Last updated on May 25, 2018.
Rakuten Marketing is an online business-to-business marketing company which provides services to website publishers and advertising brands. Those services include personalized advertising, fraud detection, facilitating transactions between Business Customers and other online tools and technology for online advertising (“Services”).
With respect to the Services, we are active members of the Network Advertising Initiative (www.networkadvertising.org) (“NAI”). We are also active members of the Digital Advertising Alliance (“DAA”), as well as the European Interactive Digital Advertising Alliance (“EDAA”). We comply with DAA Self-Regulatory Principles for Online Behavioral Advertising (“OBA”), the NAI Code of Conduct, and the Interactive Advertising Bureau (IAB) Europe Framework for OBA. Click here if you would like further information regarding the DAA Self-Regulatory Principles, here if you would like more information regarding the NAI Code of Conduct or here if you would like further information about the IAB Europe’s OBA Framework.
COLLECTION OF INFORMATION
COOKIES AND SIMILAR TECHNOLOGIES
We use different types of cookies and some cookies are put into the following categories (please note that some cookies may be used differently by different Business Customers):
- Analytical/performance cookies. They allow us to recognize a return visitor to the website of a Rakuten Marketing Business Customer.
- Functionality cookies. These are used to recognize you when you return to the website of a Rakuten Marketing Business Customer. This enables us to personalize advertising content for you, and remember your preferences (for example, your choice of language or region).
- Targeting cookies. These cookies record your visit to the website of a Rakuten Marketing Business Customer, the pages you have visited and the links you have followed. We use this information to make the advertising displayed to you more relevant to your interests. You can find more information about the individual cookies we use and the purposes for which we use them in the table below:
Here is a list of some of our cookies that our Business Customers may choose to use:
|Type of cookie||Cookie name||Source||What it does|
|Analytics||_#srchist||Rakuten Marketing||Stores details about the traffic source.|
|Analytics||_#sess||Rakuten Marketing||Stores information about the current visit.|
|Analytics||_#vdf||Rakuten Marketing||Stores details about the traffic source.|
|Analytics||_#uid||Rakuten Marketing||Stores consumer information|
|Analytics||_#slid||Rakuten Marketing||Stores consumers purchase information.|
|Analytics||_#clkid||Rakuten Marketing||Stores details about the traffic source.|
|Analytics||_#lps||Rakuten Marketing||Stores details about the traffic source.|
|Analytics||_#tsa||Rakuten Marketing||Stores details about the traffic source.|
|Analytics||_#env||Rakuten Marketing||Stores information about the consumer.|
|Analytics||stc[site id]||Rakuten Marketing||Stores details about the traffic source.|
|Analytics||_#nxd||Rakuten Marketing||Stores details about the traffic source.|
|Analytics||userID||Rakuten Marketing||Stores information about the consumer.|
|Analytics||cID||Rakuten Marketing||Stores details about the traffic source.|
|Analytics||pID||Rakuten Marketing||Stores details about the traffic source.|
|Analytics/Targeting||uuid||Nextperf||Unique user identifier|
|Analytics/Targeting||nxtck_srv||Nextperf||Server Loadbalancer Identifier|
|Analytics/Targeting||mzxxxx||Nextperf||Header bidding cookies|
|Analytics/Targeting||_swuid||Rakuten Marketing||Track user ID|
|Analytics/Targeting||N/NNNNNNNNNN(N’s represent the numbers)||Rakuten Marketing||Track user click on ads|
|Analytics/Targeting||linkshare_cookieNNNNN (NNNNN is the ID for the Offer associated with Banner that is displayed on the page.)||Rakuten Marketing||Ad|
|Analytics/Targeting||lsn_statp||Rakuten Marketing||Consumer ID|
|Analytics/Targeting||lsn_qstring||Rakuten Marketing||Stores details about the traffic source.|
|Analytics/Targeting||lsn_track||Rakuten Marketing||Stores details about the traffic source.|
|Analytics/Targeting||lsclick_midNNNNN (NNNNN is the MID for the advertiser that the click belongs to)||Rakuten Marketing||Stores details about the traffic source.|
Opt-Outs AND WITHDRAWAL OF CONSENT
If you are located in the EU and we are relying on your consent to process your personal information, you have the right to withdraw your consent at any time. To withdraw your consent, or to learn more about your rights as a data subject, please see the EU USERS BELOW paragraph below. Regardless of whether you are located in the EU or elsewhere, you may exercise the applicable opt-out options below.
Web Browser/Cookie-Based Opt-Out
You may stop or restrict the placement of cookies on your computer or remove them from your browser by adjusting your web browser preferences. There are also many programs that allow you to manually delete your cookies.
To be clear, the opt-out from targeted ads must be performed on each device and browser that you wish to have opted out. For example, if you have opted out on your computer browser, that opt-out will not be effective on your mobile device. You must separately opt out on each device. However, once you have opted out on one device (“Opted-Out Device”), we will not use any new data from the Opted-Out Device to identify you on another device for interest-based advertising purposes, and will not use data from another device for interest-based advertising purposes on the Opted-Out Device.
If you erase or otherwise alter your cookie/device settings (including upgrading certain browsers or devices) you may need to perform each opt-out process again, unless we can match the device as outlined above.
Even if you opt out of targeted ads based on cookies, you may still see ads based on other general factors such as webpage context or browser type.
Mobile Application-Based Opt-Outs
Cookie-based opt-outs are not effective on mobile applications. Users may opt out of certain advertisements on mobile applications or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS and Android device, click on the following links:
- iOS – https://support.apple.com/en-us/HT202074
- Android – https://support.google.com/ads/answer/2662922?hl=en
You may also download and set your preferences on the App Choices mobile application(s) available in Google Play or the Apple App stores.
Third Party Marketing Opt-Out
USE OF INFORMATION
We use information, which may include personal information, held about you to perform the Services and for other purposes outlined below. You can find out more about our Services at https://rakutenmarketing.com.
Specifically, we use your information as follows:
- Sharing it with third parties such as Business Customers, advertising partners, Ad Networks, Data Providers and corporate affiliates. This is in order to allow our Business Customers to operate online advertising campaigns, conduct internal analysis to perform and to improve the effectiveness of the advertising services we provide to our Business Customers, associated technologies, and the services of our corporate affiliates.
- Combining information we collect about you with information we obtain from Business Customers and other partners, Ad Networks and/or other companies such as Data Providers including our corporate affiliates (pursuant to their own privacy policies). This is in order to provide Services to our Business Customers such as tools to see how their website or mobile applications are used and tools to enable the display of targeted advertisements across multiple devices. This gives the capability to conduct internal analysis in order to perform and improve the effectiveness of the online advertising services that we provide to our Business Customers and the services of our corporate affiliates.
- Determining whether a web user profile fits a relevant segment (e.g., a web user that visits a sporting good website might fit within the segment of users interested in sporting goods).
- Presenting advertisements tailored to interests you have shown. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites or applications you view with information on that product. We believe that such advertising is helpful because you will see advertisements that are relevant to your interests. We may use Ad Networks to deliver advertisements and related services to you on behalf of our advertisers.
- Determining whether multiple devices (e.g., a desktop computer and a mobile phone) are connected by applying probabilistic techniques (e.g., algorithmic and other mathematical techniques) to data that we collect. For example, determining the probability that a desktop web cookie and a mobile device belonging to the same user. We may supplement such probabilistic data with deterministic data (e.g., unique identifiers). We may also share this device matching information with our Business Customers to enable them to provide advertising, analytics or other services.
- Determining whether you have seen a particular advertisement before to avoid sending you duplicate advertisements.
- Understanding the patterns of people who see advertisements.
- Providing insights and reporting back to Business Customers and other partners. This includes statistical reporting in connection with the activity on a website or mobile application, optimization of the location of ad placement, ad performance, reach and frequency metrics, billing, and logging ads served on a particular day to a particular website or application.
- Determining the probability and nature of connections between devices.
- Creating online advertising models through lookalike modeling or similar research methodologies.
To be clear, we may, to the extent permitted by applicable law, collect or create information that is not personal information such as sets of aggregate data and other generalized information, including information about browsing, usage and interactions and de-identified personal information that does not reveal your identity. We retain the right to use and disclose information that is not personal information in any manner permitted by law.
DO NOT TRACK
There is currently no universally recognized standard for Do Not Track signals. Accordingly, at this time, cookies used on our website and used in providing our services do not respond to any Do Not Track signals or browser settings. You may opt-out of receiving cookies by adjusting your web browser settings to reject cookies.
YOUR CALIFORNIA PRIVACY RIGHTS
California Law permits our customers who are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please contact us by email, firstname.lastname@example.org or write to us at the address listed under Contact Information.
RIGHTS OF EU USERS
If you are located in the EU and EU data protection law applies to the processing of your information, we provide the controls described in this policy so you can exercise your right to request access to, update, remove and restrict the processing of your information. You also have the right to object to the processing of your information or export your information to another service.
When you first visit a website or application, we read cookies and similar technologies on the internet browser of your device or in connection with applications you use that allows us to identify browsers and devices that have previously interacted with our Services or Business Customers. This initial reading of cookies and similar technologies allows us to determine whether you or the user(s) of your device, have previously given consent to the use of “personal data” as defined under applicable EU law.
Legal Basis For Using EU User Personal Data:
In the EU, the processing of your personal data must rely on a legal basis. For these regions, there are different legal bases that we rely on to use your personal data, namely:
- Legitimate interest: We may process your personal data for consumers, Business Customers, and our legitimate interests. For example, to provide or improve our Services, perform affiliate matching (e.g., for determining referral fees or commissions owed to Business Customers), manage relationships with Business Customers, or for security purposes and fraud prevention. When we process personal information to meet our legitimate interests, we put in place safeguards to ensure that your privacy is protected and to ensure that our legitimate interests are not overridden by your interests or fundamental rights and freedoms
- Consent: Our Business Customer and us will rely on your consent to use your personal data (including, without limitation, technical data, cookie data, usage information, and geo-location data), for personalized or interest-based advertising purposes. This allows our Business Customer and us to find other consumers with similar online behaviors to create lookalike modeling or to share your personal data with third parties for their marketing purposes. You may opt-out of your data usage at any time by using this Subject Access Request page or by using the tools outlined above.
In addition to the other rights outlined above, individuals based in the EU also have the right to be informed of the following:
- Data Sharing: The direct recipients of your personal data include our corporate affiliates, as well as Business Customers such as advertisers and publishers in the Rakuten Ad Network. There may also be indirect recipients of a limited amount of personal data based on your internet activity because of how advertising technology and digital marketing function. Among the types of entities who may access data are: agencies, agency trading desks, retargeting entities, ad servers, privacy verification entities, measurement and analytics entities, data suppliers, data aggregators, demand-side platforms and supply side platforms, ad networks, and others on ours or our Business Customers’ behalf.
- Duration of the Processing: Rakuten Marketing may actively process your personal data for one year from the time of your last interaction with our Services or the websites or applications of our Business Customers (“Interaction Date”). We may, however, store your data in a pseudonymized or anonymized form for up to seven (7) years after the Interaction Date in order to comply with other legal requirements. After such time we delete your personal data from our system(s).
- Transfers of Personal Data: Rakuten Marketing and our Business Customers may be located in various countries throughout the world. As a result, personal data may also be transferred from the EU to the United States and other jurisdictions whose laws may differ from those in the EU. Rakuten Marketing relies on the Rakuten, Inc. Binding Corporate Rules (BCR) for legal data transfers outside of the EU within the Rakuten Group companies. The Luxembourg Data Protection Authority, acting as the lead authority for Rakuten, Inc., has approved the BCR. The BCR ensures your personal data is protected by requiring all Rakuten Group companies to follow the same rules when processing your personal data. For more information on the BCR’s please visit https://corp.rakuten.co.jp/privacy/en/bcr.html. For data transfers to entities outside of the Rakuten Group in countries that have not been deemed to provide an adequate level of protection by the European Commission, we may use specific contracts promulgated by the European Commission, such as the Standard Contractual Clauses.
EU Data Subject Rights
Under certain circumstances, EU users have rights under data protection laws in relation to your personal data, including as follows.
- Access, Correction, Restriction, Erasure and Portability: You have the right to (i) access your personal data which we may have in our system(s); (ii) request correction of your personal data we have in or system(s); (iii) object to or request that we restrict the processing of your personal data under certain circumstances; (iv) request erasure of your personal data from our system(s) under certain circumstances; and (v) request transfer of your personal data out of our system(s) in a commonly used format. To exercise the access, correction, restriction, erasure and portability rights, please fill out the form located here and provide the verification information as stated on the form.
- Withdrawal of Consent: Where we are relying on consent to process your personal data, you have the right to withdraw your consent at any time. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. In order to withdraw your consent, please use the go to the data subject access request page and submit a request.
- Right to Lodge a Complaint: EU users also have the right to lodge a complaint about Rakuten Marketing processing your personal data with your local data supervisory authority. We would, however, appreciate an opportunity to address your complaint before you approach the supervisory authority so please contact us in the first instance with any complaints you may have by sending an email to email@example.com.
Rakuten Marketing will use all reasonable efforts to facilitate your exercise of the above rights in accordance with applicable data protection laws. Please note that in order for you to assert these rights, we need to verify your identity to confirm your rights. This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.
We take appropriate reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of personal information. This includes the necessary physical, electronic and managerial procedures designed to protect data integrity, access and use. Please note that no method of transmission over the Internet or method of electronic storage is 100% secure. As a result, we strive to protect your personal information but cannot ensure or warrant the security of your information against any possible loss or unauthorized access.
CHANGE IN CONTROL
COMMENTS AND QUESTIONS
For any questions about our privacy practices, you may contact us by email at firstname.lastname@example.org.
We believe it is important to provide added protection for children online. We encourage parents and guardians to spend time online with their children to participate in and monitor their online activity. Rakuten Marketing does not knowingly collect any personal information from children under the age of 13 (or such other age as may be restricted under local law). If a parent or guardian believes that Rakuten Marketing has in its database the personal information of a child under the age of 13 (or such other age as may be restricted under local law), please contact email@example.com and we will use our best efforts to remove the information from our records.
Our postal address is:
Rakuten Marketing LLC
215 Park Ave. South, 2nd Floor
New York, NY 10003
The European representative for purposes of this Policy is:
Rakuten Marketing Europe Limited
71 queen Victoria street 7th Floor Queen Victoria Street,
London EC4V 4AY
Rakuten Inc’s Data Protection Officer and the Rakuten Marketing privacy team can be reached at firstname.lastname@example.org.