Effective Date: February 23, 2025
This Privacy Policy describes how Ase.Mob (“Kurd+”, “we”, “us” or “our”) collects, uses, shares, and protects personal information when you use our online Software-as-a-Service (SaaS) platform and mobile application (“Service”). By accessing or using our Service, you agree to the collection and use of your information in accordance with this Privacy Policy.
1. Our Company Information
Legal Business Name: Ase.Mob
Registered Address:
Gulan Street
Erbil, Iraq
44001 Gu St Erbil, Iraq
Contact for Privacy Inquiries:
Email: support@asemob.com
2. Scope and Purpose
Kurd+ is an online SaaS tool and mobile app designed primarily for students, teachers, and businesses to study, create, and share learning content. This Privacy Policy explains how we process personal data in accordance with applicable data protection laws including the GDPR, CCPA, and other local privacy regulations.
3. Information We Collect
3.1 Personal Data
When you use our Service, we collect standard personal data that is typical for a web application, including:
- Name
- Email Address
- Username
- Phone number
Note: We do not collect physical addresses unless you opt for a paid service; such address data is collected and processed by our third-party payment provider, FastPay, FIB, and is not retained by Kurd+.
3.2 How Data Is Collected
- User Input: Information provided through registration forms, contact forms, surveys, and other interactive elements.
- Social Login: We offer sign-in options through Google and Apple. When you use these services, we receive basic profile information from your social account as permitted by their privacy settings.
- Cookies: We use first-party cookies to enable core functionality (e.g., logging into your account) and for analytics. Tools like Google Analytics help us improve our Service. You can opt out of non-essential cookies via our cookie banner.
- Customer Support: We use Intercom to deliver customer support; it employs first-party cookies on our domain.
3.3 Additional Collection Channels
We may also collect personal information when you interact with us in person, online, or by phone or mail in connection with:
- Receiving help through our customer support channels;
- Participating in customer surveys or contests; and
- Facilitating the delivery of our Services or responding to your inquiries.
4. How We Use Your Information
We process your personal data only for purposes that are necessary and lawful, including to:
- Provide and maintain our Service;
- Personalize and improve your experience;
- Deliver customer support;
- Analyze usage and performance (via tools such as Google Analytics and Intercom).
Our legal basis for processing includes the performance of our contract with you, your consent where applicable, and our legitimate interests under applicable laws (including GDPR and CCPA).
5. Data Sharing and Third-Party Transfers
We share your personal data only with trusted third parties, including:
- Google Analytics: For analyzing user interactions and improving our Service.
- Intercom: For delivering customer support.
These third parties are contractually obligated to protect your data in compliance with applicable data protection laws. Data transfers occur only to countries that provide an adequate level of protection as required by applicable regulations.
6. Cookies and Tracking Technologies
- Essential Cookies: Used to provide core functionality (e.g., authentication, session management).
- Analytics Cookies: Help us understand how our Service is used so we can improve it. You may opt out of these cookies by adjusting your cookie preferences via our cookie banner.
For further information on managing your cookie settings, please refer to our Cookie Notice.
7. Data Retention and Security
7.1 Data Retention
We retain your personal data for as long as your account remains active and for the duration necessary to provide you with our Service. Your personal data will not be deleted automatically due to inactivity; instead, it will only be removed upon your explicit request to delete your account.
Upon receiving a deletion request, we will initiate the process to remove your personal data from our active systems within a reasonable period (typically within 30 days). However, certain information may be retained for a limited period to comply with legal, regulatory, or contractual obligations (e.g., for record-keeping or tax purposes).
Additionally, we delete backups after a period of 30 days.
7.2 Security Measures
We implement strict security measures to protect your data, including:
- Access Controls: Only authorized developers and personnel have access to user data.
- Encryption: Sensitive information (e.g., passwords) is encrypted at rest.
- Regular Security Reviews: We continually assess and update our security practices to ensure ongoing protection.
8. Your Rights and Choices
Under applicable data protection laws, you have the following rights regarding your personal data:
- Access: Request a copy of your personal data.
- Correction: Request correction of any inaccurate or incomplete information.
- Deletion: Request deletion of your personal data, subject to legal obligations.
- Data Portability: Request your data in a structured, commonly used, machine-readable format.
- Objection and Restriction: Object to or request restrictions on our processing of your data.
- Withdrawal of Consent: Withdraw consent for processing, where applicable, without affecting the lawfulness of prior processing.
To exercise any of these rights, please contact us at support@asemob.com or use the designated channels in your account settings.
9. International Data Transfers
Your personal data may be transferred to and processed in third countries. In all such cases, we ensure that appropriate safeguards are in place to maintain a level of protection equivalent to that under the GDPR.
10. CCPA Privacy Notice for 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 the State of California for a temporary or transitory purpose.
If you meet this definition, you are considered a California resident, and we must adhere to certain rights and obligations regarding your personal information.
What categories of personal information do we collect?
In the past twelve (12) months, we have collected the following categories of personal information:
| Category | Examples | Collected |
|---|---|---|
| A. Identifiers | Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address, and account name | YES |
| B. Personal information categories listed in the California Customer Records statute | Name, contact information, education, employment, employment history, and financial information | YES |
| C. Protected classification characteristics under California or federal law | Gender and date of birth | NO |
| D. Commercial information | Transaction information, purchase history, financial details, and payment information | NO |
| E. Biometric information | Fingerprints and voiceprints | NO |
| F. Internet or other similar network activity | Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems, and advertisements | NO |
| G. Geolocation data | Device location | YES |
| H. Audio, electronic, visual, thermal, olfactory, or similar information | Images and audio, video or call recordings created in connection with our business activities | NO |
| I. Professional or employment-related information | Business contact details to provide our Services at a business level, job title, work history, and professional qualifications (if you apply for a job with us) | NO |
| J. Education Information | Student records and directory information | NO |
| K. Inferences drawn from other personal information | Inferences drawn to create a profile or summary about an individual’s preferences and characteristics | NO |
| L. Sensitive Personal Information | No specific examples provided | NO |
Additionally, we may collect other personal information outside these categories when you interact with us in person, online, by phone, or by mail in contexts such as:
- Receiving help through our customer support channels;
- Participating in customer surveys or contests; and
- Facilitating the delivery of our Services or responding to your inquiries.
Verification Process
Upon receiving your request, we will need to verify your identity to determine you are the same person about whom we have information in our system. These verification efforts require us to ask you to provide information so that we can match it with information you have previously provided us. For instance, depending on the type of request you submit, we may ask you to provide certain information so that we can match it with information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us.
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 verification. However, if we cannot verify your identity from the information already maintained by us, we may request additional information for verification and security purposes. We will delete such additionally provided information as soon as we finish verifying you.
Response Timing and Format
We will respond to a verified consumer request within fifteen (15) days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
Non-Discrimination
We will not discriminate against you if you exercise your privacy rights.
Use of Authorized Agents
If you are using an authorized agent to exercise your right to opt-out, we may deny a request if the authorized agent does not submit proof that they have been validly authorized to act on your behalf.
11. Policy Updates
We may update this Privacy Policy from time to time. Any changes will be posted on this page, and the updated policy will be effective immediately upon posting. Please check this page periodically for updates. Your continued use of our Service after any changes constitutes your acceptance of the revised Privacy Policy.
12. Children’s Privacy
Our Service is intended for users aged 13 and over. We do not knowingly collect personal data from individuals under the age of 13. If you are under 13, please do not provide any personal information through our Service.
13. Contact Information
If you have any questions or concerns about this Privacy Policy or our data practices, please contact us at:
Email: support@asemob.com
Address:
Gulan Street
Erbil, Iraq
44001 Gu St Erbil, Iraq
This Privacy Policy was last updated on February 23, 2025.