The California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act of 2020 effective January 1, 2023 (“CPRA”), any other California privacy laws, and this CCPA privacy notice (“CCPA Notice”) apply to Viber users, who are California residents (“consumers” or “you”). Any terms defined in the CCPA and CPRA have the same meaning when used in this CCPA Notice. This CCPA Notice applies to California residents’ Personal Information, which we collect directly or indirectly while using our Services or in order to provide our Services (as defined under the Viber Terms of Service), and business-to-business Personal Information.
Table of Contents
- Categories of Personal Information We Collect
- Categories of Sources of Personal Information
- Use of Personal Information
- Disclosure of Personal Information for a Business Purpose
- Sale or Share of Personal Information
- Children Under Age 16
- Personal Sensitive Information
- Information Retention
- Your Rights Under The CCPA
- How Can You Exercise the Rights?
- Authorized Agents
- Notice of Financial Incentive
- Changes to this CCPA Notice
- Other California Obligations
- Contact Us
Categories of Personal Information We Collect
We collect Personal Information which is defined under the CCPA, “Personal Information” is defined as any information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer, household or device. Personal information does not include publicly available information from government records and de identified or aggregated consumer information, as well as information excluded from the CCPA’s scope – for example, health or medical information covered by applicable laws such as the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; Personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA) and the Driver’s Privacy Protection Act of 1994.
We have collected the following categories of personal information within the last twelve (12) months:
|Category||Examples as set forth by the CCPA||Collected|
|A. Identifiers.||A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.||Yes: real name (if a user provided it), unique personal identifier, online identifier, Internet Protocol address, email address (if a user provided it), account name.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.
Some personal information included in this category may overlap with other categories.
|Yes: name, telephone number.|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).||No|
|D. Commercial information.||Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.||Yes: Viber services purchased, purchase history.|
|E. Biometric information.||Genetic, physiological, behavioral, and biological characteristics.||No|
|F. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.||Yes: browsing history, ad you have interacted with, clickstream data, directing URLs.|
|G. Geolocation data.||Physical location, approximate location derived from IP address or movements.||Yes: approximate location derived from IP address or precise location derived from the user’s GPS (if a user allowed it).|
|H. Sensory data.||Audio, electronic, visual, thermal, olfactory, or similar information.||No|
|I. Professional or employment-related information.||Current or past job history or performance evaluations.||No|
|J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).||Education records maintained by an educational institution.||No|
|K. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.||Yes: gender and user’s interests.|
|L. Sensitive Personal Information.||Government-issued identifying numbers, financial account details, genetic data, precise geolocation, race or ethnicity, religious or philosophical beliefs, union membership, mail, email, text messages, biometric data, health data, and sexual orientation or sex life.||Yes: user’s precise geolocation derived from the user’s GPS (if a user allowed it).|
Categories of Sources of Personal Information
We obtain the categories of personal information listed above from the following categories of sources:
- Directly from you, for example, when you register to our Services, you may provide us with your information such as your phone number, name, photo, etc.;
- Indirectly from your device, such as Device Identifiers (IP address, etc.), your login sessions, activity data, etc.;
- Other sources, such as social media sites if you choose to sign in through your social media account;
- Third-party service providers and partners such as analytics providers and advertising partners.
Use of Personal Information
- To fulfill or meet the reason you provided the information. For example, we will use the personal information you will provide through registration in order to create your Viber account.
- To provide, support, and develop our Services, as well as improve and customize our Services. For example, we will use your Device Identifiers and Inferences to customize the content we show you, including personalized ads, subject to your opt-out rights.
- For security and fraud detection purposes, and to maintain the safety, security, and integrity of our Services.
- To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
- As otherwise described to you when collecting your personal information.
- To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.
We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.
Disclosures of Personal Information for a Business Purpose
We may disclose your Personal Information to a contractor or service provider for a business purpose. The types of personal information we share for a business purpose, vary, depending on the purpose and the function provided by the third party to whom we disclose such information. When we disclose Personal Information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that Personal Information confidential and not use it for any purpose except performing the contract. We further restrict the contractor and service provider from selling or sharing your Personal Information.
In the preceding twelve (12) months, we disclosed the following categories of Personal Information for a business purpose:
|Category (corresponding with the table above)||Category of Recipient||Business Purpose|
|Cloud computing and storage vendors.||Storage, hosting.|
|2||Government Entities/ Law Enforcement.||Subject to a law request, such as tax and social security authorities.|
|3||Operating systems.||Operating the services.|
|4||Viber corporate family- as listed HERE, including our parent company, Rakuten Group Inc.||Corporate matters.|
|Data analysis providers.
|Providing analytic data on the use of our Services. We limit the providers ability to share such information, as detailed above.|
|Programmatic systems.||Measurement and reporting.|
|Marketing & promotions providers, CRM providers, social networks, advertising networks.||Marketing which is not cross-contextual, ad delivery.|
|Data Security Service Providers.||Debugging, security, fraud prevention.|
|Various service providers.||Improving the Services, development and optimization.|
|Customer support providers.||Customer and technical support|
|11||Category A||Advertisers (listed HERE) or partners||We share the online identifiers or unique identifiers for ad delivery, reporting and measurement.|
Sale or Share of Personal Information
We do not collect your personal information for the purpose of selling it in exchange for money; however, we do enable placement of third-party advertisements through our Services and share certain personal information for such purpose, which may amount to a “share” of your personal information under the CCPA’s broad definition of the term.
The CCPA defines “sharing” as “communicating orally, in writing, or by electronic or other means, a consumer’s personal information” to “a third party for cross-context behavioral advertising, whether or not for money or other valuable consideration.” In other words, we may share your Personal Information with a third party to help serve personalized content or ads that may be more relevant to your interests, and to perform other advertising-related services such as enabling our partners to serve such personalized content.
To enable the limited advertisements on our Services, we may share Device Identifiers (i.e., an advertising identifier associated with your device) with our third-party advertising partners (listed HERE), along with certain of your device data (e.g., language preference), age range, inferred gender, country, city, reduced IP address (or GPS location data if you allowed us to collect in your settings) and certain technical or aggregated data about you and the device you are using.
In the preceding twelve (12) months, we “sell” or “share” the following categories of Personal Information for a business purpose:
|Category (corresponding with the table above)||Category Recipient||Purpose of Sale or Share|
|Ad-network||Share for cross-context behavioral advertising.|
Children Under Age 16
Sensitive Personal Information
In the preceding twelve (12) months, we collected the following SPI: age range, inferred gender, and GPS location (subject to your consent). You may opt-out from GPS location collection through your mobile device settings, or through Viber App “Settings/privacy/personal data” by keeping the “Allow accurate location-based services” toggle off.
The retention periods are determined according to the following criteria:
- For as long as it remains necessary in order to achieve the purpose for which the personal information was initially processed. For example: if you contacted us, we will retain your contact information at least until we will address your inquiry.
- To comply with our regulatory obligations. For example: transactional data will be retained for up to seven years (or even more under certain circumstances) for compliance with our bookkeeping obligations purposes.
- To resolve a claim, we might have or a dispute with you, including any legal proceeding between us, until such dispute will be resolved, and following, if we find it necessary, in accordance with applicable statutory limitation periods.
Your Rights Under the CCPA & How You May Exercise Your Rights
The CCPA provides California residents certain rights related to their personal information, as we explain below. In order to allow you to exercise these rights, Viber made changes so you can now better control your data on the app.
If you are a California resident, you may exercise certain privacy rights related to your Personal Information. You may exercise these rights free of charge except as otherwise permitted under applicable law. We may limit our response to your exercise of these privacy rights as permitted under applicable law, all as detailed herein.
To learn more about your California privacy rights, please visit https://oag.ca.gov/privacy/privacy-laws.
|California Privacy Right||Details|
|The right to know what Personal Information the business has collected||The right to know what Personal Information the business has collected about the consumer, including the categories of personal information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom the business discloses Personal Information, and the specific pieces of Personal Information the business has collected about the consumer.
|Access Rights||You may access and request a copy of the specific personal information collected by us about you by tapping the “request your data” button in Viber’s privacy settings on your mobile app. Once the copy is ready, you will receive a file from Viber containing this information. If you have further questions please contact us.|
|Deletion Rights||The right to delete Personal Information that the business has collected from the consumer, subject to certain exceptions.
We have made it easy for you to delete your historical data on the app, while continuing to use the App. Simply tap on the “delete your data” button in your privacy settings. We will delete the data that we are not otherwise required or permitted to keep or that is necessary for the provision of the Service. Please see information and instruction regarding your account deletion HERE.
You can also delete the content you publicly share at any time.
|Correct Inaccurate Information||The right to correct inaccurate Personal Information that a business maintains about a consumer. Please note that you can also correct your personal information yourself at any time using the methods described below.|
|Opt-Out of Sharing for Cross-Contextual Behavioral Advertising||You have the right to opt-out of the “sharing” of your personal information for “cross-contextual behavioral advertising,” often referred to as “interest-based advertising” or “targeted advertising.”|
|Opt-out from selling||The right to opt-out of the sale or sharing of Personal Information by the business, for more information please see below.|
|Limit the Use or Disclosure of SPI||Under certain circumstances, If the business uses or discloses SPI, the right to limit the use or disclosure of SPI by the business, for more information please see below.|
|Opt-Out of the Use of Automated Decision Making||In certain circumstances, you have the right to opt-out of the use of automated decision making in relation to your Personal Information. Viber does not make automated decisions within the meanings contemplated under CCPA and CPRA.|
|Non-Discrimination||CCPA and CPRA provides for the right not to receive discriminatory treatment by the business for the exercise of privacy rights conferred by the CCPA, including an employee’s, applicants, or independent contractor’s right not to be retaliated against for the exercise of their CCPA rights, denying a consumer goods or services, charging different prices or rates for goods or services, providing you a different level or quality of goods or services, etc. We may, however, charge different prices or rates, or provide a different level or quality of goods or services, if that difference is reasonably related to the value provided to us by your Personal Information.
You may freely exercise your privacy rights without fear of being denied Viber Services. If you believe that your account was unlawfully blocked, you can contact us via our support page or by sending an email to firstname.lastname@example.org.
|Data Portability||You may request to receive a copy of your Personal Information, including specific pieces of Personal Information, including, where applicable, to obtain a copy of the Personal Information you provided to us in a portable format.|
|The Right to Appeal||In the event that we deny your request to exercise your rights, you may have the right to appeal our decision, depending on your state’s law. Please send your appeal request with a summary of the request and decision you want to appeal to email@example.com.|
How You May Exercise Your Rights
- We enable you to delete, edit/correct your messages anytime, even after they have been sent (they will be deleted or appear edited for you, your friend and our Services).
- You can also control your privacy settings within the App to change the visibility of your online status.
- You can disable the “seen” notification so that other users do not know whether you’ve read a message yet.
- You can choose not to share your photo and/or birthday or not to allow other users to look you up by name, which choices are available within the App.
- You can also make additional choices on your phone’s settings by changing our App’s permissions such as to allow or disable GPS location sharing, access to contact list and more.
- If you do not wish to receive Viber marketing notifications, you may adjust your system settings to decline notifications from Viber, or submit a request to our support. And if you subscribed to receive promotional emails from Viber, you can unsubscribe in any such email at any time.
- Sending a message to a bot or subscribing to a bot will allow admins of that bot to send you notifications and personal messages. If you do not wish to receive such notifications, you may adjust your account settings to decline them or opt-out at any time from receiving further notifications. You may also adjust your phone preferences to enable or disable the use of your GPS location data at any time.
- You can choose to allow or to not allow customization and personalization of our Services provided to you based on your personal information, by changing your personal data toggles in the privacy setting within the App.
Opt Out from cross-contextual ads or limiting the use of SPI:
You can simply open the Viber App, access the “Settings/privacy/personal data” menu within the App and switch the “Do Not Sell or Share My Personal Information” toggle on, and, switch your “Allow accurate location-based services” toggle off if you had previously turned it on (the “Opt-Out”). If you are having trouble finding the toggles or need further instructions you can send us an email to firstname.lastname@example.org, or contact us via our online form as described below. Furthermore, if you are having trouble finding the “Do Not Sell or Share My Personal Information” toggle you can send us an Opt-Out request at any time via the following link: https://support.viber.com/customer/portal/emails/new?type=CA
Global Privacy Control
We recognize valid opt-out preference signals sent from browsers, including the Global Privacy Control, on our websites. 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 applicable California privacy laws, such as the rights to opt out of sale, sharing, and processing your personal information for targeted advertising, for your browser. One way that you can use such opt-out signals is by following the instructions for your device or browser located here: https://globalprivacycontrol.org.
In addition to the various methods described above that allow you to easily exercise your rights via your App’s settings at any time, you may also submit a request to exercise your rights by contacting us, as follows:
- Our online form available at: https://vb.me/ContactUs – please choose the “privacy inquiry” category.
- Using the “contact us” form on the App.
- Email: email@example.com
We may require additional information from you in order to honor your request and we may decline your request as permitted under applicable law.
We will respond to a verifiable request within the timeframes set forth under the CCPA, including any extensions (in such event, we will inform you of the reason and extension period in writing). We may reply by a notification under your account, email, or other means of communication. Please note that any disclosures we provide will only cover the 12-month period preceding the receipt of your request. We do not charge a fee to process or respond to your verifiable request unless it is excessive, repetitive, or manifestly unfounded.
Please note that, only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable request related to your personal information. You may also make a verifiable request on behalf of your minor child. Such request must include sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative as well as sufficient details regarding your request that allows us to properly understand, evaluate, and respond to it.
Notice of Financial Incentive
Changes to This CCPA Notice
This notice was last updated on January 1, 2023. We may revise or update this CCPA Notice from time to time, and in any event, as required under the CCPA, we will update the CCPA Notice every 12 months. If changes to this privacy notice will have a fundamental impact on the nature of the processing or otherwise have a substantial impact on you, we will give you sufficient advance notice so that you have the opportunity to exercise your rights (e.g. to object to the processing).
The last revision date will be reflected in the “Last Modified” heading at the top of this CCPA Notice.
Other California Obligations
California Civil Code Section 1798.83 (“Shine the Light”) permits you, if you are a California resident, to request certain information regarding disclosure of Personal Information to third parties for their direct marketing purposes. Please email us at firstname.lastname@example.org for more information, however please note Viber does not disclose your Personal Information with third parties for their direct marketing within the meaning of “Shine the Light” provisions.
Do Not Track Settings: Cal. Bus. And Prof. Code Section 22575 also requires us to notify you how we deal with the “Do Not Track” settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites. For more details, including how to turn on Do Not Track, visit: www.donottrack.us.
- Our online form available at: https://vb.me/ContactUs – please choose the “privacy inquiry” category.
- Using the “contact us” form on the App.
- Email: email@example.com
Current CCPA Privacy Notice PDF Version January 2023
Previous CCPA Privacy Notice PDF Version March 2022
Previous CCPA Rights Page PDF Version November 2019