Privacy Policy and Personal Information Collection Notice

1. Information gathering

Sources of Collection We collect, process and use information about you when you:

· Sign up for our service

· Interaction with our Service

· Install and/or access our Services through our application(s), including our mobile apps and browser extensions

Connect to our Services through third parties, including social media accounts, email accounts, and business partners (described in Section 3 below)

· Contact us for support

We collect certain information when you submit it or provide it directly to us. When you have installed our mobile application or browser extension or enabled our mobile browser extension, or when you interact online with our Services, we also automatically collect information about you and your use of the Service through the use of logging, cookies, location-identification technologies and other tracking technologies. Certain information about you is collected from third parties, including when you connect through third-party services or business partner websites or when information is shared by merchants and partners. business partners with which you have also interacted.

Types of Information We May Collect

The types of information we collect about you may include personal information of the following categories:

first and last name, mailing address, email address, tax information (for sweepstakes, contests and promotions winners) ) and/or phone number

· Identifiers collected through your use of the Service, such as unique device or online identifiers, IP addresses, device or session IDs, and information related to your system configuration you (operating system and version), network and connected hardware (e.g. computer or mobile device and service provider), and software applications (e.g. other install on your mobile device)

· Customer profile information, such as payment account name, payment account number, payment card expiration date and billing address

your inclusion in any other classification protected under California law, only to the extent you provide this information to us as demographic information in a survey response that is identifiable to You

· Commercial information about you, such as product profiles, product types, sellers, types of sellers, goods or services that you have purchased, obtained or reviewed, including products, people sales and coupons you searched for, viewed, or clicked on, items added to your cart and abandoned, shopping trips initiated, sales sites accessed from the Service us, transaction history related to our Services, purchase confirmation data, accrued refunds, American Express Membership points and other loyalty currency

Internet and Other Network Activity, such as your browsing and search history and interactions with our websites and Services, including:

· products, coupons, offers, or sellers that you search for, click, favorite and/or view, including clicks you make on merchant sites you visit within the app for our mobile devices;

· URLs of the pages you visit, including those tracked by our browser extensions and mobile apps;

· stamp the date and time associated with that browser, search and click; And

· data stream clicks, that is, page-by-page clicks that you make while navigating through our Services, including the web page visited before you visited our website; And

data (as defined in Section 2 below), if you choose to sign in or create your www.rakuten.com account with Google or link an email account to the www account separately. your rakuten.com

· Language preferences for your use of the Sensory Information Service, such as a recording of your voice, to the extent you call our member services representative, as permitted under Current law;

· Member account login information, including username and password; And

· Inferences are drawn about you and your possible preferences, characteristics, behaviors and attitudes from any information we collect about you.

In some jurisdictions, certain types of information we collect that may be considered “sensitive” personal information include:

· Demographic information, such as your gender, age, household income or marital status, only to the extent you provide this information to us as demographic information in the survey responses that you can identify and

Accurate geolocation data, to the extent you have configured your device to disclose that information to us .

Note that we only use this sensitive information to provide the Services to you, and we do not collect, use or disclose this sensitive information for the purpose of inferring characteristics about you. We do not "sell" or "share" sensitive personal information or use sensitive data for "targeted advertising" as those terms are defined in US state privacy laws. .

2. Use of Information We Collect

We use the information we collect about you for the following business and commercial purposes:

To provide our services and manage your account, including:

· Process your registration with our Services, including verifying that your email address is active and valid and enrolling you in our programs

· Manage your account and interaction preferences, including following your favorite stores, merchants and locations of interest, and transaction history

· Facilitate and manage your purchases from our gift card hub

· Offer you rewards or payouts and identify opportunities for rewards and/or incentives

· Send you technical announcements, updates, security alerts and administrative notices

· Provide you with membership services and support related to your account and respond to your questions, comments and requests

Personalize and improve our service

We may use the information we collect about you to create profiles of your interests in order to personalize and tailor the content of the Services so that you are more likely to be interested. For example, we may use the stores or shopping history you most frequently visit to display offers for similar stores in relevant sections of the Service or to offer special offers. special offers that may be of interest to you through our Services, including in-store.

We may also use the information we collect about you to identify usage trends and perform statistical analysis to improve the Services, websites, applications, marketing efforts and products. and the services of our business partners that we recommend or provide, in order to provide you with better services in the future.

If you choose to sign in or create your rakuten.com account with Google or link your email account to your Service account separately, we will use email content from your linked inbox(s) You (collectively, “Inbox Data”) to confirm your eligibility for Cashback more quickly and reliably by identifying purchase or order confirmation information therein. include Limited Use requests therein. You can change the Inbox Data settings as provided in Section 4 (Your Choices).

To provide you with marketing information

With the exception of Inbox Data, the Company may use the information we collect about you to provide you with more personalized offers, special offers, discounts and/or offers. more relevant from our participating merchants via email and other forms of direct communication as well as through digital advertising. We may use your information to send you email newsletters, reward offers, discounts, promo codes, events and general information about the Service directly. You can manage these direct marketing communications as provided in Section 4 (Your Choices) below. We may also use your information (excluding Inbox Data) to advertise to you online, including to target advertisements to you on other websites. You may opt-out of the use of your personal information for targeted online advertising as provided in Section 4 (Your Choices) and Section 5 (Your Rights).

To protect you, others and our business

We may use the information we collect for risk assessment and to investigate and limit fraud, spam, and other malicious online activity within our Services and to improve our practices. our security. We may also use the information collected to assert our legal rights or to defend our legal rights against third parties.

Comply with applicable laws

We may use the information we collect about you to enable us to comply with applicable laws, rules, regulations, and judicial authorities in each geographic area in which we operate.

To administer contests, sweepstakes, surveys, polls and promotions

From time to time, the Company may invite you to participate in various contests, sweepstakes, surveys, polls and promotions. If you choose to enter a contest or promotion, your personal information may be used to administer the contest, such as to determine your contest entry or to award prizes. . If you choose to participate in a survey or poll, the feedback you submit will be aggregated and identified to provide us with insights into business and shopping trends. We maintain this information in an identifiable manner and do not attempt to re-identify it.

Manage referral programs

We may provide features that allow you to notify another individual about our Services. If you choose to use our referral features, we will require your referrer's email address in order to send them an electronic notice inviting them to join our Services. We will store this information for the sole purpose of sending this email and tracking the success of our referral program. If you choose to participate in our referral programs, you represent and warrant that you have a personal relationship with your referrer and that you are authorized to share their information with the Company for the sole purpose of destination the Company sends them a notice inviting them to join the Service. If you believe that one of your contacts has provided us with your personal information through our referral service and you would like to request removal of that information from our database

3. Disclosure of information

We may disclose the following specified types of information for our business or commercial purposes, including:

Disclosure to our service providers

We may disclose all types of your collected personal information as necessary to our third party service providers (which may include Company affiliates) who conduct various business activities, solely for our benefit or on our behalf, according to our instructions and in compliance with appropriate contractual, technical and organizational security measures to protect your data from unauthorized use, retention or disclosure. For example, we may partner with other companies to provide you with member support services, authentication services, fraud prevention on our Services, payment processing, management promotions, referral programs, sweepstakes and surveys, perform analysis, maintain the accuracy of our database, provide direct marketing and communications, limit the provision of repetitive or unnecessary marketing or communications,

Disclosures to Our Business Partners

We work with various types of third party business partners to provide you with our Cashback Shopping Service. We may disclose the following types of information to the following types of Business Partners:

Affiliate partner

When you click on a link to a seller's website presented on our Services to begin shopping Cashback, you demonstrate your intention to interact with that business through our Services and therefore that is instructing us to disclose certain information about you (including the link you clicked on to our Services and a unique ID assigned to track your purchases sourced from origin from our Service) to an affiliate network to properly explain your purchases to a seller. For a small number of sellers who do not use affiliate networks, this information is provided directly to the seller. The Affiliate will collect Internet and Network Activity (not including any Inbox Data) information about your use of our Services in connection with a seller's website, product or offer. . Our affiliate partners collect this information to track shopping trips, but some of them may also use this information to measure performance, contributing it to customer profiles. their own use and/or combine that information with information they collect elsewhere that they may make available to their other business customers for use. In such cases, our disclosure to some of these Affiliates may be deemed to be "selling" or "sharing" your personal information as those terms are determined by privacy law. applicable U.S. state privacy policy and our refusal to provide it to consumers in Section 5, below, will signal to these Affiliates not to collect or use your information from the Service. us unless necessary to authenticate and provide a Refund to you. that they can make available to their other corporate customers for use. In such cases, our disclosure to some of these Affiliates may be deemed to be "selling" or "sharing" your personal information as those terms are determined by privacy law. applicable U.S. state privacy policy and our refusal to provide it to consumers in Section 5, below, will signal to these Affiliates not to collect or use your information from the Service. us unless necessary to authenticate and provide a Refund to you. that they can make available to their other corporate customers for use. In such cases, our disclosure to some of these Affiliates may be deemed to be "selling" or "sharing" your personal information as those terms are determined by privacy law. applicable U.S. state privacy policy and our refusal to provide it to consumers in Section 5, below, will signal to these Affiliates not to collect or use your information from the Service. us unless necessary to authenticate and provide a Refund to you.

In addition, to the limited extent that we target direct marketing to you or personalize the offers you see in our Services based on profiling data we aggregate from behavior your data is tracked through our Services, for the direct benefit of a particular seller, marketing or personalization may also be considered "selling", "sharing", or processing for the purpose of "targeted advertising" of your personal information. In this case, the opt-out we provide in Section 5 below will include this type of targeted marketing and personalization. We may use the information we collect about you in combination with information about you from current and prospective trading partners to examine and analyze how our Services assist merchants and Business Partners. Information we disclose and receive from merchants or business partners to perform this analysis may include online shopping identifiers (such as shopping IDs, order IDs), email addresses hashed and Commercial Information (such as purchases made and corresponding order value). We may use the results from these tests in an aggregate and identifiable manner to improve our Services and to market our Services to merchants and corporate customers. You may choose not to allow us to disclose your information to certain third parties for this purpose in accordance with Section 5 below. We may use the results from these tests in an aggregate and identifiable manner to improve our Services and to market our Services to merchants and corporate customers. You may choose not to allow us to disclose your information to certain third parties for this purpose in accordance with Section 5 below. We may use the results from these tests in an aggregate and identifiable manner to improve our Services and to market our Services to merchants and corporate customers. You may choose not to allow us to disclose your information to certain third parties for this purpose in accordance with Section 5 below.

Referral Marketing Partner

To expand our Service subscription options and start shopping Cashback from third party websites where you learn about our Services, we contract a number of partners referral marketing business to enable that functionality, which may require us to disclose certain data about you to them. For example, if you were referred to our Services from a business partner's website, we may provide that partner with information about your subscription to authenticate the referral and activate your right. access your Service account from a partner's website. In addition, we may disclose information about your recent purchases with us and whether you have installed our mobile apps or browser extensions so that partners can can personalize their email and website content for you.

If you applied for a refund through our sister company, ShopStyle, Inc. ("ShopStyle"), we may provide ShopStyle with certain transactional information so that you can view a summary of your rewards on www.shopstyle.com. We may also place cookies on your device so that you can continue to shop with cash through www.shopstyle.com without having to log into our Services each time. For more information on how ShopStyle handles personal information,

financial partner

For the purpose of providing you with additional redemption options for your Cashback and to market our co-branded credit cards to you, we may disclose your collected information, including includes Identifiable Information, for financial business partners, which may include ICHIBA Group Companies. If you choose loyalty points or other alternative methods to receive Cashback, you are directing us to disclose your personal information, if necessary, to the relevant financial partner to facilitate favorable to that transaction. If you indicate that you would like to receive information about our co-branded credit cards from our financial partner(s), you are also directing us to disclose your information to those parties. to allow them to provide that information.

We may also disclose personal information about you to our financial partners to facilitate their marketing purposes and in some cases to direct financial partners marketing information for you. This may be considered "selling", "sharing", or processing "targeted advertising" under applicable US state privacy laws, and you may choose not to disclose this information for further information. partners in Section 5 below.

Disclosure to Digital Advertising Providers

To provide us with targeted marketing and advertising services, we partner with certain third parties that automatically collect Internet and Network Activity information about your use of the Services, such as browsing history, IP address, pages viewed and links clicked, so that they can use this information to serve you ads for our Services on other websites without you access. Some of these third parties may also use this collected information to draw inferences about you for their own purposes or to separately collect personally identifiable information about your online activities over time and on different websites (other than our Services) to help predict your preferences and to show (and allow other third parties to display) ads to you that you are most likely to be interested in. more attentive. You have the right to refuse to share our information with certain third parties for the purposes of targeted advertising or cross-context behavior. To exercise this right, you may opt out through the instructions in Section 5 below. Note that this Privacy Policy covers our use of data only and does not cover further use of data by third parties. If you want to opt out of general interest-based advertising.

Disclosures to other ICHIBA . Group Companies

We work closely with our businesses and affiliates within the ICHIBA Group and disclose your personal information to our internal business administration. Some of our Service Providers and Business Partners to whom we disclose personal information, as described above, may include other ICHIBA Group Companies. We may also disclose information in the categories of Identifiers (email addresses), Commercial Information (product metrics) and Internet and Other Network Activity (except Inbox Data) to our affiliates within the ICHIBA Group for those corporate affiliates to analyze and monitor usage and trends in order to improve their services and websites as well as for strategic planning purposes in ICHIBA Group level. Our opt-out and removal request functionality will help disqualify you from these disclosures.

Disclosure for legal purposes

We may disclose information we collect, including personal information, to the extent permitted by applicable law, (i) in response to a subpoena or other legal process, or if, in our good faith opinion, such disclosure is required or permitted by law without specific notice. disclosure; (ii) at the request of a government agency conducting an investigation; (iii) to enforce terms and conditions or other policies applicable to our Services; and (iv) to protect the rights, property, life, health, security and safety of the Company or any third parties.

Regarding the transfer of business assets

We may disclose information we collect, including personal information, to any third party in connection with or during confidential negotiations regarding any merger, acquisition, any proposed or actual sale (including liquidation, exercise, forfeiture, or forfeiture) or any other acquisition of all or any part of the Company's assets, transportation or transfer all or part of our business for another company. In such a case, the acquiring company will be contractually required to use your collected information in accordance with this Privacy Policy and applicable law or to provide prior notice to you of any such practices. any new or significant change.

In addition to the disclosures listed above, we may also disclose aggregated or de-identified information that cannot reasonably be used by the recipient to identify you.

4. Your Choices

Update account information

We encourage you to maintain the accuracy of the information you submit to us. You may provide account updates by logging into your Service account and updating your information in Settings.

Communication options

Promotional email

We may send you periodic electronic communications and direct mail when you sign up for an account. You may opt-out of receiving promotional communications from us at any time by following the instructions provided in such communications to unsubscribe or stop them, modify your account settings or contact us through the Service. Please note that even if you choose not to receive promotional communications, we may continue to send you non-promotional emails and other types of communications, as permitted by law, such as email service related to our ongoing business relationship. Service emails contain service-related messages that affect your account, such as product order confirmations, reward or payment updates, and responses to comments and feedback. you send us.

Mobile app notifications

When using our mobile application, your preferences for receiving push notifications and other mobile alerts can be configured in the settings of your mobile device.

SMS messages

If you choose to provide us with a mobile phone number and agree to receive certain messages, we may use SMS messages to contact you when you update your account, provide you with updates about your customer support ticket and for account recovery purposes. You can opt out of receiving such messages by deleting your mobile number in your account preferences or replying STOP to any incoming messages.

Data collection and sharing options

In some cases, you may have the option to refuse to provide us with certain information; however, your choices may affect your use of certain features or services for which such information is an essential component.

Inbox link

You may unlink your email account from the Service by updating or disabling the connection in your account settings. If you unlink your email account from the Service, we will no longer collect Inbox Data.

Mobile App/Browser Extension

You may stop any information collection using our mobile application and/or browser extension by uninstalling our mobile application and/or browser extension. Because browser extensions and mobile apps allow data about your online behavior on that device or browser to be collected upon installation, even without interaction, we must be uninstalled to withdraw your consent to this data collection. In some cases, you may opt out of certain data collection by updating your Settings in your browser extension or mobile device settings.

5. Your Privacy

You have certain rights regarding your personal information under applicable law, subject to certain exceptions.

Right to know and access:

You have the right to request to know personally identifiable information that we have collected, used, disclosed for business purposes, and sold or shared for targeted or multi-context advertising purposes. , including the intended use, the category of sources from which we obtained your information, and the category of third parties to whom we have disclosed your information. You also have the right to request access to (receive a copy) of the specific personal information we have collected about you (note that we will not provide any sensitive personal information that we I can hold to meet this kind of request).

Right to request deletion:

You have the right to request that we delete any personal information we have collected from you or hold about you, with certain exceptions. We will delete your personal information upon such request, except where we determine that we need the information for business purposes and have a legal right to maintain it, in which case , we will notify you of the legal exception.

Right to repair:

If you are a member, please log in to your account and visit our Privacy Preferences Center, to exercise your data privacy. Please note that to the extent you opt out of certain disclosures, we may not be able to provide you with some of our services that require such disclosure. If you have further questions, you can contact us using the information listed in the “Contact Us” section below.

Right of Non-Discrimination:

We will not discriminate against you in exercising any of your rights. Except as permitted by applicable law, we will not do any of the following because of your request to know, access, correct, or delete your information, or refuse to sell or share it:

· refuse your goods or services

charge you different rates or rates for goods or services, including through discounts or other benefits or imposing penalties

· provide you with a different level or quality of goods or services, or

suggest that you may receive a different price or rate for a good or service or a different level or quality of the good or service

How to exercise your right to know, access, correct and request deletion:

To assert your privacy, please visit our Privacy Center. To verify your identity, we'll first ask you to log into your account to access the Privacy Center, then obtain a verification code from the email address associated with your account . If we are unable to verify your identity from the information we have on file, we may ask you to provide additional information that we will only use to verify your identity and to security or anti-fraud purposes. Please note that we are not required to respond more than twice per calendar year to requests to know/access your personal information.

Right to complain

You may have the right to appeal our decision on your privacy request, depending on your state of residence. You can file a complaint by contacting us at https://www.rakuten.com/help/other-questions and selecting “Data Privacy” in the drop-down menu. We will respond according to the laws that apply in your location.

Agency.

Only you or someone legally authorized to act on your behalf can make verifiable consumer claims regarding your personal information. For any agent making a request on your behalf, we may ask you to demonstrate that you have authorized the agent to submit the request on your behalf, and we may ask you to verify your identity. your computer independently or log in to your account to provide an access code.

6. Other Notice

Shine.

Notice regarding information of minors.

This website and any related services are intended for adults 18 years of age or older, and we do not knowingly collect or sell or share personal information from consumers under the age of 16 without permission. confirmed or no verifiable opt-in consent from parents for persons under 13 years of age.

Data retention.

We may retain information about you for as long as necessary to fulfill the purposes described in Section 2. Some of your information may be kept in our systems even after your request. request deletion of your information if an exception applies or to comply with our obligations under applicable law, collect fees owed, resolve disputes, exercise our legal rights, exercise any investigation required above or for internal use in a lawful manner consistent with your reasonable expectations or compatible with the context in which the information was provided.

Information security.

We have implemented technical and organizational measures to provide a risk-appropriate level of security for the personal information we process. These measures are intended to maintain the ongoing integrity and protect the confidentiality of personal information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.