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Rakuten Attribution Privacy Policy

Rakuten Attribution Privacy Policy Statement
Effective Date: September 10, 2014
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Effective September 10, 2014, We updated our Privacy Policy Statement to replace the previous Privacy Policy of DC Storm Limited (“DCS”) as we have acquired DCS. Please read our entire Updated Rakuten DC Storm Privacy Policy. Additional information about these updates may be found in our Frequently Asked Questions.

About US and DCS Services
DC Storm Limited is a subsidiary of Rakuten Marketing LLC (“Rakuten Marketing”). Rakuten Marketing, on behalf of itself and DC Storm Limited (“DCS”), uses this website, www.rakutenmarketing.com to promote or operate its advertising services, including the attribution services offered by DCS. This Privacy Policy Statement covers our privacy practices related to the services offered by DCS. If you want more information about our privacy practices related to our other advertising services, please visit our Rakuten Affiliate Network Privacy Policy Statement, Rakuten Marketing Brazil Privacy Policy Statement or our Rakuten Display Privacy Policy Statement. The words “our” or “we” is a possessive pronoun referring to “Rakuten Marketing” and “DCS” collectively.

The DCS Platform is a SaaS platform that provides multi-channel measurement, attribution, reporting, tag management and optimization solutions for its customers. DCS collects and uses certain types of information about consumers on behalf of its customers.

Information Collected from Visitors to Our Website
While certain areas of this website may be accessed and viewed by members of the public, not all visitors to this website may use or access our services. The DCS services are available for use only by persons or entities that enter into agreements with DCS.

We gather standard information that accompanies internet transmissions (e.g. IP Address), which in some jurisdictions is personal data. Other than this information, we do not gather personal data about or from visitors to or users of this website solely as a result of such visits or usage, other than from (i) people requesting to be contacted with more information about DCS or other Rakuten Marketing service offerings, and (ii) persons or entities who request our services as an Advertiser pursuant to a written contract that we and the Advertiser sign and physically deliver an agreement. We use the personal data submitted with inquiries about DC Storm or other Rakuten Marketing service offerings to respond to those inquiries.

DCS collects and uses certain types of information about visitors to its web site in order to operate flexibly and provide a high level of service. Our website servers log the standard information that accompanies internet transmissions, like the date and time of a visit, browser type, IP address, domain names, access dates and times, referring website addresses and operating system. We also use the services of a third party to analyze information about how visitors use our website. We may also third party uses web tracking technology such as, but not limited to, cookies, Javascript and/or other kinds of Web beacons. We have no control over this third party’s tracking devices. We receive only non-personal data generated by this tracking technology unless you are requesting to be contacted with regard to DCS services, newsletters or other advertising services offered by Rakuten Marketing. We may store cookies on a visitor’s computer in order to manage a visitor’s session on our site. By accessing our site, you agree that we may place cookies on your computer and DCS and our third party may use web tracking technology, in each case, as described above. You may opt-out of receiving cookies used on this website by adjusting your web browser settings to reject cookies. If you reject cookies, you may not be able to take full advantage of all of the features of our website, including “signing in” to password protected areas. To learn more about cookies, click these links:

www.iab-performance-marketing-explained.net
http://www.allaboutcookies.org
For Microsoft Internet Explorer: http://www.microsoft.com/infor/cookies.htm
For Mozilla Firefox: http://support.mozilla.com/en-USkb/Options+window+-
Google Chrome: https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies

To access certain section of this website, you must be a client of DCS and/or Rakuten Marketing and must have entered into a legal contract with either DCS or Rakuten Marketing in order to use our services. Each of our contracts with Advertisers contains terms that set forth the obligations of DCS and/or Rakuten Marketing, as applicable, with respect to the use and disclosure of the information that is gathered from Advertisers. Each of our contracts with Advertisers contains terms that set forth the obligations of Rakuten Marketing with respect to the use and disclosure of the information that we gather through the use of our services with Advertisers. Advertisers should refer to those terms and not to this Privacy Policy.

Data Collected from Consumers As a part of DCS Services to Advertisers
In providing our services to Advertisers, DCS does not deal directly with consumers or customers of Advertisers. In order to provide reports to an Advertiser on the efficacy of their marketing activity, we need basic data about the kinds and volumes of web user activities that occur as a result of traffic to the Advertiser’s website(s), but we do not need data that identifies or permits the identification of any customers or website visitors of an Advertiser. Other than IP Address, we do not intentionally obtain any personally-identifiable data about any of such customers or visitors through our technology or services, unless the Advertiser elects to furnish it to us or authorizes us to obtain such data. To the extent that IP Address or other personally-identifiable data is used or disclosed at Advertisers’ request, our rights and obligations with regard to that information is defined by our contract with the particular Advertiser. We use IP Address for fraud/verification purposes (not for targeting purposes) or to extract non-exact geographical information; such information may be shared with Advertisers for reporting purposes and to give our Advertisers more information about the performance of their advertising campaigns. With respect to any personally-identifiable information gathered at the Advertiser’s request, we will collect, store and maintain such personally-identifiable information as a data processor in accordance with the UK Data Protection Act of 1998.

We do not, through this Privacy Policy or otherwise, make any promise or undertake any obligation directly to any user of any Advertiser website with regard to any use or disclosure of information that a user furnishes directly to any Advertiser or Publisher. Each Advertiser is solely responsible for obtaining cookie consent, establishing its own privacy policy, communicating that policy to the users of its website and ensuring that any access to, processing, storage and use by DCS as a data processor, in accordance with the applicable Advertiser Agreement, of any data about those users are consistent with that Advertiser’s own privacy policy, applicable legal requirements or other obligations or commitments to such users. To the maximum extent permitted by applicable law, we expressly disclaim any obligation or liability to any user of any Advertiser’s website of any nature, including with regard to any data about that user that DCS obtains, processes, stores, uses or discloses.

Potential Advertisers are required to submit certain personal data and information (e.g. Company name, phone and email address) on our websites in ordered to be contacted in connection with one or more of our advertising services. If we do not enter into an agreement with such Prospective Advertiser, then we may (but have no obligation to) retain the information that the applicant provided on our website. Retention of such information may be restricted under applicable laws, and we will delete information in accordance with these laws. We will not disclose this information to third parties except, as follows:

- We may disclose this information with our corporate affiliates in response to your election to be contacted for one or more our various advertising services.

- We may disclose it to government agencies or officials or other third parties if we believe such disclosure to be required or compelled under applicable law or regulations or legal process.

- We may disclose it to government agencies or officials upon their request, even if not compelled by a subpoena or other legal process, and without any duty on our part to independently confirm that such agencies or officials are legally entitled to such disclosure.

- In the event that Rakuten Marketing sells or transfers ownership, operation or control of its corporate affiliates (including DCS) or otherwise engages any subcontractor or agent to operate or provide any service related to DCS, Rakuten Marketing reserves the right to transfer or disclose all or any part of its data to the buyer, subcontractor or agent. In the case of a disclosure to a subcontractor or agent to perform services on our behalf, such contractors and agents may have access to your information, but only to perform services for us.

- In the event that Rakuten Marketing is acquired by or merged with a third party entity, or in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected as part of such merger, acquisition, sale, reorganization or other change of control.

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.

Accessing your Personal Data
You have the right to access data held by DCS about you. You may also seek confirmation from DCS that personal data is held, a written description of such personal data, the purpose(s) for which it is being used and details of any recipients of that data. You may also object to any unsolicited information sent to you by DCS.

If you wish to contact us about the personal data held about you, please e-mail DCS at privacy@dc-storm.com.

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, privacy@dc-storm.com or write to us at the address listed under Contact Information.

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. DCS does not knowingly collect any personal data from children under the age of 13. If a parent or guardian believes that DCS has in its database the personal data of a child under the age of 13, please contact privacy@dc-storm.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 data and information to the United States to our parent, Rakuten Marketing LLC. You may revoke this consent at any time by contacting DCS at the address indicated below, although this may require DCS to restrict your use of the Site.

Security
We have implemented reasonable security measures in order to protect information from loss, misuse and unauthorized access, disclosure, alteration or destruction. These include 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.

Changes to Our Privacy Policy
We reserve 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. As such, we will state the effective date this Privacy Policy was last updated and encourage you to review our Privacy Policy on a regular basis. If we have a way to do so, and your consent to do so, we will contact you by email in the event this privacy policy is materially changed. 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 with the following exception: if at the time you provide personal information to DCS, you limit how such information will be used to communicate with you, either by DCS, Rakuten Marketing or by third parties, will not change your preference in this regard without your express consent.

Change in Control
In the event that we sell or transfer ownership, operation or control, is acquired by or merged with a third party entity, or in the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we reserve the right, in any of these circumstances, to transfer or assign the information we have collected as part of such merger, acquisition, sale, reorganization or other change of control. You agree that we may provide to such entity information that is related to that part of our business that was sold to or merged with the other entity without obtaining your further consent. 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.

Questions and Comments about Our Privacy Policy/Removal or Correction of Information
Advertisers (or Prospective Advertisers) who have questions or comments about this Privacy Policy or the relevant provisions of their Advertiser Agreements should contact their account sales or services representatives.

Consumers with questions about our privacy practices or who wish to have their personal data corrected or removed may contact us by email at privacy@dc-storm.com.

Contact Information
Our postal address is:

DC Storm Limited
3rd Floor, 42 Frederick Place
Brighton BN1 4EA
United Kingdom

Rakuten Marketing LLC
215 Park Ave. South, 9th Floor
New York, NY 10003

The European data controller for purposes of this Policy is DC Storm Limited. If you are within the European Economic Area, you may contact the European data controller at the following address:

DC Storm Limited
3rd Floor, 42 Frederick Place
Brighton BN1 4EA
United Kingdom