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/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.
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.
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):
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. |
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.
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.
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.
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.
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:
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.
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.
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.
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.
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:
In addition to the other rights outlined above, individuals based in the EU also have the right to be informed of the following:
Under certain circumstances, EU users have rights under data protection laws in relation to your personal data, including as follows.
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.
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.
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.
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.
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/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.
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-subjectrights@mail.rakuten.com.