Privacy Policy

Last updated: 1 July 2024

Thank you for using Rakuten Viki!

Viki, Inc. (“Rakuten Viki”, “we”, “our” and/or “us”) provides an interactive platform where you can access entertainment content and other available features, as well as interact with other users as part of an online community. Rakuten Viki provides the Rakuten Viki branded website (“Site)”, mobile and TV applications (“Apps”), and all other features, functionalities, user interfaces, and content available within the Site and Apps (collectively, the “Rakuten Viki Service”). We are a subsidiary of Rakuten Group, Inc., based in Tokyo, Japan (“Rakuten Group”). Learn more about Rakuten Group here.

This Privacy Policy applies to your use of the Rakuten Viki Service and any other interactions between you and Rakuten Viki. It describes how we collect and process Personal Information about you, including Personal Information we may collect from or through your use of third-party social media services in relation to the Rakuten Viki Service, how we use and protect this information, and your rights in relation to this information.

As used in this Policy, “Personal Information” is information that identifies, describes, relates to, or is reasonably capable of being associated with or linked to an identifiable individual or household, or a combination of pieces of information that could reasonably allow you or your household to be identified. “Sensitive Personal Information” includes certain types of Personal Information that have been designated in various privacy and data protection laws as “sensitive’ or belonging to “special categories” due to their ability to be used by unauthorized recipients to perpetrate fraud, theft, or discriminatory treatment of individuals, such as financial account information, username/password combinations, health data, religion, political affiliation or union membership, and demographic information such as race, ethnicity, or sexual orientation. Viki does not intentionally collect or store or use for any of the purposes described below any Sensitive Personal Information except your account credentials (and payment information which is collected and handled directly by our third-party processor) even to the extent you choose to provide this type of information about yourself in comments, reviews, or other user-generated content you contribute when you use or interact with the Rakuten Viki Service. Information that is anonymized, aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable person is not Personal Information, and we may use such anonymized, aggregated or de-identified information for any business purpose, without attempting to re-identify it.

1. INFORMATION WE COLLECT

   We collect the below-listed types of Personal Information about you from a variety of sources, including directly from you, from your use of the Rakuten Viki Service, and from other sources, as described below:

   1. Information We collect directly from you

      The following are the categories of information that we collect directly from you when you provide this information in relation to your Rakuten Viki account or your use of the Rakuten Viki Service. Please note that any information you voluntarily include as part of your profile information will be visible to other users of the Rakuten Viki Service.

      1. Identifiers, such as:
         1. Your personal details (for example, full name, profile picture);
         2. Your contact details (for example, email address); and
         3. Your account login details (for example, your username and password (encrypted));
      2. Partial financial information, such as the last 4 digits of your credit card number and your credit card expiry date (if applicable). Note that full financial information needed for payment is directly collected and handled by our payment processor;
      3. Demographics you choose to provide (optional) as part of your profile, such as gender. Note that such information will only be publicly visible if voluntarily included by you as part of your profile;
      4. Commercial information, such as information about your chosen subscription plan(s); and
      5. Any other information you may choose to provide when you access, participate and/or engage in a community of users of the Rakuten Viki Service, including when you post or upload subtitles and/or content to the Rakuten Viki Service, fill out a form, submit a request to our community support, respond to a survey, post or comment on forums, submit ratings and reviews, participate in promotions and/or quizzes, and provide your consent to any activities.
   2. Information we automatically collect from your use of the Rakuten Viki Service

      We may systematically collect the below-listed categories of information from and about your use of the Rakuten Viki Service.

      1. Identifiers, such as unique identifiers for devices you use to access the Rakuten Viki Service (for example, the IP address, an app/device identifier, user agent, and advertising industry standard unique identifier);
      2. Commercial information, such as information about your transactions on the Rakuten Viki Service (for example, amount charged, date and time), content you viewed on the Rakuten Viki Service and your content consumption history;
      3. Internet and other electronic network activity information, such as how and when you use or access the Site, Apps, and Rakuten Viki Service (for example, date and time of visits, pages you view, types and frequency of content or genres you view, expressed content preferences or favourites you identify, subtitles or segments of content you edit, browsing you do, and searches you make);
      4. Location inferred from IP address, such as the city and country from which the Rakuten Viki Service was accessed;
      5. Other device information, such as certain technical information about your device relating to your browser type, language, local storage, your operating system and application version, device types, device model and manufacturer and your device operating system type and version;
      6. Information collected using cookies and similar technologies. We and our partners automatically collect information from cookies and similar technologies (for example, cookie IDs and cookie preference or consent settings), subject to your consent or opt-out, as applicable for your jurisdiction, to recognize you, track your behaviour on the Rakuten Viki Service 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 Cookies Policy; and
      7. Inferences about your potential preferences and characteristics based on any of the other Personal Information we collect, except Sensitive Personal Information, which we do not use to infer characteristics about you.
   3. Information We collect from other sources
      1. Registration through third parties

         You may choose to sign in to the Rakuten Viki Service using your existing account(s) on third-party services that are not owned or controlled by us (“Third-Party Services”), such as those provided by Facebook, Inc., Google LLC, or other Rakuten Group entities. In such case, Third-Party Services may send us the following types of information (whether this information is provided is controlled by the Third-Party Services or as authorized by you via your privacy settings on the Third-Party Services):

         1. Identifiers, such as:
            1. Your personal details (for example, name, profile picture); and
            2. Your contact details (for example, email address);
         2. IP address;
         3. Device information; and
         4. Your preferences and consents.
      2. Third Party Comment Service

         The Rakuten Viki Service allows you to post comments and information on a public-facing feature of the Rakuten Viki Service or through plug-ins, or other applications (the “Third-Party Comments Services”). Such information is public on the Rakuten Viki Service and, depending on your privacy settings, may also be made public on the internet. You can control the data you share through the privacy settings on the Third-Party Comments Services. We have no control over, and assume no responsibility for the privacy policies, terms of use and other policies on the Third-Party Comments Services. Please refer to the Third-Party Comments Services for more information; and

      3. Partnerships and advertisers

         We may receive additional information about you from third party partners and advertisers, such as your activities on and off the Rakuten Viki Service.

2. HOW WE USE PERSONAL INFORMATION WE COLLECT

   We use the Personal Information we collect from you to provide you the Rakuten Viki Service and for the following specific purposes:

   1. Providing access to and personalising the Rakuten Viki Service

      We may use your Personal Information to:

      1. Create account(s) that enable you to access and use the Rakuten Viki Service;
      2. Authenticate your identity when you log in to the Rakuten Viki Service;
      3. Personalise or otherwise customize your experience by, for example, providing you with content or content options based on your search, remembering language or other UI preferences, and recommending content based on your expressed or inferred preferences;
      4. Determine your general geographic location to personalise the Rakuten Viki Service and determine whether the content you have requested is available in your region;
      5. Process your payment for the Rakuten Viki Service through third-party service providers such as Stripe (whose Privacy Policy can be found here); and
      6. Manage, maintain, and monitor the accounts you hold with us.
   2. Advertising

      We, and our third-party advertisers, use your Personal Information to serve you with advertisements that may interest you, subject to your consent or opt-out, depending on your jurisdiction (see Section 4(a)(iii): Third-Party Advertisers).

   3. Marketing

      We and our service providers and/or business partners (“Our Partners”) may use your information to send you promotional and direct marketing communications. Our avenues for direct marketing include in-app notifications, push notifications and email, and we monitor your engagement with these avenues to measure the effectiveness of our direct marketing. From time to time, we, Rakuten Affiliates, and Our Partners may invite you to participate in surveys, questionnaires, or other promotional or market research activities or events. Your Personal Information may be used to administer the above and for our analysis if you consent to participate.

   4. Communication

      We may use your information to contact you, for example, to respond to and resolve your support requests, answer questions, issue security alerts, communicate account information and other information regarding the Rakuten Viki Service, and to maintain and moderate the Rakuten Viki Service.

   5. Security

      We may use your information where necessary to assess risk and to investigate, address, and prevent fraud, security issues, abuse and other malicious online activities on the Rakuten Viki Service. We may also use your information to improve our security measures.

   6. Research and services improvement

      We may use your information to conduct research and analysis to develop and improve the Rakuten Viki Service, identify and troubleshoot errors, and to conduct customer satisfaction assessments, in an effort to understand your preferences and provide you with the best experience.

   7. Community engagement

      We may use your information and any reviews, ratings, contributions, or messages you post on the Rakuten Viki Service to increase community engagement.

   8. Business performance analytics

      We may use your information to conduct business performance analytics to improve the Rakuten Viki Service offerings; for example, to better understand user preferences among various platforms on which the Rakuten Viki Service is available (web, mobile devices, connected television).

   9. Legal

      We may use your information to comply with legal obligations to which we are subject, to protect our intellectual property (including but not limited to our copyright and trademarks) or the intellectual property of third parties, to defend or enforce our other legal rights and our Terms of Use, to defend against any third party claims or actions, and to respond to requests or inquiries from regulators and law enforcement bodies.

   10. Application store services

       We may use your information to process payments or process or fulfil any orders of transactions on the Rakuten Viki Service made by you through an application store in accordance with their respective terms and policies. These application stores include Apple App Store (see Apple Privacy Policy) and Google Play Store (see Google Privacy Policy).

   11. Consent Management

       We use a Consent Management Platform (“CMP”) to enable us to transparently present user options, to capture, store and retrieve user preferences and to transmit user preferences or consent profiles to various third parties as necessary, regarding data processing of Personal Information for various purposes, including advertising and marketing. The CMP supports us in our Personal Information processing and disclosure, depending on whether the user has consented or not, and enables proof and documentation for the legal basis within the framework of data protection accountability.

3. LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION
   1. Users in the European Union ("EU"), the United Kingdom ("UK"), or Brazil

      If you are visiting our Site or using the Rakuten Viki Services from the EU, the UK, Brazil, or any other jurisdiction with laws similar to the General Data Protection Regulation (“GDPR”), we must have a particular legal basis to process your Personal Information. For EU, UK, or Brazilian users, we may rely on the following legal bases to use certain of your Personal Information:

      1. Performance of a contract

         The use of your Personal Information is necessary to perform our contractual obligations to provide the Rakuten Viki Service and its features and functionality to you, for example, to create and maintain your account, authenticate your login, provide community features, process transactions and payments from Rakuten Viki Service and application store services, verify whether content is available to you, and send you emails and other communication concerning the administration, security, and operation of your account or the Rakuten Viki Service, as per our terms and conditions or other policies. Failure to provide this information may prevent or delay the performance of our contractual obligations to you regarding the provision of the Rakuten Viki Service.

      2. Consent

         We will rely on your consent to use:

         1. Technical or Personal Information related to cookies and similar technologies;
         2. Your Personal Information for marketing and advertising purposes; and
         3. For other purposes for which we may request your consent, e.g., surveys, questionnaires, or other promotional or market research activities or events.

         For cookies and similar technologies, you may withdraw your consent at any time by adjusting your preferences as further explained in Section 5 or by contacting us via the means provided at the end of this Privacy Policy. For direct marketing communications you can modify your notification preferences in your “Subscription & Settings” or following an unsubscribe link in any marketing communication you receive from us.

      3. Legitimate Interests

         We use your Personal Information for our legitimate interests to:

         1. Understand how you use the Rakuten Viki Service;
         2. Personalise the Rakuten Viki Service for you;
         3. Improve the Rakuten Viki Service for all users;
         4. Maintain security of the Rakuten Viki Service; and
         5. Share information with Rakuten Affiliates for internal administration.

         Service improvements are dependent on our analyzing, for example, how you use the Rakuten Viki Service (such as pages you view, the rate at which you consume content (how often, and for how long), content you prefer and searches you make or share, the content you liked, comments you leave, third-party websites you visit through links, the success rate of any promotion, marketing campaign, or event, certain technical information about your device, or when you access the Rakuten Viki Service through a certain device, and purchase path or transaction data) and any issues or problems reported to customer service. In circumstances where we process personal data to serve our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and ensure that our legitimate interests do not override your data protection interests or fundamental rights and freedoms. You have a right to object to any of these uses except where our compelling interest outweighs your concerns, such as our interest in ensuring the security of the Rakuten Viki Service for all users. You may exercise your right to Object as described in Section 5.

   2. Additional Legal Basis for EU and UK
      1. Legal obligation and public interest

         In some cases, we may also have a legal obligation to collect or disclose your Personal Information, or may otherwise need to use or disclose your Personal Information, to protect your vital interests or those of another person, or to assert, protect or defend our or a third party’s legal rights.

   3. Additional Legal Bases for Brazil
      1. Legal obligations, legal proceedings and performance of public statutory duties

         We may use your Personal Information to comply with our legal obligations, in connection with legal proceedings, to assert, protect or defend our or a third party’s legal rights, or to perform public statutory duties we are subject to.

4. HOW WE SHARE PERSONAL INFORMATION
   1. We may disclose your Personal Information for business purposes to the following parties:
      1. Service providers

         We share your Personal Information with our service providers that perform business services and/or operations on our behalf according to our instruction. For example, we may engage other companies to process secure payments, provide authentication services, detect and prevent fraud, abuse and other malicious online activities on the Rakuten Viki Service, provide streaming and content delivery services, fulfil orders, perform analytics, facilitate direct marketing communications, administer our promotions and surveys, and support service email and messaging services.

      2. Business partners

         We share your Personal Information with Our Partners to carry out marketing activities and perform business services depending upon your selected subscription plan and/or your request to use certain features. For example, we partner with other companies to provide content, and targeted advertising services on third-party platforms, subject to your consent or opt-out, as applicable in your jurisdiction.

      3. Third-Party Advertisers

         We permit advertisements to be delivered to you on the Rakuten Viki Service by third-party advertisers (also called ad networks or network advertisers). Subject to your consent or opt-out, depending on your jurisdiction (see Section 5), advertisements may be tailored to your interests by the third-party advertisers based on preferences inferred from information they collect about your behavior on other sites and services, as well as Personal Information we may share with them about your interactions with the Rakuten Viki Services. In California in particular, the law identifies Personal Information disclosure for the purposes of cross-context behavioral advertising as a “sale” or “sharing” regardless of whether money is exchanged for it. In other jurisdictions, this is identified as processing for the purposes of targeted advertising. Subject to your opt-out or consent as may be applicable in your jurisdiction, we share the following types of Personal Information, where available, with these third-party advertisers for the purposes of their ad delivery, ad measurement, and cross-context behavioral advertising or targeted advertising on the Rakuten Viki Services: identifiers (e.g., IP address, device ID, ad ID, user agent), location data inferred from IP address, the genres of content you engage with, and cookie data.

         Other than the Personal Information we may share with them according to our contractual terms, we have no control over any other Personal Information these third-party advertisers collect elsewhere or may use to target advertisements to you, and we assume no responsibility for their privacy practices.

      4. Rakuten Group companies

         Rakuten 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.

         In addition, the Rakuten Group aims to provide you with a common service experience through the “Rakuten ID”, a program that enables you to use the same log-in credentials with any participating Rakuten Group services you use. Viki will securely share your account credentials with the Rakuten ID program for future account authentication purposes, according to the terms explained in the Rakuten ID Privacy Policy here: https://corp.rakuten.co.jp/privacy/en/rakuten-id.html, for use if you choose to connect to another Rakuten ID participating service in addition to the Rakuten Viki Service.

      5. Law enforcement agencies, courts, regulators and government authorities

         We may share your Personal Information with these parties where we assess and reasonably believe this is necessary to comply with a legal or regulatory obligation, or otherwise assert, protect or defend our or a third party’s legal rights; and

      6. Asset purchasers

         We may share your Personal Information with any third-party that purchases, or to which we transfer, all or a relevant portion 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 for the purposes described, except where otherwise specified above:
      1. Identifiers;
      2. Commercial information;
      3. General location data inferred from IP address;
      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. Note about third-party websites

      The Rakuten Viki Service may contain links to other third-party websites that we neither control nor own. We encourage you to be aware of when you are visiting these other third-party websites and to understand their privacy statements, as we have no control over, and assume no responsibility for the data collection, privacy practices or the content of any of these third-party sites you may choose to visit.

5. YOUR CHOICES AND YOUR RIGHTS OVER YOUR PERSONAL INFORMATION
   1. Your choices

      You may in some cases have the option to decline providing us with certain Personal Information, and you are not required to provide any Personal Information to us that is unnecessary for us to provide the Rakuten Viki Service to you. However, choosing not to provide information may impact your use of certain optional features or the Rakuten Viki Service. Please find below some choices you have over your Personal Information:

      1. Account

         You can change Personal Information in your account by accessing your Account and modifying the information listed in the “Edit Profile” and/or “About Me” tabs. You are not required to provide any Personal Information to us that is unnecessary for us to provide the Rakuten Viki Service to you;

      2. Marketing Communication

         You can unsubscribe or opt-out of receiving direct marketing communications from us by using the “Unsubscribe” link at the bottom of an email, by modifying your notification preferences in your “Subscription & Settings”, or by contacting us through the Rakuten Viki Service. Please note that even if you opt-out of receiving marketing communications, we may continue to send you non-marketing emails and other types of communications, as permitted by law, such as responses to your support requests, updates to our policies, or emails relating to your Rakuten Viki Service account; and

      3. Advertising

         Depending on your jurisdiction, you can opt-out of the sale or sharing of your Personal Information or the processing of your Personal Information for the purposes of targeted advertising, or we do not enable marketing cookies to be placed or read without your prior consent. You may control the use of cookies for a particular browser or device through our cookie banner. If you choose to disable cookies, it may limit your use of certain features or functions on the Rakuten Viki Service. For more information on how we use cookies and how you can manage them, please see our Cookies Policy.

         For more information about how the online advertising industry uses information it collects to provide you with targeted advertisement, and to control broadly whether you want to receive relevant advertisements from third-party advertisers, please review the information at the following links: The Network Advertising Initiative and Your Ad Choices.

   2. Your Privacy rights

      You may have certain rights regarding Personal Information based on where you reside (“Privacy Rights”), in accordance with applicable law and limitations, as described below. If you would like to exercise such rights, send us an email at privacy@viki.com, or if you are a resident of certain U.S. states, by using the web form here, and ensure to include the statement “Your U.S. State Privacy Rights” in the body of your request. Privacy rights requests will be honored within the time required by local law, which varies among jurisdictions. An agent may submit requests on your behalf, provided you or your agent provide proof that the agent is authorized to act on your behalf. Please note that we may require additional information from you in order to verify your identity and honor your requests.

      1. General Privacy Rights, including the right to request to:
         1. Know or confirm that we are processing personal data concerning you, including the categories of personal data, the purposes of processing, and the categories of recipients to whom we disclose it or in some cases the list of specific third parties to whom we disclosed personal data;
         2. Access your Personal Information that we process or receive a copy of the Personal Information we hold about you;
         3. Correct inaccurate or incomplete factual information we hold about you. In lieu of submitting a request, you can correct or delete Personal Information you provided when using Rakuten Viki Services by accessing your Account and modifying the information listed in the “Edit Profile” and/or “About Me” tabs through your account settings or any other location where you provided such information at any time.
         4. Delete your Personal Information, subject to certain legal exceptions. You can delete your Rakuten Viki Service account within your account settings (for more information, please see the article at https://support.viki.com/hc/en-us/articles/360051348154-How-Do-I-Delete-My-Account);
         5. Object to our use of your Personal Information under certain circumstances, such as when our use is based on our non-compelling legitimate interests or is used for direct marketing purposes. You can unsubscribe or opt out of receiving direct marketing communications from us by using the “Unsubscribe” link at the bottom of an email, by modifying your notification preferences in your “Subscription & Settings”, or by contacting us. Please note that even if you opt-out of receiving marketing communications, we may continue to send you non-marketing emails and other types of communications, as permitted by law, such as responses to your support requests, updates to our policies, or emails relating to your Rakuten Viki Service account;
         6. Restrict our use and limit our processing of your Personal Information to particular purposes. You can request to restrict our use of Personal Information during the pendency of your objection to our use for legitimate interests, or when alleging that our use of Personal Information is unlawful or no longer necessary for the purpose;
         7. Withdraw your consent for any processing that is based on your consent;
         8. Port your data - Receive a copy of Personal Information you provided us in an electronic format and/or have us transmit it to an external party – (right to data portability);
         9. Exercise privacy rights without fear of being denied goods or services or discrimination. We may, however, provide a different level of service where such Personal Information is necessary to provide the additional features or functionality; and
         10. Lodge a complaint – if contacting us does not resolve your complaint, you have the right to make a complaint to your data protection authority.
      2. Additional Privacy Rights applicable to users in California:

         If you are a California resident, you also have the right to:

         1. Know the categories of sources from which we collected the information, the categories of your Personal Information that we disclosed, sold or shared, and our business or commercial purpose for collecting, selling, or sharing the information.
         2. Opt-out of the sale or “sharing” of your Personal Information for the purposes of cross-context behavioral advertising – we disclose certain Personal Information to third parties for the purposes of cross-context behavioral advertising which California law defines as a “sale” or “share”. You may exercise your right to opt-out by clicking the “Do Not Sell or Share My Personal Information” button at the bottom of our Site. For California and Colorado residents, we recognize valid opt-out preference signals sent from browsers or devices, including the Global Privacy Control. When we receive such signals that do not conflict with your existing privacy preferences, we will automatically exercise opt-out rights that may be available to you under California laws, such as the rights to opt out of sale, sharing, and processing your Personal Information for targeted advertising. One way that you can use such opt-out signals is by following the instructions for your device or browser located here.
         3. “Shine the Light”: residents of California may request information once per calendar year about our disclosures, if any, of certain categories of your Personal Information to third parties for their direct marketing purposes under California’s “Shine the Light” law.
         4. Understand our use of financial incentives provided in exchange for Personal Information. California Notice of Financial Incentives: California law requires certain disclosures related to financial incentive offerings, including in relation to the value of your consumer data to our business. We may offer an opportunity to sign up to receive interest-based content via email by providing us your name, email address, or other personal contact information. There is no obligation to opt-in, and you may unsubscribe at any time by following the instructions in the mailing. From time to time, we may offer a financial incentive to those who sign up for or remain on our mailing list, complete a market research survey, make a purchase, or do not complete a purchase, such as a discount coupon or an opportunity to win a prize or giveaway in a random drawing. The details of each incentive program will be contained in the program terms. We offer these programs, among other things, to enhance our relationship with you, to provide you with content that may be of interest to you, and/or so you can enjoy more of our products/services at a lower price. Although we do not calculate the value of consumer data to our business in our accounting statements, we make the following good faith estimate for California residents to use in making an informed decision whether or not to take advantage of any financial incentive or price or service difference we may offer that relates to the collection, retention or sale of your personal information: To the extent we create overall value for our business from our financial incentive marketing programs that could be directly or reasonably related to the value of customer data, that value would vary from program to program and among individuals, but our method for calculating this value to our business would include, for each program, and in the aggregate, whether and by what amount the sales generated by the program(s) exceed the cost to us of offering them, which would include costs associated with (1) any financial incentives that are paid to consumers; (2) the cost of the marketing and distribution of the offer; (3) our marketing team’s efforts to enhance the resulting consumer data through campaign optimization and consumer engagement at sufficient scale; (4) leveraging our past investments in understanding consumers as our existing and future customers; (5) collecting and maintaining data as intellectual property; and (6) all other costs reasonably related to the programs.
      3. Additional rights applicable to residents of certain U.S. states other than California:

         If you are a resident of certain U.S. states other than California, you also have the right to:

         1. Opt-out of Processing for Targeted Advertising Purposes – we make certain disclosures of Personal Information that are used for targeted advertising. You may opt out of your Personal Information being processed for targeted advertising purposes by clicking the “Do Not Sell or Share My Personal Information” button at the bottom of our Site.
         2. Appeal our decision regarding your privacy rights request, by submitting an e-mail to privacy@viki.com with a subject heading “PRIVACY APPEAL” and setting out the details of your appeal and the reasons you think it should be granted.
6. AUTOMATED DECISIONS ABOUT YOU

   We may use software programs, algorithms, machine learning or artificial intelligence to make automated decisions about you based on your Personal Information to, for example, show you personalised content and select personalised 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 automated decisions will not have legal or similarly significant effects for you, but you can still contact us for further information on these decisions.

7. INTERNATIONAL DATA TRANSFERS

   Please 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. We may transfer to, store and/or otherwise process your Personal Information in 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 Rakuten’s EU Binding Corporate Rules and UK Binding Corporate Rules to safeguard international data transfers of EU and UK Personal Information within the group. Rakuten’s EU Binding Corporate Rules have been approved by the CNPD, the Data Protection Authority of Luxembourg and the UK Binding Corporate Rules have been approved by the ICO, the Data Protection Authority of the UK. The aforementioned Binding Corporate Rules can be found at https://corp.rakuten.co.jp/privacy/en/bcr.html.

8. SECURITY

   We care about the security of your Personal Information. We implement technical and organisational measures to ensure a level of security appropriate to the risk of processing for 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. You are also responsible to make sure that your Personal Information is accurate and that your password is unique, secure and not shared with any third-party.

9. RETENTION

   Unless otherwise specified, we will keep your account Personal Information for as long as we have a relationship with you, i.e., while you have an active account with us.

   In addition, we will retain your Personal Information outside the normal retention times to the extent there is a need to retain the data to pursue, defend, or exercise a legal right or claim, or if we are required to do so to comply with applicable legal obligations or regulatory requirements.

10. CHILDREN'S PRIVACY

    The Rakuten Viki Service is not intended for children (a) under the age of 18, (b) under the age of majority in any state, territory or country of residence from which the Rakuten Viki Service is accessed, or (c) under any other prescribed minimum age for providing consent to data collection under local law. Our registration requires the user to certify that they are above the age of 18 and above the age of majority in their home territory. We do not knowingly collect Personal Information via the Rakuten Viki Service from anyone under the age of 18 or under the age of majority in the relevant state, territory or country of residence. If you are a parent or a guardian who believes that your child/ward who is under the age of 18 or under the age of majority in your state, territory or country of residence, has improperly provided us with their Personal Information, please contact us at privacy@viki.com to remedy this situation.

11. CHANGES TO THIS PRIVACY POLICY

    We may modify or update this Privacy Policy from time to time. The most current version will govern our use of your Personal Information and is available at viki.com/privacy, with the latest update date at the top of this Privacy Policy. Older versions are available upon request. Any revised Privacy Policy is effective upon posting. If we make changes, we will provide you notice of such changes, such as by sending an email, posting to the Site, providing a notice through the Rakuten Viki Services or other reasonable means. In addition, if we make changes that we believe materially impact your rights, if applicable, we will ask you to consent to the changes.

12. CONTACT US

    If you have questions or concerns regarding the way in which your Personal Information has been used, feel free to contact our Data Protection Officer by email at privacy@viki.com. If you are seeking general assistance on Viki (including seeking a refund), please contact us here.

    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.