Viber Caller ID opt-out (Serbia)

viber-opt-out.txt

Request 1: Opt-out from Viber Caller ID processing of my phone number and name.

I am submitting this request to opt out of Rakuten Viber’s processing of my personal data for the Caller ID feature, specifically my phone number and the name associated with it, and to stop displaying my identity to other users via Caller ID.

According to Viber’s Caller ID Opt-Out notice, Viber users and non-users have the right to stay anonymous and not be identified through the Caller ID feature. Viber’s Privacy Policy further states that a phone number and contact name may be added to the Caller ID database and used to identify a caller.

I hereby exercise my rights under the Law on Personal Data Protection of the Republic of Serbia (“Official Gazette of RS”, No. 87/2018), in particular:

Article 37 – right to object at any time to processing based on legitimate interests;
Article 30 – right to erasure of personal data, including where I object and there are no overriding legitimate grounds, or where the data has been unlawfully processed;
Article 26 and Article 24 – right to be informed whether my data is being processed, for what purposes, on what legal basis, from what source, and to whom it has been disclosed;
Article 31 – right to restriction of processing pending resolution of this request.

Accordingly, I request that Rakuten Viber:

cease processing my phone number and associated name for Caller ID;
erase my phone number, name, and any linked Caller ID record from the Caller ID database and related systems, except where retention is strictly required by applicable law;
stop displaying my identity through Caller ID to any Viber user or other recipient;
inform me of the source from which my name was obtained and the categories of recipients to whom this data has been disclosed; and
confirm in writing that this opt-out and erasure have been completed.

Please also treat this message as an objection to any further processing of my personal data for this purpose under Article 37 and, pending completion, as a request to restrict processing under Article 31. Under Article 21 of the Serbian law, information on action taken should be provided without undue delay and within 30 days of receipt of the request.

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Request 2: Withdrawal of permission / opt-out from use of my contact list for Viber Caller ID

I am a Viber user and I request that Rakuten Viber stop using my contact list / address book data for the Caller ID feature, including any uploading, syncing, matching, enrichment, retention, or further use of contact names and phone numbers from my device for Caller ID purposes.

Viber’s non-user data notice states that, for Caller ID, a Viber user may grant access to contacts and agree to add contacts to the Caller ID database. Viber’s Privacy Policy also states that non-user phone numbers and contact names may be processed when included in a user’s address book and provided to Viber, and that such data may then be used in Caller ID.

I therefore exercise my rights under the Serbian Law on Personal Data Protection (“Official Gazette of RS”, No. 87/2018), including:

Article 15(3) – withdrawal of consent must be as easy as giving consent, where processing is based on consent;
Article 30 – erasure of personal data where consent is withdrawn and there is no other legal basis, or where the data is no longer necessary;
Article 37 – objection to processing based on legitimate interests;
Article 31 – restriction of processing;
Articles 24 and 26 – information/access rights regarding categories of data, purposes, legal basis, sources, recipients, and retention period.

Accordingly, I request that Rakuten Viber:

withdraw and record my withdrawal of any consent/permission previously relied on for using my contact list for Caller ID;
stop any present and future collection, upload, syncing, analysis, or use of my contact list for Caller ID;
erase any contact-list data previously obtained from my account/device and used for Caller ID, except where retention is strictly required by law;
confirm whether any contact data from my device has already been used to create, update, or enrich Caller ID records;
identify the legal basis Viber relies on for that processing; and
confirm in writing that my contact list will no longer be used for Caller ID purposes.

Pending completion of this request, please restrict processing of any contact-list data originating from my account/device for Caller ID purposes. Please respond within the period required by Article 21, namely without undue delay and within 30 days of receipt of the request, and free of charge except in the limited cases allowed by law.