Website Privacy Policy

Last updated on March 17, 2017 and effective April 17, 2017.

Rakuten Marketing LLC (hereinafter referred to as “Rakuten Marketing” or “we” or “us”) operates its corporate website at rakutenmarketing.com (“Site”). This Privacy Policy applies solely to information collected by us on our Site and outlines our privacy practices, including as they pertain to users of our Site (“you”), including employees and representatives of entities such as advertisers and publishers that have signed up for Rakuten Marketing’s services (“Business Customers”).

This Privacy Policy also describes the choices available to you regarding our use of your information collected on this Site and your choices with respect to the collection and use of such information. For privacy policies relating to Rakuten Marketing’s services please click here rakutenmarketing.com/fr-fr/legal-notices/services-privacy-policy.html.

This Site is designed to be in compliance with the DAA Self-Regulatory Principles for Online Behavioral Advertising and the NAI Code of Conduct.  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.

COLLECTION OF INFORMATION
We collect certain information from you when you visit the Sites including information regarding your browsing, usage and interactions.  We may also collect information that allows us to identify browsers and devices we have interacted with previously. The information that we collect about you may include 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 Android ID 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, 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.

We may also collect personal information, such as your name, address, phone number, e-mail address, or credit card information from the Site only when you choose to provide it to us. For example, you may choose to send us personal information in an email or by completing an online lead form on the Site. We use this information to contact you to respond to your inquiries (including about Rakuten Marketing’s various service offerings) and as otherwise permitted by this Privacy Policy. You may also submit personal information such as name and email address to subscribe to one of our newsletters.

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.

In addition, employees or representatives of current or prospective Business Customers  are required to submit certain pieces of their personal information to us in order to be contacted in connection with (or to allow us to provide) one or more of our Services. Such personal information may include, without limitation, name, phone and email of an entity or any employee or representative, bank account or credit card information and social security number. Certain Business Customers may be required to complete an online form on the Site which could ask for the prospective Business Customer’s name, address, Taxpayer Identification Number (which may be an individual’s Social Security Number), VAT registration numbers or other foreign tax identification numbers (for foreign entities) as well as information about the proposed business to be conducted by such Business Customer through the Services. If we do not enter into an agreement with such prospective Business Customer, then we may (but have no obligation to) retain and/or use the information that the applicant provided on our Site to the extent consistent with this Privacy Policy or in any other way that the applicant has authorized.

COOKIES AND SIMILAR TECHNOLOGIES
“Cookies” are pieces of information that may be placed on your computer by a website for facilitating and enhancing your communication and interaction with that website. We and certain third party business partners, vendors and advertisers may use cookies (or clear gifs, web beacons or similar devices, including devices that function in the mobile environment) to collect information and other behavioral data from you for purposes such as targeting advertising services and better understanding the effectiveness of our advertisements. To learn about cookies in general you may visit www.iab-performance-marketing-explained.net or http://www.allaboutcookies.org.

Sample information about the cookies we use and what they do is set out in the table below:

Type of cookie Cookie name Source What it does
Analytics stc[site id] Rakuten Marketing / DC-Storm Stores details about the traffic source.
Analytics __hssc HubSpot Web Analytics
Analytics __hssrc Hubspot Web Analytics
Analytics __hstc HubSpot Stores details about the traffic source.
Analytics hsfirstvisit HubSpot Web Analytics
Strictly Necessary hubspotutk HubSpot Web Analytics
Tracking _ga Google Universal Analytics Website Analytics
Analytics  s_sq Adobe Analytics Website Analytics
Unique user identifier  s_vi Adobe Analytics Website Analytics
Visitor/Prospect identifier visitor_id Pardot Website Analytics

WEB BROWSER/COOKIE-BASED OPT-OUTS
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 and 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/.

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 we 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 IP Address or browser type or no ads at all.

MOBILE APPLICATION-BASED OPT-OUTS
 Cookie-based opt-outs are not effective on mobile applications. Users may opt out of certain mobile ads 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:

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.

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.

USE AND DISCLOSURE OF INFORMATION
We may use and disclose your information, which may include your personal information, as follows:

  • We may 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.
  • We may 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 may 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 may 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 sweepstakes, raffle, content or other promotion.
  • We may disclose your information in connection with (a) requests from local, state or federal government or law enforcement officials; (b) any judicial, administrative or similar proceeding or order, such as subpoena; (c) if required by law; or (d) to investigate suspected fraud, harassment, physical threats, or other violations of any law, rule or regulation, this Privacy Policy, or the rights of third parties or to investigate any suspected conduct which we deem improper.
    In the case of a disclosure to a third parties to perform services on our behalf, such third parties shall have access to your information for the purpose of performing services for us and for use in a manner directed by us, which use shall be consistent with this Privacy Policy and any consents you provide.
    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 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. We retain the right to use and disclose information that is not personal information in any manner permitted by law.

INTEREST BASED ADVERTISING
We may ourselves, or with third party vendors, use certain data we collect (e.g., information about browsing history, usage, interactions, demographics, account activity etc.) in connection with our own or partner/advertiser/vendor information to deliver targeted advertising to you when you visit other websites or our Site. Cookies and other similar technologies described above may be used in this process as described in this Privacy Policy.   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 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.

DEVICE MATCHING
We may have the ability to match your devices using the data collected, making educated predictions, and, in some cases, using deterministic data (e.g., unique identifiers) or other content across devices.   We may then display targeted advertisements to you across your devices unless it is an Opted-Out Device.

We may also use the information we collect in conjunction with other  information (including demographic, geographic and interest-based data) from third parties such as data vendors, pursuant to their own privacy policies, to provide the Services to our advertising partners such as tools to see how their website or mobile applications are used and tools to enable the display of targeted advertisements to you, including across your devices. For example, we use probabilistic techniques (e.g., algorithmic and other mathematical techniques) to determine the probability that a desktop web cookie and a mobile device belong 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 advertising partners to enable them to provide advertising, analytics or other services.

SECURITY AND DATA RETENTION
We have implemented reasonable security measures in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. These include, among others, firewalls, data encryption redundancy and intrusion detection. Our employees are made aware of and are accountable for compliance with these procedures. Please note, however, that no method of transmission over the Internet or method of electronic storage is 100% secure. As a result, although we strive to protect your information, we cannot ensure or warrant the security of your information against any possible loss or unauthorized access.

We may retain the information collected via our Site for twenty-four (24) months following your last visit to the Site or the last time we saw you on one of the Services. After that time, we may aggregate the data and retain it for analytical purposes. We may retain the personal information provided by you through the Site, for as long as your inquiry is active (as determined by us) and for three (3) years thereafter, or if applicable, for as long as you remain on our marketing list.

CHANGE IN CONTROL
Without limiting our other rights to transfer data and information as set forth in this Privacy Policy, in the event that Rakuten Marketing sells or transfers ownership, operation or control, is acquired by or merged with a third party entity, or in the unlikely event of Rakuten Marketing’s bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, Rakuten Marketing reserves the right, in any of these circumstances, to transfer or assign the information we have collected (including 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.

Advertisers (or prospective advertisers) who have questions or comments about this Privacy Policy or the relevant provisions of their advertiser agreements should contact their account sales or services representatives.

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.

ACCESSING YOUR INFORMATION
To the extent we hold personal information about you, you have the right to access such data held by Rakuten Marketing about you. Specifically, you may  seek confirmation from Rakuten Marketing that personal information is held, a written description of such personal information, the purpose(s) for which it is being used and details of any recipients of that data. You may also ask for your information to be corrected, deleted and may object to the processing of your personal information by us as permitted by applicable data protection laws.

If you wish to contact us about the personal information held about you, please e-mail us at rm-privacy@mail.rakuten.com.

PUBLIC FORUMS
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 rm-privacy@mail.rakuten.com. 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.

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 data from children under the age of 13. If a parent or guardian believes that Rakuten Marketing has in its database the personal information of a child under the age of 13, please contact rm-privacy@mail.rakuten.com and we will use our best efforts to remove the information from our records.

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. You may also opt-out of the disclosure of personal information to third parties for their direct marketing purposes as noted in the “Opt-Out” provision above.

TRANSFERS FROM THE EU
If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from E.U. or U.S. law, please note that you may be transferring your personal information to the Rakuten Group in the United States and in other countries around the world.    We take great care in protecting your personal information and have put in place adequate mechanisms to protect it when it is transferred internationally.

CHANGES TO THIS PRIVACY POLICY
Rakuten Marketing reserves the right to change or replace this Privacy Policy at any time and from time to time. Any changes or replacement will be noted through indications on our website related to this Privacy Policy and located at rakutenmarketing.com/corporate-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, 9th Floor
New York, NY 10003, USA

The European representative of the data controller, Rakuten Marketing, for purposes of this Policy is Rakuten Marketing Europe Limited.  If you are within the European Economic Area, you may contact the European representative of the data controller at the following address:

Rakuten Marketing Europe Limited
16 Holborn, 4th Floor
London WC1V 6BX
United Kingdom