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.
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.
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):
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|
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.
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.
We may use and disclose your information, which may include your personal information, as follows:
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, email@example.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.
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
For any questions about our privacy practices, you may contact us by email at firstname.lastname@example.org.
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 email@example.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.
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 firstname.lastname@example.org 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 email@example.com.