Date of Last Modification: (Dec 8, 2021)

(a) Soul Serial LLC, a District of Columbia corporation (“the Company”, “we”, “us”, or “our”) owns and operates the website, https://soulserial.com (Site”). The Company respects the privacy of users and is committed to protecting it. This sets out the Company’s policy and practices (“Policy”) regarding the personal data that we may collect from time to time from our users (individually a “User” and collectively “Users”) at the Site and related applications or services (collectively, the “Services”). By registering or by visiting the Site you, as a User, expressly consent to our collection, use and disclosure of your personal data in accordance with this Policy. You are responsible for reading, understanding and accepting the Policy, which is incorporated into and forms part of our Terms of Service. If you do not agree and accept this Policy please do not use the Site or any of the Services.

(b) The Company has the right to modify, revise and update the Policy from time to time. All changes are effective immediately when the updated Policy is posted on the Site. If substantial changes to this Policy (as determined by the Company in its sole discretion) are made, the Company will notify the registered Users by email. You should check the Policy frequently to ensure that you are aware of any changes, as they are binding on all Users as soon as they are posted. Your continued use of the Site and/or the Services, following the posting of the updated Policy shall be construed as an acceptance and agreement by you to such changes.

(c ) This Policy does not cover information collected elsewhere, including without limitation offline and sites linked to the Site. Therefore we are not responsible for the protection and privacy of any personal data that you independently provide while visiting other sites. You should exercise appropriate caution when visiting other sites. We use a variety of methods to help protect a User’s personal data. Despite these measures you should be aware that the risk associated with submitting your personal data will never be completely eliminated and such data could be accessed through an unauthorized use or through an inadvertent disclosure.

The Company relies on the following legal basis:

(a) Contractual Necessity: To provide Users with the Services and perform the contract that they have with the Company;

(b) Legitimate Interests: It is in the Company’s legitimate interests to improve and analyze the Services, promote our products, prevent fraudulent transactions, maintain security of the Services, and provide functionality; and

(c ) Consent: In instances where the Company seeks your consent, you may refuse or withdraw your consent at any time by contacting us. Please see Section 16 for more information.

(a) The Company may collect the following information about you in a variety of ways. Such information is gathered to enhance the reader and user experience and ensure the continued operation of the Site:

(b) In addition, information that Users voluntarily provide through the Site, such as comments on discussion board posts will be collected and maintained on the Site. Emails sent to the operator of the Site will also be collected and stored.

(c ) Users also have the ability to interact with parts of the Site, such as the ability to access, create, upload and share Stories (as defined in the Terms of Service). Your contributions and/or feedback are published or displayed on public areas of the Site, or transmitted to other users of the Site or third parties (collectively, “User Contributions"). Your User Contributions are posted on and transmitted to others at your own risk. Although you may set certain privacy settings for such information by logging into your account profile on the Site, please note that no security measures are perfect or impenetrable. Additionally, the Company cannot control the actions of other users of the Site with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed or accessed by unauthorized persons. Use caution when posting any personal information online. Please review our Terms of Service for more information.

(d) When you provide the Company with information in connection with any particular activity featured on the Site or otherwise sign up for or order our products and Services or provide your contact information, including your email address in connection with that activity, product or service, you agree that such action constitutes a purchase or inquiry establishing a business relationship with the Company. You expressly consent to receiving communications from the Company based on the information you provided. For more information on how to access and control your communication preferences, please see Section 9 below.

(e) The Company and its operational service providers (“our Service Providers”) use cookies or similar technologies, which store certain information on your computer and allows us to, among other things, analyze trends, administer the Site, and to gather demographic information about our user base as a whole. The technology used to collect information automatically from Users may include the following:

The Company may also receive information about Users from third parties. For example, we and our Service Providers may use a variety of other technologies (such as tags) that collect statistical data relating to your Site activity for security and fraud detection purposes.

Do Not Track (“DNT”), a privacy preference that Users can set in some web browsers allows Users to opt out of tracking by websites and online services. The Company does not honor DNT requests, but our cookie policy set out in Section 3 (e) (i) above, describes how you can opt out of receiving cookies.

Any User, living in a country in the European Union, must be at least 18 years old, or such older age as may be legally required in his/her country, to register for or use the Site and Services. Any User living in any other country outside the European Union must be at least 13 years old, or such older age as may be legally required in his/her country, to register for or use the Site and Services. If a User is under the required age, he/she must not use the Site or Services, even if the laws of the country where the User lives, do not prohibit such use, unless that particular User’s parent or legal guardian agrees, on behalf of the underaged User, to be bound by the Terms of Service and this Policy. We do not knowingly collect any personal information or knowingly solicit information from or market to children under the age of 13. If you become aware of any personal data that we may have collected from children under the age of 13, please contact us using the information provided in Section 16 below. By accessing and using the Site and/or the Services, a User represents that he/she is of the minimum required age as described above and if not, that his/her parent or legal guardian has agreed to and accepted the Policy on behalf of the relevant User.

The Company uses the information that we collect about Users or that are provided to us, including any Personal Data, in the following manner:
(a) to provide Users with an account on the Site;

(b) to allow you to access, create, upload and share Stories (as defined in the Terms of Service) on the Site;

(c ) to send a periodic digital newsletter or promotional information about the Site and the Services or offers from the Company or other parties that may be of interest to Users;

(d) to notify Users of updates to the Site or Services;

(e) to contact Users about their use of the Site and Services and to request feedback;

(f) to perform any necessary business activity;

(g) to increase efficiency and operation of the Site and Services;

(h) to monitor and analyze usage and trends to improve Users’ experience with the Site and Services:

(i) to address any inquiries from Users;

(j) to offer new products, services and recommendations to Users;

(k) to troubleshoot problems and resolve disputes; and

(l) to take any other actions that are permitted with the consent of the User concerned.

The Company does not sell the personal data of Users to third-parties. However the Company may share information we receive about you as follows or as otherwise described in this Policy:

(a) With Service Providers and Network Partners – The Company employs or may employ third party companies and individuals to provide web related services, including without limitation, technical maintenance and assistance, database management, web analytics, payment processors, advertising networks, email service providers, help desk providers, fraud detection, accountants, law firms and auditors and for the improvement of the Site’s features or to assist us in analyzing how the Site is used. These third parties may have limited access to our database, but only for the purpose of and to the extent necessary, to provide those services, and as a User, you expressly consent to the sharing of your personal data with our Service Providers and network partners.

(b) For corporate transactions – The Company does not sell or lease your personal data to third parties for marketing purposes. We may however, share information, including personal data, with any current or future subsidiaries or affiliates of the Company, primarily for business and operational purposes. The Company may sell, transfer, or otherwise share some or all of its assets, including the personal data of Users, in connection with a merger, acquisition, reorganization or sale of assets (including, in each case, as part of the due-diligence process with any potential acquiring entity) or in the event of bankruptcy.

(c ) When Required by Law – The Company will share information with government and law enforcement agencies as required by law, including to meet national security or law enforcement requirements and, including without limitation, in connection with reporting earnings. The Company will cooperate with government and law enforcement agencies to enforce and comply with the law. The Company will disclose information about Users to government or law enforcement agencies as we, in our sole discretion, deem necessary or appropriate to respond to claims and legal process (including but not limited to subpoenas), or, at the request of such government and law agencies or other third parties conducting any investigation, where the Company determines, in our sole discretion, that such disclosure is necessary to (i) protect the property and rights of the Company or a third party, (ii) protect the safety of the public or any person, or (iii) prevent or stop activities that the Company may consider to be, or pose a risk of being, illegal, fraudulent, unethical or legally actionable.

(d) With your Consent – Users may submit personal data to the Company through a form on the Site and consent to receive communication from the Company or our business affiliates and non-affiliates based on the information provided in the relevant form.

Users have certain rights under privacy laws regarding the personal data that is provided when accessing and/or using the Site and Services. These rights include the following:

(a) Access – the right to be informed of and request access to the personal data that the Company processes about the User.

(b) Opt out – the right to opt-out of receiving marketing emails from the Company. We reserve the right to send Users certain communications relating to their account or use of the Services (for example, administrative and service announcements) via email and other means and these transactional account messages may be unaffected even if the relevant User opts-out of receiving marketing communications.

(c) Rectification – the right to request that the Company amends or updates your personal data where it is inaccurate or incomplete.

(d) Deletion – the right to request that the Company deletes your personal data. However, such right is not absolute and can be overridden to enable the Company to continue data processing in certain cases where the Company still has a legitimate interest to process your personal data.

(e) Restriction – the right to request that the Company temporarily or permanently stops processing all or some of your personal data. Notwithstanding the restriction request, the Company is permitted to store your personal data but not to process it any further.

(f) Objection – the right to object to the processing of your personal data by the Company, on grounds relating to your personal situation or relating to direct marketing.

(g) Details of Users’ Personal Data – the right to a copy of the User’s personal data that was provided to the Company by the User and the right to transfer such personal data for use in another party’s service.

(h) Automated Processing – the right to be excluded from a decision based solely on automated processing, including profiling, where the decision would have a legal effect on the User or produce a similarly significant effect.

(i) Sale of Personal Data – the right to know if and to whom your personal data is sold or disclosed and the right to request that the Company does not sell your personal data.

(j) Fairness – the right to equal service and price without any discrimination, even if the User exercises his/her privacy rights.

For more information on how to exercise a User’s rights regarding personal data, you can contact the Company in writing using the information provided in Section 16 below. The Company may require you to verify your credentials, by matching your email address, or other account information to the information in the Company’s systems, before your request is implemented. Notwithstanding any action taken to implement your request, please note that the Company may need to retain certain information for our records and to complete any outstanding transactions or as required by law.

If the User resides in one of the countries in the European Union, your privacy rights may be subject to the General Data Protection Regulations (“GDPR”) as modified or replaced from time to time. Currently, Article 45 of the GDPR affords a higher level of protection of personal data. The Company relies on derogations for specific situations as defined in Article 49 of the GDPR. If you are a User from the European Union or from another country, your personal data may, with your consent, be transferred to the United States or other countries when you access and interact with the Site and/or the Services or when you request information from the Company. The Company will use your personal data for the performance of a contract with you when you purchase goods and/or services, or to fulfill a compelling legitimate interest of the Company, in a manner that does not outweigh your rights as a User. Whenever the Company transfers, processes or stores your personal data, we will apply reasonable safeguards to protect it. The Company will use the information we collect from you in accordance with the Policy. The Company may also enter into data processing agreements when appropriate and by using the Site, Services or related products you consent to the transfers of your personal data as described here.

(a) The California Consumer Privacy Act 2018 (“CCPA”) creates additional consumer rights relating to the access, deletion of and sharing of personal data that is collected by businesses. While the Company does not sell your personal data to any third party, we may partner with third party service providers and affiliate partners who may gain access to your personal data through the use of beacons, tracking pixels or cookies as provided in this Policy. If you are a California resident, the CCPA may provide you with additional rights regarding our use of your personal data.

(b) To the extent that the Site is a covered business under the CCPA, a User residing in California is entitled, once a year and free of charge, to request and obtain from the Company information about the categories of personal data (if any), that we have disclosed to third parties for direct marketing purposes and the names and addresses of all third parties with whom we have shared your personal data during the immediately preceding 12-month period. Any request under this provision must be submitted in writing to the address provided in Section 16 below.

(c) If you are at least 18 years of age, reside in California and have provided personal data while using the Site and/or the Services, you have the right to request the removal of unwanted data that you have publicly posted on the Site. Any request under this provision for the removal of such data must be submitted in writing to the address provided in Section 16 below, and shall include sufficient detail about the public post(s) and a statement that the User resides in California. While the Company will ensure that such data is not publicly displayed on the Site, please note that it may not be completely or comprehensively removed from our systems, nor can we guarantee that such data would be removed from any cached or archived version of the Site.

(d) For more information on how to exercise your rights, you can contact us in writing using the contact information provided in Section 16 below. The Company may require you to verify your credentials, by matching your email address, or other account information to the information existing in our systems, before your request is implemented. Notwithstanding any action taken to implement your request, please note that the Company may need to retain certain information for our records and to complete any outstanding transactions or as required by law.

(e) If a User authorizes another person to act as his/her agent to submit requests on the User’s behalf, then unless the User provides the agent with a valid power of attorney under the California Probate Code, the Company would require (i) that the agent provides the Company with the written and signed authorization that the User provided to the agent; (ii) the User’s written confirmation that he/she did provide the relevant authorization for the agent; and (iii) verification of the relevant User’s identity.

The Site and the Services are hosted and offered in the United States of America (“US”), and are subject to US federal, state, and local law. If you are accessing the Site and Services from another country, please note that as you may be transferring your personal data to the US, you consent to such transfer, processing and storage of your personal data in accordance with this Policy. You also agree to abide by the applicable US federal, state, and local laws concerning your use of the Site and Services and your agreements with the Company. Any User who accesses the Site and/or Services from any jurisdiction with laws or regulations governing the use of the internet, including the collection, use, or disclosure of personal data, that are different from the US jurisdictions mentioned above, may only use the Site and Services in a manner that does not violate the laws and regulations of the country to which the User is subject. If the use of the Site and Services would be unlawful in the User’s jurisdiction, the User should not use the Site or the Services.

We use physical, technical and organizational measures designed to protect your Personal Data against unauthorized access, theft and loss. We restrict access to your Personal Data to those of Our Service Providers and employees who need to know that information to service your account or perform their job functions.

Although we take precautions intended to help protect Personal Data that we process, no system or electronic data transmission is completely secure. Any transmission of your Personal Data is at your own risk and we expect that you will use appropriate security measures to protect it.

You are responsible for maintaining the security of your account and the Personal Data in your account. We may suspend your use of all or part of the Website and Services without notice, if we suspect or detect any breach of security. You understand and agree that we may deliver electronic notifications about breaches of security to the email address on record on your account.

(a) Unless the User requests that the Company deletes certain information in accordance with Section 9, we will retain your personal data for the period necessary to fulfill the purposes outlined in this Policy or such longer retention period as required or permitted by law.

(b) The criteria used to determine the retention periods include:

The Site may include links to third-party websites, services and applications of interest, including advertisements and other external services that are not affiliated with the Company. When you use these links to leave the Site, any information you provide to these third parties is not covered by this Policy and we cannot guarantee the safety and privacy of your personal data. A link to a third-party website, service or application does not mean that the Company endorses it or the quality or accuracy of information presented on it. If you decide to visit a third-party website or service, you are subject to that third party’s privacy practices and policies, not the Company’s.

You can contact the Company by sending a written notice to: [email protected]