Soma Privacy Policy

This Soma Privacy Policy (the "Policy") includes the way we process information that is provided or collected in the Soma application (the “Soma”) service (the "Service"). In addition, the Policy also defines the information provided or collected in the course of using the applications which exist in the websites or platforms of other companies.

Through this Policy, the Company considers the personal information (the “Personal Information”) of the users important as the controller of the Personal Information. It informs them of the purpose and method of using the Personal Information provided by the users and the measures taken by the Company for the protection of the Personal Information.

This Policy will be effective on the 16th May 2022, and, in case of modification thereof, the Company will post it onto www.somaworld.com for public notice.

1. Information to be collected and method of collection

(1) Personal information items to be collected

Personal information items to be collected by the Company are as follows:

• Information provided by the users
  

The Company may collect the information directly provided by the users.

• Information is collected while the users use services
  

Besides information directly provided by the users, the Company may collect information in the course that the users use the service provided by the Company.

List and Items to be collected

Equipment information

• Hardware model name, operation system, hardware version, type and set-up of the browser, the browser's language, information of the device being used such as mobile network information, installed application information, etc.

Other information

• If conflicts or other errors occur while users are using the Service, the Company may collect the information on specific devices necessary to identify the cause of such problems.
  

(2) Method of collection

The Company collects the information of users in the way of the following:

• webpage, written form, e-mailing, tools for collection of created information
• provided by partner companies

2. Use of collected information

The Company uses the collected information of users for the following purposes:

• Member management and identification
• To detect and deter unauthorized or fraudulent use of or abuse of the Service
• Improvement of existing services and development of new services
• Making notice of function of company sites or applications or matters on policy change
• To provide information on promotional events as well as opportunity to participate
• To create users’ characters
• To comply with applicable laws or legal obligation
• Use of information with the prior consent of the users (for example, utilization of marketing advertisement)
  

Soma entrusts part of its operations to third-party businesses to provide more convenient and improved services.

Processing personal information by the Company shall be lawful only if and to the extent that at least one of the following applies:

• A user has given consent to the processing of their personal information.
• Processing is necessary for the performance of a contract to which a user is a party or to take steps at the request of a user before entering into a contract:

• Member management, identification, etc.
• Performance of a contract in relation to providing the services required by users, payment and settlement of fees, etc.

• Processing is necessary for compliance with a legal obligation to which the Company is subject.
• Compliance with relevant law, regulations, legal proceedings, requests by the government
• Processing is necessary to protect the vital interests of users or other natural persons.
• Detection of, prevention of, and response to fraud, abuse, security risks, and technical issues that may harm users or other natural persons
• Processing is necessary for the performance of a task carried out in the public interest or the excise of official authority vested in the Company.
• Processing is necessary for the legitimate interests pursued by the Company or by a third party (except where such interests are overridden by the interests or fundamental rights and freedoms of the data subject that require protection of personal data, mainly where the data subject is a child)

3. Disclosure of collected information

Except for the following cases, the Company will not disclose the Personal Information with a 3rd party:

• when the Company discloses the information with its affiliates, partners, and service providers;

• when the Company’s affiliates, partners, and service providers carry out services such as bill payment, execution of orders, products delivery, and dispute resolution (including disputes on payment and delivery) for and on behalf of the Company

• when the users’ consent to disclose in advance;

• when the user selects to be provided by the information of products and services of certain companies by sharing their personal information with those companies
• when the user selects to allow their personal information to be shared with the sites or platform of other companies such as social networking sites
• other cases where the user gives prior consent for sharing their personal information

• when the laws require disclosure:

• if required to be disclosed by the laws and regulations; or
• if required to be disclosed by the investigative agencies for detecting crimes in accordance with the procedure and method as prescribed in the laws and regulations

4. Cookies, Beacons, and Similar Technologies

We do not use these technologies to collect the information of users.

5. User’s Rights

The users or their legal representatives, as main agents of the information, may exercise the following rights regarding the collection, use, and sharing of personal information by the Company:

• The right to access to personal information;

• The users or their legal representatives may access the information and check the collection, use, and sharing of the information under the applicable law.

• The right to rectification;

• The users or their legal representatives may request to correct inaccurate or incomplete information.

• The right to erasure;

• The users or their legal representatives may request the deletion of the information after achieving their purpose and the withdrawal of their consent.
• However, the Company will not be able to erase some personal data due to the following reasons according to Article 17 of the EU GDPR(General Data Protection Regulation).
• The processing of your data is necessary for compliance with a legal obligation.
• The processing of your data is necessary for the establishment, exercise, or defense of legal claims.

• The right to restriction of processing;

• The users or their legal representatives may temporarily suspend the treatment of personal information in case of disputes over the accuracy of the information and the legality of information treatment, or if necessary, retain the information.

• The right to data portability

• The users or their legal representatives may request to provide or transfer the information.

• The right to object

• The users or their legal representatives may suspend the treatment of personal information if the information is used for direct marketing, reasonable interests, the exercise of official duties and authority, and research and statistics.

• The right to automated individual decision-making, including profiling

• The users or their legal representatives may request to cease the automated treatment of personal information, including profiling, which has a critical impact or cause a legal effect on them.
  

If, in order to exercise the above rights, you, as a user, contact the Company by sending an email to contact@somaworld.com, the Company will take measures without delay: Provided that the Company may reject the request of you only to the extent that there exists either proper cause as prescribed in the laws or equivalent cause.

6. User’s Obligations

The users shall keep their personal information up to date and be liable for the problems arising from or in connection with the information incorrectly input by themselves.

The users are responsible for ensuring and maintaining the security of their information such as Soma ID, email address, etc.. They shall neither assign nor lend such information to a 3rd party. The Company shall not be held responsible for any problems related to personal information that may arise out of or concerning the mistakes made by individual members or the cause not attributable to the Company.

The users shall appropriately manage their personal information, take full responsibility for such management, and be liable for the cooperation with the request of the Company to change the password regularly under this Policy.

The users shall comply with the applicable laws and statutes of personal information protection in each country.

7. Security

The Company regards the security of the Personal Information as very important. The Company constructs the following security measures to protect the Personal Information from any unauthorized access, release, use, or modification.

• Encryption of personal information

• Transmit users' personal information by using an encrypted communication zone
• Store important information such as passwords after encrypting it

• Countermeasures against hacking

• Install a system in the zone the external access to which is controlled to prevent leakage or damage of users' personal information by hacking or computer virus

• Establish and execute an internal management plan
• Install and operate access control system

8. Children

The Company does not knowingly collect any information from the children under 13 or equivalent minimum age as prescribed in the laws in the relevant jurisdiction. The Soma app employs a compliant neutral age-gate to prevent children from accessing the service. Suppose Soma obtains actual knowledge during the business that the app has collected personal information from a child. In that case, Soma will delete all related information from our records, closing the account.

If you'd like to report an account that you believe belongs to someone under 13, please get in contact with us via contact@somaworld.com. We will take appropriate action when we receive your report.

9. Modification of Privacy Protection Policy

The Company has the right to amend or modify this Policy from time to time and, in such case, the Company will make a public notice of it through pop-up of its service (or through individual notice such as e-mail) and obtain consent from the users if required by relevant laws.

In the event of a change to this Privacy Policy, the Company will announce the amendment reason and effective date seven days before the effective date of the change.

10. Others

A. Data transfer to other countries

Considering it engages in global businesses, the Company may provide the Personal Information to the companies located in other countries for the purpose as expressly stated in this Policy. For the places where the personal information is transmitted, retained, or processed, the Company takes reasonable measures for protecting that personal information.