Privacy Policy

Introduction

Welcome to the SoukMedia website privacy policy (Policy).

SoukMedia respects your privacy and is committed to protecting your personal data. This Policy aims to give you information on how we collect and process your personal data through your use of any of our websites detailed below (Our Websites), including any personal data you may provide when you subscribe to our regular newsletter service or engage with us for our services (as set out in clause 4.1 below), regardless of where you visit Our Websites from, and tells you about your privacy rights and how the law protects you.

We gather and process data in accordance with the prevailing data protection legislation, including the General Data Protection Regulation (GDPR) 2016 and the Data Protection Act 2018.

This Policy applies to the following SoukMedia companies:
 

• SoukMedia LLC (registered in the USA whose state of incorporation is Wyoming, USA under EIN # 30-1332902 and business address is 1007 N Orange St., 4th Floor,Suite #2833, Wilmington, Delaware, 19801, USA);

• SoukMedia Global Pte. Ltd. (registered in Singapore under number 202019990Z whose address is 68, Circular Road #02-01, 049422, Singapore); and

• Souk Media Private Limited (registered in India under number U22300DL2018PTC338962 whose registered address is 1/22, 2nd Floor, Asaf Ai Road, New Delhi - 110002).

(Collectively “we”, “us” or “our”).
 

Our Websites are:

• soukmedia.co; soukmediaglobal.com

• upcoming.global; upcoming.buzz

• Adyoda.com; adyoda.net 

• Adyoda.net

1. Purpose of this Policy
    

   This Policy, together with our Bookings Terms and Conditions (a copy of which can be found here: Link to Terms and Conditionsset out the basis on which we will process personal data we collect about you, or that you provide to us. It is important that you read this Policy together with any other privacy policy or fair processing policy we may provide on specific occasions when we are collecting or processing personal data about you so that you are fully aware of how and why we are using your data. This Policy supplements other notices and privacy policies of ours and is not intended to override them.

   Please also use the Glossary at clause 16 to understand the meaning of some of the terms used in this Policy.
   
    

2. Important information and who we are
    

   1. Controller
       

      We are the controller and responsible for your personal data.

      We have a data privacy manager who is responsible for overseeing questions in relation to this privacy policy. If you have any questions about this privacy policy, including any requests to exercise your legal rights, please contact the data privacy manager using the details set out below.
       

   2. Contact details
       

      If you have any questions about this Policy or our privacy practices, please contact our data privacy manager in the following ways:

      1. Full name of legal entity: SoukMedia LLC 

      2. Email address: privacy@soukmedia.co;

      3. Postal address: Data Compliance Officer, SoukMedia LLC 1007 N Orange St., 4th Floor, Suite #2833, Wilmington, Delaware, USA.
          

   3. Changes to this Policy and your duty to inform us of changes
       

      We keep our Policy under regular review. This version was last updated on 1st February 2024.

      It is important that the personal data we hold about you is accurate and current. Please keep us informed if your personal data changes during your relationship with us.
       

   4. Third-party links
      
      Our Websites may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy statements. When you leave Our Websites, we encourage you to read the privacy policy of every website you visit.
       

   5. Personal data, or personal information, means any information about an individual from which that person can be identified. It does not include data where the identity has been removed (anonymous data).

      
      We may collect and process the following data about you; Information that you provide:

       

      
      By filling in forms on Our Websites.

      Registering to use Our Websites.

      Subscribing to our newsletter services.

      When attending trade shows or events, webinars.

      Requesting further information, services or content.

      Completing surveys that we use for research purposes.

      
      We may collect, use, store and transfer different kinds of personal data about you which we have grouped together as follows:

      
      Identity Data includes first name, last name, username, job title, company affiliation or similar identifier and title, and attributes concerning your job.
      
      Contact Data includes billing address, delivery address, email address and telephone numbers.
      
      Transaction Data includes details about payments to and from you and other details of products and services you have purchased from us.
      
      Technical Data includes details of the computer or other device that you are using, internet protocol (IP) address, operating system and browser type and version, time zone setting and location, browser plug-in types and versions, details of your language settings, location data, weblogs, operating system and platform, and other technology on the devices you use to access Our Websites. We may collect such information for system administration purposes. We may aggregate such information and provide it to our advertisers. This is statistical data concerning browsing actions and
      patterns, and does not identify you as an individual.
      
      Profile Data includes purchases or orders made by you, your preferences, feedback and survey responses.
      
      Usage Data includes information about how you use Our Websites, products and services.
      
      Marketing and Communications Data includes your preferences in receiving marketing from us and your communication preferences.
      
      We also collect, use and share Aggregated Data such as statistical or demographic data for any purpose. Aggregated Data could be derived from your personal data but is not considered personal data in law as this data will not directly or indirectly reveal your identity. For example, we may aggregate your Usage Data to create a report on trends in the usage of Our Websites, or calculate the percentage of users accessing a specific website feature. However, if we combine or connect Aggregated Data with your personal data so that it can directly or indirectly identify you, we treat the combined data as personal data which will be used in accordance with this Policy.

      
      We do not collect any Special Categories of Personal Data about you (this includes details about your race or ethnicity, religious or philosophical beliefs, sex life, sexual orientation, political opinions, trade union membership, information about your health, and genetic and biometric data). Nor do
      we collect any information about criminal convictions and offences.
      
      We have implemented appropriate security measures to protect information from:
      
      Loss; Misuse; Unauthorised access; Disclosure; Alteration; Destruction. 

      
      Our security systems include authenticated access to internal databases. We also encrypt and anonymise data wherever it is appropriate to do so. We regularly take back-ups of our data. We regularly review overall Web security and audit procedures.

      
      In conforming with data protection laws, we endeavour to implement appropriate procedures to protect your personal data and to prevent any unauthorised access or misuse of it. We use third party cloud servers, on which your personal data is stored and accessed through big data queries from our side. We rely on these third party data servers for any data protection.

      
      Please be aware that the transmission of information via the internet is not completely secure. Although we will do our best to protect your personal data, we cannot guarantee the security of your data when transmitted via the internet to our site: any such transmission is at your own risk.
       

3. How is your personal data collected?
   
   We use different methods to collect data from and about you including through:
    

   1. Direct interactions. You may give us your Identity, Contact and Financial Data by filling in forms or by corresponding with us by post, phone, email or otherwise. This includes personal data you provide when you:

      1. enter into a contract to purchase our products or services;

      2. create an account with us;

      3. subscribe to our ‘newsletter’ service or publications including research papers, eBooks, Whitepapers, Case Studies, Videos, Surveys responses, etc

      4. request marketing material to be sent to you;

      5. enter our events, webinars, promotion or survey; or

      6. give us feedback or contact us.
          

   2. Third parties or publicly available sources. We will receive personal data about you from various third parties and public sources.
       

   3. Technical Data. We will receive Technical Data from the following parties:
       

      1. In common with the majority of comparable trading companies that use the internet we occasionally use your personal data to help Analytic Suppliers match relevant ads to you using the data analytics of those Analytic Suppliers. However, we only use the data in that way where you are a subscriber to the services of Analytic Suppliers and have therefore agreed to this service by acceding to the relevant Agreements of those Analytic Suppliers. Analytic Suppliers supply us with statistical information on how users interact with Our Websites to help us improve our user experience. This can include the use of online information from third parties who may not have a relationship with you and who collect online information using cookies or similar technologies, such as pixels tags and device identifiers, as you browse the Internet and interact with websites. We use this information to understand your interests and needs, making your advertising and communications more relevant. For more information on how we use cookies please view our cookie policy. Our Analytic Suppliers include: Facebook; Google; Twitter and Microsoft. Our third parties Include: AdRoll/NexRoll; Avocet; Eyeota; Google; Outbrain; Taboola;

      2. Identity and Contact Data from publicly available sources such as Companies House.
          

4. How we use your personal data?
   
    

   We will only use your personal data when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

   
   Where we need to perform the contract we are about to enter into or have entered into with you.
   Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
   Where we need to comply with a legal obligation.
   To ensure that content from Our Websites is presented in the most effective manner for you and for your computer.
   To provide you with relevant information, products or services of a type that you request from us or which we feel may interest you.
   To allow you to use the interactive features of our service, when you choose to do so.
   To notify you about changes to our service.

   
   You have the right to withdraw consent to marketing at any time by contacting us.

   
   In the performance of our services, we obtain information about individuals from third party sources such as data licensors.

   This may mean that we hold data about individuals even though they have not knowingly interacted with us. 
   To comply with our legal obligations, we rely on legitimate interests as a legal basis for processing such personal data and we do not obtain consent prior to sending direct marketing communications, but we do obtain consent prior to transferring data to a third party (who may then send their own marketing communications).
    

Purposes for which we will use your personal data

We have set out below, in a table format, a description of all the ways we plan to use your personal data, and which of the legal bases we rely on to do so. We have also identified what our legitimate interests are where appropriate.
Note that we may process your personal data for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal data where more than one ground has been set out in the table below.
 

1.  

2. Promotional offers from us:
    

   We may use your Identity, Contact, Technical, Usage and Profile Data to form a view on what we think you may want or need, or what may be of interest to you. This is how we decide which products, services and offers may be relevant for you.

   You will receive marketing communications from us (including if you subscribe to our ‘newsletters’).
   
    

3. Third-party marketing
   
   We will get your express opt-in consent before we share your personal data with any third party for marketing purposes.
   
    

4. Opting out
    

   You can ask us to stop sending you marketing messages at any time by following the opt-out links on any marketing message sent to you or by contacting us at any time.

   Where you opt out of receiving these marketing messages, this will not apply to personal data provided to us as a result of a product/service purchase, warranty registration, product/service experience or other transactions.
    

5. Cookies
    

   We use Cookies on Our Websites in order to optimise functionality.

   You may block cookies by adjusting setting on your browser. Please note that if you restrict all cookies you may not be able to access all or parts of Our Websites. Unless you have configured your browser to refuse cookies, our system will issue cookies as soon you visit Our Websites.

   When you first visit any of Our Websites a pop-up header will be generated alerting you to our cookie policy. It will re-appear in the event that you change your cookie settings from time to time.

   A copy of our cookie policy, including details of how to opt-out, can be found here Cookie Policy.
    

6. Change of purpose
    

   We will only use your personal data for the purposes for which we collected it, unless we reasonably consider that we need to use it for another reason and that reason is compatible with the original purpose. If you wish to get an explanation as to how the processing for the new purpose is compatible with the original purpose, please contact us.

   If we need to use your personal data for an unrelated purpose, we will notify you and we will explain the legal basis which allows us to do so.

   Please note that we may process your personal data without your knowledge or consent, in compliance with the above rules, where this is required or permitted by law.
    

7. Disclosures of your personal data
    

   We may share your personal data with the parties set out below for the purposes set out in the Purposes for which we will use your personal data table above.

   
   Internal Third Parties as set out in the Glossary.
   External Third Parties as set out in the Glossary.

   
   Third parties to whom we may choose to sell, transfer or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use your personal data in the same way as set out in this Policy.

   
   We require all third parties to respect the security of your personal data and to treat it in accordance with the law.

   
   If you have supplied your email address via Our Websites, we may occasionally send you an email to tell you about new features, solicit your feedback, or just keep you up to date with what’s going on with us, our products, and our services.

   
   We primarily use our ‘newsletters’ to communicate this type of information, so we expect to keep this type of email to a minimum.

   
   If you send us a request (for example via a support email or via one of our feedback mechanisms), we reserve the right to publish it in order to help us clarify or respond to your request or to help us support other users. We take all measures reasonably necessary to protect against the unauthorised access, use, alteration, or destruction of your personal data.
    

8. International transfers
   
   We conduct international transfers to for example the United States in accordance with an International Data Transfer Agreement.
    

9. SoukMedia Data retention
    

   1. How long will we use your personal data for?

      We will only retain your personal data for as long as reasonably necessary to fulfil the purposes we collected it for, including for the purposes of satisfying any legal, regulatory, tax, accounting or reporting requirements. We may retain your personal data for a longer period in the event of a complaint or if we reasonably believe there is a prospect of litigation in respect to our relationship with you.

      
      We normally hold and process your data for a maximum of seven (7) years from the date when you last interacted with our services. If you have never interacted with our services, we will normally hold and process your data for forty eight months from the date when we first contact you about our services. In this context “interact” means following a link which we send you, or authenticating yourself on Our Websites. We will delete your data earlier where you request us to do so as provided for below.

      
      In any event we will stop the processing of your data where you ask us to do so by contacting us by email at privacy@soukmedia.co; by post Data Compliance Officer, SoukMedia LLC 1007 N Orange St., 4th Floor, Suite #2833, Wilmington, Delaware, USA. The only circumstances in which we will not do so are where we have a legal obligation or a legitimate interest to continue processing your data.

      
      To determine the appropriate retention period for personal data, we consider the amount, nature and sensitivity of the personal data, the potential risk of harm from unauthorised use or disclosure of your personal data, the purposes for which we process your personal data and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.

      
      In some circumstances you can ask us to delete your data: see (your legal rights) below for further information.

      
      In some circumstances we will anonymise your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely without further notice to you.
      
       

10. How we deal with your legal rights
     

    1. No fee usually required
       
       You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we could refuse to comply with your request in these circumstances.
        

    2. What we may need from you
       
       We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.
        

    3. Time limit to respond
       
       We try to respond to all legitimate requests within one month. Occasionally it could take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.
        

11. Glossary
     

    LAWFUL BASIS

    Legitimate Interest means the interest of our business in conducting and managing our business to enable us to give you the best service/product and the best and most secure experience. We make sure we consider and balance any potential impact on you (both positive and negative) and your rights before we process your personal data for our legitimate interests. We do not use your personal data for activities where our interests are overridden by the impact on you (unless we have your consent or are otherwise required or permitted to by law). You can obtain further information about how we assess our legitimate interests against any potential impact on you in respect of specific activities by contacting us.

    
    Performance of Contract means processing your data where it is necessary for the performance of the contract for our services to which you are a party or to take steps at your request before entering into such a contract.

    
    Comply with a legal obligation means processing your personal data where it is necessary for compliance with a legal obligation that we are subject to.
     

12. THIRD PARTIES
     

    1. Internal Third Parties

       The members of our Group are SoukMedia LLC (registered in the USA whose state of incorporation is Wyoming, USA under EIN # 30-1332902 and business address is 1007 N Orange St., 4th Floor,Suite #2833, Wilmington, Delaware, 19801, USA); SoukMedia Global Pte. Ltd. (registered in Singapore under number 202019990Z whose address is 68, Circular Road #02-01, 049422, Singapore); and Souk Media Private Limited (registered in India under number U22300DL2018PTC338962 whose registered address is 1/22, 2nd Floor, Asaf Ai Road, New Delhi - 110002).

       We allow and you consent to any company in our group to process your personal information. Where we do so we confirm that those recipient companies will abide by the provisions of this Policy and accordingly this Policy also applies to each of those companies. as joint controllers or processors.
        

    2.  

       External Third Parties
        

        

       Service providers acting as processors who provide IT and system administration services.

       
       Professional advisers acting as processors including lawyers, bankers, auditors and insurers who provide consultancy, banking, legal, insurance and accounting services.

       
       We may disclose your personal information to the extent that we are under a duty to disclose or share your personal data in order to:

       
       Comply with any legal obligation.
       Enforce or apply our terms of use and other agreements with you.
       Protect the rights, property, or safety of SoukMedia, our customers, or others.
       This includes exchanging information with other companies and organisations for the purposes of fraud protection.
        

13.  

    California Consumer Privacy Act (CCPA)
     

     

    Under the California Consumer Privacy Act, California Civil Code Section 1798.100, if you are a resident of California you may contact us with regard to the following rights in relation to your personal data:

    
    Right of Access and Disclosure: You have a right to request access to the personal data we may hold on you for the past twelve (12) months. You may submit up to two (2) requests per year of access to your personal data.
    Right to Deletion: You have the right to ask us to delete personal data we may hold on you. There may be exceptions to the right to deletion for specific legal reasons which, if applicable, we will set out for you in response to your request.
    Right to Opt-Out of Sale of Personal Data: You have the right to opt-out of sale of personal data we may hold on you. You can exercise this right at any time.
    Right to Non-Discrimination: We will not discriminate against you for exercising any of your California Consumer Privacy Act rights.

    
    If you wish to make any of these requests, please contact privacy@soukmedia.co. We will deal with requests for access to your personal data, or deletion requests, within forty-five (45) days for California-specific requests.

    
    To help us respond as you expect, please specify that you are making a request under the California Consumer Privacy Act (CCPA). We may need to request specific information from you to help us confirm your identity.
    
     

14. EEA Specific  Rights

    If you are an individual resident in EEA, you have the following data protection rights regarding Collected Data:
     

    If you wish to access, correct, update or request deletion of your Personal Data, you can do so at any time by contacting us.

    
    You can object to processing of your Personal Data, ask us to restrict processing of your Personal Data or request portability of your Personal Data. Again,
    you can exercise these rights by contacting us.

    
    You have the right to opt-out of marketing communications we send you at any time. You can exercise this right by clicking on the “unsubscribe” or “opt-out” link in the marketing e-mails we send you. To opt-out of other forms of marketing (such as postal marketing or telemarketing), please contact us.

    
    Similarly, if we have collected and processed your Personal Data with your consent, then you can withdraw your consent at any time. Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect the processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.

    
    You have the right to complain to a data protection authority about our collection and use of your Personal Data. For more information, please contact your local data protection authority.

    
    If you seek access to, or wish to correct, update, modify or delete Personal Data (hereinafter referred to as a “Request”) which forms a part of Collected Data, please contact us at privacy@soukmedia.co. We respond to all requests we receive from individuals wishing to exercise their data protection rights within a reasonable timeframe in accordance with applicable data protection laws.
    
     

15. Privacy Shield
     

    We comply with the EU-U.S. Privacy Shield Framework as set forth by the U.S. Department of Commerce regarding the collection, use, and retention of personal information transferred from the European Union and the United Kingdom to the United States in reliance on Privacy Shield. We have certified to the Department of Commerce that we adhere to the Privacy Shield Principles with respect to such information. If there is any conflict between the terms in this privacy policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov.

    
    With respect to Personal Information received or transferred pursuant to the Privacy Shield Framework, we are subject to the regulatory enforcement powers of the U.S. Federal Trade Commission. In certain situations, we may be required to disclose Personal Information in response to lawful requests by public authorities, including to meet national security or law enforcement requirements. We are potentially liable in cases of onward transfer to third parties of data of EU individuals received pursuant to the EU-U.S. Privacy Shield.

    
    In compliance with the Privacy Shield Principles, we commit to resolve complaints about our collection or use of your personal information. EU individuals with enquiries or complaints regarding our Privacy Shield policy should first contact SoukMedia via: privacy@soukmedia.co.

    
    We have further committed to cooperate with the panel established by the EU data protection authorities (DPAs) with regard to unresolved Privacy Shield complaints concerning data transferred from the EU. EU individuals may invoke binding arbitration when other dispute resolution procedures have been exhausted.
    
     

16. Your Legal Rights
     

    You have the right to:

    
    20.1 Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

    
    20.2 Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

    
    20.3 Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

    
    20.4 Object to processing of your personal data where we are relying on a legitimate interest and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

    
    20.5 Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios:

    
    If you want us to establish the data’s accuracy.
    Where our use of the data is unlawful but you do not want us to erase it.
    Where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims.
    You have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

    
    20.6 Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

    
    These rights apply regardless of whether data is stored electronically, on paper or on other materials.

    
    If you wish to exercise any of the rights set out above, please contact us.
     

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