Rakuten International Privacy Policy and Notice of Personal Information Collection

This website, located at https://rakuteninternational.com (the “Site”), is operated by Rakuten USA, Inc. as the headquarters for our subsidiaries and corporate affiliates operating in the Americas and EMEA regions (“Rakuten International”, “we” or “us”), and part of the “Rakuten Group,” which includes all worldwide affiliates and subsidiaries of our parent company, Rakuten Group, Inc., based in Tokyo, Japan.

This Privacy Policy explains how Rakuten International collects, processes, and discloses personal information about you when you access or use this Site to discover information about Rakuten International's headquarters, leadership, affiliates, and the services and job opportunities provided by Rakuten Group companies headquartered in the Americas and EMEA regions, or when you otherwise interact with us, such as when you visit our office facilities (“Facilities”) or register for or attend an event we facilitate (“Event”). Certain Events or Facilities may have additional privacy disclosures and or terms, as applicable, for data collected by Rakuten International or other Rakuten Group companies that is specific to that Event (e.g., dietary restrictions, physical accommodations needed, etc.), or Facility visit (e.g., local Wi-Fi, security cameras, visitor registration systems), and any such additional terms will be provided to relevant data subjects or consumers in connection with that Event registration or Facility visit.

We also process the personal information of job applicants and Rakuten International's staff. If you click through from this Site to our Rakuten Group Careers page located at https://global.rakuten.com/corp/careers/midcareer/ or apply for a job with a Rakuten Group company, our global Recruitment Privacy Policy will govern the personal information collected from and about you during the recruiting process and explain your privacy rights. The personal information we collect, process, and retain about our Rakuten International staff and former staff members in relation to their work activities and relationship with us is governed by our internal Staff Privacy Policies, which are accessible to all current staff of Rakuten International companies. Former staff may request a copy of the applicable Staff Privacy Policy by contacting us as provided in the Contact Us section, below.

In addition to non-staff data we collect as a business on our own behalf when you interact with this Site, our Events, or our Facilities, Rakuten International may receive and process personal information about you in our role as a service provider or processor to some of our Rakuten International subsidiaries and affiliates, on behalf of those businesses, to assist them in providing the independent services those businesses offer to consumers and their business clients, or for other corporate management business purposes such as strategic planning. To the extent you interact with them, please see the privacy policies of these Rakuten International businesses (linked below) to understand what personal information they collect from and about you, how they may use and disclose it, and to exercise your consumer rights under applicable privacy laws.

Types of Information We May Collect:‍

When you visit our Site or otherwise interact with us as described herein regarding Events and Facility visits, we may collect the following types of information about you:

• Identifiers, such as your name, username, address, email address, IP address, unique online identifiers;
• Customer Records Information, such as your signature, image, telephone number, and/or, for the purposes of Events, necessary information about your health/dietary restrictions;
• Characteristics of Protected Classifications, such as any information you provide us about a disability that is relevant to Event or Facility accommodations;
• Internet or Other Network Activity Information, including online browsing or search history in relation to Facilities Wi-Fi services, Facilities electronic access logs, where applicable, or information about your interaction with our Site;
• Professional or Employment-Related Information—including the company for which you work and your job title;
• Sensory Information, such as your image as collected via security cameras or access credential photos, where applicable
• Account credentials, such as usernames and passwords.

Note that we do not collect types of information considered “sensitive” personal information under applicable U.S. state privacy laws.

Sources of Collection:

We may collect the above types of information in various ways, as described below:

Information You Provide to Us Directly

We collect information you provide directly to us, such as when you fill out a form, register for an Event, pose for a photo, or otherwise submit, send, or provide your information to us yourself.

Information We Collect Automatically

When you access or use our Site, we automatically collect certain information about you, including:

• Log and Device Information: We systematically collect standard information related to your access to and use of the Site and the device you used to access the Site, such as the type and version of your browser and operating system, access dates and times, pages viewed, IP address and the referrer web page from which you linked to our Site.
• Event and Facilities Access Data: When you attend an Event or visit our Facilities, we may automatically collect certain information about you as applicable for that Event or Facility, including security camera footage, badge and access logs, Wi-Fi access and activity logs and information regarding the device with which you accessed our Facilities Wi-Fi.

We may use the information we collect about you for the purposes listed below:

To Provide our Site and Services

We use your information to administer your visit to our Site and Facilities or attendance at an Event, to complete registration for Events, or to provide the Event for which you registered and any related services to you.

To Provide Customer Service and Communicate with You

We use your information in order to respond appropriately to your inquiries, complaints, or requests communicated to us through our Site or otherwise. We also use your information to communicate to you about Events for which you register or request information. We may also use your contact information for follow-up communications with you about an Event, such as to request feedback, provide additional information, or thank you for your attendance.

To Administer Optimism and Similar Events

We use your information to facilitate your registration for our Optimism conference and similar events, provide event access credentials, administer event participation, coordinate travel or accommodation as applicable, send event materials and agendas, collect your preferences for meals or access needs, and manage your communication preferences for post-event follow-up and marketing communications.

To Promote our Events

We use information from and about past Event attendees to promote future Events to you via direct mail communications, subject to your objection or opt-out rights, depending on the applicable privacy laws in your jurisdiction.

To Facilitate Interaction Among Event Attendees

Subject to your objection or opt-out, we may provide a list of attendees and their contact information to other Event participants for the purpose of facilitating communication and interaction among attendees.

To Improve our Events and Facilities

We may solicit and collect your post-Event feedback for the purpose of improving our future Events and our Facilities.

To Secure and Protect Persons and Property in Relation to our Site, Events, and Facilities

We may use information about your use of our Site or Wi-Fi to limit spam, malware, and other malicious online activities and security risks, and to improve and enforce our online security measures. We may also use information such as building access logs, badge reader records, security cameras and registration systems to identify, investigate, mitigate, and help prevent illicit, illegal, fraudulent or dangerous activities or situations in relation to our Facilities or Events, or otherwise as necessary to protect the safety, security, and legal rights of persons and/or Rakuten International or to enforce our policies.

To Comply with Law or Exercise or Defend Legal Rights

We may use information about you to defend or assert our legal rights or those of a third party, or to comply with our legal obligations in the relevant jurisdictions in which we operate our Facilities, Events, or conduct other business.

Note that we may deidentify or aggregate your information so that it can no longer associated with you, and that we may use such aggregated or deidentified information for any purpose. To the extent we deidentify information for a particular purpose, we maintain it in a deidentified manner and do not attempt to re-identify it.

Legal Bases: If you are located in the European Economic Area (EEA), the United Kingdom (UK), and certain other locations, we must have an identified legal basis to process your personal information. We process your personal information for the purposes described above, under the following legal bases:

• To meet our legitimate interests as a business, including to provide, administer, improve, and secure/protect our Site, Events and Facilities and to promote our Events, including emailing you about future events and including your information on an Event attendee list available to other attendees. When we process personal information to meet our legitimate interests, we put in place robust safeguards to ensure that your privacy is protected and to ensure that our legitimate interests do not override your fundamental privacy rights and freedoms, such as the ability to object or opt-out of processing where our legitimate interest is not compelling, as set forth in Section 5.
• To fulfil our contractual obligations to you, for example to facilitate your Event registration, participation, and other Event-related transactions, and your access to and use of our Facilities.
• On the basis of your consent– Certain information that you opt-in to provide, such as when you utilize certain optional features of our tools or applications, or participate in certain optional activities at Events or Facilities where your data may be collected or processed, we process on the basis of your consent. If we ask for your consent to process your personal information, you may withdraw your consent at any time by following the processes outlined in Section 5, below, to exercise your privacy rights, or by contacting us using the details at the end of this Privacy Policy.
• To comply with our legal obligations, or to assert or defend our legal rights under relevant EEA or UK law.

We do not sell, share, or process your personal information for targeted advertising purposes. We may disclose all the categories of personal information for business or commercial purposes as follows:

To Our Affiliates and Subsidiaries

We may disclose information that we collect about you with our affiliates and subsidiaries or other Rakuten Group companies in our role as a service provider or processor to assist them in providing the independent services those businesses offer to consumers and their business clients, or for other business purposes such as managing shared Facilities, Events, and corporate administrative purposes including strategic planning.

To Our Conference Sponsors

We may disclose your personal information as necessary to conference sponsors for a business purpose in connection with your participation in our events, such as the Rakuten Optimism conference. This may include information such as your name, contact details, company affiliation, and event registration information. Sponsors may use this information to provide you with relevant event-related materials or follow-up communications, in accordance with their own privacy policies.

To Vendors/Service Providers

We may disclose your personal information as necessary to vendors, contractors, and service providers that perform services for us, for a business purpose, including business operations-related services such as IT platform providers, data storage, analytics, Event management, and security.

To Comply with Law or Exercise or Defend Legal Rights

We may disclose information about you in response to a legally sufficient official request for information, or if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities during an investigation or to meet national security or law enforcement requirements. We may also disclose information about you as necessary to defend or assert our legal rights or those of a third party, to defend against a complaint or legal claims, or to comply with our legal obligations in the relevant jurisdictions in which we operate our Facilities, Events, or conduct other business.

To Protect Rakuten International or Others

We may disclose your information to law enforcement or other authorities if we believe your actions have violated the law, or to protect the rights, property, and safety of Rakuten International or others.

In Connection with a Business Transaction

We may disclose your information in confidence in connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. If there are changes to the internal structure of our parent company such that another Rakuten International affiliate or subsidiary takes on the role of centrally collecting, using or disclosing personal information in accordance with this Privacy Policy, that affiliate or subsidiary will be obligated to notify you of this occurrence and handle your information in accordance with this Privacy Policy in place of Rakuten International.

International Data Transfers

Because we operate as part of a global business, recipients of the personal information we collect may be located outside the jurisdiction in which you are located (or in which we provide our Site, Events or Facilities). As a result, your personal information may be transferred to, stored, or otherwise processed in a country that is not regarded as ensuring an adequate level of protection for personal information in relation to your country of residence.

We have put in place appropriate safeguards (such as standard contractual clauses) in accordance with applicable legal requirements to ensure that your data is adequately protected when transferred. As a Rakuten Group company, Rakuten International relies on the Rakuten Group Binding Corporate Rules (BCRs) (https://corp.rakuten.co.jp/privacy/en/bcr.html) to legitimize international data transfers of EEA and UK personal data within the Rakuten Group.

You may have certain rights regarding your personal information based on applicable local laws, including the following rights:

• Right to Know and Access: You have the right to request that we confirm whether or not we are processing personal information about you and that we provide certain information to you about our collection and use of your personal information, including:
  • The categories of personal information we collected about you;
  • The categories of sources from which we collected your personal information;
  • The categories of third parties to whom we disclosed your personal information, including which categories of your personal information we disclosed for a business purpose to which categories of recipients, or in some cases the list of specific third parties to whom we disclosed personal information;
  • Our business or commercial purpose for collecting your personal information;
  • The amount of time we intend to retain your information; and
  • The specific pieces of personal information we collected and maintain about you.
• Right to Request Deletion: You have the right to request that we delete your personal information, subject to certain exceptions. Upon such a request, we will delete (and direct our service providers or contractors to delete) your personal information from our records, except to the extent we determine that a statutory exception applies or we have a legal obligation to maintain the information.
• Right to Request Correction: You have the right to request that we correct any personal information about you that is factually inaccurate or complete any personal information that is incomplete.
• Right to Opt-Out of Sale/Sharing of Personal Information: We do not sell, share, or process your personal information for cross-context targeted advertising purposes. For registrants of Events, if you prefer that we not disclose your personal information to our conference sponsors, you may opt out at any time by emailing us at RI-RS_privacy@rakuten.com with your request. Please note that opting out may limit your ability to receive sponsor-related communications, materials, or access to certain sponsor-hosted features during our events.
• Right to Object to Our Processing: For visitors in the EEA or UK, you have the right to object to our processing on the basis that your individual rights and freedoms outweigh our legitimate interests or to the use of your information for our direct marketing purposes.
• Right to Restrict Our Processing: For visitors in the EEA or UK or Brazil, you may have the right to Restrict our processing of your personal data if its accuracy is challenged, on the basis that such processing is unlawful, or while it is determined whether our legitimate interests outweigh your individual rights and freedoms.
• Right to Non-Retaliation: We will not retaliate against you for exercising any of your privacy rights conferred by the CCPA or any other applicable law, including when you are an applicant to an educational program, a job applicant, a student, an employee, or an independent contractor.‍
• Right to Appeal: In certain U.S. states, you have the right to appeal our decision regarding your privacy rights request. You may submit an appeal request by contacting us as provided below. We will respond according to the law applicable in your location.

How To Exercise Your Privacy Rights

To exercise your privacy rights as described above, you should contact us by email at this address: RI-RS_privcay@rakuten.com, or you may call us toll-free at +1 888-551-2118.

Please note that in certain U.S. states, you may not make a request to know or access your information more than twice within a 12-month period.

Your request must be verifiable. In order for us to verify your identity, we will need to match certain information that we may ask you to provide in your request with data that we maintain and have determined to be reliable for the purposes of verification. We will only use personal information you provide as part of your request to fulfill the request or verify your identity or authority to make the request.

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. We may require any agent making a request on your behalf to prove that you authorized the agent to submit a request on your behalf and we will ask you to personally verify your identity as the requestor.

Shine the Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes. We do not share your information with third parties for their direct marketing purposes. You may contact us using the information in the Contact Us section to request more details under California’s “Shine the Light” law.

Notice Regarding Information of Minors

This Site and any related services, including our Events and Facilities are intended for adults over 16 years of age, and we do not knowingly collect or process the personal information of minors under 16 years of age without affirmative authorization or without affirmative, verifiable consent from a parent for those under age 13.

We may retain information about you for as long as it is necessary to fulfill the purposes described Section 3. Some of your information may be retained in our systems even after you request your information to be deleted if an exception applies, or in order to comply with our obligations under applicable law, resolve disputes, enforce our legal rights, to undertake any investigations necessitated by the foregoing, and otherwise use internally in a lawful manner that is reasonably aligned with your expectations or compatible with the context in which the information was collected or provided.

We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the personal information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of users' personal information. We evaluate these measures on a regular basis to confirm that they continue to maintain and apply an appropriate level of security.

This Privacy Policy is current as of the date set forth above. We may change this Privacy Policy from time to time consistent with applicable privacy laws and principles and our practices in relation to personal information. If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, including when we make a material change, we will provide you with additional notice (such as adding a statement to our website homepage). We encourage you to review the Privacy Policy whenever you access the Site or otherwise interact with us to stay informed about our information practices and the choices available to you.

If you have any questions about this Privacy Policy, please contact us at:

Rakuten USA, Inc.

800 Concar Drive, San Mateo, CA 94402

Email: RI-RS_privcay@rakuten.com

Toll-free tel: +1 888-551-2118

NOTE: If you are trying to reach Rakuten.com Member Services (for Rakuten Rewards), please contact them at: memberservices@rakuten.com

To request a copy of any prior version of this Privacy Policy, you may contact us using the information provided in the Contact Us section above.