PRIVACY POLICY ARCHIVE

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/.

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:

Choose the menu “tools” then “Internet Options”
Click on the “privacy” tab
Select the appropriate setting using the slider

For Mozilla firefox:

Choose the menu “tools” then “Options”
Click on the icon “privacy”
Find the menu “cookie” and select the relevant options

For Opera 6.0 and further:

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