1. GENERAL

1.1. Koogi is an internet-based digital subscription service that gives you (hereinafter “You” or the “User”) access to streaming videos and podcasts on Your mobile phone or on Your tablet or other devices (the “Service”) pursuant to the terms and conditions of the User Agreement (the “Terms”). The Service is provided by Kooji International Minority Education, inc. (hereinafter ”Koogi” or “we”). This privacy policy explains Koogi’s practices regarding its collection, use, and disclosure of certain information, including Your personal information when we provide the Service to You. It serves to inform You about our processing of Your personal information and ensure that Your personal information is treated with respect and in accordance with the applicable data protection legislation when using the Service.

1.2. You should always feel safe when sharing Your personal information with Koogi. Koogi has taken the technical and organizational security measures that are required to ensure that Your personal information is protected from unauthorized access, use, modification, and deletion.

2. PERSONAL DATA CONTROLLER

2.1. Kooji International Minority Education, inc. is the data controller for the processing of Your personal information handled by Koogi. Information on how to contact us can be found in section 12.

3. WHEN DOES KOOGI COLLECT PERSONAL DATA?

3.1. Koogi collects Personal Information about You when:

– You set up an account with Koogi and use the Service,

– You order an add-on service or a product from Koogi,

– You register as a subscriber to Koogi’s newsletter,

– You report errors or contact Koogi’s customer services for any other reason,

– You link the Service to Your Facebook account,

– You answer a survey, including but not limited to customer satisfaction questionnaires or marketing surveys, or reply to a communication from Koogi, or

– It is otherwise necessary to manage the relationship between You and Koogi.

3.2. Koogi also collects information through our own or third-party cookies and similar tracking technologies that may track Your activities and choices, i.e. when You use the Service or visit our website. Further information about Koogi’s use of cookies is stated in Koogi’s cookie policy.

4. WHAT PERSONAL DATA DOES KOOGI COLLECT?

4.1. When You set up an account with Koogi or contact Koogi’s customer services, Koogi collects personal information about You. Basic user data that Koogi collects include Your name and/or user name, e-mail address and/or phone number, and Your payment details. Koogi may also collect data regarding Your date of birth, gender, and additional contact details such as Your address. Koogi may also collect personal information that You provide about Your family members (including Your family members’ names, dates of birth, and their interests). When using the Service or any additional Koogi services and products, and when visiting Koogi‘s website, Koogi may also collect data concerning usage, viewing, and technical data, including Your IP address. If, when You signed up as a customer with Koogi, You signed up as an invoice customer, Koogi may also need to collect and process some of the information You provide to Koogi’s payment service provider to facilitate such invoicing.

4.2. If You choose to link the Service to Facebook, Koogi may collect information that You give Facebook permission to share with Koogi.

4.3. Further Koogi may also collect and process Information that You provide in public forums on Koogi‘s website or to Koogi when You use Koogi’s website, Koogi’s sites on third-party platforms such as social networking sites or link Your profile on a third-party site or platform with Your personal account.

4.4. Koogi may also collect and process certain information related to Your chosen method of payment. The personal information collected by Koogi for this purpose serves to check Your eligibility for the Service and to identify Your method of payment. However, as Koogi cooperates with third party payment service providers who operate independently in systems separated from Koogi, no complete payment data, such as complete credit card numbers, will be stored or collected by Koogi.

5. HOW LONG IS THE DATA KEPT?

Koogi will keep personal information regarding You only as long as it is necessary, having regard to the purpose of the processing. This means that personal information collected and processed for marketing purposes will be stored for as long as You have an account and deleted twelve (12) months after Your subscription has ended unless You have given Koogi Your voluntary consent to continue to process such data. In order to monitor usage of gift cards and Free Trial periods, we will store the basic information You have provided at sign-up (Your name and/or user name, e-mail address and/or phone number, and payment details) for a period of twenty-four (24) months after Your subscription, use of a gift card or Free Trial has ended. We will also, during the same period, keep Your personal Koogi requests & media library information, to facilitate Your easy return. Koogi may store data for longer if required by law or if required in order to monitor Koogi’s legal interests, for example, if there are ongoing legal proceedings.

6. WHY DOES KOOGI PROCESS INFORMATION ABOUT YOU?

6.1. Koogi processes Your personal information for various purposes. Primarily, Koogi processes Your personal information in order to provide, manage, develop and customize the Service and its features, to manage the customer relationship with You and to meet security and other statutory requirements. Your personal information may also provide the basis for market and customer analysis, market research, statistics, business monitoring, and business and methodological development for Koogi. This may e.g. include processing of personal data for the purpose of creating customer audiences on third party platforms.

6.2. Koogi also processes Your personal information to provide better and more personalized offers and services. Personal information may, for example, be processed, linked, segmented and analyzed in order, by means of targeted marketing, to provide information, offers, or recommendations on Koogi or its partners’ goods and services, which are tailored to Your preferences, behaviors, needs or lifestyle. Koogi may also analyze and combine the information about You to which Koogi has access via the Service from Your online visits or other records (e.g. Facebook or other similar social media providers) for purposes specified in this section.

6.3. In addition to the above, Koogi processes Your personal information to prevent, detect and investigate potential prohibited or illegal activities, including fraud, and to enforce our terms of use (e.g. determining whether You are eligible for a Free Trial period or for any other offer or marketing campaign as the case may be).

7. WHAT IS THE LEGAL BASIS FOR THE PROCESSING?

7.1. A majority of the personal information that Koogi processes about You are processed because it is necessary for Koogi’s performance of the Terms, i.e. in order for Koogi to be able to provide and administer the Service and its features. Such is the case when Koogi processes, inter alia, Your contact information such as Your e-mail address or Your phone number and information from the payment service provider.

7.2. Some of the personal information that Koogi processes are processed based on a balance of interest, i.e. Koogi’s interest in processing the data outweighs the impact and risk the processing may have on Your integrity. Such is the case when Koogi processes Your data for marketing purposes and when we store Your Koogi audio/e-book library information after your subscription has ended.

7.3. Additionally, some data is processed based on Your consent. This is the case for the processing of such data that Koogi gets access to via Your Facebook account and for marketing of Koogi’s partners’ goods and services.

7.4. To the extent that processing is carried out on the basis of consent, it is voluntary for You to give such consent and You may at any time, wholly or partly, withdraw Your consent. If You choose to withdraw Your consent, and Koogi’s processing is such that it requires Your consent, the processing will be carried out in accordance with Your most recently given consent.

8. DATA SECURITY AND INTEGRITY

The security, integrity, and confidentiality of Your personal information is all important to us. We have implemented technical, administrative, and physical security measures that are designed to protect Your personal information from unauthorized disclosure, use, and modification. From time to time, we review our security procedures in order to assess the need to implement additional measures or to make technical upgrades to existing procedures. Please be aware that, despite our best efforts, few security measures are impenetrable and we therefore kindly ask that You inform us immediately of any suspicious activities that You notice in the Service.

9. WHO DOES KOOGI GIVE THE DATA TO?

9.1. Koogi may disclose Your personal information to affiliates, business partners, and other third parties in order to fulfill the agreement with You or to fulfil agreements with Koogi’s suppliers and partners.

9.2. Koogi may also disclose personal information to companies that process personal information on our behalfs, such as our IT system providers, customer service companies, and affiliates. If personal information is disclosed to such companies that process data on Koogi’s behalf, Koogi enters into data processing agreements with such parties in order to ensure that a high level of security for Your personal information is maintained.

9.3. Personal information may also be disclosed, if needed, to comply with statutory legal requirements or requirements from authorities or agencies, to safeguard Koogi’s legal interests, or to detect, prevent, or pay attention to fraud and other security or technical issues.

9.4. Your personal information may be transferred to or stored in a country outside the EU/EEA. If Your personal information is transferred or stored outside the EU / EEA, special safety measures will be taken, we will e.g. ensure that such transfer is carried out in accordance with this privacy policy and as permitted by the applicable laws on data protection, for example through the use of data transfer agreements that includes de standardized EU-model clauses for transfer of data adopted by the EU Commission and that are available on the EU Commission’s website.

10. LINKS TO EXTERNAL WEBSITES

Information provided by Koogi may contain links to websites operated or owned by someone other than Koogi. Koogi is not responsible for the processing of personal information carried out on these websites. Koogi encourages You to read through the information regarding the processing of personal information that is available at the respective website.

11. CHANGES TO THE PRIVACY POLICY

This privacy policy may be revised from time to time. If Koogi makes any significant changes to the privacy policy, Koogi will inform You by e-mail or through the Service before the changes take effect. The privacy policy will also be published on Koogi’s website. If any change requires Your consent, Koogi will obtain new consent from You.

12. RIGHT TO REQUEST INFORMATION AND CORRECTIONS ETC.

12.1. You have the right to be given free information about, inter alia, the personal information that Koogi processes on You and for what purpose Koogi is processing Your personal information (so-called record extract). Any such request for a record extract must be made in writing and be signed by You.

12.2. You are also entitled to have inaccurate, misleading, or incomplete data corrected, anonymized or deleted. You are also entitled to request Koogi to restrict the processing of Your personal information and to object to the processing. Furthermore, You may exercise Your right to data portability, which means that You have the right to receive the personal information processed about You in a structured, commonly used and machine-readable format.

12.3. Please note that some of the rights above only may be exercised in certain situations, e.g. the right to data portability, which only applies when the processing is carried out on the basis of an agreement or a consent and if the processing is carried out by automated means. In case You have any questions regarding how Koogi processes Your personal information, want to exercise any of Your rights or want to know more about the rights, You may contact us as indicated below.

E-mail address: support@koogi.tv
Address: Attention: Support, 5 Woodstone Dr, Cedar Grove, New Jersey 07009, USA

12.4. If You do not want Koogi to process Your personal information for direct marketing, You can give written notice thereof to Koogi. In each newsletter, You will also be informed that You can opt out of receiving further newsletters.

12.5. You are also entitled to lodge a complaint with a supervisory authority if You consider that Your personal information has been processed in contradiction with applicable data protection legislation.

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Last reviewed on 12 June 2022
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