Last updated on March 17, 2017 and effective April 17, 2017.
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.
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.
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||stc[site id]||Rakuten Marketing / DC-Storm||Stores details about the traffic source.|
|Analytics||__hstc||HubSpot||Stores details about the traffic source.|
|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:
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:
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 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
COMMENTS AND QUESTIONS
For any questions about our privacy practices you may contact us by email at email@example.com.
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 firstname.lastname@example.org.
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 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.
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. 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.
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