PRIVACY POLICY ARCHIVE

Version: May 2018

As of May 1, 2018 the main changes to the privacy policy are as follows:

• Prepared in compliance with the EU’s General Data Protection Regulation (GDPR) – the policy has been adapted to reflect the requirements of the GDPR, in both form and substance
• A description of the basis on which we collect and process personal data – and the legitimate interests that we pursue in doing so
• Transparency – we have set out in greater detail the types of data we collect, when and what we transfer to third parties such as advertisers – for example, see the table in the section ‘Disclosure of Your Personal Information to Brands or Partners’
• Increased user controls – fully describing our ability opt-out of seeing third-party advertising offers on our widget (partner offers will still show). The ability to withdraw consent for marketing emails remains and is unchanged.
• A description of our information security safeguards
• A description of our data retention practices
• A description of the rights that EU citizens have in respect of their data

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This Privacy Policy (“Privacy Policy“) explains how Rokt^® entities (“Rokt“, “us“, “our“, and “we“), collect and use Personal Information (defined below) and sets out the basis on which Personal Information we collect from or about you will be processed by us. This document aims to provide a concise, transparent, intelligible and easily accessible information about how we process personal data – please read it.

This Privacy Policy applies to all users of Rokt experiences provided via rokt.com, other Rokt websites including Shesaid.com and Tomorro.com (“Rokt Owned Sites”), and Rokt technology that is integrated on third-party partner websites, app or mobile-device applications (“Partner Sites”) (collectively, “Rokt Sites“).

This Privacy Policy replaces and supersedes the last version of this Privacy Policy for all users

Who is Rokt? What does Rokt do?

Rokt is the transaction marketing company. We provide services to Rokt Sites partners (“Partners”) that allow you to receive 1st party and 3rd party offers, contests, promotions, coupons, discounts, app download invitations, calendar subscription invitations, surveys/poll invitations and invitations to enter sweepstakes and interact with other marketing services (including during or after a transaction) (collectively, “Offers”) from those Partners and third-party brands (“Brands”), displayed on Rokt Sites. You may choose to sign up to receive communications in respect of such Offers, including by email, phone or SMS, from Brands or Partners, and from Rokt.

What are the consequences of signing up to Offers, or not?

There is no obligation on you to sign up to Offers, at all. As a consequence of signing up to Offers, we will share your personal data with the party identified in the Offer, so that any Offers they have offered may be fulfilled by them, and so they may provide further information associated with such Offers, as further detailed below under ‘Use and Disclosure of your Personal Information’. Importantly, there are no negative consequences if you do not sign up to an Offer, nor are you prevented from accessing the services in future from that company – simply no further action will be taken in respect of that Offer.

Our commitment to Privacy

Rokt takes your privacy very seriously and is committed to protecting it, as well as securing the data entrusted to us by Partners, Brands and you. We understand that you will only use our service if you can trust us to protect your Personal Information and use it appropriately. For more information on how we secure your data, see ‘Information Security Safeguards’ below.

What is Personal Information?

“Personal Information” or “Personal Data” is information about you which (i) can be used to identify, contact or locate you; (ii) can be combined with other information that is linked you; or (iii) is defined as “personal data” or “personal information” by applicable laws or regulations relating to the collection, use, storage or disclosure of information about you. Personal information includes contact information (e.g. email address, telephone number), online information (e.g. IP addresses, device identifiers), and other data which can be used individually or in combination with other data to identify an individual (such as gender, marital status, age, postcode).

Types of Personal Information that we collect, when, why and from whom (our basis for processing)

We collect and process a number of categories of Personal Information, on the basis of the legitimate interests of Rokt, its Partners and Brands:

• Personal Information you give us when you engage with, or sign up to, Offers across Rokt Sites;
• Personal Information you provide to us through our various customer contact channels;
• Personal Information about you provided to us by Brands and Partners (as part of our services to them), such as your identifying details (such as email address, gender, age/DOB, postcode, title, phone number), transaction details or conversion data (such as what you purchased, when and via what method);
• Usage data about your interaction with Offers, or any communications sent on behalf of Rokt, Brands or Partners, including:
  • information relating to your Offer interaction, such as Offer click-through rates and viewing data;
  • device information and website analytics information retrieved from your device/web browser, such as device profile, IP address, browser type/version, language preferences, access times, referring website address, your general geographic area based on your IP address;
• Information we obtain using cookies, eTags/ cache browsers, pixels, web beacons/ GIFs, local storage, or other identifiers or other tracking technologies on Rokt Sites and in e-mails we send you, that tell us the pages you view, the links you click, whether an e-mail has been opened, transaction information and other actions relating to our services and technology;
• Information about you that we may obtain from third-party sources and platforms (including data validation services, authentication service providers (including for calendaring services), data enrichment providers, social networking sites, online marketing and segmentation providers and ad-targeting companies) to supplement the information we collect from Partners and Brands and directly from You. For example, when you sign up to a sweepstakes competition or drawing Offer using your email address, we verify with a validation service that the email address is real, in order to ensure valid registration information and prevent fraudulent signups. In other cases, we may use age verification providers in order to ensure that offers are appropriate for a particular individual above or below the age of majority, or the age of digital consent.

In some circumstances where we process your Personal Information on the basis of our legitimate interests and those of our Partners and Brands, separate consent may be required by law for us to operate our technology (for example, in the case of cookies or other tracking technology that we use to access end user devices). Your consent may be obtained by us or on our behalf by our Partners and Brands.

The legitimate business interests referred to above, which have been balanced against the rights and freedoms of data subjects and their reasonable expectations, include:

• (i) the provision and use of website preference management software and analytics services ensuring customers have the best possible website experience by ensuring that content is relevant, engaging and personalized for each user viewing content on Rokt Sites (e.g. “if you just bought this product, you might like…”) or accords with the Partner’s specified user journey or journey parameters;
• (ii) the provision and use of website Brand management tools to promote brand safety for website users and owners;
• (iii) ensuring website safety by ensuring Offers presented to users are age-appropriate and shown only to their intended audience (e.g. not to children);
• (iv) the provision and use of website analytics and conversion tracking tools to assess the transaction attributes to optimize future marketing campaigns and future marketing strategy;
• (v) the provision of customer and email management software services allowing customers to effectively subscribe or unsubscribe to Offers that may be of interest or value to them;
• (vi) allowing website owners to recoup the actual cost of providing website services to users;
• (vii) validating users to verify the accuracy of customer data and to reduce fraudulent signups;
• (viii) creating and retaining evidential records to validate the provision of consent to direct marketing;
• (ix) using limited data sets for suppression purposes to prevent further unwanted processing for users who have either (a) objected to direct marketing or (b) have exercised their right to erasure (in respect of Personal Information provided by them), if applicable.

Note you have a right to object processing on the above basis – see below under ‘Your rights in relation to your Personal Information’.

Note in order to offer you a more consistent and personalized experience in your interactions with Rokt, information collected through one Rokt Service may also be combined with information obtained through other Rokt Services.

Use and Disclosure of your Personal Information

Rokt’s technology allows us to display Offers from Partners and Brands on Rokt Sites, and allows you to sign up to receive communications in respect of such Offers. The following subsections detail how your Personal Information is used by Rokt (i.e. for what purpose), as well as the basis on which we disclose information to Partners and Brands and other third-party processors.

(i) Use of Personal Information by Rokt

We use your Personal Information for purposes including:

• providing, maintaining, protecting, and improving our technology, products and services,
• monitoring the effectiveness of our services;
• selecting, displaying and providing to you Offers that are targeted and customized and personalized to your interests, attributes, preferences and experiences;
• predicting what Offers are relevant and engaging to people like you based on your known characteristics;
• disclosing the information to Partners and, if applicable, Brands – as set out in the sub-section (iii) below;
• making our services easier to use by eliminating the need for you to repeatedly enter your information;
• Offer targeting and suppression purposes, including display retargeting;
• sending you confirmation messages, further details messages and follow-up reminders for Offers that you have signed up to, via the applicable or appropriate medium including email, SMS, or communicating with you at the telephone number provided or confirmed (which may include using an automatic telephone dialing system or pre-recorded message), on our own behalf and on behalf of Partners and Brands;
• where you have signed up on rokt.com, Shesaid.com or Tomorro.com, or verbally confirmed with our staff, sending you marketing and promotional materials you have elected to receive;
• administering Rokt-sponsored sweepstakes, competitions or drawings you enter – including contacting you if you win, displaying your details online, publishing your name in relevant newspapers or disclosing details of winners to relevant authorities, if required by law;
• maintaining appropriate legal or business records;
• enabling us to conduct customer research and develop new services;
• validating the information you provide to us;
• to protect our rights, property or safety, our users and employees, or any third-party (incl. Brands or Partners); and
• complying with applicable laws and regulations.

We may state a more specific additional purpose when we collect your Personal Information.

(ii) Disclosure of Your Personal Information to Brands or Partners

Our use of your Personal Information also includes Rokt:

• Disclosing your Personal Information (including information you give us and Offer-related information to the Partner) when you engage with Offers while on the Partner’s site, including by swiping or clicking on Offers;
• Disclosing your Personal Information (including email address and segmentation data (e.g. gender, age/DOB, postcode, title, phone number and third-party provided data), even where this information is not directly displayed on screen), to named Brands if you indicate that you wish to accept their Offers (including by swiping or clicking). For example:

Where you sign up to an Offer that involves:	We may share the following Personal Information:
Receiving information from a Brand via email or otherwise joining their CRM	Your email and name, gender, state, country, zip code or other location details, age or date of birth, and your device, browser information and transaction information where relevant to the Offer you have accepted (like date or location of an event)
Receiving a call from a Brand	Your phone number, email and name, gender, state, zip code or other location details, age or date of birth, and your device, browser information and transaction information where relevant to the Offer you have accepted (like date or location of an event)
Visiting a Brand’s site, signing up to a calendaring invitation or downloading an app	Pseudonymized details about You like hashed email for tracking, attribution and custom audience purposes
Other Offer types	Information consistent with the nature of the Offer being provided, similar in nature to the details set out above

Electronic Communications – Where a Partner or Brand has made an Offer, and you indicate that you wish to accept it (including by swiping and clicking), we disclose your Personal Information to the Partner or Brand (as applicable) so that any Offers they have offered may be fulfilled by them, and so they may provide further information associated with such Offers to you via the applicable or appropriate medium (including email, SMS, or communicating with you at the telephone number provided or confirmed (which may include using an automatic telephone dialing system or pre-recorded message)). That information is provided to such party for the purpose of fulfilling the Offer, or other purpose explicitly disclosed at the time of collection, and your information will be handled by that party in accordance with its own privacy policy.

Note we do not sell, rent, share or trade your Personal Information to Brands for marketing purposes unless you have granted us permission to do so.

(iii) Further disclosure of your Personal Information

We may additionally disclose your Personal Information as follows:

• to third-party agents and processors, such as our technology vendors, CRM and data management platforms, data transmission companies, email service providers, data validation service providers, authentication service providers, data enrichment providers, online marketing and segmentation providers; and ad-targeting companies, as applicable, predominantly located in the USA, for third-party processing;
• to Brands or Partners if you have entered a contest or promotion sponsored by Rokt via their site;
• to any member of the Rokt group, meaning subsidiaries of parent company Rokt Pte Ltd, and their respective professional advisors, directors, employees, contractors and personnel;
• as required by any law, subpoena, court order, or other enforceable legal process (including laws outside your country of residence);
• as necessary to detect, prevent, or otherwise address fraud, security or technical issues;
• as necessary for us to do in order to establish or exercise our legal rights or defend against legal claims; or
• as part of or in anticipation of a business sale, merger, consolidation, investment, change in control, transfer of substantial corporate assets, reorganization, liquidation, or similar business transaction or corporate event.

and for such other purposes that are consistent with the way we have informed you that we will use your Personal Information in this Privacy Policy; and subject to appropriate confidentiality and security measures.

Disclosure of your Personal Information to recipients ‘overseas’

Rokt processes Personal Information in multiple countries, on high-security servers, possibly located outside the country in where you live, with our primary servers located in the USA. Before we disclose your personal information to an overseas recipient, we take steps as are necessary and reasonable in the circumstances to ensure that the overseas recipient does not breach privacy laws in relation to your Personal Information.

Where we disclose your personal information to Brands and other third-party processors, it is likely (although not assured) the Brand or third-party processor will be located in one of the markets in which we operate or have a presence – namely the United States, Australia, Singapore, Japan, the EU, the United Kingdom and New Zealand and any other countries in which operate as disclosed at http://rokt.com/about-us.

Rokt discloses Personal Information of individuals located in the European Economic Area with: (i) suppliers; (ii) other members of the Rokt group; and (iii) Brands and Partners located outside of the European Economic Area. Such transfers may be made: (a) to a third country or territory that is assessed by the European Commission as ensuring an adequate level of protection; (b) to recipients who have in place appropriate safeguards, such as standard contractual clauses that are approved by the European Commission or binding corporate rules that have been approved by a competent supervisory authority; or (c) where a transfer to a third country is occasional and necessary in relation to a contract between us or in your interest or for the establishment, exercise or defense of legal claims. In order to safeguard transfers of personal data for EU residents outside of the EU, Rokt discloses information concerning EU residents both (i) with suppliers and (ii) within the Rokt group, on the basis of EU-approved standard contractual clauses approved under Art 47 GDPR.

Information Security Safeguards

The security of your Personal Information is a priority for us, especially when your personal information is transferred ‘overseas’.

We take appropriate technical and organizational measures (including physical and electronic security) to safeguard Personal Information from loss, misuse, unauthorized access, modification or disclosure. The measures we use are designed to provide a level of security appropriate to the risk of processing your Personal Information. Specific measure that we use include:

• restricting access to Personal Information where practicable;
• using industry-standard encryption to protect data in transit and at rest;
• building and maintaining a secure (private) network with no direct access between the internet and systems processing your data;
• using pseudonymization techniques such as hashing email addresses or device IDs that we associate with you to reduce the risks when processing that data;
• conducting regular scans and penetration tests of our applications and networks to identify (and address) any potential vulnerabilities;
• demanding equivalent security and confidentiality measures from any third parties we do business with.

Data Retention

Rokt sets data retention periods in consultation with Partners and Advertisers in determining how long to retain the Personal Information about you supplied to us by them, subject to you exercising your lawful data subject rights, and further subject to any requirement for us to hold data for such period as may be required to establish, exercise or defend legal rights or ongoing legitimate business interests (e.g. to prove that you signed up to a particular Offer or electronic communication).

These periods vary by market in accordance with local laws. Please refer to the ‘User Rights’ section below for more information about how you can exercise your rights.

In respect of other categories of Personal Information and Personal Information collected on Rokt Owned Sites, if Rokt has no ongoing legitimate business need to process your Personal Information, we will take all reasonable steps to destroy the information and/or ensure that the information is de-identified or anonymized or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.

Rokt is not responsible for how long Partners and Brands may retain your Personal Information. You should consult the privacy notices provided by Partners and Brands with whom you interact in order to determine how long they may retain your Personal Information.

How we use Tracking Technologies

Like many companies, when we display online Offers to you, we may use one or more persistent “Tracking Technologies” (such as cookies, entity tags (eTags), pixels, web beacons/ GIFs, local storage, or other identifiers on your device and browser settings) in order to recognize you and your device each time we display Offers to you. We also apply statistical probabilities to data sets, which attempt to recognize or make assumptions about, users and devices (e.g., that a user of multiple devices is the same user). Tracking Technologies may set or alter settings or configurations on your Device. We use both session and persistent tracking technologies.

We use these technologies for a number of purposes to enhance your online experience, such as for preference setting, offer selection, analytics, conversion attribution and fraud reduction. By rejecting Tracking Technologies, this does not mean that you will no longer see ads when you visit Rokt Sites.

Further information on our use of Tracking Technologies, and how you can exercise your rights not to accept the use of Tracking Technologies, is set out in our ‘Cookies’ Policy.

What this Privacy Policy does not cover

Where Rokt provides information to a third-party (such as a Brand or Partner) (for example in relation to an Offer), you acknowledge that your Personal Information will be handled by that third-party in accordance with its own privacy policy and not in accordance with the Rokt privacy policy. You should consult our Brand’s and Partner’s own privacy policies for further details on their use, disclosure, transmission or storage of your Personal Information.

This policy does not apply to the practices of organizations that Rokt does not own or control, or to people that Rokt does not employ or oversee even if offers, coupons or links to their websites appear within our technology.

As a marketing technology provider, Rokt does not endorse any specific Partner or Brand, nor does it take any responsibility for concluding or finalizing Offers on their behalf. Rokt gives you the opportunity to elect to receive information about Offers that you determine are of interest to you – without taking any of your specific personal circumstances into account.

Your rights in relation to your Personal Information

Subject to applicable law, you may have a number of rights regarding the processing of your Personal Information, including:

• the right to request access to, or copies of, your Personal Information that we process or control, together with information regarding the nature, processing and disclosure of that Personal Information;
• the right to request rectification of any inaccuracies in your Personal Information that we process or control;
• the right to request, on legitimate grounds:
  • deletion of your Personal Information that we process or control; or
  • restriction of processing of your Personal Information that we process or control;
  • the right to object, on legitimate grounds, to the processing of your Personal Information by us or on our behalf;
• the right to request, available information on the source of the personal data where it is not from you;
• where we rely on your consent to use your Personal Information (e.g. for the sending of direct marketing by electronic mail), the right to withdraw that consent – see below under ‘How do I withdraw consent/ unsubscribe?’
• where we process your Personal Information on the basis of your legitimate interests the right to object to the processing of your personal information – see below under ‘How do I Opt Out?’
• the right to file a complaint with a Data Protection Authority regarding the processing of your Personal Information by us or on our behalf.

Other users may have similar rights granted to them under local laws. In such case we will act in accordance with those laws.

To exercise one or more of these rights, or to ask a question about these rights or any other provision of this Privacy Policy, or about our processing of your Personal Information, please use the contact methods described below.

Note as a security measure, to ensure that we properly identify you, such requests will only be actioned in respect of, and confirmed by way of reply email to, the specific email address from which the request was made. Note we will refuse requests made in respect of email addresses which a user cannot access. User requests will be answered as soon as possible but not later than one month after they are made or such other time that may be required under applicable privacy laws.

How do I withdraw consent / unsubscribe?

Withdrawing consent from Rokt for direct marketing communications / unsubscribing

Where you have given your consent for specific purposes, such as sending direct marketing by electronic mail, Rokt provides a facility for you to withdraw such consent for Rokt to process the Personal Information for that purpose. Note there are no adverse consequences for withdrawing your consent.

To unsubscribe from:

• any specific electronic correspondence from Rokt by using the ‘unsubscribe’ link contained in emails we send you or replying “STOP” to any SMS message you receive;
• all future email correspondence from Rokt, please send an email to privacy@rokt.com with the subject “Withdraw Consent” and we will unsubscribe you from all communications we send you.

Note: if you withdraw consent, we will keep a copy of your email address on file to record that you have withdrawn your consent, and we will retain any information not provided on the basis of consent, and any information to the extent necessary to establish, exercise or defend legal rights.

Withdrawing consent from Brands and Partners for direct marketing communications / unsubscribing

In order to withdraw consent from Brand and Partners, to exercise your data subject rights or to otherwise access, update or delete any of your Personal Information retained by them, you should contact them directly.

Where Brands and Partners have integrated with the Rokt unsubscribe mirroring service, where you request to unsubscribe from any further email correspondence from Rokt, you will be presented with the option to also unsubscribe from Brands and Partner communications at the same time. This may only be done by following the unsubscribe link contained in the emails we send you, and will be confirmed at the time of making the unsubscribe.

Otherwise, if you wish to unsubscribe from any further electronic correspondence from Brands or Partners, you should submit a request to those organizations directly using the unsubscribe facility provided by them, or otherwise as described in their communications to you, or as set out in their Privacy Policy.

Is Unsubscribing the same as Opting Out?

No. Unsubscribing/ withdrawing consent means we won’t send future electronic communications to you unless you sign up again to subsequent offers. However, if you want to avoid in future seeing any third-party Brand Offers on Rokt Sites, you should ‘Opt Out’. The next section deals with Opting Out.

How do I Opt Out?

Opting out from Brand Offers

Rokt provides a facility for you to opt out of seeing all future third-party Brand Offers on Rokt Sites (thereby avoiding any targeted third-party offers in future).

To request this please send an email to privacy@rokt.com with the subject “Opt Out”. Note we will keep a copy of your email address on file to retain a record that you have opted out. If you use another email with Rokt Partners, then you may need to Opt Out from multiple email addresses in order to ensure you don’t see any targeted third-party offers in future.

Even if you Opt Out you will still need to unsubscribe directly from any Partner or Brand’s mailing list if you want to stop receiving electronic communications from them.

Opting out from Partner Offers

Even if you Opt Out you will still see offers from Partners which are native to the Partner’s site. You cannot opt out from seeing first party Partner Offers.

Children’s Privacy

Rokt does not allow advertisements to be targeted at individuals under the age of 16.

Rokt does not knowingly collect Personal Information from or about children under the age of 13. If we learn that we have collected Personal Information on a child under the age of 13, we will delete that data from our systems.

Rokt encourages parents and guardians to monitor their children’s activities online.

Complaints

Rokt treats complaints relating to privacy very seriously. If you submit a concern or complaint, we will endeavor to deal with it comprehensively and reach an outcome with which all parties are satisfied. If you have any questions concerning any element of this privacy policy, or privacy complaints, please contact the privacy team at privacy@rokt.com

Changes to this Privacy Policy

Rokt may update this privacy policy at any time. If we do so, we will post any Privacy Policy changes on our website, which you can review at any time. You will also be presented with this Privacy Policy whenever you are shown Offers on Rokt Sites. Your continued use of such services after any change will signify and confirm your assent to changes to our Privacy Policy.

Whom to contact about this policy

Rokt’s Data Protection Officer can be contacted via dpo@rokt.com.

Rokt Pte Ltd is the parent company of the Rokt Group, with subsidiary companies operating in Australia, the United Kingdom, Japan, the Netherlands, Germany and the USA. For a list of our offices, and contact details, go to https://rokt.com/about-us/.

Rokt (UK) Ltd is designated as a representative within the European Union for all other members of the Rokt Group that are located outside of the European Union. Rokt (UK) Ltd shall be addressed in addition to other members of the Rokt Group by supervisory authorities and data subjects on all issues related to processing for the purposes of ensuring compliance with the General Data Protection Regulation (Regulation 2016/679).

 

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Rokt^® Cookie Policy

This Cookie Policy (“Cookie Policy“) explains how Rokt^® entities (“Rokt“, “us“, “our“, and “we“), collect and use use cookies and similar tracking technologies (“Tracking Technologies“). This document aims to provide a concise, transparent, intelligible and easily accessible information about these technologies – please read it.

This Cookie Policy applies to all users of Rokt experiences provided via rokt.com, and Rokt technology that is integrated on third-party partner websites, app or mobile-device applications (“Partner Sites“) (collectively, “Rokt Sites“).

This Cookie Policy replaces and supersedes the last version of the policy for all users. It should be read in conjunction with our Privacy Policy.

How we use cookies and similar tracking technologies

Like many companies, when we display online Offers to you, we may use one or more persistent Tracking Technologies (such as Cookies, entity tags (eTags), pixels, web beacons/ GIFs, local storage, or other identifiers on your device and browser settings) in order to recognize you and your device each time we display Offers to you. We also apply statistical probabilities to data sets, which attempt to recognize or make assumptions about, users and devices (e.g., that a user of multiple devices is the same user). Tracking Technologies may set or alter settings or configurations on your Device. We use both session and persistent Tracking Technologies (explained below).

We use these Tracking Technologies for a number of purposes such as to remember you, ensure Rokt services are relevant and personalized, and understand what elements of Rokt technologies work well, and which ones don’t. We also use Tracking Technologies to enhance your online experience, such as for preference setting, offer selection, analytics, conversion attribution and fraud reduction.

By engaging with and using Rokt services, you are agreeing to our Privacy and Cookie policies and consent to the use of tracking technologies by us as described in these policies. If you don’t want to accept cookies, that’s fine too – further information is provided below to help you turn them off. In some circumstances where we process your Personal Information on the basis of our legitimate interests and those of our Partners and Brands, separate consent may be required by law for us to operate our technology (for example, in the case of cookies or other tracking technology that we use to access end user devices). Your consent may be obtained by us or on our behalf by our Partners and Brands.

What is a cookie?

A cookie is a text file containing small amounts of information which is placed by a website within a computer device through your web browser; the cookie is subsequently sent back to the same website by the browser.

Cookies are designed to assist your computer or device to remember something a user has done within that website e.g. remembering that the user has logged in, or which buttons have been clicked, or what content has been searched for and presented.

For more information about cookies visit www.aboutcookies.org or www.allaboutcookies.org or www.youronlinechoices.eu.

What are other types of Tracking Technologies?

In addition to cookies, there are other similar technologies used by Rokt on Rokt Sites. This includes:

• eTags – these are forms of cache cookies which persevere across browser sessions uniquely identify the user’s browser
• web beacons/ Pixels/ GIFs – these are small graphics that are rendered invisibly on web pages when you open a page and contain a unique identifier which are used to understand browsing activity.
• local storage – these are sets of data that are stored on your browser by Rokt Sites which maintain preferences and usage history.
• other – we capture browser settings from the user such as browser, browser version, plug-ins installed.

Do I have to accept cookies and other types of Tracking Technologies?

To make the most of the Rokt services, cookies need to be enabled on your browser; certain features may not work effectively if you reject cookies or other Tracking Technologies.

If you do not wish to use cookie when using Rokt services, see the ‘How to control and delete Cookies’ section below for details on how to adjust the settings in your browser.

If you choose not to allow cookies you will still be able to engage with Rokt services but your experience may differ from that if you have cookies enabled. Without cookies you may see repeated content, offers, social engagement requests or market research questions.

Cookies we use

To help you understand how we use cookies we provide below a list of the current cookies that Rokt places via the Rokt domain (which we refer to here as ‘first party cookies’) and those placed by third party domains (which we refer to as ‘third party cookies’). Whether a cookie is a ‘first’ or ‘third’ party refers to whether the domain that places the cookie into your browser is the same domain as the page you are visiting at the time the cookie is placed. If a user visits a website and a separate domain sets a cookie through that website, it is referred to as a third party cookie. Note in some cases Rokt’s cookies may be served as ‘third party’ cookies on the domain of another company, ie on Partner Sites .

The following list provides information on the cookies we use, in order to provide you with the information you need to provide specific and informed consent in relation to our use of cookies.

We will update this list periodically as we make changes to cookies used as part of the Rokt experience across websites, mobile websites and mobile applications; or if we can provide more specific information in relation to the cookies used on our platform. Note web, mobile, tablet and apps may not always use the same cookies. We’ve highlighted which channel uses which cookie so it’s easier for you to understand which ones might affect you.

This list includes cookies deployed by Rokt on Partner Sites.

Cookie Name or ID	Description of purpose and functionality
Rokt widget cookies
imid rl_mid rl_pwmid RoktRecogniser	These are persistent cookies served by Rokt when you access a Rokt widget on the Rokt Publisher Network. Persistent means they stay on your browser after you’ve finished your session on our site, and remains there until you delete them. When you sign up to an Offer or Sweepstakes on a Rokt widget, Rokt assigns you a unique identifier, which is recorded in a cookie placed on your machine. These ‘Member ID’ cookies record that you’ve signed up to a specific offers, so we don’t show you the same offer multiple times, even if you’ve done so across different widgets. Certain of these cookies are used in different contexts, depending on the location from which you access Rokt services. RoktRecogniser is a Tracking Technology that helps us identify that you’re the same user across devices and browsers, by using tracking according to your browser settings, eTag, 1st & 3rd-party data, as well as 1st and 3rd party local data storage. These additional parameters allow Rokt to track the user beyond their email address after they’ve opted into Rokt offers.
rl_hwgo rl_hpworl_hwo rl_pwfid	This is a persistent cookie served by Rokt. Rokt places these cookies to prevent you from repeatedly seeing the same widgets over and over, if you regularly sign up to Offers or Sweepstakes on the Rokt Publisher Network.
Third Party Cookies
Google Analytics	These web analytics cookies, provided by Google Inc., are used to collect information about how visitors use our site. Rokt uses the information to compile reports and to help us improve our site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Googleadservices.com	These web analytics cookies, set by Google Inc to help advertisers determine how many times people who click on their ads end up taking a ‘conversion action’.
Google (DoubleClick)	These cookies (e.g. IDE) are used for advertising purposes across the internet and help measuring the success of our advertising campaigns.
HubSpot	These include analytics cookies for tracking visitors, their page views, keeping track of a visitor’s identity, usage tracking and other targeting purposes. Other HubSpot cookies are used to identify you if you message us via the Rokt website.

 

How to control and delete cookies and tracking technologies

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.

If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you chose to delete cookies, any settings and preferences, including advertising preferences, controlled by those cookies will be deleted.

If you would like to opt-out of all other types of Tracking Technologies we employ on Rokt Sites, you may do so by blocking, deleting, or disabling them as your browser or device permits.

How do I disable cookies?

If you want to disable cookies you need to change your website browser settings to reject cookies. How to do this will depend on the browser you use and we provide further detail below on how to disable cookies for the most popular browsers:

• Chrome
• Internet Explorer
• Firefox
• Safari
• Microsoft Edge

What happens if I disable cookies?

This depends on which cookies you disable, but in general, Rokt services may not operate in an effective way if cookies are switched off.

Note by rejecting Tracking Technologies, this does not mean that you will no longer see ads when you visit Rokt Sites.

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Version: October 2015

Who are we?

Rokt is a digital referral-marketing business. We have designed a secure and transparent way for you to opt-in to receive information about advertising offers, coupons, discounts, surveys or other services (“Offers”) and enter sweepstakes, contests or competitions (“Sweepstakes”) from third party advertisers (“Advertisers”) and Publishers (“Publishers”). These Offers and Sweepstakes are displayed via widgets across and within our network of Publisher websites and mobile applications and Rokt owned-and-operated websites (“Rokt Sites”) (together, the “Publisher Network”).

Our commitment to privacy

Rokt takes your privacy very seriously and is committed to protecting it. We understand that you will only use our service if you can trust us to protect your Personal Information (defined below) and use it appropriately.

This privacy policy sets out the basis on which any Personal Information we collect from you, or you provide to us, will be processed by us. Please read the following carefully to understand our practices regarding your Personal Information.

“Personal Information” is information that you provide to us which personally identifies you, including your name, email address, telephone number, gender, marital status, age, postcode and other personally identifiable information you give us in order to provide services to you.

Information that we collect

We may collect information in a number of ways:

• Personal Information you give us when you opt-in to Offers, Sweepstakes or our other services while engaging with our widgets across our Publisher Network, or if you register for an account or membership on a Rokt Site;
• Information about your interaction with our widgets, including website analytics information retrieved from your web browser, such as Internet Protocol address, browser type, language preferences, access times, referring website address, your general geographic area based on your IP address, in order to customise our services to you;
• Information that allows us to provide you with more focused and targeted communications, collected using cookies, web beacons, pixel tags, customised links or similar technologies in e-mails we send you, that tell us the pages you view, the links you click, whether an e-mail has been opened and other actions relating to our widgets and services. For further information on our use of cookies – see our Cookies Policy below.
• Information relating to your advertisement interaction and viewing data, such as ad click-through rates and information about what you viewed across the Rokt Publisher Network. We may also collect transaction data from your activity on our Publisher Network and advertiser segmentation lists from our Advertising partners.
• Information provided to us through our customer contact channels.
• Information about you that we may obtain from third-party sources and platforms (including social networking sites, validation services, online marketing companies, ad-targeting companies or advertisers or publishers) to supplement the information we collect with information obtained from those third party sources. For example, if you elect to connect to your third-party social networking service profile (such as Facebook, LinkedIn, Twitter) through the Rokt Network, or socially share an Offer or Sweepstake, we may access and use relevant details that you permit to be accessed through that social networking service such as username, profile image, location information, interests, activities, ‘likes’, connection list and age for those services.

Use of your Personal Information

The following subsections set out how your Personal Information will be used by Rokt (including but not limited to sending you third party advertisements we believe are relevant to you) and may be used by Advertisers and Publishers.

(i) Use of Personal Information by Rokt

Our use of the Personal Information you give us, and your consent to us using your Personal Information, includes Rokt:

• providing, maintaining, protecting and improving our widgets, products and services;
• selecting and displaying to you Offers that are personalised and customised to your interests, preferences and experiences;
• providing your personal information to Advertisers or Publishers in relation to those Offers with your consent;
• making our widgets easier to use by eliminating the need for you to repeatedly enter the same information;
• monitoring the effectiveness of Offers and campaigns;
• sending you details of Offers that you have asked to receive, via any medium including via email and SMS or at the number(s) you provided (which may include using an automatic telephone dialing system or pre-recorded message);
• communicating with you, if you agree, by email, mail or telephone or at the number(s) you provided (which may include using an automatic dialing system or pre-recorded message), including for Rokt Sites.
• sending follow-up or reminder messages including via email and SMS;
• sending marketing and promotional material that we believe you may be interested in;
• administering Sweepstakes you enter, on behalf of Rokt, Advertisers or Publishers, including contacting you if you win, displaying your name and state on our website, publishing your name in relevant newspapers or disclosing details of winners to relevant authorities, if required by law;
• maintaining appropriate legal or business records;
• enabling us to conduct customer research and develop new services; and
• verifying information you provide to us.

We may state a more specific additional purpose at the point we collect your Personal Information.

In order to offer you a more consistent and personalised experience in your interactions with Rokt, information collected through one Rokt service may be combined with information obtained through other Rokt services.

(ii) Use of Your Personal Information by Advertisers and Publishers

We do not sell, rent, share or trade your Personal Information to third parties for marketing purposes unless you have granted us permission to do so. Instances where this occurs are described below.

Where you enter a Sweepstakes on a Rokt widget displayed on our Publisher Network, you agree the purpose of the collection is to allow the Advertiser(s) or the Publisher (as applicable) to use your Personal Information:

• to fulfill the selected Offer and contact you with marketing information associated to the Offer, via any medium including via email and SMS or at the number(s) you provided (which may include using an automatic dialing system or pre-recorded message);
• administering Sweepstakes you enter including contacting you if you win, displaying your name and state on our website, publishing your name in relevant newspapers or disclosing details of winners to relevant authorities, if required by law.
• Where you select (or maintain pre-checked tick box) and accept an Offer on a Rokt widget you agree that the purpose of the collection is to allow the Advertiser or Publisher to use your Personal Information to fulfil the selected Offer by contacting you with information directly associated to the Offer, and not for any additional purpose (without your consent) including via email and SMS or at the number(s) you provided (which may include using an automatic dialing system or pre-recorded message).

Other purposes may be disclosed at the time of collection, and will be carried out in accordance with the Privacy Policy of the Advertiser or Partner organization.

Disclosure of your Personal Information

We disclose Personal Information to Advertisers and Publishers as set out in the sections above.

We may also disclose Personal Information to third party agents, third party processors (if applicable for third party processing), professional advisors, directors, employees, contractors and personnel only for such purposes that are consistent with the way we have informed you that we will use the information in this Privacy Policy; and subject to appropriate confidentiality and security measures.

We may also disclose your personal information to any member of the Rokt group, meaning subsidiaries of parent company Rokt Pte Ltd.

Other than as set out above, we will not disclose any of your Personal Information to third party companies, organisations and individuals, unless one of the following circumstances applies:

• that disclosure is required by any law, subpoena, court order, or other enforceable legal process;
• it is necessary to detect, prevent, or otherwise address fraud, security or technical issues;
• it is necessary for us to do in order to establish or exercise our legal rights or defend against legal claims; or
• that disclosure is required as part of a proposed or actual transfer or sale of all or part of our business or assets.

Disclosure to overseas recipients

Rokt processes Personal Information in multiple countries, on high-security servers, possibly located outside the country in where you live. Before we disclose your personal information to an overseas recipient such as an Advertiser or data warehouse we take steps as are reasonable in the circumstances to ensure that the overseas recipient does not breach privacy laws in relation to your Personal Information. Where we disclose your personal information to Advertisers and other third party processors, it is likely (although not assured) the Advertiser or third party processor will be located in one of the markets in which we operate or have a presence – namely the United States, Australia, Singapore, the United Kingdom and New Zealand and any other countries in which operate as disclosed on https://rokt.com/about-us/.

Information Security

The security or your Personal Information is a priority for us. We take physical and electronic security measures to safeguard Personal Information from loss, misuse, unauthorised access, modification or disclosure. This may include restricting access to Personal Information, entering into security or confidentiality arrangements with third parties. In certain areas Rokt uses industry-standard SSL encryption to protect data transmissions.

If Rokt no longer needs the information we will take all reasonable steps to destroy the information and/ or ensure that the information is de-identified.

How we use Cookies

When we display online Offers to you, we may place one or more persistent cookies on your computer in order to recognise your computer each time we display an advertisement to you. Further information on our use of Cookies is set out in our Cookies Policy below.

What this Privacy Policy does not cover

Where Rokt provides information to a third party at your request (for example in relation to an Offer), you acknowledge that your information will be handled by that third party in accordance with its own privacy policy and not in accordance with the Rokt privacy policy. You should consult our Advertiser’s and Publisher’s own privacy policies for further details on their use, disclosure, transmission or storage of your Personal Information.

This policy does not apply to the practices of organisations that Rokt does not own or control, or to people that Rokt does not employ or oversee even if offers, coupons or links to their websites appear within our widgets.

Opting out of communications from Advertisers and Publishers

If you wish to unsubscribe from any further email correspondence from Advertisers or Publishers, you should submit a request to those organisations directly using the unsubscribe facility provided by them, or otherwise as described in their communications to you.

You should contact those organisations directly about accessing, updating and deleting any of your Personal Information retained by them.

Children’s Privacy

Rokt does not knowingly collect Personal Information from children under the age of 13. If we learn that we have collected Personal Information on a child under the age of 13, we will delete that data from our systems. Rokt encourages parents and guardians to go monitor their children’s activities online.

Accessing, updating and deleting your Personal Information held by us

You may request to unsubscribe from any further email correspondence from Rokt or Rokt Sites through the relevant domain at any time or using the ‘unsubscribe’ link contained emails we send you.

If you wish Rokt to correct, or remove, Personal Information we have collected about you on our network, you can do so by emailing Rokt directly with your request at privacy@rokt.com, unless we have to keep that information for a legitimate business or legal purpose. When updating your personal information, we may ask you to verify your identity before we can act on your request. You may also request to opt out from seeing targeted Offers and receiving communications from Rokt in future by emailing privacy@rokt.com with the subject line ‘Opt Out’, from the email address to be opted-out. We will implement this as quickly as possible, and in any case within 10 days. We will retain a copy of that email address to record and implement the opt out across browsers on an ongoing basis. Note if you opt out, you may still see initial invitations to engage with our services, and some services we deliver may not function properly. For further information on controlling and deleting cookies from your browser, see our Cookies Policy.

Complaints

Rokt treats complaints relating to privacy very seriously. If you submit a concern or complaint, we will endeavour to deal with it comprehensively and reach an outcome with which all parties are satisfied. If you have any questions concerning any element of this privacy policy, or privacy complaints, please contact the privacy team at privacy@rokt.com

Changes to this Privacy Statement

Rokt may update this privacy statement at any time. If we do so, we will post any Privacy Policy changes on our website, which you can review at any time. You will also be presented with this Privacy Policy whenever you are on a Rokt widget. Your continued use of our website or widgets after any change will signify and confirm your assent to changes to our Privacy Policy.

Whom to contact about this policy

Rokt Pte Ltd is the parent company of the Rokt Group. For a list of our offices, go to https://rokt.com/about-us/.

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COOKIE POLICY

How we use cookies

Rokt uses cookies to help personalise and improve your online experience across the Rokt Sites and the Rokt Publisher Network (including SHESAID.com ). They enable us to remember you, ensure Rokt services are relevant and personalized, and understand what elements of our widget experience work well, and which ones don’t.

By engaging with and using Rokt services, you are agreeing to our Privacy and Cookie policies and consent to the use of cookies and similar technologies by us as described in these policies. If you don’t want to accept cookies, that’s fine too – further information is provided below to help you turn them off.

What is a cookie?

A cookie is a text file containing small amounts of information which is placed by a website within a computer or device through your web browser; the cookie is subsequently sent back to the same website by the browser.

Cookies are designed to assist your computer or device to remember something a user has done within that website e.g. remembering that the user has logged in, or which buttons have been clicked, or what content has been searched for and presented.

For more information about cookies visit www.aboutcookies.org

Do I have to accept cookies?

To make the most of the Rokt services, cookies need to be enabled on your browser; certain features may not work effectively if you reject cookies.

If you do not wish to use cookie when using Rokt services, see the ‘How to control and delete Cookies’ section below for details on how to adjust the settings in your browser.

If you choose not to allow cookies you will still be able to engage with Rokt services but your experience may differ from that if you have cookies enabled. Without cookies you may see repeated content, offers, social engagement requests or market research questions.

Cookies we use

To help you understand how we use cookies we are providing a list of the current cookies that Rokt places via the Rokt domain (which we refer to here as ‘first party cookies’) and those placed by third party domains (which we refer to as ‘third party cookies’). Whether a cookie is a ‘first’ or ‘third’ party refers to whether the domain that places the cookie into your browser is the same domain as the page you are visiting at the time the cookie is placed. If a user visits a website and a separate domain sets a cookie through that website, it is referred to as a third party cookie. Note in some cases Rokt’s cookies may be served as ‘third party’ cookies on the domain of another company in the Rokt Publisher Network.

The following list provides information on the cookies we use, in order to provide you with the information you need to provide specific and informed consent in relation to our use of cookies.

We will update this list periodically as we make changes to cookies used as part of the Rokt experience across websites, mobile websites and mobile applications; or if we can provide more specific information in relation to the cookies used on our platform. Note web, mobile, tablet and apps may not always use the same cookies. We’ve highlighted which channel uses which cookie so it’s easier for you to understand which ones might affect you.

This list includes cookies deployed by Rokt on our partner websites. These cookies may be disabled by Rokt for certain partners based on the services that Rokt has in place which is managed independently with each partner on the Rokt network.

Cookie Name or ID	Description of purpose and functionality
Rokt widget cookies
midimidrl_midrl_omidrl_pwmid	These are persistent cookies served by Rokt when you access a Rokt widget on the Rokt Publisher Network. Persistent means they stay on your browser after you’ve finished your session on our site, and remains there until you delete them.When you sign up to an Offer or Sweepstakes on a Rokt widget, Rokt assigns you a unique identifier, which is recorded in a cookie placed on your machine. These ‘Member ID’ cookies record that you’ve signed up to a specific offers, so we don’t show you the same offer multiple times, even if you’ve done so across different widgets. Certain of these cookies are used in different contexts, depending on the location from which you access Rokt services.
rl_hwgorl_hpworl_hwo#	This is a persistent cookie served by Rokt.Rokt places these cookies to prevent you from repeatedly seeing the same widgets over and over, if you regularly sign up to Offers or Sweepstakes on the Rokt Publisher Network.
Third Party Cookies
Google Analytics	These web analytics cookies, provided by Google Inc., are used to collect information about how visitors use our site. Rokt uses the information to compile reports and to help us improve our site. The cookies collect information in an anonymous form, including the number of visitors to the site, where visitors have come to the site from and the pages they visited.
Googleadservices.com	These web analytics cookies, set by Google Inc to help advertisers determine how many times people who click on their ads end up purchasing their products.

How to control and delete cookies

You have the ability to accept or decline cookies. Most Web browsers automatically accept cookies, but you can usually modify your browser setting to decline cookies if you prefer.

If you choose to accept cookies, you also have the ability to later delete cookies that you have accepted. If you chose to delete cookies, any settings and preferences, including advertising preferences, controlled by those cookies will be deleted .

How do I disable cookies?

If you want to disable cookies you need to change your website browser settings to reject cookies. How to do this will depend on the browser you use and we provide further detail below on how to disable cookies for the most popular browsers:-

For Microsoft Internet Explorer:

1. Choose the menu “tools” then “Internet Options”

2. Click on the “privacy” tab

3. Select the appropriate setting using the slider

For Mozilla firefox:

1. Choose the menu “tools” then “Options”

2. Click on the icon “privacy”

3. Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

1. Choose the menu Tools> Files”> “Preferences”

2. Click Privacy and select one of the available options

What happens if I disable cookies?

This depends on which cookies you disable, but in general, Rokt services may not operate in an effective way if cookies are switched off.