27th July 2020

This privacy policy may not be applicable to you. Its applicability is confined to such persons who are prompted (on their individual devices) to read this policy, or to such persons whose personal information is otherwise collected by us.

Your Privacy Is Important to Us
This privacy policy (hereinafter, “Privacy Policy”) sets out basic principles adopted by KeyPoint Technologies UK Limited and our subsidiaries (collectively “we”, “us”, or “our”) for collecting, using, disclosing and protecting personal information consistent with Indian information security laws and associated regulations. This privacy policy covers information collected Xploree AI Keyboard mobile application (hereinafter, “Xploree”).

Xploree 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. Xploree 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. Xploree has been developed by KeyPoint Technologies (UK) Limited.

Scope and Content
You accept this Privacy Policy when you sign up for, create login credentials via a third-party service, access, or use Xploree, its services, content, features, technologies or functions (collectively, “Services”). We may update this Privacy Policy to reflect changes to our information practices. If we make any material changes, we will notify you by email (sent to the e-mail address specified in your account) or by means of a notice in this website prior to the change becoming effective. We encourage you to periodically review this page for the latest information on our privacy practices.

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 Xploree and its Capabilities
Xploree 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. Xploree can also be supplied to end-users directly as a third party Android/iOS application on Play store/Apple store. With Xploree, users can access industry specific dictionaries from fields like Medicine, Telecom, IT, Finance, Law, Business etc.

For more information, click here.

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 Xploree. We also typically avoid storing or collecting the login credentials for your online profiles. However, if you choose to create login credentials, we may use your personal information (email address, profile picture, user name etc.) associated with such login credentials to help us personalize and improve your experience by enabling you to enjoy our personalized services across multiple devices. In any case, we do not send any sensitive personal text you type to our servers.

Xploree allows you to create your own keyboard theme using your photos present on the device library/gallery. To do so, we may request access to your photos. However, we don’t send/aggregate any of your photos from your device to our server. Such information is stored only on your device.

When you use the "Pixture Effects" feature of Xploree to create cartoons or stamps, the captured images, or the images you use to create cartoons or stamps, will be uploaded to our servers so that it gives an appropriate result. This information will be erased from all our servers within two hours of time. The images information will be uploaded to our servers only when you give us a clear consent. Also, you can disable the permission by going to the app settings under the device/phone settings. In that case, till we get the clear consent from you, we do not collect your image information.

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.

To ensure a more seamless experience with our app, we collect server logs to access information like IP address, app crashes, and other system activities. We use such information to diagnose problems with our server, to prevent phishing/spamming attacks. For you to derive more meaningful experiences, we may relate the above mentioned with personal information like email address. However, if you wish to opt out, we will disassociate your IP address with personal information and we will thereafter delete your personal information or de-identify it so that it is anonymous and not attributed to your identity.

Also, we may collect the information about software installed on your device to understand your preferences and to improve the recommendations we give you on product, content etc.

If you request information about our Xploree SDK, we will also collect information about your mobile application, such as application name and platforms that it runs on.

We use a unique identifier or we associate the unique identifier with Android/iOS 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 setting’s menu.

If you have questions about how to disable your device’s location services, we recommend you contact your mobile service carrier or the manufacturer of your particular device or try turning it off at the device level. To opt-out of being served advertisements or having your shopping habits tracked, please contact us at privacy@keypoint-tech.com.

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), 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, Xploree 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.

Xploree will not collect, use or disclose your personal information without your consent, whether explicit or otherwise. By using our Services, you are consenting to Xploree 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 Xploree 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 Xploree using the information already collected by it through your previous identifier, so that you may be provided with personalized services on your fresh identifier.

Information that we collect when you use Xploree Pay Bills
When you use the Xploree Pay Bills, we will collect your mobile number, location via IP address, bill amount, recharge amount, bill account number, bank ID and transaction ID. At any point, we never collect your bank account details or debit/credit card details.

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. Xploree will not collect or store your personal information without your consent, whether explicit or otherwise.

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 prediction technology which suggests the next word you are trying to type and to personalize your keyboard typing experience, to provide additional information about our SDK, to send you marketing emails, newsletters or respond to your request. 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 newsletter and marketing communications from us at any time. In order to do so, please send us an email at privacy@keypoint-tech.com.

Location information
To enrich your discovery experience with more locally relevant and location-based content, we collect precise location data, after you permit our application to access location services. We may collect the precise location of your device when the application is running foreground. We may use your IP address to derive your approximate location. You may opt-out from dispersing precise location information at any time by disabling the GPS or other location-tracking functions on your device.

The location information that we aggregate from the user is not solely for ads/discoveries. We use the location information to provide content like weather information at your location. Apart from that, the location information that we collect is used to provide information like news, movies, nearby restaurants, etc.

Your location can be determined by GPS, IP Address and/or Information about things near your device, such as Wi-Fi access points, cell towers, and Bluetooth-enabled devices

User Access and Choice
If your personal information changes, or if you no longer desire our service, you may correct, update, or delete it by emailing us at privacy@keypoint-tech.com. If you wish to request access, or deletion of your personal information please contact us at the email address listed above. We will respond to your request within a reasonable timeframe.

We will retain your information for as long as your account is active or as needed to provide you services. We will retain and use your information as necessary to comply with our legal obligations, resolve disputes, and enforce our agreements.

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 Xploree. 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 and will not sell your personal information with anyone outside of our 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 analyse the effectiveness of our advertising campaigns and promotions and (b) as required by law enforcement, such as to comply with a subpoena, bankruptcy proceedings, or similar legal process when we believe in good faith that disclosure is necessary to protect our rights, protect your safety or the safety of others, investigate fraud, or respond to a government request.

If we are involved in a merger, acquisition, or sale of all or a portion of our assets, you will be notified via email and/or prominent notice on our website, of any change in ownership, uses of your personal information, and choices you may have regarding your personal information. We may also disclose your personal information to any other third party with your prior consent.

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 privacy@keypoint-tech.com.

We may also share your personal information with companies, organizations or individuals outside of our 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.

Tracking Technologies
We use a variety of tools like Apxor analytics, Google analytics that use analytic servers to analyse trends, administer the mobile application, tracking users’s behaviourwith the application, and to gather demographic information about our user base as a whole. We may receive reports based on the use of these technologies by these companies on an individual as well as aggregated basis. We use analytic servers to remember users’ settings and for authentication.

We partner with a third party to either display advertising on our mobile application or to manage our advertising on mobile applications. Our third party partner may use technologies such as analytic servers, cookies to gather information about your activities on our mobile application in order to provide you advertising based upon your browsing activities and interests. If you wish to not have this information used for the purpose of serving you interest-based ads, you may opt-out by clicking here. Please note this does not opt you out of being served ads. You will continue to receive generic ads.

Mobile Analytics
We use a variety of tools like Apxor analytics, Google analytics to allow us to better understand the functionality of our Mobile Software on your phone. This software may record information such as how often you use the application, the events that occur within the application, aggregated usage, performance data, and where the application was downloaded from, software installed on your device to understand your preferences and to improve the recommendations we give you on product, content etc. We do not link the information we store within the analytics software to any personal information you submit within the mobile application.

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 privacy@keypoint-tech.com. We have a designated Data Protection Officer (DPO) to ensure that the provisions of the regulation are applied and address your queries 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 misuse 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 Hyderabad, India and you expressly submit yourself to the exclusive jurisdiction of the Indian laws and the Courts in Hyderabad, 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.