Last Updated: January 1, 2020
Advertising and Analytics Services Provided by Others
A. Information You Provide to Us
1. Our Clients
We collect information from our Clients to provide them with our Services.
We collect information you provide directly to us a sour Client. For example, we collect information from you when you:
· Utilize any of our Services (e.g., customer information, including name, postal address, telephone number, and email address);
· Create an account through our online portal on the Site (“Account”) in order to receive our Services. We may collect information in association with your use of our Services, such as standard information relating to your information requests, and any customer service requests and notes or details explaining what you asked for and how we responded.
· Send us a message through the Site, request a quote from us, fill out a form or enter information through the Site, or otherwise communicate with us. We may collect information such as your name, telephone number, postal address, email address, and any other information you choose to provide; or
· Provide us with any other information in order for us to deliver our Services.
B. Automatically Collected Information and OtherInformation We Collect When You Use Our Site
When you access or use our Site, we automatically collect information about you, including:
· LogInformation: We collect information related to your access to and use of the Site, including the type of browser you use, app version, access times, pages viewed, your IP address, and the page you visited before navigating to our Site.
· DeviceInformation: We collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
· InformationCollected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site are popular, count visits and times visited, see what products and services are displayed and searched, and collect server log information other than the above. Web beacons (also known as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Site or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Section 8(B) below. To the extent we or our partners use such technologies through the Site, we offer an opt-out as discussed in Section 7(V).
Specifically, we may use the information we collect about you for the purposes listed below:
A. Provide Our Services
We use your information to improve and optimize the user experience, operation and performance of our Services, and to manage and maintain your Account. We use Client Customer Information to facilitate our Clients’ provision of Client Services to Client Customers. For example, we use Client CustomerInformation (e.g. name and address) to support the fulfillment and shipment of orders.
B. To Communicate with Clients
We may use your information to understand your preferences better and to appropriately personalize the marketing messages we send to Clients. We may also use your information to send marketing communications about the Services and other products, services, and information that may be of interest to Clients.See Section 8(C) below for more information about how to opt-out of these communications at any time.
D. ForCustomer Service
E. ForSite Improvement
We may use your information for our everyday business operations such as auditing, administration of the Site, and analytics. Your information may also be used to improve the content and/or functionality of the Site.
F. For Research, Development, and Analytics
We may use your information for business purposes including providing analytic services and for other strategic purposes.
G. ToPrevent or Mitigate Fraudulent or Illegal Activities
We may use your information to prevent, identify, and investigate scams, cyber-attacks, and other potentially illegal or fraudulent activities, or in relation to any other activities necessary to protect the legal rights of Rakuten SL and/or the rights of third parties.
H. Exercising or Defending Legal Claims
We may use your personal information to exercise our legal rights or defend against legal claims, for example, to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our terms and conditions.
I. For Other Business Purposes
We may use your information for any other purpose disclosed to you at the time we collect or receive the information, or otherwise with your consent.
A. With Our Subsidiaries and Affiliates
We may share information about you with our subsidiaries and affiliates or other Rakuten related entities in order to perform analytics, for strategic purposes, or to provide other services.
B. With Our Vendors
We disclose your personal information with vendors, service providers, and third parties that perform services for us, including business operation related services such as providing us with shipping services, order tracking services, and IT services.
C. To Comply with Law
In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.
D. To Protect RakutenSL or Others
If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Rakuten SL or others.
E. In Connection with a Business Transaction
In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company.
F. With Your Consent or at Your Direction
We may share your information when authorized by you or to provide you with a service you have requested.
G. With our Clients
We only share Client CustomerInformation with the Client that furnished or made such information available to us to provide Services to that Client or as otherwise directed by thatClient.
In addition to the above listed disclosures, we may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.
Our Site may contain links to other web sites, including but not limited to affiliated web sites. Other web sites which are not controlled by Rakuten SL may reference or link to our Site. We encourage you to review the privacy policies of every web site that you visit that our Site may link to or that may link to our Site. We are not responsible for the privacy practices or content of such other web sites or mobile applications.
You have the right to privacy in line with the local laws that applies to you. For example, consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.)and the “Shine the Light” Law (CaliforniaCivil Code Section 1798.83).If you are a California resident, this section applies to you.
A. Additional Disclosures Related to the Collection, Use,Disclosure, and Sale of Personal Information
B. Sale of Personal Information
We do not sell your information for money, but we and our business partners use tracking technologies to help us to understand our customers and visitors to the Site, to enhance your online experience, and customize our offerings in ways that may be deemed a “sale” of personal information under the CCPA. This includes working with third parties such as ad networks which collect personal information via tracking technologies to serve personalized advertisements on and off our Site, provide us with data collection, reporting, ad response measurement. To the extent we or our partners use such technologies on theSite, we offer an opt-out as discussed below in Section7(D).
C. Your Privacy-Related Rights
This Section lists the privacy-related rights (“Rights”)that California users have under the CCPA regarding their personal information.This Section describes your Rights and how to exercise those Rights.
Right to Know and Access: You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Access, and Delete below), we will disclose to you:
· The categories of personal information we collected about you
· The categories of sources for the personal information we collected about you
· Our business or commercial purpose for collecting or selling that personal information
· The categories of third parties with whom we share that personal information
· The specific pieces of personal information we collected about you (also called a data portability request)
· If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
○ sales, identifying the personal information categories that each category of recipient purchased; and
○ disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
Right to RequestDeletion: You have the right to request that we delete any personal information we have collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.
Right toOpt-Out of Sale of Personal Information:
Right to Non-Discrimination:We will not discriminate against you for exercising any of your CCPA rights.Unless permitted by the CCPA, we will not:
· Deny you goods or services.
· Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
· Provide you a different level or quality of goods or services.
· Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
D. How To Exercise Your Right to Know, Access, and Request Deletion
To exercise your right to know, access, or delete as described above, you may submit a request to us by either:
· Calling us at [866 722 9687].
· Completing the webform located at [https://www.rakutensl.com/ccpa].
You may only make a request to know or access twice within a 12-month period.
Your request must be verifiable. In order for us to verify your identity, we will match two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification. If your request is to know or access specific pieces of personal information, you will be required to sign a declaration under penalty of perjury that the you are the consumer whose personal information is the subject of the request.
We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
E. Authorized Agent
Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We may require the agent to provide a written permission from you to submit a request on your behalf and to verify their identity, or demonstrate that he or she has power of attorney in connection with a request to know, access or delete.
F. Shine the Light
California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. We do not share your information with third parties for direct marketing purposes.
G. California Do Not Track Disclosure
California Business & Professions Code Section 22575(b)(as amended effective January 1, 2014) provides that California residents are entitled to know how Rakuten SL responds to “Do Not Track” browser settings. Rakuten SL does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed. We continue to review new technologies and may adopt a standard once one is created.
A. Account Information
You may update and correct certain Account information you provide to us at anytime by logging into your account or emailing us, or [insert any other methods available to users]. If you wish to [delete or deactivate] your Account, [please email us at [insert email address]] [or describe other method, such as through settings on the Site], but note that we may retain certain information as required by law or for legitimate business purposes. We may also retain cached or archived copies of information about you for a certain period of time.
Most web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove or reject browser cookies. Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of our Site.
C. Communications with Rakuten SL
If you no longer wish to receive emails you may click on the hyperlink titled“Unsubscribe” at the bottom of any marketing related email sent to you by Rakuten SL, and then follow the directions to unsubscribe from email, or you can modify your preferences in your Account settings located in the Site. Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your Account or the Services.
We may retain information about you for as long as it is necessary to fulfill the purposes described above in Section3. Some of your information may be retained in our systems even after you request your information to be deleted in order to comply with our obligations under applicable law, collect fees owed, resolve disputes, enforce our legal rights, otherwise use internally in a lawful manner that is reasonably aligned with the expectations of the consumer or compatible with the context in which the information was provided, and to undertake any investigations necessitated by the foregoing.
We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the personal information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of users’ personal information. We evaluate these measures on a regular basis to confirm that it continues to maintain and apply an appropriate level of security.
500 Amigo Court, Suite 100
Las Vegas, Nevada 89119]
tel: 866 722 9687