Last updated on May 25, 2018.
This Site is designed to be in compliance with the DAA Self-Regulatory Principles for Online Behavioral Advertising and 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 or 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
We collect information from you when you visit the Sites including information regarding your browsing, usage, and interactions. We also collect information that allows us to identify browsers and devices we have interacted with previously. The information that we collect about you: the type of Internet browser, browser language and operating system you use; your device’s Internet protocol (“IP”) address; access dates and times; unique device identifiers as well as hardware or operating system device identifiers (e.g., IDFA for iOS and AAID for Android); connection type (wired or Wi-Fi); the region where your device is located; network to which your device is connected; longitude/latitude of a (mobile) device; SDK data; engagement data; geo-IP data; the mobile carrier (if available); the website you came from before, and visited after; and information related to the pages you are viewing on the Website.
Certain sections of the Site (including certain password protected sections) can only be accessed by employees or representatives of Business Customers. Each of our contracts with Business Customers may contain terms that set forth more specific obligations and rights of Rakuten Marketing with respect to the use and disclosure of the information that we gather from a specific Business Customer.
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:
Sample information about the cookies we use and what they do is set out in the table below
|Types of cookies||Source||What it does||Link to source|
|Analytics and Targeting||Rakuten Marketing||Stores details about the traffic source.||https://rakutenmarketing.com/legal-notices/services-privacy-policy|
|Analytics||Google Universal Analytics||Website Analytics||https://developers.google.com/analytics/devguides/collection/analyticsjs/cookie-usage|
|Analytics and Targeting||LinkedIn Tracking||Website Analytics||https://www.linkedin.com/legal/cookie-table|
|Analytics and Targeting||Adwords||Website Analytics||https://support.google.com/adwords/answer/7521212|
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 AND DISCLOSURE OF INFORMATION
We may use and disclose your information, which may include your personal information, as follows:
- We use your information, as provided by you through the Site, to contact and correspond with you and/or to respond to your inquiries, as well as for other business purposes such as adding you to our marketing lists, reviewing your application if you are applying to become a Business Customer.
- 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 for ourselves and 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 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 also use your information to analyze your interactions with and performance of our Site, to determine how much time visitors have spent on the Site, to improve our Site and our Services, for our research activities and to gather demographic information about our user base as a whole.
- If you are a Business Customer, we may use and disclose your personal information as necessary to provide the Services.
- We share your information with our corporate affiliates (including our parent company and its personnel) for the purposes of conducting internal analysis to improve our services and the services of our corporate affiliates.
- We disclose your information to third parties who are providing services on our behalf. For example and without limitation, (a) where you apply for participation as a publishing customer in one of our advertising platforms, we may share information submitted by you with third party vendors to authenticate and/or supplement your application information; (b) we may also share Business Customers’ credit card information with our third party banking and payment portal for the purposes of collecting payments due to us or to facilitate payment to a Business Customer; (c) we may share information in connection with any sweepstakes, raffles, contests or other promotions you’ve entered or intend to enter for the purposes of facilitating your participation in that sweepstake, raffle, content or other promotion.
- We do not sell your personal information to third parties or mass marketers.
- Finally, please note that if you specifically consent to additional uses or disclosures of your information, we may use your information in a manner consistent with that consent.
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, email@example.com 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 our legitimate interests. For example, to provide or improve our Services, 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: We 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. 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.
- Fulfillment of Contract: We will process your business contact information you provide when registering for our services to provide the Services and manage relationships. We will also reach out to you about the additional opportunities within our Services to make sure you are aware of all of the available options.
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 access to the Service.
- Duration of the Processing: Rakuten Marketing may actively process your personal data for two years 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 firstname.lastname@example.org.
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 email@example.com.
THIRD PARTY SITES AND PARTNERS
Our Site may contain links to other websites, including our advertisers’ websites. Other websites may also reference or link to our Site. Some of our advertisers or third-party website or technology partners may place their own cookies and/or other data collection tools on your Internet browser; however, we have no access to or control over these cookies and/or other data collection tools. These other domains and/or websites are not controlled by us. We encourage our users to read the privacy policies of each and every website that they interact with. We do not endorse, screen or approve, and are not responsible for the privacy practices or content of such other websites. Visiting these other websites is at your own risk.
Our Site offers a publicly accessible blog. You should be aware that any information you provide in these areas may be read, collected, and used by others who access them. To request removal of your personal information from our blog, contact us at firstname.lastname@example.org. In some cases, we may not be able to remove your personal information, in which case we will let you know if we are unable to do so and why.
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.