Privacy Policy

Last updated on August 15, 2025

This Privacy Policy (“Policy”) applies to personal information that we, Rakuten Marketing LLC dba Rakuten Advertising (“Supplier”, “we”, or “us”), a business-to-business advertising technology company, collect and process from and about the business representatives of our advertiser and publisher clients (“Clients”), prospective Clients, visitors to our B2B corporate website (“Site”), including the Client portals accessible from the Site (currently hosted on the rakutenmarketing.com domain), users of our Client mobile applications (“Apps”), and attendees of our business industry events (“Events”). For this personal information, we act as the data controller or business, as applicable under the relevant privacy laws and regulations.

This Policy does not apply to the personal information we process on behalf of our Clients as part of our business-to-business advertising services (the “Services”). For the Services, which do not include any cross-context targeted advertising, we act as a service provider or data processor, as applicable under the relevant privacy laws and regulations, and our clients are the businesses or data controllers of any personal information processed therefor, as reflected in our Client DPAs. Please refer to the privacy policies of our respective Clients for information on their data practices.

We are part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company, Rakuten Group, Inc., based in Tokyo, Japan.

If you have any questions or concerns about our use of your personal information, please contact us using our Privacy Request Form.

Information We Collect

As a data controller, we collect certain categories of information from and about you that can vary based on how you interact with us – for example, we collect different categories of information when you visit our Site, access our Client portals, use our Client Apps, or register for and attend our Events. This information is further described below. Please note that we collected or processed the applicable categories of information below in the preceding 12 months, subject to your exercise of any privacy rights you may have, based on the laws applicable in your jurisdiction, as described more fully in the Section titled Your Privacy Rights.

  • Personal and online identifiers such as your name, address, job title (if applicable), phone number, email address, username, social media account information (where relevant), and, when you access our Site and Apps, certain information about the browser and device with which you connect, such as your device’s Internet protocol (“IP”) address; unique device identifiers as well as hardware or operating system device identifiers (e.g., IDFA for iOS and AAID for Android); information about the type of Internet browser, browser language, and operating system you use; connection type (wired or Wi-Fi); the inferred region where your device is located; network to which your device is connected; and, the mobile carrier (if available).
  • Account information required for your Client account, such as name, address, phone number, email address, financial account information (to the extent needed to pay for or receive payment as part of our Services),Taxpayer Identification Number (which may be the same as an individual’s Social Security Number), VAT registration numbers, or other foreign tax identification number (for foreign entities).
  • Commercial and transaction information such as information about Services considered and purchased and payments made, received, or due as part of the Services.
  • Contents and metadata regarding communications such as email exchanges, support requests, onboarding support, feedback about Services, and records, summaries and/or transcripts of sales meetings and calls.
  • Information about your behavior on our Site and Apps such as information regarding your browsing, usage, and interactions; information that allows us to identify browsers and devices we have interacted with previously; the website you came from before and visited after; information related to the pages you are viewing on the Site; and App usage analytics including features accessed, time spent in the App, and user interactions.
  • Event-related information such as registration, contact, and payment information, sessions in which you express interest or participate, meeting information input into our Event scheduling application, sweepstakes or other contest entries, comments or feedback on the Event, and photos or other images of you that we capture during the Event.
  • Information from cookies and other tracking technology (including clear gifs, web beacons, or technologies that function for this purpose in the mobile environment) that we may set or read in connection with the operation of our Site and Apps, when you interact with them. For details related to the cookies and other tracking technology that we use as well as instructions for consent or opting-out, please review our Cookie and Tracking Technology Policy.
  • Mobile application information. When you use our Apps, we may collect:
    • Device and Application identifiers including mobile device identifiers, and app installation identifiers
    • App Usage and Performance Data including features accessed, session duration, crash reports, and performance metrics
    • Authentication Information for Publisher Member Agreement (PMA) account access and verification
    • Push Notification Data including notification preferences, delivery status, and interaction data
    • Device Information including operating system version, app version, device model, and network connectivity status

How We Use Personal Information

We use the information we collect from or about you in the following ways:

  • to provide and manage our Services, including account management and billing;
  • to provide App functionality including authentication, account access, and publisher tools;
  • to provide advertisers and publishers access to reporting associated with our Services;
  • to respond to applications and inquiries from prospective Clients and Event attendees;
  • to respond to inquiries and requests for support from our Clients, Site and App users, and Event attendees, including privacy rights requests;
  • to conduct internal analysis to analyze performance, assess user experience, understand the audiences for our Site, Apps, and Services, and to train our personnel, for improvement purposes;
  •  to communicate with you about our Services and Events, including to send push notifications about account activity, network updates, and Service announcements;
  • to contact you and/or provide information requested by you, including access to our newsletters and blogs;
  • to promote and provide other marketing information about our Services;
  • to otherwise operate, maintain, administer, and improve our Site, Apps, and Services; and
  • to comply with legal obligations and protect our legal rights.

Legal Basis For Using EEA Personal Data:

If you are located in the European Economic Area, our legal basis for collecting, using, and disclosing the personal data described above will depend on the personal data concerned and the specific context in which we collect it. Usually, we rely on the following legal bases to process your personal data:

  • Fulfilment of Contract: We will process the business contact information, billing and payment information, and account information you provide when registering for our Service as necessary to provide and manage the Services we contract with you to provide, including account management and billing, providing the features and functionality of our Apps and Client portals, providing reporting and other tools to Clients, and securing access via authentication.
  • Legitimate interest: We may process your personal data for our legitimate interests, including to respond to applications and inquiries from prospective Clients and Event attendees, to respond to inquiries and requests for support from our Clients, Site and App users, or Event registrants, to record, transcribe, or summarize sales meetings and calls, to conduct internal analysis to analyze performance, assess user experience, understand the audiences for, and improve the effectiveness and functionality of our Site, Apps, Events, and Services, train our personnel, to communicate information to you about our Services and Events, including to send push notifications about account activity, network updates, and service announcements, to prevent fraud and provide security for our Site, Apps, Events, and Services, to pursue or defend our legal rights, and, for existing Clients, for direct email marketing to promote our service offerings to make sure you are aware of all the available options. When we process personal information to meet our legitimate interests, we put in place safeguards to ensure that your privacy is protected and allow to you object, and ensure that our pursuit of our legitimate interests should not be overridden by your fundamental rights and freedoms.
  • Consent: We will rely on your consent to use your personal data (including, without limitation, information collected via cookies and tracking set on your device) for personalized, retargeted, or interest-based advertising purposes and, for prospective Clients, to send you marketing information when you inquire about our Services. You may withdraw your consent at any time by using our Privacy Request Form or by using the tools outlined above.
  • Legal obligation: In some cases, we may also have a legal obligation to collect personal information from you, retain it for a specific period, or disclose it to third parties such as government entities or law enforcement, or may otherwise need the personal information to protect your vital interests or those of another person. Processing where we rely on our legal obligations includes tax filings, tax and financial audits, responding to authority inquiries, fulfilling privacy rights requests, and maintaining your privacy settings on our Site in order to effectuate them.

If you have questions about or need further information concerning the legal basis on which we collect and use your personal information, please contact us using the contact details provided under the Contact Information section of this Privacy Policy.

Disclosure of Personal Information

We disclose (and have disclosed, in the preceding 12 months) information about you and your usage of our Site, Apps, and Events as follows:

TO SERVICE PROVIDERS OR PROCESSORS

  • to infrastructure, technology, operational, and other service providers to help support the infrastructure necessary to operate and troubleshoot the Site and Apps and put on the Events; or
  • to other entities that are providing services for our benefit for a business purpose, such as (a) when you apply for participation as a publisher on our network, we may share information submitted by you with vendors to authenticate and/or evaluate your application information; (b) we may also share Client credit card or financial account information with our banking and payment vendor for the purposes of collecting payments due to us or to facilitate payment to a Client; or (c) we may share information in connection with a sweepstakes, contest, or other promotion you entered for the purposes of facilitating such promotion;
  • to infrastructure, technology, operational, and other service providers to help support the effectuation of the Services; or
  • to our group companies and other partners who provide data processing services to us (for example, to support the delivery of, provide functionality on, or help to enhance the security of our Services), or who otherwise process personal information for purposes that are described in this privacy policy, notified to you when we collect your personal information, or notified to you by the group company or partner.

TO OTHER CONTROLLERS OR THIRD PARTIES

We may also disclose certain information about you and your use of our Services to third parties for the following purposes, which may be considered a “sale” or “sharing” of your data, subject to any right you have to withdraw consent, object or opt-out as provided below.

  • to third-party marketing partners for the purpose of targeting or retargeting advertising to you about our Services or Events.
  • to third-party Event sponsors, in connection with your attendance at the Event.

IN OTHER BUSINESS OR LEGAL CIRCUMSTANCES

We may also disclose information about you:

  • to law enforcement authorities or other government officials when compelled to do so by a valid legal process or regulatory requirement;
  • when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss or in connection with an investigation of suspected or actual illegal activity;
  • if necessary to protect the vital or legal interests of another person;
  • in order to assert or defend our legal rights;
  • in connection with a corporate reorganisation or a sale or transfer of all or a portion of our business or assets; or
  • to any other person, with your informed consent to the disclosure.

Your Rights

Know, Access, Correct, Delete

If you wish to verify our collection, access, correct/update, or request deletion/erasure of your personal data as provided by applicable laws, please use our Privacy Request Form; if you attended one of our Events, downloaded our App, or participated in a recorded call with our team, please include that information in your request. If you are an individual whose information we process on behalf of an advertiser or publisher Client (for example, an end-user whose data was collected through our Client’s use of our advertising Services), please direct your request to that business directly as they are the data controller.

Opt-Out/Object to Processing/Withdraw Consent

If you do not want your personal data to be used by us for targeting or retargeting ads to you on third-party sites and apps (cookie-based retargeting), you should indicate your preferences by opting out or withdrawing your consent, as applicable, in our Privacy Choices/Privacy Settings tool, accessible from the footer of our Site (when relevant).

If you do not want your personal data to be used by us for direct email marketing purposes or retargeting based on your email address you may unsubscribe in the footer of any direct marketing email or opt-out, object, or withdraw your consent by using our Privacy Request Form,

If you do not want your title, company name, business contact information, or the fact of your attendance at our Event shared with third-party Event sponsors (for Event registrants/attendees), you may opt out of or object to such disclosures by using our Privacy Request Form.

If we have collected and processed your personal information based on your consent, you can withdraw your consent at any time. Withdrawing consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your personal information conducted in reliance on lawful processing grounds other than consent.

Opt-Out Preference Signals

We recognize valid opt-out preference signals sent from browsers or devices, including the Global Privacy Control signal, on our Site. When we receive such signals, we will automatically exercise opt-out rights that may be available to you under certain U.S. state privacy laws, such as the right to opt out of sale, sharing, and processing of your personal information for targeted advertising based on cookies or other Site tracking mechanisms, in relation to your browser or device, as applicable. You can use such opt-out signals by following the instructions for your device or browser.

Web Browser-Based Opt-Out

Outside of the tool we provide to effectuate your Privacy Choices/Privacy Settings on our Site, you may stop or restrict the placement of cookies on your computer, or remove them from your browser, by adjusting your web browser preferences to block or reject third-party cookies. There are also many programs or applications that allow you to manually delete your cookies. Read more about information regarding this form of cookie-based opt-out in our Cookie and Tracking Technology Policy.

Mobile Application-Based Opt-Outs

Because mobile applications utilize different technology for tracking and targeting ads, users may opt out of certain advertisements on mobile applications or reset advertising identifiers via their device settings. You can read more on how to limit ad tracking or to reset the advertising identifier on your iOS or Android device.

You may also download and set your preferences on the App Choices mobile application(s) available in the Google Play and Apple App stores.

For our mobile Apps specifically, you can:

  • Disable push notifications within the App settings or through your device;
  • Reset advertising identifiers through your device’s privacy settings;
  • Limit app permissions including location, camera, and other device access through your device settings;
  • Delete the App which will remove all locally-stored data.

Additional Rights of Individuals in the EEA

In addition to the above-discussed privacy rights, individuals in the European Economic Area have the following additional data protection rights:

  • data portability – you have the right to receive the personal data you have provided to us in a structured, commonly used and machine-readable format;
  • restriction of processing of your personal data – where the accuracy of your personal data held by us is contested, the processing is unlawful, resolution of your objection to our processing is pending, or where we no longer need the data but you need it to establish or exercise legal claims, you may request that we appropriately restrict our processing of your personal data;

You also can exercise these rights by using our Privacy Request Form.

You have the right to complain to an interested data protection authority at any time about our collection and use of your personal information. For more information, please contact your local data protection authority. Although it is not required, we would appreciate an opportunity to address your complaint first, before you approach the supervisory authority.

Additional Rights of California Residents

This section contains disclosures required by the California Consumer Privacy Act (“CCPA”) and other relevant California laws and applies only to “personal information” that is subject to the CCPA and such other laws.

Notice of Right to Opt-out of Sale/Sharing. A California consumer shall have the right to direct a business that “sells” (provides or makes available the consumer’s personal information to a third-party for monetary or other valuable consideration, unless the individual intentionally interacts with the third-party through the business or directs the business to disclose personal information to the third-party) or “shares” (makes available to a third-party a consumer’s personal information for the purposes of cross-context behavioral advertising) that consumer’s personal information to cease selling or sharing it thereafter.

Please refer to the above section entitled Opt-Out/Object to Processing/Withdraw Consent for instructions on how to exercise this right.

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.

Also, individuals who are residents of California have the following additional data protection rights, subject to certain exceptions and limitations:

  • The right to know the categories and specific pieces of personal information we collect, use, disclose, and sell or share about you, the categories of sources from which we collected your personal information, our purposes for collecting or selling and sharing your personal information, the categories of your personal information that we have either sold or disclosed for a business purpose, and the categories of third parties with which we have shared personal information;
  • The right not to be retaliated against for the exercise of the privacy rights conferred by the CCPA.

To exercise any of the above rights, please use our Privacy Request Form.

Note that we may need to request additional information from you to verify your identity or understand the scope of your request, although you will not be required to create an account with us to submit a request or have it fulfilled. We will require you to provide, at a minimum, the information indicated as required on the webform. You may designate an authorized agent to make a request on your behalf by having the agent complete the webform. We do not knowingly sell or share personal information of minors under 16 years of age.

Duration of Processing

Unless otherwise specified, we will keep your personal information for as long as we have a relationship with you. In addition, we will retain your personal information outside the normal retention times to the extent there is a need to retain such information to pursue, defend, or exercise a legal right or claim, or if we are required to do so to comply with applicable legal obligations or regulatory requirements.

Transfers of Personal Information

We and our Clients, Service Providers and third-party partners may be located in various countries throughout the world. As a result, your personal information may be transferred to and processed in countries other than the country in which you reside. These countries may have data protection laws that are different from the laws of your country (and, in some cases, may not be as protective). However, we have taken appropriate safeguards (such as contractual commitments and internal policies) to require that your personal information remains protected in accordance with this Privacy Policy.

To legitimize data transfers within the Rakuten Group of companies (subsidiaries and affiliates of Rakuten Group, Inc.), we rely on the Rakuten Group Binding Corporate Rules (BCRs), which require all Rakuten Group companies to adhere to the same high standards when processing your personal information. The Luxembourg Data Protection Authority and the UK Information Commissioners Office, respectively, have approved the Rakuten Group EU and UK BCRs. For more information, please read about the BCRs.

For data transfers to entities outside of the Rakuten Group, in countries that have not been deemed to provide an adequate level of protection by the relevant local data protection authority, we agree to and rely on specific contracts developed by those authorities. For example, for EU and UK personal data that is transferred to another entity in a third country, we rely on the Standard Contractual Clauses and UK Addendum.

Security

We take appropriate technical and organizational 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.

For our mobile Apps, we implement additional security measures including:

  • App-level encryption for any sensitive data stored locally on devices;
  • Secure authentication protocols for Client account access;
  • Regular security updates and vulnerability assessments; and,
  • Secure data transmission using industry-standard encryption protocols.

Please note that no method of transmission over the Internet or electronic storage is 100% secure. As a result, we strive to protect your personal information but cannot ensure or warrant the security of your information against any possible loss or unauthorized access.

Third Party Sites and Partners

Our Site and Apps may contain links to other websites, including our Clients’ websites. Other websites may also reference or link to our Site or Apps. These other domains and/or websites are not operated by us, and we do not endorse, screen, approve, or take responsibility for the privacy practices or content of such other websites, nor do we have access to or control over their data collection tools. Visiting these other websites is at your own risk, so we encourage our users to read the privacy policies of each and every website with which they interact.

Children’s Information

You must be 18 years or older to use our Services and Apps. Our Site, Services and Apps are not intended to process personal data of children under the age of 16 and we do not knowingly collect any personal information from children under the age of 16. If a parent or guardian believes that we have in our database the personal information of a child under the age of 16, please contact us and we will use our best efforts to remove the information from our records.

Changes to this Privacy Policy

We use reasonable processes to ensure compliance with this Privacy Policy and periodically verify that the Privacy Policy is accurate. We reserve the right to change or replace this Privacy Policy at any time to reflect any changes in our privacy practices. When we update our Privacy Policy, we will take appropriate measures to inform you consistent with the significance of the changes we make. We will obtain your consent to any material Privacy Policy changes if and where this is required by applicable data protection laws. Any changes or replacements will be posted on our Site or App and are effective upon posting. You can see when this Privacy Policy was last updated by checking the “last updated” date displayed at the top of this Privacy Policy. We encourage you to review our Privacy Policy on a regular basis.

For mobile App users, we may also notify you of material changes through:

  • In-app notifications for significant policy updates;
  • Push notifications where you have consented to receive them; and/or,
  • Email notifications to your registered account email address.

Contact Information

We encourage you to raise any concerns or questions about this Privacy Policy or our privacy practices, so that we have the opportunity to resolve any confusion or complaints regarding our use and disclosure of your personal data.

The Rakuten Advertising privacy team, including our DPO, can be reached via our Privacy Request Form or our website, or at our main postal address:

Rakuten Marketing LLC DBA Rakuten Advertising
800 Concar Drive
Suite 175
San Mateo, CA 94402 USA

If you are located in the UK or within the European Economic Area, the data controller of your personal data is Rakuten Marketing LLC dba Rakuten Advertising.

Our UK establishment for purposes of this Privacy Policy is:

Rakuten Marketing Europe Limited
Vintners Place
68 Upper Thames St., London EC4V 2AF United Kingdom

Our EU establishment for purposes of this Privacy Policy is:

Rakuten Advertising France S.A.S
92 rue Réaumur, 75002 Paris, France