Services Privacy Policy

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

This Privacy Policy explains what information Rakuten Marketing LLC and our affiliates Rakuten Marketing Europe Ltd. and Rakuten Marketing Brazil (hereinafter referred to as “Rakuten Marketing” or “we,” “us” or “our”) collect and use in connection with the services (the “Services”) we provide to our advertising and other business customers (“Business Customers”).This Privacy Policy also covers the choices available to end users of websites and other digital properties regarding our use of your information collected through the Services and how you can opt out of such use of your information in connection with our Services. Note that this Privacy Policy applies to data collected on third party sites in connection with the Services. For information collected through Rakuten Marketing LLC’s corporate website, please see Rakuten Marketing LLC’s Website Site Privacy Policy rakutenmarketing.com/pt-br/legal-notices/website-privacy-policy.html.

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”). This Privacy Policy is designed to comply with 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 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.

We collect certain information from you when you visit the websites and applications that participate in or interact with our Services and 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”). Specifically, we collect information regarding your browsing, usage and interactions. We may also collect information that allows us to identify browsers and devices you 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, 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) including 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 is governed by the privacy policy and legal terms of the Data Provider and the website using the data.

COOKIES AND SIMILAR TECHNOLOGIES
In connection with certain features of our Services to Business Customers, we 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) if you interact with websites, applications or advertisements in our network. These cookies and similar technologies store information about your browsing, use and download activity within the network of sites 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 and their use of such technologies is governed by the respective privacy policies of the advertisers/Ad Networks, Data Providers and/or partner site.

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

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 here rakutenmarketing.com/pt-br/legal-notices/services-privacy-policy.html.

Specifically, we use your information for a variety of purposes, including:

  • sharing it with third parties such as Business Customers, advertising partners, Ad Networks, Data Providers and corporate affiliates in order to provide Services, conduct internal analysis to perform and improve the Services, 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 in order to provide Services to Business Customers, conduct internal analysis in order to perform and improve the Services and the services of our corporate affiliates;
  • inferring eligibility of users for interest, geographic and demographic-based segments;
  • presenting advertisements tailored to interests you have shown;
  • determining whether you have seen a particular advertisement before so as 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, including statistical reporting in connection with the activity on a website or mobile application, optimization of 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;
  • evaluating the probability and nature of connections between devices; and
  • creating online advertising models through lookalike modelling 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, Data Providers. Third parties are not bound by this Privacy Policy. As such, 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.

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 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.

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 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, rm-privacy@mail.rakuten.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
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.

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 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 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.

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/pt-br/legal-notices/services-privacy-policy.html. 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 controllers based outside the European Economic Area for purposes of this Policy is:

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