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Rakuten Display Privacy Policy

Rakuten Display (formerly Rakuten MediaForge) Privacy Policy Statement
Effective Date: September 10, 2014
Effective September 10, 2014, Rakuten Marketing LLC has updated its Privacy Policy Statement to replace the previous Privacy Policy of Rakuten MediaForge. Please read our entire updated Privacy Policy Statement. Additional information about these updates may be found in our Frequently Asked Questions.

About Us and Rakuten Display Services
Rakuten Display is a division of Rakuten Marketing LLC (“Rakuten Marketing”). Rakuten Marketing uses this website, www.rakutenmarketing.com to promote or operate our advertising services, including the display/retargeting services offered by Rakuten Display. This Privacy Policy Statement covers our privacy practices related to our Rakuten Display services, as follows: display/retargeting and interest-based advertisements. 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 Attribution Privacy Policy Statement.

Rakuten Display is a remarketing/retargeting tool for Advertisers that collects de-identified usage data from visitors and users. The information we gather is completely de-identified. Rakuten Display uses the information to display targeted advertisements to Internet users. Rakuten Display does not provide any personal identifiable information (“PII”) to our Advertisers when consumers interact with or view Rakuten Display targeted advertisements. Rakuten Marketing values the protection of consumer privacy. With respect to our Rakuten Display Services, we are active members of the Network Advertising Initiative (“NAI”) (www.networkadvertising.org) and adhere to the NAI Code of Code. We also comply with the self-regulatory principles of the IAB with respect to our Display/Retargeting services.

Information Collected from Visitors to This Website
We gather standard information that accompanies Internet transmissions, which in some jurisdictions is personally-identifiable information. Other than this information, we do not gather PII 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 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 PII submitted with such inquiries about our service offerings to respond to those inquiries.

This 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 use the services of our subsidiary, DC Storm Limited, or a third party to analyze information about how visitors use our website. We or the third party may use web tracking technology such as, but not limited to, cookies, Javascript and/or other kinds of Web beacons. We have no control over the third party’s tracking devices. We receive only non-PII generated by this tracking technology. Rakuten Marketing may store cookies on a visitor’s computer in order to manage a visitor’s session on our site. By accessing our website, you agree that Rakuten Marketing may place cookies on your computer and the third party may use web tracking technology, in each case, as described above. In general, you may opt-out of receiving cookies from 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:

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 Rakuten Marketing and must have entered into a legal contract with Rakuten Marketing in order to use our services. 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 from our Advertisers.

Prospective Advertisers are required to submit certain PII (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 the company or otherwise engages any subcontractor or agent to operate the Rakuten Display service or provide any service related to Rakuten Display, 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.

Please note that this Section only refers to cookies used on our website (and the removal of cookies used on our website) and not to the cookies used in our Rakuten Display Services. The removal procedures outlined in this Section will not remove cookies used in our Rakuten Display services. For more information about display/retargeting cookies (and the opt-out practices for the removal of those cookies), please refer to the Section entitled “Opting-Out of Display/Retargeting Cookies” below.

Information Collected Through the Use of the Rakuten Display Services
When an end user views or interacts with Rakuten Display advertisements or a partner’s website we collect and store information about the interactions and usage. The information we collect relates to interaction behavior, including, but not limited to, products and offers viewed in-ad browsing and searching, video content viewed, and other de-identified behavioral data. In order to gather such information as it relates to specific users, Rakuten Display and partners set and store browser cookies on the computer of each unique user. We do not collect any PII as such we do not share any PII with our clients or advertising partners.

Rakuten Display may combine non-PII usage information with information we obtain from clients/advertisers, ad network partners, and/or other companies. In conjunction with our Advertiser and ad network partners, we may use cookies, web beacons, or similar technologies (i) to present advertisements tailored to interests you have shown while browsing, (ii) to determine whether you have seen a particular advertisement before so as to avoid sending you duplicate advertisements, and (iii) to understand the patterns of people who see advertisements. In doing so, our servers collect non-PII such as your browser type, operating system, websites you have visited, the time of the visits, the content you viewed, ads you viewed, and similar information. Our Advertiser and ad network partners may connect information about your visit on a particular Advertiser website with information about your visit on other sites and tailor your advertisements based on this combined information. We may share non-PII, summary, or aggregate customer data with our Advertiser partners, ad network partners, corporate affiliates (who use our Services) and other third parties. Our Advertiser and ad network partners are not be bound by this privacy policy. As such, their use of third party cookies, web beacons, and similar technologies by these ad network providers may be governed by their own policy. If you wish to receive targeted advertising, you may opt-out of some companies targeted advertising services by visiting http://www.aboutads.info/choices/ or http://www.networkadvertising.org/choices/. If you wish to opt-out of display/targeted/interest-based advertising by Rakuten Display, please follow the instructions set forth below in the Section entitled “Opting-Out of Display/Retargeting”.

Sensitive Information
In the performance of our Rakuten Display services, we use IP address for fraud and verification purposes. We will not collect or use sensitive PII from consumers. Sensitive PII includes information we know to be related to an end user’s name, address coupled with social security number credit card information, financial information, confidential medical information, racial or ethnic origins, political or religious beliefs or sexuality.

Use of De-Identified Information
Rakuten MediaForge Display uses the de-identified information it collects to customize the advertisements that consumers see on participating web sites and to analyze if the advertising resulted in sales. At times, we send our clients and partners the aggregated de-identified data for their use in determining which products and offers to display in their ads. The specific source of the data is not disclosed.

How De-Identified Information is Secured
We take appropriate reasonable security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. This includes the necessary physical, electronic and managerial procedures 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 information, we cannot ensure or warrant the security of your information against any possible loss or unauthorized access.

Use of Cookies for Display Media/Targeting Services
In connection with certain features of our services to Advertisers, we use cookies to tag end users of our Advertiser sites with de-identified cookies. The tagged end users are given a de-identified identifier in order to track products viewed on the Advertiser and ad partner site. Our ad partner site will also use cookies that will work in conjunction with the first cookie tagged on the Advertiser or partner site to serve targeted advertisements to such tagged end users. The cookies track the products viewed by the visitor and pages visited of the Advertiser or partner site for whom Rakuten Display is delivering ads. The cookies we currently use permit us to serve targeted advertisements but do not permit us to determine the identity of any end user or gather any other personally-identifiable information about that user, such as postal address, email address, phone number, social security number or any credit card number. Cookies used by our Advertiser or partner sites are governed by the respective privacy policies of the Advertiser and/or partner site.

Opting-Out of Display/Retargeting Cookies
There are many programs that allow you to manually delete your cookies. In addition, Rakuten Display offers consumers the opportunity to select a persistent “blank” or “opt-out cookie” to prevent information from being uniquely associated with your browser. This way, you can opt-out of Rakuten Display cookies, without erasing or altering other cookies associated with your browser. If you wish to not participate in our targeted advertising program there is a simple process you can follow. Simply click on the opt-out link below which will take you to a site that will analyze which cookies are stored in your browser. You can select “Rakuten Display” or “Rakuten MediaForge” from this list and click “submit” to be removed from our services. To opt out, please click here http://www.networkadvertising.org/choices/.

PLEASE NOTE that if you erase or otherwise alter your browser’s cookie file (including upgrading certain browsers) you may need to perform this process again.

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, rmf-privacy@mail.rakuten.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. Rakuten Marketing does not knowingly collect any personally identifiable information from children under the age of 13. If a parent or guardian believes that Rakuten Marketing has in its database the personally-identifiable information of a child under the age of 13, please contact rmf-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 U.S. law, including those whose privacy laws may be more strict than U.S. laws, please note that you are transferring your personal information to the United States to Rakuten Marketing. You may revoke this consent at any time by contacting Rakuten Marketing at the address indicated below, although this may require Rakuten Marketing to restrict your use of the Site.

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. If we have a way to do so, and your consent to do so, Rakuten MediaForge 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 Rakuten Marketing, you limit how such information will be used to communicate with you, either by Rakuten Marketing or by third parties. As such, we will state the date this Privacy Policy was last updated. We encourage you to review our Privacy Policy on a regular basis.

Change in Control
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 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 Rakuten Marketing 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. In this event, we will use reasonable efforts to notify you before information about you is transferred and becomes subject to a different 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 rmf-privacy@mail.rakuten.com.

Contact Information
Our postal address is:

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