Effective May 23rd, 2022
Welcome to Korkuma!
Korkuma is a global company. By using our Services, you agree that your personal information that you provide directly to us, or that we collect through your use of our Services, may be transferred to and stored in the Czech Republic and in Ireland, handled as described in this Policy.
Information we collect
A User is someone who Live-streams Content to their Viewers through Korkuma’s Platform. To become a User, you must create an account in accordance with our Terms. You must also provide us with additional information for tax purposes. Depending on your location you may have to provide us with some combination of your:
- Business Name / First and Last Name
- Address / Place of residence / Registered or real seat
- ID Number / VAT ID, TAX ID / Date of birth / NON-PROFIT Registration Number
- Phone number, e-mail address
We collect and process following information about your Live Streams via our Platform: the number of Live Stream events, time watched by Viewers, number of comments per Live Stream, number of likes per Live Stream and the tier of your subscription to our Platform.
A Viewer is someone who connects to Korkuma’s Live Stream Platform to see User’s Live Stream. Korkuma does not store any of your personal information, except as outlined below. Once you join User’s Live Stream you only need to fill in a nickname for the current live stream session and you may spectate the Live Stream and comment in the chat. Once the Live Stream ends we do not store any of your personal data, with the exception of your email address.
Additional Information We Collect
Automatically Collected Information
We collect information automatically as you navigate the site or through our third-party analytics providers. We may store usage information such as the type of device you use to access Korkuma, your operating system, browser type, IP address, and device ID, the pages you visit or request, links clicked, referring sites, user interactions and your search terms. We also derive your location from your self-disclosed country, your IP address, and from your payment card.
From time to time, we may solicit your participation in User surveys to better understand and serve our User base which you may elect to share or not. We collect such information to ensure we provide the best possible service. To the extent that you participate, we will store your survey responses.
Information Collected by Third Parties
How We Use Your Information
We process your information to:
- verify your identity to comply with EU, state, and international laws
- allow you to sign into your account
- process subscription payments
- send you e-mails relevant to your usage, as controlled by your e-mail preferences
- reply to your questions
- provide to you existing and enhanced services related to your Korkuma account
- understand how you use the service, and create better tools for Users to serve Viewers
- conduct research and development to improve Korkuma and develop future products
- prevent fraud and abuse on Korkuma
- provide you with reasonable accommodation, if you notify us of a disability
Information We Share with Users
By becoming a Viewer of a Live Stream event, you agree to have the following information shared with that User:
- email addresses of the User
Information We Share with Third Parties
We never sell your information to third parties. We will only share data with third parties, other than with Users, under the following circumstances:
- with our service providers, who are companies that are contractually engaged with us to provide us with services, such as e-mail management, analysing data trends, credit card processing, multi-currency settlement solutions, increasing our brand awareness and user engagement with marketing initiatives, and fraud detection and prevention. These companies may have access to your data to perform their services and are obligated by contract to safeguard any of your data they receive from us to the same extent that Korkuma protects it.
- to protect the security or integrity of Korkuma, and to protect the rights, property, or safety of Korkuma, its employees, users, or others, if we believe that disclosure is reasonably necessary to comply with a law, regulation, or other valid legal process (e.g., subpoenas or warrants served on Korkuma). If we are going to release your data, we will do our best to provide you promptly with notice by e-mail if applicable, unless we are prohibited by law from doing so.
- with our partners, who may have access to your data to perform their services, and who are obligated by contract to safeguard any of your data they receive from us to the same extent that Korkuma protects it.
In particular your personal data might be processed by following third parties:
Processing of personal data by Users
Authorisation to process personal data
If you appear on Korkuma as a User, Korkuma may authorize you to process the personal data of Viewers in connection with the performance of contractual obligations between the User and Korkuma, within the scope of the data described in the section Information We Share with Users.
Rights and obligations of the User as a processor
The User, as a processor of personal data, is obliged to implement appropriate technical and organisational measures to ensure a level of security appropriate to the risk, taking into account the state of the art, the cost of implementation, the nature, scope, context and purposes of the processing, as well as the differently likely and differently serious risks to the rights and freedoms of natural persons entailed by the processing, and, where appropriate, to take measures, including possible encryption, firewalls, secure devices and access rights systems, pursuant to Article 32 (1) (a) to (d) of the General Data Protection Regulation (GDPR).
Furthermore, the User is obliged to take such measures, together with internal procedures to detect and manage security breaches, taking into account in particular the risks posed by the processing, in particular the accidental or unlawful destruction, loss, alteration or unauthorised disclosure or access to personal data transmitted, stored or otherwise processed.
In accordance with Article 33 (2) of the GDPR, the User is obliged to report the personal data breach to Korkuma without undue delay after becoming aware of the breach. The notification will be made to the following email address: email@example.com.
The User is entitled, on the basis of an explicit instruction from Korkuma, to involve in the processing of personal data other processors who process personal data on the basis of a contractual relationship with the original processor and with whom the original processor - the User has concluded a contract for the processing of personal data. The User as processor shall impose on the additional processors the same data protection obligations as set out in this Policy between Korkuma and the User as processor, in particular the provision of sufficient guarantees regarding the implementation of appropriate technical and organisational measures so that the processing complies with the requirements of the GDPR. If the said further processor fails to fulfil its data protection obligations, the User shall remain liable to Korkuma for the fulfilment of the obligations of the further processor concerned.
As processor, the User undertakes to:
- process personal data only on the basis of documented instructions from Korkuma, including the transfer of personal data to a third country or an international organisation, unless such processing is already required by EU or Member State law to which Korkuma is subject, in which case the User shall inform Korkuma of this legal requirement before processing, unless such legislation prohibits such information for important reasons of public interest;
- ensure that the persons authorised to process personal data are bound by an obligation of confidentiality or are subject to a legal obligation of confidentiality;
- taking into account the nature of the processing, assist Korkuma through appropriate technical and organisational measures, where possible, to comply with Korkuma's obligation to respond to requests to exercise the data subject's rights;
- in accordance with Korkuma's decision, either erase all personal data or return them to Korkuma after the termination of the provision of services related to the processing, and erase existing copies, unless there is a legitimate reason for storing the personal data in question;
- provide Korkuma with all information necessary to demonstrate that the obligations set out in this Article have been complied with and to allow and contribute to audits, including inspections, carried out by Korkuma or any other auditor appointed by Korkuma.
The User, as a processor, is responsible for its employees, contractors and other contractual partners who come into contact with the User's personal data in the performance of their duties and obligations and are obliged to maintain confidentiality of personal data and security measures whose disclosure would compromise the security of personal data in accordance with this Policy and the GDPR. The obligation of confidentiality continues after the end of employment or relevant work. The processor shall supervise the compliance of its employees with these obligations.
The User is obliged to notify Korkuma in a timely manner of any problems that could prevent the proper and timely provision of the subject matter of the performance under this Policy.
Once the purpose of processing personal data within the meaning of this Policy has passed, personal data will no longer be processed. In this case, the data will be irretrievably destroyed as instructed by Korkuma and in accordance with the GDPR and other relevant regulations.
Your Preferences and Rights over Data
Choosing Your Preferences
Settings link lets you see your account preferences. You can see and adjust your settings by viewing your preferences and, if you wish, by changing your selections.
By agreeing to our Terms of Service, you expressly agree that Korkuma may:
- provide you with information about our service, service enhancements, or new Korkuma products, while you are on our web site or using our apps.
- send you messages regarding your existing service, or enhancements related to your existing service, when you are off our Platform, via e-mail, or text, if you have signed up for a service that uses text messages.
- send you messages related to services we provide which are separate from your existing service via e-mail, from which you may opt-out.
- send you marketing e-mails or texts if you don’t have a Korkuma account but have consented to receive such messages, from which you may opt-out.
- promote your scheduled Live Streams for greater discoverability.
Opting out of Marketing
You may object to the use of your data for marketing purposes at any time, free of charge, when we collect your personal information and in every marketing communication. You may also object to the use of your data for marketing upon creation of your account or anytime thereafter by sending a written request to firstname.lastname@example.org.
Opting out will stop marketing e-mails. Please allow up to 30 days for your opt-out request to be processed. If you have an account with Korkuma, you will continue to receive service-related e-mails, and texts, if you have opted into receiving texts.
We will never sell your information to third parties for marketing purposes without your prior consent.
Accessing, Updating or Exporting the Information in Your Account
You can access and update certain information associated with your account on the settings pages.
Deleting Your Account
You can have your account deleted by sending a deletion request to email@example.com. Please be aware that this is a final act and cannot be reversed. If you would like to transport your data, please be sure to download your data first before you delete your account.
Turning off E-mail Notifications
You can change your e-mail notifications in your settings. While this allows you to stop any notification e-mails, we will still send some critical service e-mails.
Turning off Mobile Notifications
If you download the Korkuma App you may also receive notifications on your mobile device. These can be disabled in the App settings.
Verification of Requests
Users maintain password-protected accounts with Korkuma. If you submit a request to exercise your privacy rights, you will be asked to verify the request by logging into your Korkuma account.
If we are unable to verify your request, then for your protection, we reserve the right to deny the request.
Compliance with EU Privacy Laws
Korkuma is an international company that complies with the GDPR. We act as Data Controllers, as defined under the GDPR, and process personal data based on our legitimate interests, and for contractual necessity in providing you the Service as described in “How We Use Your Information.” We also process and share personal information based on notification and Users’ consent, which our Users may revoke at any time.
Your personal data will not be transferred to countries outside of the European Union, unless this is necessary for the performance of the Agreement or for any other reason in accordance with the rules for such transfer laid down in the Regulation.
Exercising Your Data Rights
Users in certain locations may have certain rights under the General Data Protection Regulation (GDPR) regarding data that Korkuma controls as a Data Controller as defined under the GDPR, including:
- the right of access to their personal data;
- the right to correct or rectify any inaccurate personal data;
- the right to restrict or oppose the processing of personal data;
- the right to erase or delete their personal data;
- the right to personal data portability; and
- the right to opt-out of the sale of personal information.
You can exercise rights over your data on Korkuma in the following ways:
- accessing, reviewing, modifying, and updating your data in your account settings.
- deleting a previously-disabled account by e-mailing Korkuma.
- opting out of marketing in your account settings.
- If you are unable to log into your account, and are unable to recover your account with a password reset in order to lodge your privacy request, then you may reach out to us. We reserve the right to decline your access to or recovery of your account, at our discretion, to prevent an unauthorized takeover of your account.
If you have privacy concerns or questions, you can contact us via e-mail.
Prohibition against Discrimination
We do not discriminate against anyone who exercises their privacy rights.
Our Data Retention Period
We retain your account information for ten years after your account is last active, unless you delete, or you request us to delete, your account. We may continue to retain some information, even after you delete your account if we are required to do so in order to comply with various laws.
Korkuma is not directed or intended for children under the age of 13, and we do not knowingly collect personal data from such children. If you believe we might have personal data from a child under the age of 13, please let us know at firstname.lastname@example.org.
We may sometimes make changes to this policy. If we make material changes that adversely affect your rights under this policy, we will let you know by posting an announcement on the site, or where appropriate by sending you an e-mail in advance of the changes coming into effect. Continuing to use Korkuma after a change to this policy means you accept the new policy. If you have any questions, please e-mail us.