Last updated on March 17, 2017 and effective April 17, 2017.
COLLECTION OF INFORMATION
We do not intentionally collect or use personal information directly from you such as your name, address, phone number, e-mail address, or credit card information to provide services to Business Customers. However, and as further discussed below, we may receive certain personal information such as email addresses when our Business Customers, especially advertising customers, elect to furnish such personal information to us.
COOKIES AND SIMILAR TECHNOLOGIES
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||_#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.|
|Unique user identifier||uuid||Nextperf||Stores information about the consumer.|
|Server Loadbalancer Identifier||nxtck_srv||Nextperf||Stores details about the traffic source.|
|Cookie Check||tc||Nextperf||Stores information about the consumer.|
|User Optout||opt_out||Nextperf||Stores information about the consumer.|
|User Opt-out||token_nextperformance||Nextperf||Stores information about the consumer.|
|Cache Cookie||ccv2||Nextperf||Stores details about the traffic source.|
|Header bidding cookies||mzxxxx||Nextperf||Stores details about the traffic source.|
|Track user ID||_swuid||Rakuten Marketing||Stores information about the consumer.|
|Track user click on ads||N/NNNNNNNNNN(N’s represent the numbers)||Rakuten Marketing||Stores details about the traffic source.|
|Ad||linkshare_cookieNNNNN (NNNNN is the ID for the Offer associated with Banner that is displayed on the page.)||Rakuten Marketing||Stores details about the traffic source.|
|Consumer ID||lsn_statp||Rakuten Marketing||Stores information about the consumer.|
|Qstring||lsn_qstring||Rakuten Marketing||Stores details about the traffic source.|
|IsTrack||lsn_track||Rakuten Marketing||Stores details about the traffic source.|
|IsClick||lsclick_midNNNNN (NNNNN is the MID for the advertiser that the click belongs to)||Rakuten Marketing||Stores details about the traffic source.|
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 advertisements 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:
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 here rakutenmarketing.com/legal-notices/services-privacy-policy.html.
Specifically, we use your information for a variety of purposes, including:
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.
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 Business Customers/advertiser/partner/vendor information to deliver targeted advertising to you when you visit the websites and applications that participate in or interact with our Services. Cookies and other similar technologies described above may be used in this process. 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.
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 Providers, pursuant to their own privacy policies, 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 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 Business Customers to enable them to provide advertising, analytics or other services.
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.
SECURITY AND DATA RETENTION
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, 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 personal 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 the Services for up to thirty-six (36) months following 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.
CHANGE IN CONTROL
COMMENTS AND QUESTIONS
For any questions about our privacy practices you may contact us by email at firstname.lastname@example.org.
ACCESSING YOUR PERSONAL INFORMATION
To the extent we hold personal information about you, you have the right to access such data held by Rakuten Marketing about you. You may also 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 object to any unsolicited marketing information sent to you by Rakuten Marketing.
If you wish to contact us about the personal information held about you, please e-mail us at email@example.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 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 firstname.lastname@example.org and we will use our best efforts to remove the information from our records.
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.
Our postal address is:
Rakuten Marketing LLC
215 Park Ave. South, 9th Floor
New York, NY 10003
The European representative of the data controllers based outside the European Economic Area for purposes of this Policy is:
Rakuten Marketing Europe Limited
16 Holborn, 4th Floor
London WC1V 6BX