PRIVACY POLICY*

This Policy applies to your use of services (including related services, applications, tools, etc., hereinafter the “Services”) provided to you by Rakuten, and other Rakuten Group companies that have adopted this Policy (collectively, “we” or “us”). Please be aware that for certain Services, we or other Rakuten Group companies may provide you with privacy statements in addition to, or in place of, this Policy, as appropriate.

Rakuten Group aims to provide you with a unique and personalized experience when you interact with the Services. In order to achieve this goal, Rakuten Group provides a unified ID program called “Rakuten ID,” which includes a single log-in function that makes it easy for you to access and use applicable Services provided globally by Rakuten Group. You may create your own Rakuten account (your “Account”), and use all related services (together, the “Membership Service”) in accordance with this Policy and the Rakuten Membership Terms & Conditions set forth separately by Rakuten.

Please only use the Services or the Membership Service after you have carefully read and understood this Policy, the Rakuten Membership Terms & Conditions, and other applicable terms. In using the Services or the Membership Service, you represent that you understand the contents of this Policy describing our collection, use, transfer and retention of your information herein.

If you have any questions or inquiries regarding this Policy, please refer to the information provided in “Contact Us.”

(*) “We” refers to the following Rakuten Group companies or services. For more information about each of the companies, please refer to the links below:
1.Rakuten Group, Inc.
2.Target, Inc.*
3.Rakuten Baseball, Inc.
4.Rakuten Travel Services, Inc.
5.Keiba Mall, Inc.
6.Rakuten Ticket, Inc.
7.Rakuten Edy, Inc.
8.Linkshare Japan K.K.
9.Rakuten Data Marketing, Inc.
10.Rakuten Payment, Inc.
11.Rakuten Senior(Rakuten Mobile, Inc.)
12.Rakuten Shashinkan(Rakuten Mobile, Inc.)
13.Rakuten Vissel Kobe, Inc.
14.Rakuten Car, Inc.
15.Rakuten Energy, Inc.
(As of Nov 1, 2022)

*Target, Inc.,
1-14-1 Tamagawa, Setagaya-ku, Tokyo; Representative Director: Yuta Terachi

For the purposes stated in Section 3 (“Use, Legal Basis of Use and Retention of Your Information”), we collect information about you as described in this Section 2. This includes information that you give us directly, information about your use of the Services, and information received from third parties. All the personal information that we collect and use in accordance with this Policy is centrally managed and stored by Rakuten.

2-1. Your log-in information

Identifiers:

• Your user ID and password
• Your name and email address

2-2. Information related to your use of the Membership Service and the Services

Identifiers, protected characteristics, commercial information, Internet or other electronic network activity information:

• Information you give us in connection with your Account, such as your gender, age, date of birth, telephone numbers, and address
• Information relating to your use of reward points, coupons, cashbacks and other incentive programs provided to you as part of the Membership Service
• Information relating to your use of the Services (including activities such as page viewing and comment posting), or to the transactions you make using the Services, such as purchases or subscriptions (including the payment methods you use)

2-3. Payment information and information used for personal identification

Financial, medical, or health insurance information:

• Information relating to payment settlements, such as credit card information, bank account information, and e-money related account information
• Documents that we are required to collect by law in order to authenticate your identity (such as your driver’s license, health insurance certificate or certificate of residence), and the information included therein

2-4. Device information and information obtained using Cookie Technologies

Internet or other electronic network activity information, geolocation data:

When you use the Membership Service or the Services, interact with any content or advertising related to such services, or accept any cookies, web beacons, unique identifiers and other related technologies (collectively, the “Cookie Technologies”) that we employ, we automatically collect certain information about you and the device you are using.

Such information may include:

• Mobile advertising identifiers such as your device ID or other information that allows us to identify the device you are using;
• Operating system and internet connection related information;
• Geo-location information;
• Referring URL;
• IP Address;
• URLs viewed and time stamp of time viewed
• Server log information other than the above
• Information related to products and services displayed and searched

For a more detailed explanation on the information we collect through the Cookie Technologies, please refer to the Cookie Policy webpage.

However, if you are using Rakuten Global Express, please refer to the policy below:
Rakuten Global Express Cookie Policy

2-5. Information we collect from other sources

Identifiers, protected characteristics, commercial information, internet or other electronic network activity information, geolocation data:

During your use of the Membership Service and the Services, we may request, collect and store your information such as your credit information and information necessary for fraud prevention and detection from publicly available sources and third parties, as may be necessary from time to time and as permitted under applicable laws. In addition, based on your separate consent, we may receive other personal information about you from third party sources.

Unless necessary for the purpose of providing you with the service in question or for other legally permissible reason, during your use of the Services or the Membership Service, we do not intentionally collect or use information that may be considered sensitive, such as information relating to your race, religion, social status, medical or criminal history, or whether you were a victim of a crime (together, “Sensitive Information”). In the event that you voluntarily give your Sensitive Information to us, we will treat such information as information related to your use of the Membership Service and the Services (2-2) that has been provided to us with your express consent, and process it in accordance with this Policy.

2-6. Inferences regarding preferences or other characteristics

We may infer your preferences or other characteristics from the information we collected above.

We use your personal information to provide you with the single log-in function as part of Rakuten ID, the Services and the Membership Service, and advertising and marketing content in accordance with your interests and preferences; to conduct research and development; to respond to customer inquiries; and to prevent and mitigate fraudulent or illegal activities.

3-1. Use of Your Information

Specifically, we may use your information for the purposes listed below:

3-2. Legal Basis of the Use of Your Information

In the European Economic Area, we are obliged to have a legitimate reason (or legal basis) for each processing activity and in most cases, the basis on which we rely will be one of the followings:

• to fulfil our contractual obligations to you, for example to provide the Membership Service and the Services, which includes services for you and a Merchant to arrange a commercial transaction;
• to comply with our legal obligations, for example obtaining proof of your identity to enable us to meet our anti-money laundering obligations; and
• to meet our legitimate interests, for example to understand how you use the Membership Services and the Services and to improve them and to provide tailored marketing messages to you via certain channels. Our legitimate interests to process your personal information consist of our missions and desires to provide you with a unique and personalized experience when you interact with Rakuten Group’s services through your Rakuten ID.

Additionally, we may ask you to give us your consent to collect and use certain types of personal information, for example, when we would like to send you email marketing messages and process Sensitive Information. If we ask for your consent to process your personal information, we will ensure that you may withdraw your consent at any time.

3-3. Retention of Your Information

We will keep your personal information necessary to fulfil our contractual obligations for as long as we have a relationship with you, and for a period of 10 years thereafter. Other information, such as Device information and information obtained using Cookie Technologies, will used and retained at maximum for 2 years after the collection. We will only retain your personal information after this time if we are required to do so to comply with applicable laws, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.

4-1. Disclosure within Rakuten Group

In order for Rakuten Group to develop and provide you with ever more unique and attractive services, it is essential that Rakuten Group companies are able to share information with one another.

For this reason, Rakuten centrally manages and stores the personal information that we collect in accordance with this Policy. Whilst Rakuten is responsible for centrally managing and storing your personal information (learn more about the entity responsible for managing your personal information here.), we, Rakuten Group companies who have adopted this Policy, will have access to your personal information and will use it in accordance with the provisions of this Policy.

In addition, we may disclose your personal information to other Rakuten Group companies, including those located outside of Japan. These companies may access and use your information as set forth in the table below.For more information on the names of the destination countries in cases where information is provided to Rakuten Group companies located outside of Japan, please refer to this page.

4-1-1 Disclosure and use of information by Rakuten Group companies operating services that support Rakuten ID.
Types of Information	Your log-in information (identifiers) (2-1)
Purposes of Use	To provide you with the single log-in function as part of Rakuten ID program (3-1); and To respond appropriately to customer inquiries (3-5)
4-1-2 Disclosure and use of information by Rakuten Group companies providing services that you requested, when you utilize your Account at, or link your Account with, an applicable Rakuten Group service.
Types of Information	Your log-in information (identifiers) (2-1); Information related to your use of the Membership Service and the Services (identifiers, protected characteristics, commercial information, internet or other electronic network activity information) (2-2); Payment information and information used for personal identification (financial, medical, or health insurance information) (2-3); and Device information and information obtained using Cookie Technologies (internet or other electronic network activity information, geolocation data) (2-4)
Purpose of Use	The purposes of use are the provision of the requested service by the Other Rakuten Group Company and any other purpose described in the privacy policy of the Other Rakuten Group Company providing the service.
4-1-3 Disclosure and use of information by Rakuten Group companies that oversee R&D operations (See this page)
Types of Information	Your log-in information (identifiers) (2-1); Information related to your use of the Membership Service and the Services (identifiers, protected characteristics, commercial information, internet or other electronic network activity information) (2-2); and Device information and information obtained using Cookie Technologies (internet or other electronic network activity information, geolocation data) (2-4)
Purpose of Use	To undertake service improvement, research and development (3-4)
4-1-4 Disclosure and use of information by all Rakuten Group companies
Types of Information	Information related to your use of the Membership Service and the Services (protected characteristics, commercial information, Internet or other electronic network activity information) (2-2) (with specific contact information such as your birth date, phone number and addresses removed or masked so that you may not be contacted directly); and Device information and information obtained using Cookie Technologies (internet or other electronic network activity information, geolocation data) (2-4)
Purpose of Use	To provide you with advertisements, promotion and marketing content (3-3); and To undertake service improvement, research and development (3-4)

If there are changes to the internal structure of Rakuten Group so that another Rakuten Group company takes on the role of centrally managing and storing personal information in accordance with this Policy, that Rakuten Group company will handle your information in accordance with this Policy in place of Rakuten.

4-2. Disclosure to Sellers of Goods and Services

We provide your personal information to sellers and relevant service providers (each a “Merchant”), including those located outside of Japan, when you use the Services to purchase products, or to request transaction related services such as a booking confirmation or a product delivery (including offers to make transactions). In such cases, we only disclose your information in Section 2 (“The Information We Collect”) to the extent necessary to effect the transaction.

Personal information provided for the purpose of effecting transactions between you and Merchants is managed by the Merchants. In addition to completing the transaction you have requested, Merchants may use your personal information for the purposes of providing you with information via email newsletters after the transaction, analyzing your purchases and use of their services, or for the improvement of their own business operations.

Please click here if you would like to learn about the privacy laws in countries where personal information is sent when it is provided to Merchants outside of Japan.

Please exercise caution when disclosing any information to the Merchants as any information which you disclose directly to the Merchants will not be governed by this Policy. Any such disclosure will be subject to the privacy notices that they provide.

4-3. Disclosure to Other Third Parties

In addition to the disclosures described above, we may also disclose your personal information to certain trusted third party service providers, including those located outside of Japan, where necessary to carry out our business operations.

Please be assured that we will only disclose your personal information in compliance with applicable laws, and with the appropriate management and supervision of the relevant third parties.

Occasionally, judicial or regulatory authorities may request access to or disclosure of information about you for law enforcement purposes. Such requests typically pertain to criminal investigations or other legal proceedings. Where they are necessary and legitimate, we will respond to such requests in accordance with our internal policies and applicable laws.

Additionally, in cases where it is necessary to prevent and mitigate fraudulent or illegal activities (3-1-6.), or to protect life, body, or property, we may disclose your personal information to another Rakuten Group company or to a third party.

Furthermore, we may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Policy.

We may disclose any type of your information in Section 2 (“The Information We Collect”) to the minimum necessary in order to achieve the purpose of the disclosure.

We will not use or disclose your information for purposes not set forth in this Policy without informing you and taking any necessary steps in advance as required under applicable law.

4-4. Analysis by Personal Information Matching and Use in Advertisement Delivery

We match and analyze your personal information obtained from third parties (Rakuten Group companies and business partners with whom we have entered into agreements with) with your personal information that we already manage. For example, in order to deliver advertisements that are more customized for you, we match and analyze personal information (such as your advertising identifiers, email addresses, and phone numbers) received from third parties with advertising identifiers and other personal information that we have about you. In addition, for third parties to improve and develop their marketing and services, we match and analyze personal information received from third parties with your personal information, process it into a format from which you cannot be personally identified, and then provide it to such third parties.

Furthermore, we provide to third parties the personal information that we manage (business partners with whom we have entered into agreements that provide advertising delivery and other services*) in order to deliver advertisements. For example, in order for third parties to deliver advertisements to you, we disclose personal information (including advertising identifiers, email addresses, and phone numbers) to these third parties. Such information is matched and analyzed with personal information and personal referable information (advertising identifiers etc.) managed by these third parties so they can deliver advertisements that are more customized for you. When doing so, these third parties use your personal information for the delivery of advertisements that we have requested.

*A list of the business partners that provide advertising delivery services and the names of the countries for those business partners located outside of Japan is available here.

We may also provide your personal information such as your advertising identifiers to third parties, including advertisers, in order to confirm the results of advertising, award points, and fulfill other purposes. These third parties may link this information to personal information such as advertising identifiers or personal referable information that they manage. This information is then provided to us along with information such as condition achievement information. We will link the information we receive with information we manage in order to confirm the results of advertising and to award points.

We may receive information related to you (personal referable information) such as identifiers and behavior history from third parties that do not hold personally identifiable information such as your name. Subsequently, we link this to your personal information to use such information in accordance with the purposes explained in Section 3.1 (“Use of Your Information”), except where other purposes are indicated. Specifically, we collect cookies, mobile advertising identifiers, email addresses and phone numbers (including those that have been through irreversible conversion processing), advertisement delivery logs such as the number of views for advertisements, website viewing and search histories, purchase histories (including shopping done at brick-and-mortar stores), location information and other behavior history, and television viewing logs. This information is used after linking it to personal information we manage. In such cases, the information is managed properly as personal information in accordance with applicable laws.

6-1. Your Rights

You may have certain rights regarding your personal information, subject to applicable laws. These may include the following rights to:

• access your personal information: you can request access the information about your personal information, such as the categories, the purposes of the processing or any other information required under the applicable law;
• rectify your personal information: you can rectify inaccurate personal information concerning you;
• erase your personal information: you can ask us to erase your personal information we have collected;
• restrict our use of your personal information;
• object to our use of your personal information: you can object to certain types of our processing of your personal information depending on the circumstances, such as profiling or any other processing required under applicable laws;
• data portability: receive your personal information in a usable electronic format and transmit it to an external party;
• learn more about the sources from which we collect information, the purposes for which we collect and share information, the information we hold, and the categories of parties with whom we share your information;
• opt out of “sales”: for California residents, opt out of certain disclosures of personal information that California law defines as “sales” even if no money is exchanged (you may exercise that right here: Do Not Sell My Personal Information). We may “sell” your personal information in accordance with the following provisions:
  • Disclosure and use of information by Rakuten Group companies that oversee R&D operations (4-1-3)
  • Disclosure and use of information by all Rakuten Group companies (4-1-4);
  • Disclosure to Other Third Parties (4-3); and
  • Our Cookie Policy and Rakuten Global Express Cookie Policy;

Where you intentionally direct us to do so, where we share your personal information for a business purpose or where any other circumstances permitted by the applicable law exist, such disclosures may not be considered as “sales.”

We do not “sell” personal information of minors under 16 years of age without affirmative authorization;

• be free from discrimination: you can freely exercise these rights without fear of being denied goods or services.; and
• lodge a complaint: you can lodge a complaint to the Global Privacy Manager of Rakuten or a data protection authority in accordance with Rakuten's BCRs.

If you would like to ask about or exercise such rights, please contact us in accordance with the information in “Contact Us”. You may use an authorized agent to exercise your rights in accordance with the applicable law. In that case, please ensure that you give the written permission to the agent.

Once we receive the request, we will verify your identity based on your personal information that we already have and that we may additionally require from you for the verification purpose.

Please note that we may also require additional information from you in order to respond your request appropriately.

We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.

Please also note that your rights are not absolute, and there are some grounds where we may decline your request as permitted under applicable laws.

6-2. Your Choices

As a principle, you will have a choice whether to provide information to us. However, where you have a choice and decide not to provide us with certain information, you may not be able to make use or take advantage of all the features provided by the Membership Service or the Services. You may also be unable to receive certain information that may otherwise benefit you, such as notifications of campaigns or promotions.

You can change your preferences for receiving promotional email and your preferred contact methods at any time by following the relevant instructions on our websites.

We want to do all we can to keep your personal information accurately recorded in our system. To this end, we endeavor to provide you with easy access to your information. You can view, modify and remove most of the information that you have given to us through your Account management page. Please remember to update information about yourself that has become inaccurate or outdated.

If you would like to access your information in written form, or through a means other than your Account management page, please contact us via the method described in ”Contact Us”. Fees may apply. In some cases, depending on the nature of the information and how it is stored, it may not be possible for us to fulfill your request.

We are committed to handling your personal information in accordance with high security standards and in compliance with applicable law. We do so in order to prevent unauthorized access or unauthorized disclosure of your information, to maintain the accuracy of such information and, when necessary, to ensure its proper destruction. When collecting or transferring your personal information, we employ data encryption technology, and restrict access only to those persons who require it to fulfil their job responsibilities. We conduct periodic reviews of our practices to ensure that our safeguards are properly implemented and remain state of the art. Please also refer to “Details about Our Information Security” below to learn about the security management measures that we take.

Details about Our Information Security Practices.

Because of the global nature of our business, the information that we collect from you may be transferred to countries whose data protection laws are not as comprehensive as those from where you are based. The main countries and regions to which your personal information is transferred through our business activities include the United States, Singapore, and India. When we transfer personal information overseas, in addition to ascertaining the privacy protection legal systems of those countries and regions, we put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us via the method described in (“Contact Us”). For global data processing within us, we put in place adequate measures including Binding Corporate Rules we implemented, a recognized European data protection standard. Binding Corporate Rules (the “BCRs”) provide for an appropriate level of protection. Our rules have been approved by the relevant European Union Authorities and these are also a strong commitment to protect your privacy around the world. Rakuten's BCRs are available here.

In order to maintain the security of your Account it is essential that you take adequate measures to protect your password. You should not use the same password that you use for other services, and you should never share your password with anyone. Please treat any email or other communication requesting your password as unauthorized and suspicious and forward the communication to us, using the contact method provided in “Contact Us”.

If you do share your Rakuten password with a third party for any reason, including when the third party has promised to provide you additional services such as account aggregation, the third party will have access to your Account and your personal information. In such cases, to the extent that the liability is not attributable to us, we are not liable for any losses or damages that you may incur as a result of activities that take place on your Account. If you believe someone else has obtained unauthorized access to your password, please change it and contact us immediately.

What to do when faced with orders or bills you don’t recognize（Japanese)

From time to time, in order to comply with changes in applicable laws or for legitimate business purposes, we may make changes to this Policy. Any changes we make will be displayed on this page. Please check back from time to time to ensure that you have read the most recent version of this Policy.

If you have any questions or concerns regarding the contents of this Policy or other aspects of how your personal information is handled, please see the Help page. Our contact information is listed there.

If you would like to discuss or exercise your rights granted by the applicable laws, please contact us through the following inquiry methods below. For example, the rights may include the right to opt out of “sales”, which is granted to California residents. For more description of your rights and the procedures, please see Section 6 (“Your Rights and Choices”).

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Once you contact us, we will respond without undue delay to you. Please note that when contacting us, we may ask you for certain information to verify your identity and respond to your request appropriately.