Privacy Policies

Kofuku Social is a user-centric, category-led, anonymous social media platform designed specifically to facilitate structured engagement and promote health and wellness conversation/discussions. The primary purpose of Kofuku Social is to provide a psychologically safe, judgment-free digital environment where users can ask questions, share personal experiences, and participate in community-driven interactions through elements such as polls and quizzes related to matters of personal and public health.

We, at Kofuku Social, understand how important privacy is to our users and are fully committed to protecting the privacy of all those who access our platform.  This Privacy Policy explains what personal data we collect, how and why we use it, when we may disclose it, how we protect it, how long we retain it, and the rights and choices available to users. This Privacy Policy applies to the Kofuku Social mobile application, website, and related services (hereinafter collectively referred to as ‘Platform’). Kofuku processes personal data in accordance with applicable laws, including the Digital Personal Data Protection Act, 2023 (“DPDP Act”), the Digital Personal Data Protection Rules, 2025 (“DPDP Rules”), to the extent applicable and in force and other applicable laws and regulations.  Until the relevant provisions of the DPDP Act come into force (most of them on 13 May 2027), Kofuku also complies with the Information Technology Act, 2000 and the Information Technology (Reasonable Security Practices and Procedures and Sensitive Personal Data or Information) Rules, 2011 (the "SPDI Rules").

The Platform is operated by Kofuku Technologies Private Limited, a company incorporated in India with its registered office at 1st Floor, FL-1B, 10E, Ho Chi Minh Sarani, Russel Street, Kolkata, West Bengal, 700071 ("Kofuku", "we", "us"). Kofuku is the Data Fiduciary for the personal data described in this Privacy Policy. You may access this Privacy Policy in English or in any language listed in the Eighth Schedule to the Constitution of India, as required by Section 5(3) of the DPDP Act.

This Privacy Policy explains how Kofuku collects, uses, stores, shares,** and protects personal data. Where processing is based on consent, Kofuku will obtain consent through an appropriate mechanism in accordance with applicable law. Consent may be withdrawn in accordance with this Privacy Policy and applicable law.  Consent will be requested through a clear affirmative action, separately for each purpose that requires it, and will not be bundled with acceptance of the Terms of Use. Some processing may be carried out without consent where the DPDP Act permits it (Section 7), for example, to comply with a law or court order, or to respond to a medical emergency or a threat to someone's life or safety.

APPLICABILITY:

This Privacy Policy applies to all users who access or use the Kofuku Social Platform, including registered and anonymous users, moderators and expert contributors.

DATA WE COLLECT:

We collect the following categories of limited personal data to enable your participation, personalisation and safety while using the platform:

Personal Data

  • Email address, phone number(for account creation, verification, or support, gender, age (demographic Information), which is a mandatory section. Only the information needed to create and secure your account is mandatory. Your email address and phone number are never shown publicly. Your age is needed to determine whether you are under 18, in which case parental consent is required (see "Children's Data" below). 
  • Third-Party Authentication Data: Basic profile information (such as name, email address, and unique user identifier) shared by Google, Facebook, or Apple when you authenticate or sign up using your respective accounts. We receive only the information you authorise the provider to share, and we use it only to create and sign in to your account. It is not displayed on your profile or linked publicly to your posts. Your use of these sign-in services is also governed by the provider's own privacy policy.

Sensitive Personal Data 

  • Health-related information disclosed in posts, discussions, or polls (e.g., mental health, fitness, parenting, lifestyle)  You decide whether to share such information. Because health information is sensitive, we process it only with your consent and with additional safeguards, and we never use it for advertising.
  • We seek explicit consent from all registered users of the Kofuku Social Platform that they are of legal age (18+) whenever a user seeks to share sensitive data potentially; i.e., when they explore or post in the Hush Talk, She Reads Category, Kofuku Social will take explicit consent from the user that they are of legal age (18+) to view or create content. This is a confirmation of your age, not consent to the processing of your data. Kofuku may use additional age-verification measures where the law requires.

Technical Data

  • Device identifiers, IP address, browser type, OS
  • App usage statistics, crash logs, and cookies in accordance with our cookie policy as set out below. We collect and use technical information primarily to operate, secure and improve the Platform, including for authentication, fraud and abuse prevention, troubleshooting, analytics, performance monitoring, security and incident investigation.
  • Kofuku Social stores images and other media uploaded by users for the purposes of providing the relevant Platform functionality. Access to such content is restricted through appropriate technical and organisational controls. Kofuku does not use any user-uploaded content, including health-related images, for advertising or marketing purposes.
  • Kofuku may preserve or disclose such content where required by applicable law, pursuant to a valid legal process, or where reasonably necessary to protect users, investigate serious misuse or maintain Platform security. 

Communications & Preferences

  • Feedback, in-app queries, or correspondence with the Grievance Officer
  • Preferences and settings (notifications, content filters)

AUTOMATED TOOLS AND AI FEATURES:

Kofuku uses automated tools, including artificial intelligence, to moderate content, detect abuse and child sexual exploitation. Information you submit to an AI feature may be processed by our technology providers, acting only on our instructions. AI-generated responses are labelled as AI-generated, are general information only and are not medical advice.

HOW WE USE YOUR INFORMATION?

We use collected data to:

  1. Operate, maintain and improve the Kofuku Social Platform

  2. Personalise content, make usage recommendations to the individual user and improve overall user experience.  This personalisation relates to Platform content and usage recommendations only; it does not apply to advertisements.  Personalisation that uses health-related information is carried out only with your consent.

  3. Communicate with users

  4. Respond to user queries, complaints or legal requests

  5. Conduct internal analytics and performance assessments

  6. Send updates, newsletters or promotional content (only with consent)

  7. To comply with applicable legal, regulatory and law-enforcement requirements as per relevant industry standards and our policies, including this Privacy Policy and applicable Terms of Use for a service.

  8. To prevent fraud, abuse, harassment, manipulation and misuse of the Platform.

  9. To moderate content and maintain user safety. 

  10. To detect, investigate and respond to security incidents. 

  11. To verify age and, where required, to obtain verifiable consent from a parent or lawful guardian.

Kofuku does not sell or monetise users’ health-related information to third parties. 

User-generated content, user intent data, health disclosures, interactions and browsing history are not used for advertising or promotional purposes. If advertisements are displayed, they are contextual to the non-sensitive Content Category being viewed, are never personalised, and are not displayed in sensitive Content Categories. Kofuku does not share personal data with advertisers, and advertising partners are not permitted to use cookies, pixels or SDKs on the Platform to profile users.

ANONYMITY AND USER IDENTITY

Anonymity is central to Kofuku Social. You may create and post content without disclosing your identity. Please note, however, your identity may be revealed only under these circumstances:

  1. When ordered by a Court or Government Authority, , including lawful requests under the Information Technology Act, 2000, the IT (Intermediary Guidelines and Digital Media Ethics Code) Rules, 2021 (the "IT Rules") and the Bharatiya Nagarik Suraksha Sanhita, 2023

  2. For investigation of criminal offences, on a lawful request from a law-enforcement agency

  3. Where necessary to respond to a medical emergency or a threat to the life or safety of any person, or to report child sexual abuse as required by law.

Your identity will never be disclosed to other users. Where disclosure is required, Kofuku will share only the information needed for that purpose and will keep a record of the disclosure.

DATA SHARING AND DISCLOSURE

We may share your personal data with:

  1. Third-party vendors who assist in our operations, subject to data protection agreements. - These include cloud hosting, analytics, customer support, communication and security providers, who process personal data only on our instructions under a valid contract as required by Section 8(2) of the DPDP Act.
  1. Our subsidiaries and affiliates for consistent service delivery. Data is shared only for the purposes set out in this Privacy Policy and with equivalent safeguards.
  1. When required by law, including requests under applicable laws. This includes courts, law-enforcement agencies, regulators and authorised Government agencies (for example, under Section 69 of the IT Act, the IT Rules or the POCSO Act).

  2. A successor entity in the event of a merger, acquisition or restructuring, which must continue to protect your data in line with this Privacy Policy.

Users retain ownership of their content. Any license granted to Kofuku over user-generated content is limited to what is necessary to operate and provide the Platform. That license is non-transferable and non-sublicensable and does not authorise advertising, marketing or promotional reuse of the content. Kofuku may keep content after you delete it where the law requires, for example for 180 days for investigation purposes under the IT Rules. 

Where vendors, subsidiaries or affiliates need access to user-generated content to provide the Platform, they may process it only on Kofuku's instructions for that service purpose, subject to the applicable data protection agreements. This access does not grant them independent rights in, or a sublicense to, the content.

DATA SECURITY

We employ industry-standard safeguards to protect your data:

  • Encryption: AES-256 encryption for stored data, TLS for data in transit.
  • Access Controls: Role-based access for moderators and staff.
  • Pseudonymisation: Health posts and community data are stored separately from account identifiers such as your email address and phone number. 
  • Regular Audits: Periodic vulnerability assessments and compliance reviews . Kofuku reports cyber-security incidents to CERT-In within six hours, as required by the CERT-In Directions of 28 April 2022.

We implement technical and organisational measures to protect your personal data against unauthorised access or disclosure in compliance with applicable laws. To protect your privacy, you should not provide Kofuku Social with any information that is not specifically requested or that you do not wish to share.

CROSS-BORDER DATA TRANSFERS:

Kofuku may use service providers and technology infrastructure located outside India. Accordingly, personal data may be processed or stored outside India. Where personal data is transferred, processed, or stored outside India, Kofuku will do so in accordance with applicable Indian law and any restrictions, requirements, or directions applicable to such processing or transfer.  Personal data will not be transferred to any country or territory that the Central Government has restricted under Section 16 of the DPDP Act.

DATA RETENTION:

We keep personal data only for as long as necessary for the purposes in this Privacy Policy, unless the law requires us to keep it longer. In particular:

  • Account information is kept while your account is active and is erased within a year after you delete your account, unless the law requires us to keep it.
  • Under the IT Rules, registration information is kept for 180 days after you delete your account, and content removed because of a legal requirement is preserved for 180 days (or longer if a court or authority requires) for investigation purposes.
  • Traffic data and processing logs are kept for at least one year, as required by the DPDP Rules, and system logs for 180 days, as required by CERT-In.
  • If you do not use the Platform for an extended period, we may erase your data in line with the DPDP Rules. We will notify you at least 48 hours before doing so.

CHILD SEXUAL ABUSE AND EXPLOITATION (CSAE)

Kofuku maintains a zero-tolerance policy toward any form of child sexual abuse, exploitation, or endangerment on the platform. We are committed to strict compliance with the Protection of Children from Sexual Offences Act, 2012, and other applicable child-protection regulations globally.

Strict Prohibition

Users are strictly prohibited from creating, uploading, sharing, requesting, soliciting, or engaging with any material, discussion, image, or conduct that constitutes child sexual abuse or exploitation

This includes, but is not limited to:

  • Sexualized depiction of a minor
  • Grooming, enticement, or inappropriate communication with or about a minor
  • Sharing or seeking explicit content involving minors
  • Any behaviour that may place a child at risk of harm, exploitation, or sexual offences

Monitoring & Detection

Kofuku uses automated safety systems and content filters to detect and prevent CSAE-related content or behaviour across the platform.

Any detection of CSAE triggers immediate content removal, account suspension, and further investigation.

Mandatory Reporting

As required under the POCSO Act, Kofuku is legally obligated to:

  • Report any suspected or confirmed instance of child sexual abuse, exploitation, or grooming to the appropriate law-enforcement authorities, and (Sections 19 and 20 of the POCSO Act)

  • Preserve relevant data as mandated for investigative purposes. This includes preservation under the IT Rules.

  • Reporting will be done without prior notice to the user, in compliance with statutory requirements and to protect potential victims.

Cooperation with Authorities

We shall cooperate with recognised law-enforcement agencies, cyber-crime units, and child-protection bodies in investigating, identifying, and prosecuting perpetrators of child exploitation

We may share user data only to the extent legally required for such investigations.

Protection Measures for Minors

All minor users are restricted to age-appropriate sections of the platform, and minors are never shown advertisements based on their data.

We do not publicly disclose user age data and prohibit any direct, private interactions or conduct that may expose minors to inappropriate content or boundary violations.

Any account suspected of posing a risk to a minor may be restricted, suspended, or permanently banned.

User Responsibility

  • Users must not misuse the platform in any manner that could facilitate CSAE.

  • Users are encouraged to immediately report any suspicious activity or harmful conduct involving minors to info@kofuku.com. Users can also report to the National Cyber Crime Reporting Portal (cybercrime.gov.in or helpline 1930), or call 1098 (Childline) or 112 in an emergency. 

YOUR ACKNOWLEDGEMENT:

By using this app/website, you acknowledge that you have read and understood the Privacy Policy of Kofuku Social and agree to the collection, utilisation, or disclosure of personal data submitted by you, as described in this Privacy Policy. By submitting your Personal Information in our app/website, you are giving your consent for processing the same in a manner outlined in this Privacy Policy.

YOUR RIGHTS

Under the DPDP Act, you have the following rights regarding your personal data:

  1. To request access to your personal data;  This includes a summary of the personal data we process, the processing activities, and the identities of the parties with whom it has been shared (Section 11).

  2. To request correction of inaccurate or incomplete data;

  3. To request deletion of personal data where applicable;

  4. To withdraw consent where processing is based on consent;

  5. To raise a grievance regarding the processing of your personal data; and 

  6. To nominate another person to exercise your rights in the event of your death or incapacity (Section 14); and

  7. To complain to the Data Protection Board of India if your grievance is not resolved (Section 13).

To exercise these rights, please contact us using the details provided in the “Grievance Redressal” or “Contact Us” section of this Privacy Policy.  We will respond within the period prescribed under the DPDP Rules, which cannot exceed 90 days.

BREACH NOTIFICATION

In the unlikely event of a data breach, Kofuku Social will notify the Data Protection Board of India and affected users without undue delay and in accordance with applicable timelines under the DPDP Act. The notification will disclose the nature and extent of the breach, potential consequences, and the corrective measures to prevent recurrence. Kofuku will notify the Board without delay on becoming aware of a breach and will provide detailed information to the Board within 72 hours (Rule 7, DPDP Rules). Kofuku will also report cyber-security incidents to CERT-In within six hours.

UPDATES TO THIS POLICY

Kofuku Social may update this Privacy Policy periodically to reflect legal or operational changes.
All updates will be posted here with a revised “Last Updated” date.
Significant changes will be notified via in-app alerts or email. All users of the Kofuku Social Platform should periodically check the Privacy Policy tab to keep themselves up to date with any amendments to this policy.  If a change affects processing based on your consent, we will ask for fresh consent where required. 

COOKIES:

We use cookies, Pixels, and SDKs to improve the use and functionality of the Kofuku Social platform and to gain a better understanding of how visitors use the platform, its information, and the services offered on it. Cookies help us tailor Kofuku Social platform to your personal needs, improve its user-friendliness, gain customer satisfaction feedback. We have data protection safeguards in place and require third-party service providers to protect personal data and use it only for authorised purposes

You can decline the cookies from our platform by changing the settings of your web browser or app settings. However, please note that you may not be able to use all or some part(s) of our platform properly if you choose to disable any or all Cookies.

GRIEVANCE REDRESSAL

If you believe your data has been misused or your privacy rights violated, please contact:

Grievance Officer and Data Protection Contact
Name: Yubaraj Bhattacharya
Email: yubaraj@kofukuhcs.com
Address: Ecospace Business Park Premises, 3A Building, 4th Floor, Newtown, Kolkata, West Bengal: 700156

The Grievance Officer will acknowledge and resolve your complaint within the timelines prescribed under Rule 3(2) of the IT Rules. If you are not satisfied with the decision, you may appeal to the Grievance Appellate Committee (gac.gov.in) within 30 days. For privacy complaints, you may approach the Data Protection Board of India once you have used this grievance process.

UPDATES TO THIS PRIVACY POLICY  

This Privacy Policy is valid from the time of its publication on our platform, and all previous versions of this Privacy Policy become invalid as of such time. Any future changes we make to this Privacy Policy will be posted on our platform. Please check back frequently to see any changes.     

CONSENT

By creating an account with Platform, you are hereby accepting this Privacy Policy and our Terms. You expressly provide your consent to us for the use and disclosure of your Personal Information in the manner prescribed in this Privacy Policy. 

Last updated: 14/11/2026