Kurdigram Privacy Policy

1. Introduction

This Privacy Policy sets out how we, Kurdigram Messenger Inc. ("Kurdigram"), use and protect your personal data that you provide to us, or that is otherwise obtained or generated by us, in connection with your use of our cloud-based messaging services (the "Services"). For the purposes of this Privacy Policy, 'we', 'us' and 'our' refers to Kurdigram, and 'you' refers to you, the user of the Services.

1.1 Privacy Principles

Kurdigram has two fundamental principles when it comes to collecting and processing private data:

1.2. Terms of Service

This Privacy Policy forms part of our Terms of Service, which describes the terms under which you use our Services and which are available at https://kurdigram.com/. This Privacy Policy should therefore be read in conjunction with those terms.

1.3. Table of Contents

This Privacy Policy explains the following:

1.4. EEA Representative

If you live in a country in the European Economic Area (EEA), the Services are provided by Kurdigram, which for the purposes of applicable data protection legislation is the data controller responsible for your personal data when you use our Services. However, as Kurdigram is located outside the EEA, we have designated one of our EEA-based group companies, Kurdigram UK Holdings Ltd (71-75 Shelton Street, Covent Garden, London, England, WC2H 9JQ), as a representative to whom you may direct any issues you have relating to our processing of your personal data.

2. Legal Ground for Processing Your Personal Data

We process your personal data on the ground that such processing is necessary to further our legitimate interests (including: (1) providing effective and innovative Services to our users; and (2) to detect, prevent or otherwise address fraud or security issues in respect of our provision of Services), unless those interests are overridden by your interest or fundamental rights and freedoms that require protections of personal data.

3. What Personal Data We Use

3.1. Basic Account Data

Kurdigram is a communication service. You provide your mobile number and basic account data (which may include profile name, profile picture and about information) to create a Kurdigram account.

To make it easier for your contacts and other people to reach you and recognize who you are, the screen name you choose, your profile pictures, and your username (should you choose to set one) on Kurdigram are always public. We don't want to know your real name, gender, age or what you like.

We do not require your screen name to be your real name. Note that users who have you in their contacts will see you by the name they saved and not by your screen name. This way your mother can have the public name 'Johnny Depp' while appearing as 'Mom' to you and as 'Boss' to her underlings at work (or the other way around, depending on how these relationships are structured).

3.2. Your E-mail Address

When you enable 2-step-verification for your account or store documents using the Kurdigram Passport feature, you can opt to set up a password recovery email. This address will only be used to send you a password recovery code if you forget it. That's right: no marketing or "we miss you" bullshit.

3.3. Your Messages

3.3.1. Cloud Chats

Kurdigram is a cloud service. We store messages, photos, videos and documents from your cloud chats on our servers so that you can access your data from any of your devices anytime without having to rely on third-party backups. All data is stored heavily encrypted and the encryption keys in each case are stored in several other data centers in different jurisdictions. This way local engineers or physical intruders cannot get access to user data.

3.3.2. Secret Chats

Secret chats use end-to-end encryption. This means that all data is encrypted with a key that only you and the recipient know. There is no way for us or anybody else without direct access to your device to learn what content is being sent in those messages. We do not store your secret chats on our servers. We also do not keep any logs for messages in secret chats, so after a short period of time we no longer know who or when you messaged via secret chats. For the same reasons secret chats are not available in the cloud — you can only access those messages from the device they were sent to or from.

3.3.3. Media in Secret Chats

When you send photos, videos or files via secret chats, before being uploaded, each item is encrypted with a separate key, not known to the server. This key and the file's location are then encrypted again, this time with the secret chat's key — and sent to your recipient. They can then download and decipher the file. This means that the file is technically on one of Kurdigram's servers, but it looks like a piece of random indecipherable garbage to everyone except for you and the recipient. We don't know what this random data stands for and we have no idea which particular chat it belongs to. We periodically purge this random data from our servers to save disk space.

3.3.4. Public Chats

In addition to private messages, Kurdigram also supports public channels and public groups. All public chats are cloud chats (see section 3.3.1 above). Like everything on Kurdigram, the data you post in public communities is encrypted, both in storage and in transit — but everything you post in public will be accessible to everyone.

3.3.5. Phone Number and Contacts

Kurdigram uses phone numbers as unique identifiers so that it is easy for you to switch from SMS and other messaging apps and retain your social graph. We ask your permission before syncing your contacts.

We store your up-to-date contacts in order to notify you as soon as one of your contacts signs up for Kurdigram and to properly display names in notifications. We only need the number and name (first and last) for this to work and store no other data about your contacts.

Our automatic algorithms can also use anonymized sets of phone numbers to calculate the average number of potential contacts an unregistered phone number may have on Kurdigram. When you open the 'Invite friends' interface, we display the resulting statistics next to your contacts to give you an idea of who could benefit most from joining Kurdigram.

You can always stop syncing contacts or delete them from our servers in Settings > Privacy & Security > Data Settings.

If you are using Android, Kurdigram will ask you for permission to access your phone call logs (READ_CALL_LOG). If you grant this permission, Kurdigram will be able verify your account by transmitting a phone call instead of asking you to enter a code. Kurdigram uses this permission only to confirm receipt of the confirmation call by verifying the number in the call log.

3.3.6. Cookies

The only cookies we use are those to operate and provide our Services on the web. We do not use cookies for profiling or advertising. The cookies we use are small text files that allow us to provide and customize our Services, and in doing so provide you with an enhanced user experience. Your browser should allow you to control these cookies, including whether or not to accept them and how to remove them. You may choose to block cookies with your web browser, however, if you do disable these cookies you will not be able to log in to Kurdigram Web.

4. Keeping Your Personal Data Safe

4.1. Storing Data

If you signed up for Kurdigram from the UK or the EEA, your data is stored in data centers in the Netherlands. These are third-party provided data centers in which Kurdigram rents a designated space. However, the servers and networks that sit inside these data centers and on which your personal data is stored are owned by Kurdigram. As such, we do not share your personal data with such data centers. All data is stored heavily encrypted so that local Kurdigram engineers or physical intruders cannot get access.

4.2. End-to-End Encrypted Data

Your messages, media and files from secret chats (see section 3.3.2 above), as well as the contents of your calls and the data you store in your Kurdigram Passport are processed only on your device and on the device of your recipient. Before this data reaches our servers, it is encrypted with a key known only to you and the recipient. While Kurdigram servers will handle this end-to-end encrypted data to deliver it to the recipient – or store it in the case of Kurdigram Passport data, we have no ways of deciphering the actual information. In this case, we neither store nor process your personal data, rather we store and process random sequences of symbols that have no meaning without the keys which we don't have.

4.3. Retention

Unless stated otherwise in this Privacy Policy, the personal data that you provide us will only be stored for as long as it is necessary for us to fulfill our obligations in respect of the provision of the Services.

5. Processing Your Personal Data

5.1. Our Services

Kurdigram is a cloud service. We will process your data to deliver your cloud chat history, including messages, media and files, to any devices of your choosing without a need for you to use third-party backups or cloud storage.

5.2. Safety and Security

Kurdigram supports massive communities which we have to police against abuse and Terms of Service violations. Kurdigram also has more than 400 millions users which makes it a lucrative target for spammers. To improve the security of your account, as well as to prevent spam abuse, and other violations of our Terms of Service, we may collect metadata such as your IP address, devices and Kurdigram apps you've used, history of username changes, etc. If collected, this metadata can be kept for 12 months maximum.

5.3. Spam and Abuse

To prevent phishing, spam and other kinds of abuse and violations of Kurdigram's Terms of Service, our moderators may check messages that were reported to them by their recipients. If a spam report on a message you sent is confirmed by our moderators, your account may be limited from contacting strangers – temporarily or permanently. You can send an appeal using Spambot. In case of more serious violations, your account may be banned. We may also use automated algorithms to analyze messages in cloud chats to stop spam and phishing.

5.4. Cross-Device Functionality

We may also store some aggregated metadata to create Kurdigram features (see section 5.5 below) that work across all your devices.

5.5. Advanced features

We may use some aggregated data about how you use Kurdigram to build useful features. For example, when you open the Search menu, Kurdigram displays the people you are more likely to message in a box at the top of the screen. To do this, we calculate a rating that shows which people you message frequently. A similar rating is calculated for inline bots so that the app can suggest the bots you are most likely to use in the attachment menu (or when you start a new message with "@"). To turn this feature off and delete the relevant data, go to Settings > Privacy & Security > Data Settings and disable "Suggest Frequent Contacts".

5.6. No Ads

Unlike other services, we don't use your data for ad targeting or other commercial purposes. Kurdigram only stores the information it needs to function as a secure and feature-rich cloud service.

6. Bot Messages

6.1. Ecosystem

Kurdigram has an API that allows third-party developers to create bots. Bots are apps that look like special Kurdigram users: you can talk to them from your chat list, add them to groups or use a special "inline" interface to access their features. By performing any of these actions, you will be sending some of your data to the respective third-party bot developers.

6.2. How Bots Can Receive Data

You can send data to bot developers when you interact with their bots in one of these ways:

6.3. What Data Bots Receive

In any of the above cases, the developers of an automated user (bot) can get your public account data (see section 3.1 above): your screen name, username and profile picture(s).

Bots can also receive the following data when you interact with them.

6.4. Bots Are Not Maintained by Kurdigram

Other than our own bots, no other bots or third-party bot developers are affiliated with Kurdigram. They are completely independent from us. They should ask you for your permission before they access your data or you make it available to them.

7. Third Party Payment Services

7.1. Payment Information

The Payment Platform for Bots is available to users as of Kurdigram 4.0. Kurdigram does not process payments from users and instead relies on different payment providers around the world. It is the payment providers that handle and store your credit card details. Neither Kurdigram nor the merchants on the platform (bot developers) have access to this information. Although we work with payment providers they are completely independent from Kurdigram. Please study their relevant privacy policies before making your data available to them.

7.2. Credit Card Information

When making a purchase, you enter your credit card details into a form supplied by the payment provider that will be processing the payment, and this information goes directly to the payment provider's server. Your credit card information never reaches Kurdigram's servers. We do not access and do not store your credit card information. When you save your credit card info, it is saved on the respective payment provider's servers and the payment provider gives Kurdigram a token that you can reuse for future payments. It is not possible to reconstruct your credit card info from the token.

7.3 Shipping Information

When you enter shipping information in the process of placing an order, we send it directly to the merchant bot developer. We can store your shipping information for you if you choose to save it for future purchases. We will delete this information immediately if you ask us to.

7.4. Clearing Payment Information

You can clear all payment information associated with your account at any time by going to Kurdigram Settings > Privacy & Security > Data Settings and selecting 'Clear Payment & Shipping Info'. If you choose to remove your payment information, we will delete your stored shipping info and payment tokens from all providers and ask the payment providers to remove your credit card information that they store.

7.5. Payment Disputes

Due to the fact that Kurdigram doesn't store any credit card details or transaction information, it is impossible for us to handle complaints or cashbacks – any disputed payments are the responsibility of the bot developers, payment providers, and banks that participated in the exchange.

8. Who Your Personal Data May Be Shared With

8.1. Other Kurdigram Users

Other users of our Services with whom you choose to communicate with and share certain information, who may be located outside the EEA. Note that by entering into the Terms of Service and choosing to communicate with such other users of Kurdigram, you are instructing us to transfer your personal data, on your behalf, to those users in accordance with this Privacy Policy. We employ all appropriate technical and organizational measures (including encryption of your personal data) to ensure a level of security for your personal data that is appropriate to the risk.

8.2. Kurdigram's Group Companies

We may share your personal data with: (1) our parent company, Kurdigram Group Inc, located in the British Virgin Islands; and (2) Kurdigram FZ-LLC, a group member located in Dubai, to help provide, improve and support our Services. We will implement appropriate safeguards to protect the security and integrity of that personal data. This will take the form of standard contract clauses approved by the European Commission in an agreement between us and our relevant group companies. If you would like more information regarding these clauses, please contact us using the details in section 12 below.

8.3. Law Enforcement Authorities

If Kurdigram receives a court order that confirms you're a terror suspect, we may disclose your IP address and phone number to the relevant authorities. So far, this has never happened. When it does, we will include it in a semiannual transparency report published at: https://t.me/transparency.

9. Your Rights Regarding the Personal Data You Provide to Us

9.1. Your Rights

Under applicable data protection legislation, in certain circumstances, you have rights concerning your personal data. You have a right to: (1) request a copy of all your personal data that we store and to transmit that copy to another data controller; (2) delete (see section 10 below) or amend your personal data; (3) restrict, or object to, the processing of your personal data; (4) correct any inaccurate or incomplete personal data we hold on you; and (5) lodge a complaint with national data protection authorities regarding our processing of your personal data.

9.2. Exercising Your Rights

If you wish to exercise any of these rights, kindly contact us using the details in section 12 below.

9.3. Data Settings

You can control how your data is used (e.g., delete synced contacts) in Settings > Privacy & Security > Data Settings (using one of our mobile apps).

Sadly, if you're generally not OK with Kurdigram's modest requirements, it won't be possible for us to provide you with our Services. You can delete your Kurdigram account by proceeding to the deactivation page.

10. Deleting data

10.1. Accounts

If you would like to delete your account, you can do this on the deactivation page. Deleting your account removes all messages, media, contacts and every other piece of data you store in the Kurdigram cloud. This action must be confirmed via your Kurdigram account and cannot be undone.

10.2. Messages

10.3. Self-Destructing Messages

Messages in Secret Chats can be ordered to self-destruct. As soon as such a message is read (2 checks appear), the countdown starts. When the timer expires, both devices participating in a secret chat are instructed to delete the message (photo, video, etc.). Media with short timers (less than a minute) are shown with blurred previews. The timer is triggered when they are viewed.

10.4. Account Self-Destruction

By default, if you stop using Kurdigram and do not come online for at least 6 months, your account will be deleted along with all messages, media, contacts and every other piece of data you store in the Kurdigram cloud. You can go to Settings to change the exact period after which your inactive account will self-destruct.

11. Changes to this Privacy Policy

We will review and may update this Privacy Policy from time to time. Any changes to this Privacy Policy will become effective when we post the revised Privacy Policy on this page www.kurdigram.com/privacy. Please check our website frequently to see any updates or changes to our Privacy Policy, a summary of which we will set out below.

March 25, 2019

Important changes made to this Privacy Policy will be notified to you via Kurdigram.