PRIVACY POLICY

  1. What This Policy Covers
  2. The Information We Collect
  3. Use, Legal Basis of Use and Retention of Your Information
  4. Disclosure of Information about You
  5. Your Rights and Choices
  6. Updating Your Information
  7. Security and International Transfers
  8. Changes to this Privacy Policy
  9. Contact Us

Rakuten Group, Inc. (here in after “Rakuten” or “we”) provides the Big Picture Campaign (the “Campaign”). When you wish to enter the Campaign, we collect, use, and store your information accordingly.

This privacy policy (the “Policy”) was created to help you understand why and how the Rakuten use your information, and the rights and choices you have in this regard.

1. What This Policy Covers

This Policy applies to your once you enter the Campaign provided to you by Rakuten. Please be aware that regarding services from which you have specifically agreed to receive marketing, we or the other Rakuten Group companies may provide you with privacy statements in addition to, or in place of, this Policy, as appropriate.

The Rakuten Group aims to provide you with a unique and personalized experience when you interact with the Rakuten Group’s services. In order to achieve this goal, the 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 the Rakuten Group companies. 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 contact us using the information provided in Section 9 (“Contact Us”).

2. The Information We Collect

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 for the Campaign, the information we generate for the Campaign and the information already received as part of Rakuten ID. 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:

2-2. Information related to the Campaign

Your information necessary to run the Campaign:

2-3. Information related to advertising

If you provide your consent to advertising, your information to manage advertising:

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

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

3. Use, Legal Basis of Use and Retention of Your Information

We use your personal information to provide you with the single log-in function as part of Rakuten ID, the Campaign, and advertising and marketing content in accordance with your interests as expressed when entering the Campaign.

3-1. Use of Your Information

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

3-1-1. To provide you with single log-in function as part of the Rakuten ID program:
3-1-2. To run the Campaign:
3-1-3. To provide you with advertisements, promotion and marketing content:
3-1-4. To respond appropriately to customer inquiries:
3-1-5. Advertisements, promotions and marketing content created by the promoter:
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:

3-3. Retention of Your Information

The personal information collected to fulfill our obligations under the Campaign will be stored up to 3 years after the end of the campaign. Other information, such as Device information and information obtained using Cookie Technologies, will used and retained as set in the Cookie Policy. We will only retain your personal information after this time if we are required to do so to comply with the applicable laws, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.

4. Disclosure of Information about You

4-1. Disclosure within the Rakuten Group

Whilst Rakuten is responsible for centrally managing and storing your personal information, the Rakuten Group companies which business is relevant to your country will have access to your personal information and will use it in accordance with the provisions of this Policy.

You can find the list of the companies below and their activities:

United-Kingdoms:

Spain:

France:

Japan:

United States:

Rest of the World:

If there are changes to the internal structure of the 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 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 or the European Economic Area, where necessary to carry out our business operations. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected.

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

On occasion, 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 law.

Additionally, in cases where it is necessary to prevent and mitigate fraudulent or illegal activities, 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 types your information in Section 2 (“The Information We Collect”) to the minimum necessity 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.

5. Your Rights and Choices

5-1. Your Rights

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

If you would like to ask about or exercise such rights, please contact us in accordance with Section 9 (“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 the applicable law.

5-2. 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 enter the Campaign, as your information as necessary to run it. Should you refuse to provide your information or ask us to delete your information, you will not be a part of the Campaign anymore.

Regarding marketing, you can change your preferences for receiving promotional email at any time by following the relevant link in each marketing communication that we send.

6. Updating Your Information

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 are able to 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 Section 9 (“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.

7. Security and International Transfers

We are committed to handing 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 refer to this page for more details about our 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. When we transfer personal information overseas, we have 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 at the details in accordance with Section 9 (“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 https://corp.rakuten.co.jp /privacy/en/bcr.html

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 Section 9 (“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.

8. Changes to this Policy

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.

9. Contact Us

If you have any questions or concerns regarding the contents of this Policy or other aspects of how your personal information is handled, or if you would like to discuss or exercise your rights granted by the applicable laws, please contact us via below support e-mail address: prj-fcb-pp@mail.rakuten.com.

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 5 (“Your Rights and Choices”).

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 in order to verify your identity and respond to your request appropriately.

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