Privacy Notice for Users in the EEA and UK under the General Data
Protection Regulation[Last Updated: September 22, 2022]
This privacy notice provides more details to the information contained in Viber's Privacy
Policy and applies to users in the European Economic Area (EEA) and the UK ("EU Region
Privacy Notice"), in accordance with applicable laws.
This EU Region Privacy Notice provides you with information regarding our processing
operations, our lawful basis to process your personal data, categories of third parties weshare your personal data with, data transfer outside the European region, data retention,
and as required under the General Data Protection Regulation and the UK Data Protection
Act 2018 (and as amended by Schedule 1 to the Data Protection, Privacy and Electronic
Communications (Amendments etc.) (EU Exit) Regulations 2019) (collectively "GDPR"), as
well as information regarding your rights related to your personal data that Viber processes
when you use our Services (as detailed under Viber's Terms of Service).

TABLE OF CONTENTS
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Data Controller & Data Protection Officer
The Data We Collect
How We Use Your Data & Lawful Basis for Processing Your Personal Data
Data Sharing - Categories of Recipients We Share Personal Data With
Data Transfer
Data Retention
Your Rights Related to Your Personal Data
Changes to this EU Region Privacy Notice

Data Controller & Data Protection Officer
Viber Media S.à.r.l., a société à responsabilité limitée incorporated under the laws of theGrand Duchy of Luxembourg, is the controller of your personal data.
You may contact us and our Data Protection Officer, as follows:••••

Our online form available at: https://vb.me/ContactUs - please choose the "privacy
inquiry" or "GDPR inquiry" categories.
Using the "contact us" form on the App.
By Email: DPO@viber.com
By mail:Viber Media S.à r.l.,
Attention: Data Privacy Officer
2, rue du Fossé, L-1536
Luxembourg, Grand Duchy of Luxembourg.

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The Data We Collect
The operation and use of our Viber App and Services involves collection of personal data,
where the types of such data depend on the type of Service and interaction with us. For
example, when you sign up for Viber, you directly provide us personal data. We also
automatically collect certain personal data from our users' device. We explain which
information we collect and how we collect it below.
The types of personal data collected through use of our Services, including App and website,
are listed below. We note that, some types of personal data we collect are required for all
Viber Services (for example, your phone number), some types may be required solely forcertain Services or features you decide to use (for example, Viber Pay), and some are
optional, and subject to your discretion (for example, your photo).
We do not read, listen or store your messages and/ or calls made privately:
We wish to clarify that we do not read or listen to the content of your messages and/or calls
made privately via Viber and we do not store those messages (including any media files
transferred therein) once they have been delivered to their destination (which on average
takes less than one second). If for some reason the message was not delivered to its
destination within up to 2 weeks, it will be deleted from our servers. We note that we allow
you the option to back up your chat history data on your own external data backup service(like iCloud or Google Drive) – see HERE for more info on backup.
Data provided or collected through registration & under your Viber account or
participation in Viber's activities:
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•
•

Identifiers, such as:o Your mobile number (including mobile country/network code);o Your personal details, (e.g., name, date of birth), if you provided them;o Your contact details (e.g., email address), if you provided them;o Your account login details, such as your username and any of your password
or security pin-code, which you have chosen, if any;o Device identifiers, as described below.
Your photo, if you provided it (including any avatar, etc.).
Your interests, if you chose to provide them to us.
Your phone address book, meaning, the names, the phone numbers and thefavorites list from your contact lists, if you approved access to them.

Geolocation data:•

General location, we use IP addresses we collect and additional information (e.g.,phone number area codes), to estimate your general location (e.g., city level); we
may also use your residential address, if it’s been provided by you.

•GPS based location, we will collect the GPS location for very specific purposes (asdetailed below), and solely if you gave us permission.

Financial information provided or collected through your use of our limited financial
services (e.g., payment solutions), or purchased subscription and offers:•

Purchased subscriptions, products or services:If you purchase credit or subscribe to a Viber Out plan on our App or websites, wewill process your billing data (e.g., full name or your user name, phone number,
payment method), as well as transactions-related information (e.g., the purchasing
amount; date of purchase, currency; IP address, country, first and last 4 digits of yourcredit card).

•

Viber Chatbot Payment Transactions:
Transactions-related details (time and date of purchase, purchase description,purchase amount, currency, the merchant, etc.)•

Viber Pay Services:o Know Your Client ("KYC") data – including full name, date of birth, country ofresidence, and confirmation of the KYC verification status (i.e., approved or
declined), KYC level;o Transaction and wallet related information – including your digital walletbalance), details of the tokenized version of the credit/debit card of the user,
payment transaction information (including the instruction ID, payment
method, amount, currency, date and time, sender and beneficiary identities,
status of the payment, etc.), etc. In addition, if you send or receive payments,
we may have access or otherwise store the sender's or recipient's accountdetails (e.g., bank account details, details of the tokenized version of thecredit/ debit card);o Details of your wallet such as your IBAN, wallet ID, etc;
o Your email address;
o Hashed pin code.

Data we collect automatically from your device, e.g., data collected using cookies andother device identifying technologies ('Cookies and Tracking Technologies'):•••

Device identifiers, meaning identifiers for devices you have used to access our
websites and application, including IP address, unique device identifiers, advertising
related identifiers, MAC identifiers.
Electronic network activity data, such as information stored on log files, when you
access our Service and website for example, including access time and date stamp,
pages viewed, IP address, the pages that directed you to our website, information
related to errors and crash reports.
Activity data, relating to your usage of Services, such as connection status, whether
you have received and seen messages sent to you, if you are currently on anothercall and data related to the calls and messages that you send and receive, such aslength of the call, who called who, who messaged who, and at what time, your•

personal preferences related to such usage (for example how often, for how long,what options are selected, etc.). Such activity data may also include:o With your permission, we may collect data about links you visit through anyof your messages or elsewhere in the App; and with respect to your activity
in communities, channels - data about the communities and channels you
have visited or follow, messages you have liked, messages you have sent, thecontent you have viewed;
o Items you searched and shared via Chat Extensions;o Offers selected or redeemed; ando Viber Pay activity.
Other device data, e.g., data about your device’s operating system, your browser,browser or operating system language, your wireless network, your mobile carrier.

For more information regarding how we and our partners use cookies, as well as yourchoices and controls, please see our Viber Ads, Cookies and Tracking Technologies' Policy.
Data we collect or receive from other sources and inferred data:•••

Social media data:o If you sign in through third party social media sites like VK - your public
profile, including name, relationship status, age, avatar, friends list, accounts
you follow or who follow you, your email address, birthday, occupation
history, education history, interests, current country, city, and video viewing.
Access is ongoing and based on what you already share publicly;o Social media data received through your contacts on social media, depending
upon your and your contacts’ setting on such social media sites.
Your contact name, as saved on other users’ devices if they chose to share theircontacts with us.
Viber may also process inferences about your account and Device identifier, suchas:o Inferred gender - for example, inferred from your name;o Inferred interests - inferred from the links you visited and your activity incommunities and channels – as long as you permitted so;o Inferences from third party data and ads-related interactions - we may
receive inferred data, linked to your device identifier (mainly, a unique device
identifier generated by cookies or other tracking technologies used on our
website and Services) from our trusted third-party advertisers and service
providers. Such inferred data we receive may include inferences about yourinterests and characteristics, generated by such third parties from otherwebsites and services you have visited (for example, whether you areinterested in fintech, cars etc., which income group you might pertain to, as
well as the locations you tend to visit, based on your GPS location). In
addition, inferences can be generated from data on how you interact withads displayed on our App after clicking on them and data about your activity
and preferences derived from the clicks on our own ads (and the subsequentinstalls of our App) associated with your device identifier, delivered on third
party's advertising platforms by our trusted third parties. For more

information, please see our Viber Ads, Cookies & Tracking Technologies
Policy.
User Submitted Content:
If you choose to participate in Viber's activities (e.g., contests), or as part of yourparticipation in communities/channels/bots' activities available on Viber, you may
voluntarily publish, submit or post content such as videos, images, graphics, text, videos,etc., which may include personal data (e.g., an image of a person).
Data we collect from your communications with us, including support, customer services
and other inquiries:
If you choose to contact us through any means of communications we make available, you
may provide us with certain information such as your contact details (e.g., name, email,phone number, mobile carrier, country – mainly where you are not a user of our Services)and other information you voluntarily wish to provide (mainly, related to the issue you wish
us to address or resolve). We will further store our contact history and correspondence withyou.
Non users' data:
Mobile phone number and contact name, as saved on a Viber user's phone address
book: We may process your mobile phone number even if you are not a Viber user, in theevent that your phone number was included in our existing user’s address book that has
been provided to us (and subject to such user providing us with approval to access thedevice address book). We will also save the name it was saved under by our user. We do it
to show our user who in their contacts is already using our Services and who is not, to allow
users find and communicate with their contacts who are users or who are not users in amore efficient way, and solely for as long as a relevant Viber user’s account exists on Viber.
In the event you will become an active user, the existing users whose phone book included
your number, will be notified that you have joined the Service and you will be automatically
added to their App's contact list.
If you are not a Viber user and would like to exclude your phone number, please contact
us at: https://vb.me/ContactUs.
Business partners data:
When you communicate with us for business purposes as a business partner of ours, we willsave your contact data provided by you (names, phone number, email, address etc.), as wellas any correspondence we have had. We use trusted third-party providers to manage themaintenance and storage of such data.
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How We Use Your Data & Lawful Basis for Processing Your Personal Data

Under the GDPR, we must have a lawful basis to process your personal data. This may
include collection of personal data for the purpose of performing our contract with you (forexample, create your Viber account), fulfilling our legitimate interests (for example,
collection of data in order to secure our Services), complying with our legal obligations, aswell as, where applicable, processing personal data based on your consent (for example,
when you voluntarily request to participate in our marketing activities). You can find here
information regarding the purposes for which we process the types of personal data listed
above, as well as our lawful basis for such processing operations.
In a summary, our lawful basis to process your personal data will be one of the following:
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Performance of Contract: We rely on the contractual obligations for the purpose ofproviding you with the Services in accordance with our Terms of Service, such as,
enabling you to register to, log in and/or activate the Services, to back up your datain connection with in-app purchases, or limited financial services if you use these.
Legitimate Interest: We rely on legitimate interest in connection with our marketing
campaigns, product development, continued improvement of existing features andprovision of certain features, processing a non-user data for the contact list
purposes, fraud/spam prevention, and in order to create your Rakuten account.
When we process personal data to meet our legitimate interests, we put in placerobust safeguards to ensure that your privacy is protected to ensure that the risk toyour interests or fundamental rights and freedoms is minimized.
Legal Obligation, Compliance and Public Interest: In some cases, we may also have alegal obligation to process your personal data such as fulfilling your user’s rights or
may otherwise need your personal data to protect your vital interests or those ofanother person.
Consent: Where required under applicable law, we will obtain your consent tocollect, use or share your data, including for the use of certain cookies on our
website (as provided on the Viber Ads, Cookies & Tracking Technologies Policy). You
can withdraw your consent at any time.

The table below further details the lawful basis we rely on in order to process personal data,aligned with the purpose of use. Certain types of personal data might be used for multiple
purposes, and accordingly will be processed under different lawful basis.
Please note that, the actual processing operation per each purpose of use and lawful basis
detailed in the table above, may differ. Such processing operation usually includes set ofoperations, made by automated means, such as collection, storage, use, disclosure bytransmission, erasure or destruction, and may involve transfers of personal data to third
party countries as further detailed in the Data Transfer section below.
Type of Data
For full explanation, see"The Data We Collect"
section above

Purpose of Use

Lawful Basis for Processing Personal
Data

Data provided or collected
through registration &under your Viber account:● Identifiers, such as:
Performance of Contract:••••

Your mobile
number;Your personal
details;Your contact details;Your account login
details;

Our processing of this data is necessary
for performing our contract with you –meaning, to create and administrate
your Viber account in order to enable
you to use our Services, including:● In order to enable you to register
to, log in and/or activate the Services,
access Customer Support;● Your photo● Your phone address
book

Authentication &Account
Administration● General location● To authenticate and verify youraccount, as well as to make sure you do
not already have a Viber account, we
will use your phone number to send
verification notice.

Data we collectautomatically from yourdevice:● Synchronizing your contact list on
the App (e.g., contacts that are Viberusers).

● Device identifiers● To create your profile, customize
your Viber account according to theinformation you have provided (i.e.,
name, photo, etc. including where you
sign in through your social media
account), and display such informationas part of your profile when you use
Viber Services.

Geolocation:● Other device data
Data collected from othersources and inferred data:● Social media data:•

If you signed inthrough third partysocial media.

Data provided or collected
through registration &under your Viber account:● Identifiers, such as:

Providing ourServices Communication &Content Features(messaging, voice
and video calls,

Performance of Contract:
Our processing of this data is necessary
for performing our contract with you –meaning, to operate, provide and•Your mobile
group chats,
number;communities,• Your personal
channels, bots, chatdetails;
extensions, explore• Your contact details; screen, stickers,• Your account login
Viber lenses, etc.),
details;
and enabling
backups● Your photo● Your phone address
book
Geolocation:deliver our Services to you and thecommunication features, including:● To allow mobile carriers to connect
calls to you and from you.
● To show your online status.
● To enable you to send messages,
participate in Viber calls, delete
messages, etc.
● To provide you with other App's
features such as operational
notifications (e.g., missed calls).

● General location
Data we collectautomatically from yourdevice:● Device identifiers● Electronic network
activity data

● We will use your IP address to
extract your approximate location, inorder to enable you to use certain
features that are only available incertain countries (for example, sticker
packs).
● Enable you to upload and create
backups of your messages on external
services.

● Activity data
● Other device data
Data we collect from othersources and inferred data:● Enable you to post and share yourUser Submitted Content (e.g., images
and videos, etc.) on our communities,
channels, and bots, where allowed by
its administrator, and generally utilize
our content features● Social media data:••

If you signed inthrough third partysocial media sites your public profile;
Social media data
received throughyour contacts onsocial media,
depending upon
your and yourcontacts’ setting on

As stated above, your messages will not
be stored by us once they have beendelivered.

•such social media
sites;Your contact name,as saved on otherusers’ devices if theychose to share theircontacts with us.

User Submitted Content
Data provided or collected
through registration &under your Viber account:Consent:● Identifiers:•

Your mobile
number;● Your phone address
book

Synchronize Your
Address Book

Data we collect from othersources and inferred data:● Your contact name, as
saved on other users’
devices if they chose toshare their contacts with us.

Performance of Contract:

Data provided or collected
through registration &under your Viber account:● Identifiers, such as:•••Your mobile
number;Your personal
details;Your contact details.

Financial information
provided or collected
through your use of ourlimited financial services

We will obtain your consent in order to
use this data for the purpose ofsynchronizing your contact list
(meaning, in order to show you yourcontacts on the Viber interface so you
contact them through Viber) You havethe right to withdraw consent at any
time, by changing the App's settingsand permissions on your phone,
without affecting the lawfulness ofprocessing based on consent before its
withdrawal.

Viber Out Credit,
Subscription &Other Purchased
Services

We process this data when it isnecessary for performing our contract
with you, meaning – to enable your useof the Viber Out Credit or purchase ofsubscriptions on our App or website,
including for verification purposes. For
example, a log with your purchase will
be recorded, and such log will include
your IP address or other device
identifier.
When you purchase Viber Out Credit orsubscriptions on our website, Viber may
share certain information with our(e.g., payment solutions), or
purchased subscription andoffer:● Purchased
subscriptions, products orservices: billing data (e.g.,billing address, full name oruser name, phone number,account, payment method),transactions-related
information (e.g., thepurchasing amount date ofpurchase currency; IP
address, country, first andlast 4 digits of your creditcard).

third-party Payment Service Providers,such as your email address. Your credit
card number will be provided by you
directly to the applicable Payment
Service Provider and Viber will not haveaccess to this data.

Data we collectautomatically from yourdevice:● Device identifiers
Data provided or collected
through registration &under your Viber account:● Identifiers, such as:
•
•
•
•
•
•

Your mobile
number;Your personal
Viber Pay Services
details;Your contact details;Your account login
details;
Country ofresidence;
Hashed pin code.

Financial information
provided or collected
through your use of ourlimited financial services(e.g., payment solutions), or

Performance of Contract:
We process this data when it isnecessary for performing our contract
with you, meaning – to enable your useof the Viber Pay services, and forexample:● We must identify you in order toenable you the use of the Viber Pay
Services;● Viber will share certain KYC data
you provide with its Payment Service
Provider, and they may in turn sharewith downstream banks, payment
service providers, messaging systems,
i.e., SWIFT, etc., to enable the payment
processing;purchased subscription andoffer:•••••

Know Your Client("KYC") data;
Transaction andwallet related
information;
Your IBAN andwallet ID;
Your email address;
Hashed pin code.

Geolocation:•

General location● We access your IP address to verify
your location and determine eligibility
for services;● App and customer support
authentication.
Legitimate Interests:
We rely on legitimate interest inconnection with the processing of bankaccount details of recipients to whom
you have made a payment transfer, inorder to enable you to easily makefuture transfers to such recipient's
account.

Data we collectautomatically from yourdevice:● Device identifiers● Activity data:•

Offers selected orredeemed.

Performance of Contract:
Financial information
provided or collected
through your use of ourlimited financial services(e.g., payment solutions), or
purchased subscription andoffer:
Viber Chatbot● Viber Chatbot Payment Payments
Transactions, meaningtransactions-related details
including shopping history(time and date of purchase,purchase description,purchase amount, currency,
the merchant, etc.).

We process this data when it isnecessary for performing our contract
with you, meaning – to enable your useof the Viber Chatbot Payments tointeract and pay to third party
merchants. We will use your datasolely for fulfilling our role as anintermediary and we will share with
Google Pay or Apple Pay or any otherlinked payments provider. The
confirmation of the payment isprovided directly to the merchant andViber does not receive or share any
payment data or registration data fromApple Pay nor Google Pay. Note that,your use of Apple Pay and Google Pay,

including their use of your data, issubject to their respective terms andprivacy policy which can be found here:
Google Pay, Apple Pay.
Consent:
Data provided or collected
through registration &under your Viber account:

We will obtain your consent in order to
use this data for the purpose of
enabling you to participate in ourcontests or other marketing activities
offered by us from time to time. You
have the right to withdraw consent at
any time, without affecting thelawfulness of processing based onconsent before its withdrawal.

● Identifiers, such as:•Your mobile
number;• Your personal
Participation indetails;• Your contact details. Contests &Please note that the specific types ofMarketing Activities
the data listed herein that we will
Data we collectprocess may vary, depending on theautomatically from yourcontest or activity type. For example,
device:some contests may involve a prize weneed to ship to you and for this we will
● Device identifiers
request you to provide your physicaladdress. In addition, some contests orGeolocation:
activities are applicable solely to
specific regions, and for this we will use● General location
your general location (for example,
according to your phone number area
User Submitted Contentcode), to validate your eligibility toparticipate in a specific contest.
Consent:

Geolocation data:● GPS based location

GPS Location
Sharing

We will obtain your consent in order tocollect and use this data for the
purpose of enabling you to share yourlocation with your contacts. You havethe right to withdraw consent at any
time, without affecting the lawfulnessof processing based on consent before
its withdrawal.

Legitimate Interest:

Data provided or collected
through registration &under your Viber account:

We rely on legitimate interest inconnection with our processing of thisdata for the purpose of improving ourservices, and for example:● Identifiers, such as:•••Your mobile
number;Your personal
details;Your contact details.

● We use activity data, device
identifiers and IP-based location to fix,and evaluate the technical functionality
and availability of the Services, as well
as for statistical analysis of the usage
and functionality, productdevelopment, continued improvementof existing features and provision ofcertain features.

● Your Interests
Geolocation data:● General location
Data we collectautomatically from yourdevice, e.g., data collectedusing cookies and otherdevice identifying
technologies ('Cookies andTracking Technologies'):● Device identifiers● Electronic network
activity data
● Activity data
● Other device data
Data we collect from othersources and inferred data:● Social media data
● Your contact name● Inferences about youraccount and device
identifier:•

Inferred gender;

Improving andCustomizing theService & Analytics
of Viber Activity● We further rely on legitimate
interest in connection with ourprocessing of this data for the purposeof customizing and personalizing ourServices, and for example we use yourdata provided through registration andinferred data (such as inferred gender
or inferences derived from ads-related
interactions), interests and IP-based
location to customize content we show
you, including our customized offers ofcertain services.
When we advertise our Services to youon third party platforms, we may
receive indications of which
advertisement led you to join our
Service based on unique device
identifiers associated with your device,in order, among others, to assess theperformance of our campaigns andfurther to look for similar users.
Additional information (including how
to opt-out of data collection throughthe use of cookies) is available on our
Viber Ads, Cookies & Tracking
Technologies Policy and under yourchoices and controls explained in Your
Rights Related to Your Personal Datasection below.

•

Inferences fromthird party data andads-related
interactions.

Data provided or collected
through registration &under your Viber account:

Legitimate Interest:
We rely on legitimate interest inconnection with our processing of thisdata, for example:● Identifiers, such as:•••Your mobile
number;Your personal
details;Your contact details.

● Your email address, name andinferred gender or age range, for the
purpose contacting you with marketingand offers relating to products offeredby Viber, and our third party trusted
partners.

● Your Interests
Geolocation data:● General location● GPS based location● Country of residence.
Data we collectautomatically from yourdevice:● Device identifiers● Electronic network
activity data
● Activity data
● Other device data
Data we collect from othersources and inferred data:● Social media data

MarketingCommunications &Location Based
Offers● Your IP address will be used to
extract your general location or, where
provided, your country of residence, forthe purposes of presenting offers
applicable to your region.
Please note that even after you havechosen to unsubscribe (see how you
can do it in Your Rights Related to Your
Personal Data section), we may send
you service-related communications,
including administrative messages that
relate to your use of the Services.
Consent:
We will obtain your consent in order tocollect and use GPS location data forthe purpose of precise location-based
marketing offers and communications.
You have the right to withdraw consent
at any time, without affecting thelawfulness of processing based onconsent before its withdrawal.

● Inferences about youraccount and Device
Identifier:•

Inferred gender.

Data provided or collected
through registration &under your Viber account:● Identifiers, such as:••••Your mobile
number;Your personal
details;Your contact details;Your account login
details.

● Your phone address
book
Geolocation data:● General location
Financial information
provided or collected
through your use of ourlimited financial services(e.g., payment solutions), or
purchased subscription andoffer.
Data we collectautomatically from yourdevice:● Device identifiers● Electronic network
activity data
● Activity data

Performance of Contract:
We process this data when it isnecessary for performing our contract
with you, meaning – to communicate
with you, give you information about
Customer Service & your account, and respond to yourOperationalrequests and inquiries.
Messages
Legitimate Interest:
We rely on legitimate interest with ourprocessing of this data for the purposeof improving our customer support (forexample in order to train our customer
support team, as well as internalmanagement operations).

● Other device data
Data we collect from othersources and inferred data:● Social media data:•

If you sign inthrough third partysocial media sites.

Data we collect from yourcommunications with us,
including support, customer
services and other inquiries.
Data provided or collected
through registration &under your Viber account:● Identifiers, such as:••••

Legitimate Interest:

Your mobile
number;Your personal
details;Your contact details;Your account login
details.

Geolocation data
Financial information
provided or collected
through your use of ourlimited financial services(e.g., payment solutions), or
purchased subscription andoffers:● Purchased
subscriptions, products orservices: transactionsrelated information (e.g.,
the purchasing amount).

Safety, Security &Fraud Prevention

We rely on legitimate interest inconnection with our processing of data
for security purposes such as,
authentication, identity verification andfraud and spam prevention. This may
include URLs included in messages andmessages, which were reported as
SPAM by other users, or wereotherwise suspected to be unsolicitedand using your operating systemauthentication services. We may use
automated decisions to close an
account based on such data and otherlogic we have created for this, in orderto protect other users and prevent
recurring breaches.

● Viber Pay Services
Data we collectautomatically from yourdevice:● Device identifiers● Electronic network
activity data
● Activity data
● Other device data
Legitimate Interest:
Data provided or collected
through registration &under your Viber account:

We rely on legitimate interest inconnection with our processing of thisdata to provide our advertising services(meaning, to enable the display ofadvertisements, provided by third party
advertisers, in our App and Services), tomeasure and optimize the performanceof ads and deliver more relevant ads,
provided however, that for such
purpose we will not share your datawith advertisers or other third parties.

● Your interests
Geolocation data:● General location● GPS based location
Data we collectautomatically from yourdevice:● Device identifiers● Activity data
● Other device data
Data we collect from othersources and inferred data:● Social media data
● Inferences about youraccount and Device
identifier

AdvertisingConsent:
We obtain your consent in order to use
and share certain data, such as device
data and identifiers, age range, inferredgender with third party advertisingpartners for the purpose of
personalized advertisements.
Additional information (including how
to opt-out of data collection throughthe use of cookies) is available on our
Viber Ads, Cookies & Tracking
Technologies Policy.
In addition, we will obtain your consent
in order to collect and use data about
links you visit and data about thecommunities and channels you have

visited or follow, messages you have
liked, messages you have sent, thecontent you have viewed, for the
purpose of personalized advertising.
You have the right to withdraw consent
at any time, without affecting thelawfulness of processing based onconsent before its withdrawal.
Legitimate Interest:

Business partners data

B2B
Communications
and Engagements

We rely on legitimate interest inconnection with our processing of thisdata, including for direct marketing
purposes – meaning, we will store youremail address and use it to send you
our marketing offers. You have theability to opt out of our direct
marketing emails at any time.
Performance of Contract:
Our processing of this data might bealso necessary for performing ourcontract with you (depending on our
engagement).
Legitimate Interest:

Non-User Data

Provide Service to
Existing Users

We rely on legitimate interest inconnection with the processing of nonViber users' phone number (and names
under which they were saved by Viberusers) in the event such contact was
included in our user’s address book thathas been provided to us, and for the
purpose of showing our user who intheir contacts is already using ourServices and who is not, to allow theuser find and communicate with theircontacts who are users in a more
efficient way. If you are not a Viberuser and would like to be excluded
from such processing, please contact
us at https://vb.me/ContactUs.

Legitimate Interest:
We rely on legitimate interest inconnection with our processing, use
and sharing of data for the purpose of
May include all types ofdefending our rights and enforcing ourdata Viber stores,
depending on the
Defend our Rights & polices, terms and agreements, forcircumstances, as detailed Enforce our Policies example, in the event of a dispute,
claims and legal proceedings, and solely
under The Data We Collectto the extent necessary for suchsection above.
purpose. For example – we may recordand log some of your actions, such as
acceptance of our terms and polices,
acceptance of certain offers, etc.
Compliance with a legal obligation;
We use your data where it is necessary
to comply with legal obligations towhich we are subject to andcooperation with regulators and law
enforcement bodies – where there is avalid legal request such as bindingorder.
Please see below examples of EU laws
and Luxembourg laws that apply to
May include all types ofViber and according to which we may
data Viber stores,
process, use, maintain or store yourCompliance withdepending on the
Legal Obligations & data:
circumstances, as detailed
Public Interests
under The Data We Collect• Data Protection Legislation: We
section above.
will process your personal data
upon your request to exercise
your rights under the GDPR. We
will store an indication of youraccess request and order to beable to demonstratecompliance.
• Corporate and Tax Legislation:
We may be required to provide
regulators with information
under applicable corporate andtax legislations.

•

•

•

•

Consumer Protection
Legislation: We will process
your personal data inaccordance with local laws
enacted under Directive EU
2019/770 on certain aspects
concerning contracts for the
supply of digital content anddigital services.
Telecommunications: We willprocess telecommunication
data in accordance with local
laws enacted under the Eprivacy
Directive and under
the future e-Privacy Regulation.
Criminal Investigations andLegislation: We may be required
to provide authorities withinformation in compliance withcriminal investigations laws
applicable to electronic
communications provider orotherwise applicable to us.
Civil Proceedings: We may berequired to provide authorities
with information in compliancewith regulation (EU) No
1215/2012 on jurisdiction andthe recognition andenforcement of judgments incivil and commercial matters
and Council Regulation (EC) No
1206/2001 of 28 May 2001 on
cooperation between the courtsof the Member States in thetaking of evidence in civil orcommercial matters.

Protection of vital interests:
We may process your data in very
limited and rare circumstances, where
we find it necessary and essential forthe purpose of protecting your or third
party's life safety and security as well as
humanitarian purposes.

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Data Sharing – Categories of Recipients We Share Personal Data With
We share data with third parties, including our corporate family and with trusted companies
that help us provide our Services in compliance with strict data security and privacy
practices, as well as other third parties such as our advertising partners and third parties
offering services through our App. We may also share personal data in limited
circumstances where we are required to do so under applicable law. You can find here
information about the categories of such third-party recipients, what other Viber users cansee, as well as the purpose for which the personal data is shared with such third parties.
Categories of Recipients

Additional Information
We may share the data we collect about you with theViber corporate family, including our parent company,
Rakuten Group Inc., and its and our affiliates (as listedHERE), and subsidiaries, for the following purposes:••

The Viber Corporate Family••

Certain types of data, such as name, email, photo,phone numbers and Viber unique ID, may bedisclosed in order to provide joint content and ourServices (e.g., registration, coordination ofmembership accounts between the Viber
corporate family, transactions, analytics andcustomer support).
Additionally, we may share certain types of data
about you as may be necessary to help detect andprevent potentially illegal acts, violations of Viberpolicies, fraud and/or data security breaches.
We share data with Viber's subsidiaries due to ourglobal operations, as we have teams and offices
located worldwide, and each such subsidiary may
operate the services or other functions (such as
development, etc.) for a certain region.
Further, we share data with our affiliated company,
Rakuten Marketing LLC, as our service provider forour marketing and advertising activities.

For users registering to Viber from November 20, 2019 –details provided during your registration will be sharedwith Rakuten group to create the Rakuten account and/or
to link your Rakuten account with your Viber account.
Your Rakuten account or any activity related to your use of
Rakuten services is governed by Rakuten ID Privacy
Policy.

We share your personal data with our trusted service
providers and business partners that perform business
operations for us on our behalf (as data processors) andpursuant to our instructions.
This includes the following categories of service providers:
•

•
•

•

Our Service Providers•••

Advertising and marketing service providers, who
help us with advertising measurements and app
installations;
Data storage providers, with whom we entrust thehosting and storage of our data;
Customer support providers, who help us perform
such functions as customer support and customer
service;
Data analytics and data management providers,
who help us improve, personalize and enhance our
Services;
Measurement partners, who help us withmeasurements, tracking and targeting;
Payment and fintech services providers, whoenable processing payments and fintech actions on
our app;
Data security partners, who help us detect andprevent potentially illegal acts, violations of ourpolicies, fraud and/or data security breaches andensure compliance with legal obligations.

Where we share information with services providers andpartners, we ensure they only have access to suchinformation that is strictly necessary in order for us toprovide the Services. These parties are required to secure
the data they receive and to use the data for pre-agreed
purposes only, while ensuring compliance with allapplicable data protection regulations (such service
providers may use other non-personal data for their own
benefit).
As part of Viber’s Services, we allow third parties to create
communities and channels on Viber, and develop through
Third-Parties Offering Service
the use of Viber’s API their own bots, chat extensions andThrough our App
integrate into Viber explore screen in order tocommunicate with Viber users ("Third Party
Communications").

In the event you voluntarily choose to interact with theThird-Party Communications through your use of theServices, such third parties may receive certain data about
you, such as your user’s name, photo, country, somedevice data and Viber unique ID. These third parties are
not processing the data on our behalf and are considered“independent controllers” of such data for the purposes of
the GDPR, meaning, their use of your data shall be subject
to their policies and privacy practices.
To enable the limited advertisements on our Services, we
may share data with our third-party advertising partners,
and advertising service providers. This includes partners
managing our advertising placements (Rakuten included)
and also advertisers themselves and their agencies or third
parties managing their advertising demands.
The list of our advertising partners is available HERE
Advertising Partners

We will share with such advertising partners a uniquedevice identifier (i.e., an advertising identifier associatedwith your device) along with age range, inferred gender,
country, city, reduced IP address (or GPS location data if
you allowed us in your settings) and certain technical oraggregated data (e.g., your language preference).
Your unique advertising identifier is created by yourmobile device’s operating system and you can change it orchoose not to share it at any time. If you want to know
more, read our Viber Ads, Cookies & Tracking
Technologies Policy.

Legal and Law Enforcement

We may disclose certain data to law enforcement,
governmental agencies, or authorized third parties, in
response to a verified request relating to terror acts,
criminal investigations or alleged illegal activity or any
other activity that may expose us, you, or any other Viberuser to legal liability, and solely to the extent necessary tocomply with such purpose.
This disclosure is subject to our strict data security andprivacy practices and without compromising our end-toend encryption. It may include, depending on thecircumstances, certain types of your Activity Data,
Identifiers and phone address book.

In the event of a corporate transaction (e.g., sale of a
substantial part of our business, merger, consolidation orasset sale) we will share the data we store with ouracquiring company.
Corporate Transactions
We will obligate the acquiring company to assume therights and obligations as described in our Privacy Policy(including this notice), and we will notify you of suchcorporate changes in your data processing.
If you use our Viber Pay services, we will share with ourthird-party payment processor Know Your Client ("KYC")
data, phone and email address, fraud data, etc.

Limited Payment Services

If you use our Viber Chatbot Payment, we will share with
Google Pay or Apple Pay or any other linked payments
provider the following information: (i) name of thepayment service provider merchant; (ii) price of the items
purchased and currency; and (iii) the description of theitems purchased. The confirmation of the payment isprovided directly to the merchant and Viber does notreceive or share any payment data or registration datafrom Apple Pay nor Google Pay. Note that, your use ofApple Pay and Google Pay, including their use of your data,
is subject to their respective terms and privacy policy
which can be found here: Google Pay, Apple Pay.
If you use our Viber Out Credit and subscriptions, we will
share your email address with our payment processor, forthe purpose of verification and fraud detection.
When you use our Services, other users can see certain
data about you:
● Unless you have changed your settings:

Other Users

•
•
•
•

your user name and photo;
your phone number (if you are in communication
with them);
your connection status;
whether you have received and seen messages
sent to you.

● If you are currently on another call.

● If they are part of the call with you, data related to thecalls and messages you have sent and received such aslength of the call, who called who, who messaged who,
and at what time, the type of call (audio/video) andwhether you answered the call on your primary or anotherdevice.
● For disappearing messages, we will notify the otherusers of any screenshots you’ve taken (so please respect
the vibe and do not take them).
● When you join Viber, the contacts in your address
book that are already Viber members may be informedthat you’re now on Viber too.
● A reminder about your birthday on the date of yourbirthday.
● When you join Viber Pay, the contacts in your address
book that are already Viber members may be informedthat you’re now using Viber Pay. In addition, Viber users
will see an indication whether you are a Viber Pay user.
● If your “Use Peer-to-Peer” option is on, other users canuse technical tools to see your IP address. You can turnthis option off at any time on your privacy settings.
● Your public posts: If you post information on our
public spaces such as communities or channels, it may besearchable and available to anyone on Viber. You canalways delete your posts on those public spaces, but Viber
cannot control and is not responsible for what other users
do with this information (e.g., store on their devices,publish on Viber or outside of it etc.), thus, werecommend you do not disclose your personal data
through the content of your posts.
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Data Transfer
Due to our global operations, your personal data will be shared with Viber corporate family,
as well as our service providers and business partners around the world including outside
the EEA and UK. We take measures to ensure the transfer of such data will provide sufficient
safeguards, as required under the GDPR. These measures include compliance with Binding
Corporate Rules of the Rakuten Group, as well as contractual commitments of our partners
and service providers. We further explain below why we transfer personal data, themeasures we take to ensure your personal data will be secure upon transfer, and your rights
in this regard.
Due to our global nature and operation, your personal data may need to be processed incountries that may not offer the same level of protection as in your home country. Whenpersonal data collected within the EEA and the UK is transferred outside these locations, wewill take the steps necessary to ensure that the transfer of such data provides sufficient
safeguards, as required under the GDPR.
•••

We store and process all categories of your personal data on our computers andservers. Your data will be stored in our servers located in the US, however note that,
our communications servers are located globally in order to enable the operation of
our communications services.
As part of the Rakuten Group, the transfer of your personal data to entities which
are a part of our Viber corporate family (whether located in the EEA and UK or not),are made in accordance with the Rakuten Group Binding Corporate Rules tolegitimize international data transfers within the Group. The Rakuten Group Binding
Corporate Rules can be found at https://corp.rakuten.co.jp/privacy/en/bcr.html
Some of our service providers and business partners are located in various locations,
including outside of the EU, EEA or UK. In such events, transfers of your personal
data will be made in accordance with applicable data protection laws, and as
specifically, without derogating from the above, all transfers of personal data outside
the EU, EEA or UK are also subject to the provisions of the Standard Contractual
Clauses (known as "SCC") approved by the European Commission (and theequivalent for the UK and for Switzerland where applicable) available HERE. Where
applicable and required by law we ensure supplementary measures are placed, suchas encryption in transfer and at rest.

Subject to applicable laws, you may exercise your rights to receive information on suchtransfer mechanisms detailed above, by contacting us through our online form available
at: https://vb.me/ContactUs (please choose the "privacy inquiry" or "GDPR inquiry"
categories), or through additional means of communications we have provided under thisnotice.
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Data Retention
As we have explained above, we process personal data for various purposes. Accordingly,
we only keep personal data as long as required to fulfill the purpose for which the data wascollected, or, in some instance, where we have other necessities to retain the personal data,
for example, where required by law. We explain below the criteria used by us to determine
the retention of your personal data (meaning, for how long we store it and when we delete
it, aligned with the type of data and purpose of collection).
The criteria used by us to determine Viber's retention periods are as follows:•

The type of personal data and purpose of collection – unless otherwise specified,
we retain data as long as it is necessary and relevant for us to achieve the purposes
for which the personal data was collected. For example:o Personal data required to be retained in order to maintain your Viber accountand to enable you the use of Viber Services – these types of data, including
your mobile number, and phone address book, will be retained for as long as
you maintain your Viber account.
o Personal data you have voluntarily provided during registration or throughyour account – these types of data, including your photo, date of birth, email
address and interests, will be retained for as long as you maintain your Viber
account.
o The details of your communication with our customer support team will be
stored for 10 years.
o Call Detail Records (CDRs) of your calls and messaging activity are kept as araw data for 24 months from creation. CDRs may include, for example, youphone number and device identifiers (i.e., IP address, unique device
identifier).
o We delete any message once delivered, or after 14 days if delivery attempts
throughout this period was not successful.

If you decide to delete your Viber account, the CDRs and communications with ourcustomer support will be retained as detailed above, and we will further retain records offinancial information (using Viber Pay, purchasing subscriptions, etc.), for the periods
required under applicable laws, or as needed in accordance with our fraud monitoring
program.
All other types of data related to your Viber account will be deleted, unless we are required
to further retain the data, subject to the criteria detailed below. We may keep activity dataon a non-identifiable basis to improve our Services. Your posts on channels andcommunities may remain available if you do not delete them. Please note that deletion of
the App (i.e., uninstall the App from your device) will not delete your account. Please see
information and instruction regarding your account deletion HERE.
••

Compliance with our legal obligations – we are required to retain certain types ofdata in order to comply with our obligations under applicable laws. For example, weneed to retain transactions information to comply with tax legislation. In addition,
we may retain certain types of personal data in the event we are required to do so
subject to a binding legal request or a court order. Further, subject to EU Directive
2002/58/EC we are required to retain certain personal data (such as phone number)to convey messages and calls.
Dispute, claims and legal proceedings – if you have a dispute with us, we may retain
certain types of personal data as necessary and applicable to your claims, including
any legal proceedings between us, until such dispute was resolved, and following, if
we find it necessary, in accordance with applicable statutory limitation periods. In
addition, in the event you request to exercise your rights, we will maintain theapplicable correspondence for as long as needed to demonstrate compliance, andusually in accordance with applicable statutory limitation periods.

•Retention for non-users' data – If you are not a Viber user, and we process yourdata to enable Viber users to communicate with you via Viber Services, we will retain
such data as long as it is relevant to Viber users, or until you have requested us tostop processing your phone number. You can request to exclude your phone number(by contacting us at: https://vb.me/ContactUs). Furthermore, if one of our users
used our Viber Out Services in order to communicate with you (i.e., call you throughViber), we will retain a log of such call (Call Detail Records – CDR – as detailed
above), which will include your phone number, for 24 months from creation.

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Your Rights Related to Your Personal Data
Under the GDPR, you have certain rights regarding the personal data that Viber hascollected about you. Such rights may include (depending on the type of data and our lawfulbasis for processing) the right to know which types of data we collect and why we collect it(as we detail under this notice), the right to request rectification of your personal data, theright to request us to delete your personal data, the right to restrict processing of personaldata, the right to data portability, the right to access your personal data, the right to object
to the processing of certain forms of data, the right to appeal automated decisions andprofiling, the right to withdraw your consent at any time, as well as the right to lodge acomplaint to a supervisory authority. We further explain below the operational meaning ofeach such right, as well as when and how you may exercise your right.
The Right to Be Informed
This EU Region Privacy Notice and Viber’s Privacy Policy describes our practices in detailusing simple language. Everything you need to know is here. If you have more questions,feel free to contact our support team.
The Right to Rectification
If you believe we have the wrong data about you, or that your data is incomplete, feel free
to change it at any time through the profile settings on your Viber settings on your mobile
device. If you can’t find what you are looking for, contact us.
The Right to Erasure
We have made it easy for you to delete your historical data on the App, while continuing to
use the App. Simply tap on the delete your data button in your privacy settings. We will
delete the data which we are not otherwise required to keep or is necessary for theprovision of the Service. And no need to worry – deleting your data won’t remove the chatson your Viber App on your phone.
Note that when you deactivate the Viber account your data and chats are automaticallydeleted from your devices.

The Right to Restrict Processing
We allow you to opt out of certain processing of your data by using the Viber privacy
settings on your mobile device. You can decide which processing operations you want to
opt-out of. You can also change the settings on your mobile device operating system at any
time to prevent us gaining access to certain data such as your accurate location – but thismay negatively impact on your user experience.
The Right to Data Portability
We have created a request your data button in Viber’s privacy settings on your mobile
device to make a simple way for you to access the data connected to your account. Once itis ready, you will receive a file from Viber containing this data.
The Right of Access
You may access your data by using the request your data button in Viber’s privacy settings
on your mobile device. If you have further questions contact us.
The Right to Object
You can object to the processing of certain forms of data by contacting our support.
Complete this online form and explain your special circumstances. If you receive emails
from us, you can always opt out on the bottom of the email, or by contacting our
support. We also allow you to opt out of certain processing of your data by using the Viber
privacy settings on your mobile device.
The Right to Appeal Automated Decisions and Profiling
We may make an automated decision to block a user, in case we suspect this user is using
our services for illegal acts or acts that violate our terms of service. If you believe that youraccount was unlawfully blocked, you can contact our support team.
The Right to Withdraw Consent
Where we have collected or other process your personal data based on your consent, at any
time, you have the right withdraw your consent.
If you would like to further understand or exercise your rights, please contact us by:••••

Our online form available at: https://vb.me/ContactUs - please choose the "privacy
inquiry" or "GDPR inquiry" categories.
Using the "contact us" form on the App.
Email: DPO@viber.com
By mail:Viber Media S.à r.l.,
Attention: Data Privacy Officer

2, rue du Fossé, L-1536
Luxembourg, Grand Duchy of Luxembourg.
We will contact you if we need additional information from you in order to honor yourrequests.
You have the right to submit a complaint with our lead supervisory authority or any othercompetent data protection supervisory authority. Our lead supervisory authority is the
National Commission for Data Protection – Grand-Duchy of Luxembourg.
In addition to the above, Viber provides you with certain choices and controls you may
exercise, related to your personal data, as follows:
•
•
•
•
•
•

•

•

We enable you to delete or edit your messages anytime, even after they have been
sent (they will be deleted or appear edited for you, your friend and our Services).
You can also control your privacy settings within the App to change the visibility ofyour online status.
You can disable the “seen” notification so that other users do not know whether
you’ve read a message yet.
You can choose not to share your photo and/or birthday or not to allow other users
to look you up by name, which are available within the App.
You can also make additional choices on your phone’s settings by changing our App’s
permissions such as GPS location sharing, access to contact list and more.
If you do not wish to receive Viber marketing notifications, you may adjust yoursystem settings to decline notifications from Viber, or submit a request to our
support. And if you subscribed to receive promotional emails from Viber, you canunsubscribe in any such email at any time.
Sending a message to a bot, subscribing to a bot will allow admins of that bot to send
you notifications and personal messages. If you do not wish to receive such
notifications, you may adjust your account settings to decline them or opt-out at any
time from receiving further notifications.
You can choose to allow or to not allow customization and personalization of ourServices provided to you based on your personal data, by changing your personal
data toggles in the privacy setting within the App.

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Changes to this EU Region Privacy Notice
We may make changes to this EU Region Privacy Notice from time to time. If we do (except
for minor tweaks), we will notify you via our App and website.
We may modify or update this privacy notice from time to time.
If we change this privacy notice (except for technical tweaks), we will notify you of thechanges. Where changes to this privacy notice will have a fundamental impact on the natureof the processing or otherwise have a substantial impact on you, we will give you sufficientadvance notice so that you have the opportunity to exercise your rights (e.g., to object tothe processing). The last modification date of this privacy policy will be reflected in the “Last
Updated” header above.
In the event you read this policy in any language other than English, you agree that in theevent of any discrepancies, the English version shall prevail.
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Current Privacy Notice for EEA and UK users under the GDPR PDF Version Viber GDPR
Privacy Notice September 2022
Previous GDPR Privacy Rights PDF Version Viber GDPR Privacy Notice March 2022
Previous GDPR Privacy Rights PDF Version GDPR Privacy Rights November 2019