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Services Privacy Policy

RAKUTEN SERVICES PRIVACY POLICY

Last updated on May 25, 2018.

This Privacy Policy explains what information Rakuten Marketing LLC and our corporate affiliates, Rakuten Marketing Europe Ltd., Rakuten Marketing Brazil and Rakuten Marketing Australia Pty Ltd (hereinafter referred to as “Rakuten Marketing” or “we,” “us” or “our”), collect and use in connection with the services we provide to our advertisers, brands, content publishers and participants in our Ad Network (as defined below), and other business customers (“Business Customers”). Rakuten Marketing is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company Rakuten, Inc., based in Tokyo, Japan.

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”).

This Privacy Policy also covers the choices available to end users (“you” or “your”) of websites and other digital properties regarding our collection and use of your information collected through the Services and how you can exercise certain rights regarding such collection and use.  Note that this Privacy Policy applies to data we collect on third party websites and applications in connection with the Services, such as the websites and applications of our Business Customers, as well as websites and applications that we reach through third-party vendors such as Ad Networks. Please contact us if you want more information about these third-party properties/vendors. For information collected through Rakuten Marketing LLC’s corporate website, please see Rakuten Marketing LLC’s Website Privacy Policy https://rakutenmarketing.com/fr-fr/legal-notices/website-privacy-policy.

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.

IF LOCATED IN THE EUROPEAN UNION (EU), REFERENCES IN THIS PRIVACY POLICY TO WHAT WE DO WITH PERSONAL DATA ARE MORE FULLY EXPLAINED IN RIGHTS FOR EU USERS BELOW.

 

COLLECTION OF INFORMATION

We collect certain information from you when you visit the websites and applications that participate in or interact with our Service. We may also obtain information about you as further explained in this section from third-party data providers such as service providers and corporate affiliates (« Data Providers »). In the course of providing services to our Business Customers, we collect the following information 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; viewing an advertisement; and information related to the website you are viewing (e.g., in order to ascertain your interests). This includes information about the products and offers viewed in advertisement browsing and searching, any expressed interests in products within certain segments, and other such information.  For clarity, the collection and use of data from Data Providers’ websites and applications are governed by the privacy policy and legal terms of the Data Provider and the website and/or application using the data.

 

COOKIES AND SIMILAR TECHNOLOGIES

In connection with certain features of our Services to Business Customers, we may set cookies on your web browser (or use other technologies like clear gifs, web beacons or similar devices, including devices that function in the mobile environment) when you interact with websites, applications or advertisements in our network. Cookies are small alphanumeric files that are placed on your computer.  Along with similar technologies, cookies store information about your browsing, use and download activity within the network of websites in which the Services operate. The cookies we use include session cookies, (i.e., cookies that will persist only until you end your session on our Services), and persistent cookies, (i.e., cookies that persist even after you end your session on our Services). The cookies and similar technologies contain a unique identifier that can be used to track your activity, including products viewed on a Business Customer website.  Information collected through the use of the cookies and similar technologies is used by us for purposes described in this Privacy Policy such as to track the web pages, applications, advertisements and products viewed by you for statistical analysis and to serve targeted advertising content to you on behalf of our advertisers. Cookies and similar technologies may be used by our advertising exchanges, advertising networks and similar third parties (“Ad Networks”), advertisers, Data Providers or other partners. The use of such technologies is governed by the respective privacy policies of the advertisers/Ad Networks, Data Providers and/or partner website.

To learn more about cookies visit: www.iab-performance-marketing-explained.net or www.allaboutcookies.org.

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  tc   Nextperf  Cookie Check
 Analytics/Targeting  opt_out   Nextperf  User Optout
 Analytics/Targeting  token_nextperformance   Nextperf  User Opt-out
 Analytics/Targeting  ccv2   Nextperf  Cache Cookie
 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.

The online advertising industry also provides websites from which you may opt-out of receiving targeted ads/interest-based advertising from us, our data partners and our other advertising partners that participate in self-regulatory programs. You may use the NAI opt-out tool at http://www.networkadvertising.org/choices/, which will allow you to opt out of seeing targeted ads from us and other members. The DAA’s opt-out tool can be found at http://www.aboutads.info/choices/.  EU users who have provided their consent to our use of cookies and similar technologies to process their personal information (see the paragraph titled RIGHTS FOR EU USERS below) can use the EDAA’s opt-out tool which can be found at http://www.youronlinechoices.eu/.

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:

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

If you do not want your personal information shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to rm-privacy@mail.rakuten.com. However, we are not responsible for removing your personal information from the lists of any third party who has previously been provided with your information in accordance with this Privacy Policy.

 

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.

As noted in the paragraph above, we may share information we collect about you with third parties such as our Business Customers, advertiser partners, Ad Networks and Data Providers. Third parties are not bound by this Privacy Policy. As such, except as provided herein or under applicable law, their use of any information or other data we share with them, third-party cookies, web beacons, and similar technologies may be governed by their own privacy policy or permissions you granted them.

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, rm-privacy@mail.rakuten.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.

Apart from this initial browser or device reading, if you are located in the EU then the references in this privacy policy to the collection and use of your personal data will occur only after we determine the appropriate legal basis to process such information: (i) consent, (ii) legitimate interest (as described below), or (iii) our compliance with a legal obligation. References to the opt-out possibilities set forth above will apply to you if you have first given consent to the use of your personal data as outlined below. Then you may choose to limit how we may use your personal data.  EU users also have specific rights which are enumerated below.

 

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 rm-subjectrequests@mail.rakuten.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.

 

SECURITY

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

Without limiting our other rights to transfer data and information as set forth in this Privacy Policy, Rakuten Marketing reserves the right in any of the following circumstances to transfer or assign the information we have collected. This includes Rakuten Marketing selling or transferring ownership, operation or control; is acquired by or merged with a third party entity; has an unlikely event of claiming bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors or the application of laws or equitable principles affecting creditors’ rights generally. The information transferred or assigned to these aforementioned events includes any personal information, if any, as part of such merger, acquisition, sale, reorganization or other change of control. Any entity acquiring assets comprising or consisting of your information shall agree to handle such information in accordance with the terms of this Privacy Policy.

 

COMMENTS AND QUESTIONS

We use reasonable processes to ensure compliance with this Privacy Policy and periodically verify that the policy is accurate. We encourage you to raise any concerns using the contact information provided below and we will investigate and attempt to resolve any complaints and disputes regarding use and disclosure of information.

For any questions about our privacy practices, you may contact us by email at rm-privacy@mail.rakuten.com.

 

CHILDREN’S INFORMATION

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 rm-privacy@mail.rakuten.com and we will use our best efforts to remove the information from our records.

 

CHANGES TO THIS PRIVACY POLICY

Rakuten Marketing reserves the right to change or replace this Privacy Policy at any time. Any changes or replacement will be noted through indications on our website related to this Privacy Policy, or by other notice to you, and located at https://rakutenmarketing.com/fr-fr/legal-notices/services-privacy-policy. You will be deemed to have been made aware of and will be subject to, the changes to the Privacy Policy after such notice has been posted. We will state the date this Privacy Policy was last updated. We encourage you to review our Privacy Policy on a regular basis.

 

CONTACT INFORMATION

Our postal address is:
Rakuten Marketing LLC
215 Park Ave. South, 2nd Floor
New York, NY 10003
USA

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
United Kingdom

Rakuten Inc’s Data Protection Officer and the Rakuten Marketing privacy team can be reached at  rm-subjectrequests@mail.rakuten.com.