personal information in the immediately preceding calendar year. If you are a California resident and would like to make such a request, please submit your request in writing to dpo@kumu.ph.

If you are under 18 years of age, reside in California, and have a registered account with Kumu, you have the following rights:

• To request removal of unwanted data that you publicly posted in the app; and
• To request removal of such data,

Send your request to dpo@kumu.ph and include the email address associated with your account and a statement that you reside in California. We will make sure the data is not publicly displayed on the app, but please be aware that the data may not be completely or comprehensively removed from all our systems (e.g., backups, etc.).

CPRA Privacy Notice

This section applies only to California residents.

The California Code of Regulations defines a “resident” as:

1. every individual who is in the State of California for other than a temporary or transitory purpose; and

2. every individual who is domiciled in the State of California who is outside of the State of California for a temporary or transitory purpose All other individuals are defined as “non-residents”

If this definition of “resident” applies to you, we must adhere to certain rights and obligations regarding your personal information as provided by California Privacy Rights Act (CPRA).

YOUR RIGHTS WITH RESPECT TO YOUR PERSONAL DATA

1. Right to request deletion of the data

You can ask for the deletion of your personal information. If you ask us to delete your personal information, we will respect your request and delete your personal information, subject to certain exceptions provided by law, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities. You may send your deletion request to dpo@kumu.ph.

2. Right to be informed

Depending on the circumstances, you have a right to know:

• whether we collect and use your personal information;
• the categories of personal information that we collect;
• the purposes for which the collected personal information is used;
• whether we sell or share personal information to third parties;
• the categories of personal information that we sold, shared, or disclosed for a business purpose;
• the categories of third parties to whom the personal information was sold, shared, or disclosed for a business purpose;
• the business or commercial purpose for collecting, selling, or sharing personal information; and
• the specific pieces of personal information we collected about you.

In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.

3. Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

We will not discriminate against you if you exercise your privacy rights.

4. Right to Limit Use and Disclosure of Sensitive Personal Information

If the business collects any of the following:

• social security information, drivers’ licenses, state ID cards, passport numbers;
• account login information;
• credit card numbers, financial account information, or credentials allowing access to such accounts;
• precise geolocation;
• racial or ethnic origin, religious or philosophical beliefs, union membership;
• the contents of email and text, unless the business is the intended recipient of the communication; and/or
• genetic data, biometric data, and health data data concerning sexual orientation and sex life

you have the right to direct that business to limit its use of your sensitive personal information which is necessary to perform its services to you.

Once a business receives your request, they are no longer allowed to use or disclose your sensitive personal information for any other purpose unless you provide consent for the use or disclosure of sensitive personal information for additional purposes.

Please note that sensitive personal information that is collected or processed without the purpose of inferring characteristics about a consumer is not covered by this right, as well as the publicly available information.

To exercise your right to limit use and disclosure of sensitive personal information, please send your request to dpo@kumu.ph.

5. Verification Process

Upon receiving your request, we will need to verify your identity to determine whether you are the same person whose information is in our system. These verification efforts will require you to provide information so that we can match it with the information you have previously provided to us. We may also use other verification methods as the circumstances dictate.

We will only use personal information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. However, if we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we conclude the verification process.

6. Other privacy rights

• You may object to the processing of your personal information;
• You may request correction of your personal data if it is incorrect or no longer relevant, or ask to restrict the processing of the information;
• You can designate an authorized agent to make a request under the CPRA on your behalf. However, we may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf in accordance with CPRA;
• You may request to opt out from future selling or sharing of your personal information to third parties. Upon receiving an opt-out request, we will act upon the request as soon as feasibly possible, but no later than fifteen (15) days from the date of the request submission.

To exercise these rights, you can contact us by emailing dpo@kumu.ph. If you have a complaint about how we handle your data, we would like to hear from you.

COLORADO RESIDENTS

This section applies only to Colorado residents. Under the Colorado Privacy Act (CPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

To submit a request to exercise these rights described above, please email dpo@kumu.ph.

If we decline to take action regarding your request and you wish to appeal your decision, please email us at dpo@kumu.ph with Subject “Appeal”.

We will inform you, in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions within forty-five (45) days from receipt of your appeal.

CONNECTICUT RESIDENTS

This section applies only to Connecticut residents. Under the Connecticut DataPrivacy Act (CTDPA), you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that product legal or similarly significant effects (“profiling”)

To submit a request to exercise these rights described above, please email dpo@kumu.ph.

If we decline to take action regarding your request and you wish to appeal your decision, please email us at dpo@kumu.ph with Subject “Appeal”.

We will inform you, in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions within forty-five (45) days from receipt of your appeal.

VIRGINIA RESIDENTS

Under the Virginia Consumer Data Protection Act (VCDPA):

“Consumer” means a natural person who is a resident of the Commonwealth acting only in an individual or household context. It does not include a natural person acting in a commercial or employment context.

“Personal data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. “Personal data” does not include de-identified data or publicly available information.

“Sale of personal data ” means the exchange of personal data for monetary consideration. If this definition “consumer” applies to you, we must adhere to certain rights andobligations regarding your personal data.

Your rights with respect to your personal data

• Right to be informed whether or not we are processing your personal data
• Right to access your personal data
• Right to correct inaccuracies in your personal data
• Right to request deletion of your personal data
• Right to obtain a copy of the personal data you previously shared with us
• Right to opt out of the processing of your personal data if it is used for targeted advertising, the sale of personal data, or profiling in furtherance of decisions that produce legal or similarly significant effects (“profiling”)

Exercise your rights provided under the Virginia VCDPA

You may contact us by email at dpo@kumu.ph.

If you are using an authorized agent to exercise your rights, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.

Verification process

We may request that you provide additional information reasonably necessary to verify you and your consumer’s request. If you submit the request through an authorized agent, we may need to collect additional information to verify your identity before processing your request.

Upon receiving your request, we will respond without undue delay, but in all cases,within forty-five (45) days of receipt. The response period may be extended once by forty-five (45) additional days when reasonably necessary. We will inform you of any such extension within the initial 45-day response period, together with the reason for the extension.

Right to appeal

If we decline to take action regarding your request, we will inform you of our decision and reasoning behind it. If you wish to appeal our decision, please email us at dpo@kumu.ph. Within sixty (60) days of receipt of an appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decisions. If your appeal is denied, you may contact the Attorney General to submit a complaint.

PRIVACY RIGHTS +

We generally rely on Personal Data provided by you (or your authorized representative). In order to ensure that your Personal Data is current, complete and accurate, please update us if there are changes to your Personal Data.

Subject to certain restrictions and limitations, you have certain rights in respect of your Personal Data. In particular, you have the following rights:

• Right to access – to receive a copy of your Personal Data. We will have to adequately verify your identity before any action can be taken;
• Right to rectification – to request for amendments to be made to your Personal Data where this is inaccurate or incorrect;
• Right to restriction – to ask that we restrict or suppress the processing of your Personal Data which means that whilst we are permitted to store the Personal Data we cannot otherwise process it;
• Right to erasure – to request for the deletion of your Personal Data that we hold. However, we may not always be able to delete your Personal Data for legal and regulatory reasons;
• Right to object – to object to the processing of your Personal Data which we carry out in reliance on our legitimate interests. In such instances, we will investigate to see if there is compelling reason for processing to continue. You cannot object to the processing which is a legal obligation or where we must process your Personal Data to satisfy a contract to which you are a party. Also, you can object to marketing communications at any time;
• Right to withdraw you consent – to withdraw your consent to the processing of your Personal Data at any time (where kumu is processing your personal information based on your consent). Please note that withdrawing your consent may prevent us from further providing all or part of our Services to you but does not affect the lawfulness of our processing of your Personal Data based on such consent before the withdrawal;
• Right to data portability – to receive certain Personal Data that you have provided to us, in a machine-readable form and/or that we transmit it to a third party with your express authorisation; and
• Right to lodge a complaint – to complain to the relevant supervisory authority if your privacy rights are violated, or if you have suffered as a result of unlawful processing of your Personal Data.

We may ask you for identifying information and attempt to match it to information that we maintain about you. If we can’t verify your identity or authority to make the request, and confirm the Personal Data belongs to you, we won’t be able to complete your request. We will notify you to inform you of this. You do not need to create an account with us to make a verifiable request. Personal data submitted in a verifiable request will only be used to confirm the requestor’s identity or permission to make the request.

If you would like to exercise your rights, please contact the Data Protection Officer using the contact details below.

To the extent permitted under applicable data protection laws, we may charge a reasonable fee for an access request to cover our administrative costs of providing the information in certain situations. If so, we will inform you of the fee before we proceed with your request.

We will respond to your request as soon as reasonably possible and within thirty (30) calendar days. Should we not be able to respond to your request within thirty (30) days after receiving your request and where we are permitted to do so under applicable data protection laws, we will inform you in writing within thirty (30) days of the time by which we will be able to respond to your request.

ADDITIONAL INFORMATION OR ASSISTANCE +

To protect your privacy and implement security, we will take reasonable steps to verify your identity before granting your request. We reserve the right to charge an appropriate fee for complying with your request where allowed by applicable law. There may be situations where we cannot grant your request especially if it jeopardizes the privacy of others, is frivolous or vexatious, or would be extremely impractical.

CHILDREN’S PRIVACY +

kumu recognizes and values the importance of protecting the privacy of children, which we define as anyone under the age of thirteen. Our Services are not intended for or directed to children under the age of thirteen (13), and anyone under the age of thirteen are not permitted to use kumu. If we discover that we are processing data for such users (under the age of 13), we shall take reasonable steps to guarantee that their records are erased and data processing is ceased. Please inform us if you suspect we have Personal Data about or acquired from a child under the age of 13.

You must also be of legal age in your country to consent to the processing of your Personal Data (in some countries we may allow your parent or guardian to do so on your behalf).

ACCESSIBILITY +

We are committed to ensuring that our communications are accessible to people with disabilities. To make accessibility-related requests or report barriers, please contact us at dpo@kumu.ph.

CHANGES +

We may revise this Privacy Policy from time to time without any prior notice. You are advised to review this Privacy Policy periodically for any changes. You may determine if any such revision has taken place by referring to the date on which this Privacy Policy was last updated.

If we make material changes to the Privacy Policy, we will let you know via email and/or a prominent notice on our Service, prior to the change becoming effective and update the date at the top of this Privacy Policy. Your continued use of our services constitutes your acknowledgement and acceptance of such changes.

CONTACT +

You may contact our Data Protection Officer if you have any inquiries or feedback on our Personal Data protection policies and procedures, or if you wish to make any request, in the following manner:

Data Protection Officer

dpo@kumu.ph
Unit 702 – 703 Liberty Plaza Building, 102 HV Dela Costa St. cor. Valero St.
Salcedo Village Makati City.

MORE RESOURCES

• Terms of Use
• Old Terms of Use
• Old Privacy Policy v1.0
• Cookie Policy
• Old Privacy Policy v2.0
• Kumunity Guidelines
• Responding to legal requests
• Recruitment Privacy Policy