1. Introduction
SOOM VIDEO TECHNOLOGY COMPANY LIMITED (“SOOM VIDEO,” “SOOM,” “Doratoon,” “us,” or “we”) respects the privacy and personal information of the members of the SOOM and is committed to it through compliance with this privacy policy (“Privacy Policy”). This Privacy Policy applies to the https://doratoon.com website and the https://soom.us/ website, associated software (including Doratoon, SOOMUS, and other apps and services that specifically state that this Privacy Policy applies to them (collectively the “Service(s)” or “SOOM Services”). It excludes services that have separate privacy policies that do not incorporate this Privacy Policy.
Privacy Policy explains what information we collect from you, how we use that information, how you can review or change the personal information you provided to us, when this policy is effective, how we may change this policy, and the steps we take to ensure that your personal information is protected. We share your personal information only with your consent or as described in this Privacy Policy.
In specific cases, we use the term “Designated Countries” to refer to countries in the European Union (EU), European Economic Area (EEA), and Switzerland.
By registering for, downloading, or using the Services, you accept this Privacy Policy and our Cookie Policy, which is part of our Terms of Service (https://doratoon.com/about/agreement).
2. The Doratoon Data Processing Principles
1. We process your Personal Data in compliance with relevant laws, fairly and in a transparent manner.
2. We process your Personal Data only for legitimate purposes and as described in this Privacy Policy.
3. We make reasonable efforts to keep your Personal Data accurate and up to date.
4. We take reasonable steps to ensure that inaccurate Personal Data is erased or rectified.
5. We keep your Personal Data in a form that enables us to identify you for no longer than is necessary for the purposes for which your Personal Data is processed.
6. We process your Personal Data in a manner that ensures appropriate security of your Personal Data, including against unauthorized or unlawful processing and against accidental loss, destruction or damage, using appropriate technical or organizational measures.
3. Definitions Used in This Privacy Policy
Personal Data: means information that we collect from and/or about you as a natural person (private individual), that can be used to identify you, or that is combined with information that can identify you directly or indirectly (in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person).
You: means any user of the Doratoon Services.
User: means any person who uses the Service(s).
Service(s): without regard to whether it is provided through the Website(s) or the Application(s), means all the services described in the Terms of Service (https://doratoon.com/about/agreement).
4. Changes to this Privacy Policy
We review our Privacy Policy on a regular basis. This Privacy Policy may be amended from time to time, and if we make material changes to it, we will provide you notice through the Services, or by other appropriate means (including but not limited to email, via this page or via the user interface).
Your continued use of our Services after a revised privacy policy is posted will constitute your acknowledgment that the collection, use, and sharing of your personal data are subject to the updated policy. The “effective date” of this Privacy Policy is referenced and displayed at the beginning of it.
5. What personal data we collect and why
We collect information about you when you use our services. In addition, third parties may collect information about you when you use our services. Collected information may include or reflect personal information that could identify you, as well as non- personal information. We collect the following information from and about you:
Information you Share
Account Information
You don’t have to create an account to use some of our service features, such as searching and viewing public presentations. If you do choose to create an account and become a member, you must provide us with some personal information so that we can provide our services to you including your name, email address and/or phone number, occupation, title, and a password. If you choose to authenticate using a third-party account (e.g., Google), you authorize us to obtain account information from the third-party platform.
Payment Information
In order to gain access to specific premium features within our Services, you must provide us with payment information, including your credit or debit card number, card expiration date, CVV code, and billing address.
Support Information
The Services also include our customer support, where you may choose to submit information regarding a problem you are experiencing. For example, if you designate yourself as a technical contact, open a support ticket, speak to one of our representatives directly or otherwise engage with our support team, you will be asked to provide contact information, a summary of the problem you are experiencing, and any other documentation, screenshots or information that would be helpful in resolving the issue.
Survey Information
From time to time, we may ask our registered users or visitors to participate in surveys. These surveys are optional. If you choose to participate, any information you provide to us, including personal information, will be linked with your account in our system. If you would not like your information to be used in this way, you have the option to not participate in surveys or, if you do participate, to provide us only with information you consent to our use of in accordance with this Privacy Policy.
Parts of our Services allow users to upload, create and stream user content, including presentations, messages, comments, images, videos, and other materials. If you choose to upload personal information through these means in a manner that makes it visible to the public, we will consider that information public and will not limit its use or disclosure in the manner described in this Privacy Policy.
Content Information (User Content)
We may associate certain content information (such as titles, metadata, and digital art assets) that is stored in your presentations, infographics, videos or other free-form content inputs, such as comments, with personal information about you or others. Information in your presentations, videos, and infographics belong to you, and you are responsible for making sure that your content complies with our Terms of Service (https://doratoon.com/about/agreement).
If your content is made public, anyone (including us) may view its contents and potentially make other uses of it. If you have included private or sensitive information in your public presentations, videos or other content, such as your name, address, email addresses, and the like, that information may be indexed by search engines or used by third parties. If your user content is shared privately, those you have shared it with may use it in a manner inconsistent with our Terms of Use, and/or inconsistent with your wishes, including disclosing it publicly. Please exercise discretion concerning those you share your private content with.
Information You Share About Others
Contact Information
Some components of the Services allow you and others to share user content and send personal messages with other registered users and non-registered users. To use this feature, you must provide us with personal information about others including an email address for each recipient. For example, when collaborating on a presentation you may want feedback from other team members or non-team members and you can do so by adding those members as collaborators.
Additional Information We Receive About You
Use of the Services
When you visit our websites, sign in into our Services, interact with our email notifications, or visit a third-party service that includes content from our Services, we may receive information about you, or combine such information with other personal information. This service usage information includes data such as your IP address, browser type, operating system, the referring web page, pages visited within our Services, location, your mobile carrier, device information (including device and application IDs), search terms, and cookie information.
Third-Party Services
We may provide links to online services that we do not own or operate. These services fall outside of this Privacy Policy and we have no control over the data they collect. For example, if you click on an advertisement, you may be taken to the advertiser's website. Once on a third-party site, your data may be collected by others. We encourage you to read the privacy policies of such services before using them.
You may use content and/or functionality from third-party services in your presentations, videos and User Content. This Privacy Policy covers our websites and apps, but does not cover any third-party site, content, or app.
Services you link to your account
We receive information about you when you or your administrator integrate or link a third-party service with our Services, including information from the third party who provides the linked service. For example, if you create an account or log into the Services using your Google credentials, we receive your name and email address as permitted by your Google profile settings in order to authenticate you. We also provide options within the Services that enable you to link to services such as Slack and Salesforce, so you can receive real-time notifications and integrate content within those platforms. Our Doratoon video feature allows you to upload videos and stream through other platforms. To learn more about these third parties’ privacy practices, please consult their privacy policies.
Cookies, Web Beacons and Other Similar Technologies
The Services, our service providers, linked services, and third party content and/or functionality that appears on the Services may use cookies and other tracking tools including web beacons, pixel tags, clear GIFs, and the like. Please see our cookie policy for more information about these technologies.
Our Partners and Service Providers
Doratoon relies on a number of other companies, agents,and/or contractors to perform services on our behalf and to assist us in operating and providing the Services to you. For example, we may engage such service providers to provide marketing, communications, website hosting, infrastructure, and IT services, to personalize and optimize the Services, provide customer service, collect debts, and analyze and enhance data. In the course of providing such services to us, these companies may obtain information about you, including personal information, and that information will be shared with us. We do not authorize these companies to use or disclose your personal information except in connection with providing the services we request from them.
6. List of Our Data Processors
We may involve new partners and service providers, including for short trial periods, to assist us in operating and providing the Services to you.
Another of our service providers is Google Analytics, which collects information such as how often users visit this site, what pages they visit when they do so, and what other sites they used prior to coming to this site. To learn more about how Google Analytics collects and uses your data when you use the Service, and how you can control the information sent to Google Analytics, please review https://www.google.com/policies/privacy/partners .
7. Do Not Track Signals
At this time, the Services do not respond to “do not track” signals sent from web browsers.
8. Information We Do Not Collect
The Services are for a general audience and do not direct any content, products, or Services at children under 13 years of age. We understand and are committed to respecting the sensitive nature of children’s privacy online. If you are a user between the ages of 13 and 18, you may only use Doratoon through an account established by a parent or guardian, with that parent or guardian’s permission – provided that in your jurisdiction there is no requirement for you or your parent to provide any consent to Doratoon for a minor’s use beyond what is already provided in Doratoon’s Terms of Use and Privacy Policy. By way of example, in some Designated Countries users as old as 16 may be required to have their parent or guardian submit a specific consent to Doratoon, and in those countries users under 16 years of age may not use Doratoon.
Also, in certain Designated Countries minors at or beyond the age of 13 might be permitted by local laws to give consent directly to personal their data processing parental or guardian permission. We urge you to familiarize yourself with your jurisdiction’s requirements on this subject.
Doratoon does not knowingly collect personal information about children not authorized to use Doratoon – if you believe we have unknowingly collected such information, please contact us at doratoon@laipic.us.
We do not intentionally collect sensitive personal information, such as genetic data, health information, or religious information. Although we do not request or intentionally collect such sensitive personal information, we realize that you might store this kind of information in your account, such as in a presentation, video, and/or infographic. If you store any sensitive personal information on our servers, you are consenting to our storage, processing, and use of that information in accordance with this Privacy Policy.
9. How we use and process your Personal Data
9.1 General
In most cases, we process your Personal Data to provide you with the Services. However, other purposes may apply, as set forth below.
We process your Personal Data in compliance with our legal obligations and with this Privacy Policy. We provide an adequate level of protection to your Personal Data by E.U. data protection regulations and standards, even in cases when we transfer your Personal Data outside the Designated Countries, for example by using approved standard contractual clauses, binding corporate rules, and/or safe harbor programs.
The legal bases for processing depend on the services you use and how you use them. We collect and use your information when:
● We need it to provide you the Services and thereby to perform our contractual obligations to you, including to operate and improve the Services, provide customer support and personalized features and to protect the safety and security of the Services;
● It satisfies a legitimate interest (which is not overridden by your data protection interests), such as for research and development, to market and promote the Services and to protect our legal rights and legitimate interests or those of third parties, and to comply with our legal obligations;
● You have provided consent;
9.2 Details
Provide the Services
Provide the Services to you, including to process transactions with you, authenticate you when you log in,provide customer support, operate and maintain the Services, and to ensure their secure, reliable, and robust performance.
Develop Services and Research
Conduct research and development for the further development of our Services. In particular, we use collective learnings about how people use our Services and feedback provided directly to us to troubleshoot and to identify trends, usage, activity patterns and areas for integration and improvement of the Services. In some cases, we apply these learnings across our Services to improve and develop similar features or to better integrate the services you use. We also test and analyze certain new features with some users before rolling the feature out to all users.
Personalize Experiences
Include tailored features that personalize your experience,enhance your productivity, and improve your ability to collaborate effectively with others by automatically analyzing your activities and those of your team to provide better content, notifications, and recommendations that are most relevant for you and your team. For example, we may use your email domain to infer your affiliation with a particular organization or industry to personalize the content and experience you receive on our websites and/or communications. Where you use multiple Services (e.g., Doratoon Desktop, Doratoon on the web or mobile device), we combine information about you and your activities to provide an integrated experience, such as to allow you to find information from one Service while searching from another or to present relevant information as you travel across our websites.
Communicate with you about the Services
Send communications via email, phone and within the Services, including confirming your purchases, reminding you of subscription expirations, responding to your comments, questions, and requests, providing customer support, and sending you technical notices, updates, security alerts, and administrative messages. We also provide tailored communications based on your activity and interactions with us. For example, certain actions you take in the Services may automatically trigger a feature or third-party app suggestion within the Services that would make that task easier. We also send you communications as you onboard to a particular Service to help you become more proficient in using that Service. These communications are part of the Services and in most cases, you cannot opt-out of them. If an opt-out is available, you will find that option within the communication itself or in your account settings.
Market
Send you information or materials via email about products, offers, and news we think might interest you. In specific cases where we have your consent and you have provided us additional contact information, we may contact you through other channels including telephone. These communications are aimed at driving engagement and maximizing what you get out of the Services, including information about new features, survey requests, newsletters, and events we think may be of interest to you. We also communicate with you about new product offers, promotions, and contests of Doratoon, or its licensees or selected commercial partners. You can control whether you receive these communications as described below under "Your Choices & Obligations" section.
Advertise
Target ads to registered users, visitors, and others through a variety of advertising partners. In some cases, we also use information including service usage information, and information from web beacons, pixels, and cookies, and device identifiers that we collect as mentioned above to better understand how to promote and advertise our Services to you. For example, we use Facebook Custom Audiences to promote specific our Services on through Facebook’s ad platform. We do not promote other products or services that are not related to Doratoon.
Provide customer support
Investigate, respond to and resolve complaints and Service issues (e.g., bugs).
Promote Safety and Security
Verify accounts and activity to prevent, detect and monitor suspicious or fraudulent activity and to identify violations of Service policies including our Terms of Service (https://doratoon.com/about/agreement) or this Privacy Policy and/or attempts to harm our Members or Visitors
Pursue Legitimate Interests and Legal Rights
Where required by law or where we believe it is necessary to protect our legal rights, legitimate interests and those of others, we may use or disclose information about you in connection with legal claims, compliance, regulatory, and audit functions, and in connection with the acquisition, merger or sale of a business.
Accomplish other objections, with your consent
We use information about you where you have given us consent to do so for a specific purpose not listed above. For example, we may publish testimonials or featured customer stories to promote the Services, with your permission.
If you have consented to our use of information about you for a specific purpose, you have the right to change your mind at any time, but this will not affect any processing that has already taken place. Where we are using your information because we or a third party (e.g. your employer) have a legitimate interest to do so, you have the right to object to that use though, in some cases, this may mean no longer using the Services.
If you have any questions about the lawful bases upon which we collect and use your personal data,please send an email to doratoon@laipic.us.
10. Who we share your Personal Data with
We share the information we collect from and about you in the following ways:
When you collaborate with others
When you share User Content with other users, they have the ability to share, edit, copy and download that content based on settings you or your administrator select. Your profile information may be visible to other users.
When you share User Content publicly
If your content is public-facing, third parties, search engines (e.g., Google), archives, and other members of the public will have access to it and may compile public-facing information. Please use discretion concerning what you include in your public-facing presentations, videos, and other content.
When you work with a team / with your employer
If you register for or access the Services using an account that is associated with a team or organization, information about you including your account, service usage, and user content will be accessible to that organization’s administrator. In order to enable sharing and collaboration within an organization, we also share your account information with other registered users within the same organization.
Community forums
Information you contribute to blogs, forums, and related discussion areas – along with your profile information – will be may be read, collected, and used by any member of the public who accesses these websites. Your posts and certain profile information may remain even after you terminate your account. We urge you to consider the sensitivity of any information you input into these Services.
Third-party service providers
We use others to help us provide our Services. This includes helping us do application development, hosting, maintenance, backup, storage, virtual infrastructure, payment processing, fraud detection, marketing, and analysis. Third-party service providers have access to your information as reasonably necessary to perform these tasks on our behalf and are obligated not to disclose or use it for other purposes. All our service providers must meet our security and privacy standards before they gain access to any of your information.
Advertising
We work with several third-party advertisers and/or ad networks, to place ads promoting our Services on their third-party platforms. The types of information we share with advertising partners include: device identifiers (e.g., session information) or your contact information based on your consent. You can control whether we may share this information with our advertising partners as described below.
Linked Services
In the event you opt to link your account with third-party services, personal information including account information (e.g., full name, email address, username), other information such as referrer headers and IP addresses, and if user content is being shared the content itself, will become available to them, and to users with access to that platform. The linked services may also share certain information with us. The sharing and use of that personal information will be described in, or linked to, a consent screen when you opt to link the accounts.
Law, Harm, and the Public Interest
We may share information about you with a third party if we believe that sharing is reasonably necessary to (a) comply with any applicable law, regulation, legal process or governmental request, including to meet national security requirements, (b) enforce our agreements, policies and terms of service, (c) protect the security or integrity of our Services, (d) protect us, our customers or the public from harm or illegal activities, or (e) respond to an emergency which we believe in good faith requires us to disclose information to assist in preventing the death or serious bodily injury of any person.
Business Transfers
We may share or transfer information we collect under this Privacy Policy in connection with any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company. You will be notified via email and/or a prominent notice on the Services if a transaction takes place, as well as any choices you may have regarding your information.
Aggregate Insights
We may produce and share aggregated insights that do not identify you. For example, we may choose to publish statistics regarding how many members live in the U.S. versus how many live in Europe. If you complete a survey that asks for employment information, we may publish statistics regarding which professions are most likely to use or not use our Services.
With your consent
We share information about you with third parties when you give us consent to do so.
11. Your California Privacy Rights
11.1 California Consumer Privacy Act (CCPA) Rights
Californian users have additional rights afforded to them under the California Consumer Privacy Act (CCPA).
11.1.1 Categories of personal information collected and processed by Doratoon
For more details about the personal information Doratoon has collected in the past year, please see section 5. "What personal data we collect and why". For details on how we use that information, and who we share it with, please see section 9. "How we use and process your Personal Data" and section 6. "List of Our Data Processors".
Doratoon does not “sell” (as defined in the CCPA) the personal information of users.
11.1.2 Making a request in relation to your personal information
The CCPA gives California consumers various rights with respect to the personal information we collect, including the right to (subject to certain limitations):
Request to access the personal information Doratoon has about you; and Request that Doratoon delete all of your personal information.
California users may make a request by contacting us at doratoon@laipic.us .
We will authenticate your request using the email address associated with your Doratoon account and if necessary, proof of residency.
11.2 Other California Privacy Rights
California Civil Code Section 1798.83, known as the “Shine the Light” law, permits members of our community who are California residents to request and obtain from us a list of what personal information (if any) we may have disclosed to third parties for direct marketing purposes in the preceding calendar year, including the names and addresses of those third parties. Requests may be made once a year and are free of charge. If you would like to make a request pursuant to California Civil Code Section 1798.83, you must do so in writing via email; please include the phrase “Request for California Privacy Information” in the subject line and in the body of your message.
12. Your Privacy Rights and Choices, Including Under GDPR
Based on the General Data Protection Regulation (EU) 2016/679 (“GDPR”), if you are a habitual resident of a Designated Country, you may exercise the rights below by sending an email to doratoon@laipic.us.
Residents (users) from other jurisdictions may send us similar requests, and we will handle them according to applicable law, and/or within the exercise of our discretion. Please note that we may ask you to verify your identity before taking further action on your request.
12.1 Right to review, update, or correct data
You have the right to ask us to correct inaccurate or incomplete Personal Data concerning you. You can edit some of your personal information through your account. You can also ask us to change, update, or fix your data in certain cases, particularly if it’s inaccurate.
12.2 Right to object to, limit, or restrict the use of data
You have the right to ask us to stop using all or some of your Personal Data (e.g., if we have no legal right to keep using it) or to limit our use of it (e.g., if your personal data is inaccurate or unlawfully held).
12.3 Right to delete data
You have the right to ask us to erase or delete your Personal Data. In some cases (for example, information previously posted in public areas) it may not be practical or may be unduly burdensome, to delete your Personal Data. In the event that we may not delete your Personal Data, we will inform you.
12.4 Right to receive the information and/or take your data
You have the right to receive information whether we process your Personal Data and if such Personal Data is processed, and, where that is the case, access to the Personal Data. That’s why we inform you in advance about our processing activities via this Privacy Policy.
You have the right to receive yourself or transfer your Personal Data to another company (known as the right to data portability). Such Data includes account and contact information, and in the event, you have paid for our services, we will include the payment history of such transactions.
12.5 Right to lodge a complaint
You have the right to lodge complaints about the data processing activities carried out by SOOM VIDEO TECHNOLOGY COMPANY LIMITED before the competent data protection authorities within your jurisdiction.
12.6 Right to object with the processing of data for direct marketing purposes
You have the right to object at any time to processing of your Personal Data for direct marketing purposes.
12.7 Right to withdraw the consent
You have the right to withdraw your consent to the processing of your Personal Data at any time. However, this might force us to terminate our Services to you.
12.8 How to exercise your rights
At any time, you may exercise your rights as described in this article by sending an email to doratoon@laipic.us . In the email please provide specific details about the right you are exercising. Once we receive the communication, we will respond as quickly as possible and without delay. Depending on the request, it might take us some time to respond, but we will endeavor to do so within 30 days of receiving your request.
12.9 Contacting our Data Protection Officer and Representative
If you have any questions about the above-mentioned rights or the lawful bases upon which we collect and use your personal data, please contact our Data Protection Officer and Data Protection Representative by emailing doratoon@laipic.us .
13. Account Closure; Opt-Out of Marketing Emails
You may cancel your account and you may opt-out of receiving marketing emails from us at any time. In order to cancel your account, opt-out of, or modify your personal information, you must do so by emailing us at doratoon@laipic.us. We encourage you promptly to update your personal information when it changes. Information concerning your past behavior with the Services may be retained by us as long as necessary for the purposes set out above.
Please note that although you may opt-out of receiving certain emails, we reserve the right to communicate with you via email regarding specific products and services you have ordered, requested, or inquired about.
14. How We Secure and Store Your Information
14.1 General Security
In order to protect both the Personal Data and the general information that we receive from you through your use of the Services, we have implemented various security measures. For example, when you enter personal information (such as your contact information) on our online forms, we encrypt that information using transport layer security (TLS). We also follow generally accepted industry standards to protect the Personal Data submitted to us, both during transmission and once we receive it.
14.2 Risk of Interception
Please keep in mind, however, that whenever you give out Personal Data online there is a risk that third parties may intercept and use that Data. While Doratoon strives to protect your Personal Data and privacy, we cannot guarantee the security of any information you disclose online. We cannot guarantee the security of any data provided to or received by us through your use of the Services, and any Personal Data, general information, or other data or information is provided to us at your own risk.
14.3 How Long We Keep Your Informa
As a general rule, we retain your Personal Data for as long as you have an account, and for up to three years thereafter. If you are not a user from a Designated Country, we may retain a back-up copy of your Private or Public User Content potentially with Personal Data in it, indefinitely. We will only retain your information to the extent:
1. it is needed for the purposes which we have conveyed to you;
2. we are required by law to maintain such information; or
3. it is needed for us to address any issues or inquiries that you may have;
4.the processing purpose constitutes a legitimate interest.
We dispose of Personal Data by destroying it, erasing it or anonymizing it.
We may retain logs of automatically collected information (for internal analytics); your email address; your tax information; communications with you; and your transactional information (for auditing, tax, and financial purposes). When we no longer have a legitimate business interest in retaining data, we will delete or anonymize it.
Once you delete your account, a presentation or a video we may not be able to recover it. If you have previously made a presentation or a video public, the presentation or the video or its parts, including the incorporated data, may still be discoverable via search engines and similar online resources. We have no control over search engines; however, you may send a request for deletion to major search engines in some cases.
If we receive legal process pertaining to your account or have other legal document retention requirements, we will retain your data for as long as we in good faith believe is necessary to comply with our preservation obligations. Similarly, if we believe that your account has been involved in wrongdoing, we may preserve your Personal Data to defend or assert our rights.
14.4 Cross-Border Data Transfers
In accordance with the GDPR and other applicable privacy laws, we may transfer your Personal Data from your country of residence to China (or other countries) and we process data both inside and outside of China and rely on legally-provided mechanisms to lawfully transfer data across borders (e.g. Binding Corporate Rules or Standard Contractual Clauses or safe harbor programs).
Some of the third parties described in this Privacy Policy, which provide services to us under contract, are based in other countries that may have laws that are different, and potentially not as protective, as the laws of your country of residence. When we share information of our users in the Designated Countries, we make use of European Commission-approved Standard Contractual Data Protection Clauses, Binding Corporate Rules for transfers to data processors, or other appropriate legal mechanisms to safeguard the transfer.
15. Contact Information
If you have any questions, comments, or concerns relating to the Doratoon Service or this Privacy Policy, please send an email to doratoon@laipic.us .We will make every effort to resolve your concerns.
