Privacy Policy

Last Updated: December 31, 2019

Thank you for using Soompi!

Viki, Inc. (“Rakuten Viki”, “We”, “Our” and/or “Us”) is part of the Rakuten group, which includes the affiliates and subsidiaries of Our parent company Rakuten Group, Inc., based in Tokyo, Japan. More information about Rakuten is available at https://global.rakuten.com/corp/about/company (“Rakuten Group”).

This Privacy Policy describes how We collect and process personal information about you, how We use and protect this information, and your rights in relation to this information. Personal information is information, or a combination of pieces of information that could reasonably allow you or your household to be identified (“Personal Information“).

This Privacy Policy applies when you use Viki.com, Rakuten Viki branded applications, Soompi.com, Soompi branded applications, and other Rakuten Viki related sites, applications, communications and services (“Services“).

Please read this Privacy Policy, Our Cookie Policy and Our Terms of Use carefully.

INFORMATION WE COLLECTWe will collect Personal Information about you from a variety of sources, including information We collect from you directly, information We automatically collect from your use of the Services, and information We collect about you from other sources, described below:
1. Information We collect directly from you
  The categories of information that We collect directly from you are:
  1. Identifiers, such as:
    1. Your personal details (for example, full name and picture). Please note that any personal details included as part of your profile information will be visible to other users of Our Services;
    2. Your contact details (for example, email address); and
    3. Your account login details (for example, your username and password (encrypted));
  2. Internet or other electronic network activity information, such as information about your online browsing behaviour and preferences;
  3. Visual information, such as your photo; and
  4. Any other information you may choose to provide Us when you post or upload content to the Services, fill out a form, submit a request to Our community support, respond to a survey, post to forums, submit ratings and reviews and participate in promotions, contests, sweepstakes and/or quizzes.
2. Information We automatically collect from your use of the Services
  The categories of information that We collect from your use of the Services are:
  1. Identifiers, such as:
    1. Identifiers for devices you have used to access Services (for example, the IP address, a app/device identifier and advertising industry standard unique identifier);
  2. Commercial information, such as certain information and how you use the Services (for example, pages you view, content you view or favorite, searches you make and content consumption history);
  3. Geolocation data, such as city and country
  4. Other device information, such as certain technical information about your device relating to your browser type, language, your operating system and application version, device types, device model and manufacturer and your device operating system type and version;
  5. Cookies and similar technologies, as further described in Our Cookie Policy, We and Our partners automatically collect information from cookies and similar technologies (for example, cookies IDs and settings) to recognize you, track your behaviour on the Services and your device, and to serve you with tailored advertisements. For more information on how We use cookies and how you can manage them, please visit Our Cookie Policy.
3. Information We collect from other sources:
  1. Registration through third parties
    If you don’t feel like creating an account from scratch, We provide you with the option to sign in through an account you already have with another service provider (such as: Facebook and Google). The third-party service may send Us information such as:
    1. Identifiers, such as:
      
      Your personal details (for example, name); and
      
      Your contact details (for example, email address);
    2. Geographic location;
    3. Visual information, such as profile picture; and
    4. Commercial information, such as interest, list of friends and any other information you have made available on these third-party services.
    This information is controlled by the third-party service or as authorized by you via your privacy settings at the third-party service.
  2. Social media third partiesSome of Our Services allow you to post information on a public feature of Our Services or through social media sites, plugins or other applications. Don’t forget this information is public on Our Services and depending on your privacy settings, may also become public on the internet. We may also further use such public information you share for various reasons such as improving Our Services and providing you with relevant content. You can control what data you share through privacy settings available on some social media sites. Please refer to those third-party privacy policies and terms of use to learn more about their privacy practices, as We don’t control these.
  3. Other sourcesWe may receive additional information about you from third party service providers and/or partners, such as demographic data, your activities on and off Our Services through partnerships and Our third party advertisers.
HOW WE USE INFORMATION WE COLLECT
The information We collect from you ensures you can use Our Services in a safe environment. As part of this mission, We may use your information for the following purposes:
1. ServicesWe may use your information to:
  1. enable you to access and use the Services;
  2. authenticate your identity when you log in to Our Services;
  3. personalize or otherwise customize your experience by, for example, providing you with content based on your search and preferences;
  4. determine your general geographic location to personalize Our Services;
  5. recommend content and determine whether the content you have requested is available in your region; and
  6. manage the accounts you hold with Us;
2. AdvertisingWe, and Our third-party advertisers, use your Personal Information to serve you with advertisements that may interest you (you can find below more information about Our third-party advertisers);
3. MarketingWe use your information to send you promotional messages, newsletters, marketing and other information that may be of interest to you based on your communication preferences. We, and Our third-party business partners, also use your Personal Information, on and off Our Services, to serve you with advertisements of Our Services. From time to time, We, and Our third-party service providers and/or business partners, may also use your information to administrate surveys, questionnaires, sweepstakes, contests, referral programs or other promotional or market research activities or events managed by Us, Rakuten Affiliates and/or Our partners if you consent;
4. CommunicationWe use your information to contact you to maintain Our Services and to respond and resolve your support requests, questions and issues;
5. SecurityWe use your information if We think it is necessary to investigate and prevent security issues and abuse;
6. Research and services improvementIn an effort to provide you with the best Services, We may use your information to conduct research for further development of Our Services; and
7. LegalWe may use your information to comply with legal obligations to which We are subject, protect Our intellectual property (including but not limited to Our copyright and trademarks) and enforce Our Terms of Use and cooperate with regulators and law enforcement bodies.
HOW WE SHARE INFORMATION
1. We may disclose your Personal Information for business purposes to the following parties:
  1. Service providersWe share your Personal Information with Our service providers that perform business services and/or operations on Our behalf. For example, We may engage other companies to provide authentication services, provide streaming and content delivery services, perform analytics, send newsletters and marketing emails, administer Our promotions, sweepstakes, contests, and surveys, and support email and messaging services;
  2. Business partnersWe may share your Personal Information with Our business partners to perform business services dependent upon the selected service or plan and/or your request. For example, We may partner with other companies to provide content, and targeted advertising services;
  3. Rakuten Group companiesRakuten Group, Inc. is Rakuten Viki’s parent company. We work closely with Our affiliated businesses and companies that fall under the Rakuten Group family (together, “Rakuten Affiliates“). We may share your data with Rakuten Affiliates for internal business administration purposes within the Rakuten Group.
  4. Law enforcement agencies, courts, regulators and government authoritiesWe may share your Personal Information with these parties where We believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect Our rights or the rights of any third party; and
  5. Asset purchasersWe may share your Personal Information with any third-party that purchases, or to which We transfer, all or substantially all of Our assets and business. Should such a sale or transfer occur, We will use reasonable efforts to try to ensure that the entity to which We transfer your Personal Information uses it in a manner that is consistent with this Privacy Policy.
2. The following categories of Personal Information may be shared with the parties listed above:
  1. Identifiers;
  2. Commercial information;
  3. Geolocation data;
  4. Other device information;
  5. Internet or other electronic network activity information;
  6. Cookies; and
  7. Inferences drawn from any of the above information categories.
3. (For California residents only) California law requires that We describe certain disclosures of Personal Information that involve monetary or other consideration. California law treats such disclosures as “sales” even if no money is exchanged. Such sales include Our sharing of Personal Information with third party advertisers as described below. The following categories of Personal Information may be shared with these parties:
  1. Identifiers;
  2. Geolocation data; and
  3. Cookies.
THIRD PARTY ADVERTISERSWe permit advertisements to be delivered to you by third party advertisers (also called ad networks or network advertisers). These third party advertisers may use Personal Information (for example, cookies, platform device identifiers, software agents, and IP address), in order to deliver targeted advertisements, measure their effectiveness, and to understand the usage and visitation of Our Services and the other applications and websites tracked by these companies. We do not have access to or control over cookies, platform device identifiers, software agents, or other technologies that they may use. We are not responsible for the privacy practices of third party advertisers. For more information about how the online advertising industry uses information it collects to provide you with tailored advertisement, and to control whether you want to receive those relevant advertisement from Our third-party advertisers, please review the information at the following links: The Network Advertising Initiative; and Your Ad Choices.
THIRD PARTY WEBSITESOur Services may contain links to other third-party websites. We encourage you to be aware of these other third-party websites and their privacy statements, as We are not responsible for the privacy practices or the content of these third-party sites.
YOUR CHOICES AND YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
1. Your choicesYou may in some cases have the option to decline providing Us information. However, your choice to not provide information may impact your use of certain features or Services. Please find below some choices you have over your Personal Information:
  1. AccountYou can change information about your account by accessing your Account and modifying the information listed in the “Edit Profile” tab. You are not required to provide any information to Us that is unnecessary to provide the Services;
  2. Marketing CommunicationYou can unsubscribe or opt-out of receiving marketing communications from Us by using the “Unsubscribe” link at the bottom of an automatic email or by contacting Us through Our Services. Please note that even if you opt-out of receiving marketing communication, We may continue to send you non-marketing emails and other types of communications, as permitted by law, such as response to your support requests, or Service emails relating to your account; and
  3. CookiesYou may control the use of cookies at the browser level. If you choose to disable cookies, it may limit your use of certain features or functions on Our Services. For more information on how We use cookies and how you can manage them please see Our Cookie Policy.
2. Your rightsSubject to local law, you may have certain rights regarding information that We have collected and that is related to you. We encourage you to contact Us to update or correct your information if it changes or if you believe that any information that We have collected about you is inaccurate.
  Please note that We will likely require additional information from you in order to honor your requests.
  
  If you would like to exercise such rights, send Us an email at privacy@viki.com.
  1. Your rights over your Personal Information under law
    1. General rightsAs stated above, you may have certain rights in accordance with the applicable local law and limitations, including the right to:
      1. access your Personal Information;
      2. rectify the information We hold about you;
      3. erase your Personal Information;
      4. restrict Our use of your Personal Information;
      5. object to Our use of your Personal Information;
      6. receive your Personal Information in a usable electronic format and transmit it to an external party (right to data portability); and
      7. exercise rights without fear of being denied goods or services.
      If contacting Us does not resolve your complaint, you have the right to make a complaint to your data protection authority.
    2. International Data TransfersPlease note that your Personal Information may need to be transferred to, stored and/or processed in countries where data protection and privacy regulations may not offer the same level of protection as in your home country. Please note that We may be transferring, storing and/or processing your Personal Information to the United States, Japan, Singapore, South Korea, Brazil, Netherlands and India. In such cases, We will require the recipient to provide appropriate protection for the Personal Information disclosed to it in compliance with applicable data protection laws.
      As part of the Rakuten Group, We rely on the Rakuten Binding Corporate Rules to safeguard international data transfers within the group. The Rakuten Binding Corporate Rules have been approved with the Data Protection Authority of Luxembourg and can be found at: https://corp.rakuten.co.jp/privacy/en/bcr.html.
  2. Additional Rights applicable to European Union (“EU”) users
    1. Legal basis for processing your Personal InformationAdditionally, if you are visiting the Services from the EU, We must have a legal basis to process your Personal Information. There are different legal bases that We rely on to use your Personal Information, namely:
      1. Performance of a contractThe use of your information may be necessary to perform the terms and conditions or other contractual obligations and policies under which We provide Our Services to you. Failure to provide this information may prevent or delay the performance of these contractual obligations;
      2. ConsentWe will rely on your consent to use:
        
        technical information such as cookie and similar technologies; and
        
        your information for marketing and advertising purposes.
        
        You may withdraw your consent at any time by contacting Us using the information at the end of this Privacy Policy or by following an unsubscribe link in any marketing communication you receive from Us;
      3. Legitimate InterestsWe use your Personal Information for Our legitimate interests to:
        
        understand how you use Our Services;
        
        improve Our Services;
        
        maintain security of the Services; and
        
        to share information with Rakuten Affiliates for internal administration.
        
        In such circumstances, We put in place robust safeguards to ensure that your privacy is protected and ensure that Our legitimate interests are not overridden by your data protection interests or fundamental rights and freedoms; and
      4. Legal obligation and public interestIn some cases, We may also have a legal obligation to collect your Personal Information, or may otherwise need your Personal Information to protect your vital interests or those of another person.
  3. Additional rights applicable to California usersAdditionally, if you are a California resident, you may:
    1. learn more about the sources from which We collect Personal Information, the purposes for which We collect and share Personal Information, the Personal Information We hold, and the categories of parties with whom We share your Personal Information;
    2. request a list of all third parties to which Our Services have disclosed certain Personal Information during the preceding year for those third parties’ direct marketing purposes. If you are a California resident and want such a list, please contact Us at privacy@viki.com, and ensure to include the statement “Your California Privacy Rights” in the body of your request, as well as your name, street address, city, state, and zip code; and
    3. as We make certain disclosures of Personal Information that California law defines as “sales” even if no money is exchanged (“Selling your Personal Information“) and given you are aged 18 and above, you may opt out of Selling your Personal Information (you may exercise that right here).
AUTOMATED DECISIONS ABOUT YOUWe may make automated decisions about you based on your Personal Information in the following circumstances:
1. To select personalized offers, discounts, marketing communications or recommendations to send you based on your order history, browsing history, preferences, location, device type and means of payment.
These types of decisions will not have legal or similar significant effects for you, but you can still contact Us for further information.
SECURITYWe care about the security of your Personal Information. We implement technical and organizational measures to ensure a level of security appropriate to the risk to the Personal Information We process. These measures are aimed at ensuring the on-going integrity and confidentiality of your Personal Information. However, no company can guarantee that data may not be accessed, disclosed, altered, or destroyed by breach of any of Our physical, technical, or managerial safeguards. We need your help too: it is your responsibility to make sure that your Personal Information is accurate and that your password is unique, secure and not shared with third parties.
RETENTIONWe will keep your Personal Information for as long as We have a relationship with you. We will only retain your Personal Information after this time if We are required to do so to comply with the local law, or if there are outstanding claims or complaints that will reasonably require your Personal Information to be retained.
CHILDREN’S PRIVACYOur Services are not intended for children under the age of 13, or other minimum age for providing consent to data collection under local law. Therefore, We do not knowingly collect Personal Information via Our Services from anyone under 13 (or such other minimum age as may be restricted under local law). If a parent or a guardian believes that Rakuten Viki has in its database the Personal Information of a child under the age of 13, please contact Us at privacy@viki.com.
CHANGES TO THIS PRIVACY POLICYFrom time to time we may modify or update this Privacy Policy.
The most current version will govern Our use of your Personal Information and will always be available at soompi.com/privacy, and older versions are available upon request. We will notify you if We make changes that We think will have a substantial impact on your rights. Otherwise, you agree to accept any changes or updates to this Privacy Policy by continuing to use Our Services.
CONTACT USIf you still have questions or concerns regarding the way in which your Personal Information has been used, please feel free to contact Us and Our Data Protection Officer by email at privacy@viki.com or you can also reach Us by physical mail at the following address:
Viki, Inc
Attention: Privacy Policy/Legal Department
800 Concar Drive, Suite 175,
San Mateo,
California 94402, USA.

We are committed to working with you to obtain a fair resolution of any complaint or concern about privacy. If, however, you believe that We have not been able to assist with your complaint or concern, you have the right to make a complaint to your data protection authority. In relation to EU users, your applicable data protection authority is listed at:https://edpb.europa.eu/about-edpb/board/members_en

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