Privacy Policy

Last updated: 21 June 2023

Thank you for using Rakuten Viki!

Viki, Inc. (“Rakuten Viki”, “We”, “Our” and/or “Us”) provides an interactive platform that lets you access entertainment content and be part of an online community where you can interact with other Users, and enjoy various features available on Our Site. We are a subsidiary of Rakuten Group, Inc., based in Tokyo, Japan (“Rakuten Group”). Learn more about Rakuten Group here.

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 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.

This Privacy Policy applies to your use of the Rakuten Viki branded website (“Site”) and proprietary software applications and all associated features, functionalities, user interfaces, and content available within the Site (together with the Site, collectively, the “Rakuten Viki Service”), and also governs Personal Information we may collect from or through your use of third-party social media services in relation to the Rakuten Viki Service.

  1. INFORMATION WE COLLECT

    We will 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 use of or account on the Rakuten Viki Service. Please note that any personal details 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. Financial information, such as the last 4 digits of your credit card number and your credit card expiry date (if applicable);
      3. Protected characteristics, such as gender. Note that protected characteristics will only be visible to other users of the Rakuten Viki Service if voluntarily included by you as part of your profile information;
      4. Commercial information, such as information about your subscription plan(s) and transactions you made and/or content you viewed on the Rakuten Viki Service;
      5. Internet or other electronic network activity information, such as information about your browsing behaviour on the Rakuten Viki Service and expressed preferences;
      6. Inferences drawn about you from any of the Personal Information we collect, such as content preferences; and
      7. Any other information you may choose to provide Us 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 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 certain information about your transactions on the Rakuten Viki Service (for example, amount charged, date and time) and content consumption history;
      3. Internet and other electronic network activity information, such as how and when you use or access the Site and Rakuten Viki Service (for example, date and time of visits, pages you view, types and frequency of content or genres you view, favourites you identify, subtitles or segments of content you edit, 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; and
      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.
    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;
      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

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

  2. HOW WE USE PERSONAL INFORMATION WE COLLECT

    Generally, We use the Personal Information We collect from you to provide you the Rakuten Viki Service and to ensure you can use the Rakuten Viki Service in a safe environment. We may use your Personal Information for the following specific purposes:

    1. Providing and Personalising the Rakuten Viki Service

      We may use your Personal Information to:

      1. 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 and recommend content based on your 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 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 third-party service providers and/or business partners (“Our Partners”) may use your information to send you promotional and marketing communications, and other information regarding the Rakuten Viki Service which may be of interest to you based on your preferences. For example, We may recommend to you certain content available on the Rakuten Viki Service. Our avenues for direct marketing include in-app notifications, push notifications and email. From time to time, We, and Our Partners, may also use your information to administer surveys, questionnaires, or other promotional or market research activities or events managed by Us, Rakuten Affiliates and/or Our Partners if you consent;

    4. Communication

      We may use your information to contact you to respond to and resolve your support requests, questions and issues and to maintain and moderate the Rakuten Viki Service;

    5. Security

      We may use your information where necessary to assess risk and to investigate 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 for further development of the Rakuten Viki Service 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 to increase community engagement, such as enabling the sharing with other users of reviews, ratings, contributions and messages you post on the Rakuten Viki Service;

    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); and

    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 syndicate 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 sharing, 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, or Brazil, 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 may be necessary to perform our contractual obligations to provide the Rakuten Viki Service and its features and functionality to you, 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 information such as cookie and similar technologies; and
        2. your Personal Information for marketing and advertising purposes.

        You may withdraw your consent at any time by contacting Us via the means provided at the end of this Privacy Policy or, for direct marketing communications, by following an unsubscribe link in any marketing communication you receive from Us; and

      3. Legitimate Interests

        We use your Personal Information for Our legitimate interests to:

        1. understand how you use the Rakuten Viki Service;
        2. improve the Rakuten Viki Service;
        3. maintain security of the Rakuten Viki Service; and
        4. 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 do not override your data protection interests or fundamental rights and freedoms.

    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.

    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, or to perform public statutory duties We are subject to; and

      2. Research

        We may use your Personal Information for research purposes to improve the Rakuten Viki Service.

  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. 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, send direct marketing communications, administer Our promotions and surveys, and support service email and messaging services;

      2. Business partners

        We may 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. For example, We may partner with other companies to provide content, and targeted advertising services;

      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 right to consent or opt-out, depending on your jurisdiction, these 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 and Our Site. 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. To the extent required by your jurisdiction’s law, we offer you an option to 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 a marketing cookie to be placed or read without your prior consent (see Section 5: Opt-outs). 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: identifiers (e.g., IP address, device ID, ad ID, user agent), location data, 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. For more information about how the online advertising industry uses information it collects to provide you with tailored 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;

      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 username and password to log in to participating Rakuten Group services to which you choose to connect. If you choose to connect to another Rakuten ID participating service in addition to the Rakuten Viki Service, you authorize certain of your Personal Information (specifically, your email address) to be shared from Rakuten Viki to the Rakuten ID program and the other Rakuten service according to the terms of and for the purposes explained in Our joint Rakuten ID Privacy Policy here: https://corp.rakuten.co.jp/privacy/en/rakuten-id.html;

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

        We 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 or assert Our rights or the rights of any third party; 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. 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. Note about third-party websites

      The Rakuten Viki Service may contain links to other third-party websites. 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. However, choosing not to provide information may impact your use of certain 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. Cookies

        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.

    2. Your Privacy rights

      Subject to local law, you may have certain rights regarding Personal Information related to you that We have collected, 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 California, by using the web form here, and ensure to include the statement “Your California 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. Please note that We may require additional information from you in order to honor your requests.

      1. General privacy rights, including the right to request to:
        1. access your Personal Information – access or receive a copy of the Personal Information We hold about you;
        2. rectify the Personal Information We hold about you – correct inaccurate or incomplete factual information that we hold about you;
        3. erase your Personal Information – delete Personal Information collected from you, subject to certain legal exceptions;
        4. restrict Our use of your Personal Information – limit our processing of your Personal Information to particular purposes or under certain circumstances;
        5. object to Our use of your Personal Information – applicable under certain circumstances;
        6. withdraw your consent – for any processing that is based on your consent;
        7. receive your Personal Information in a usable electronic format and/or transmit it to an external party – right to data portability;
        8. exercise privacy rights without fear of being denied goods or services – right to non-discrimination; and
        9. 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 rights applicable to users in California:

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

        1. Know - you can request that we provide you the following information:
          1. The categories of Personal Information we have collected about you since January 1, 2022;
          2. The categories of sources from which we collected your Personal Information;
          3. The categories of third parties with whom we shared your Personal Information in the preceding 12 months, including:
            1. If we disclosed your Personal Information for a business purpose, which categories of your Personal Information we disclosed for a business purpose to which categories of third parties; and
            2. If we sold your Personal Information, as “sell” is defined under the CCPA, which categories of your Personal Information we sold to which categories of third parties; and
          4. Our business or commercial purpose for collecting or selling your Personal 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” even if there is no money exchanged. 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 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. Additional rights applicable to Virginia, Colorado, and Connecticut users:

        If you are a Virginia, Colorado, or Connecticut resident, 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 make automated decisions about you based on your Personal Information 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 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. 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 Rakuten’s EU Binding Corporate Rules and UK Binding Corporate Rules to safeguard international data transfers 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

    We 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.

  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, 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 or above the age of majority in their state territory, or country of residence. 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. We will notify you if We make changes that We think will have a substantial impact on your rights. Otherwise, you shall accept all changes or updates to this Privacy Policy by continuing to use the Rakuten Viki Service after the changes or updates have taken effect.

  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.