Ce message s'affiche car vous êtes dans le navigateur embarqué de votre application,
pour participer veuillez cliquez sur les trois petits points en haut à droite puis sur "Ouvrir avec votre navigateur".

PRIVACY POLICY
ADVENT CALENDAR CAMPAIGN

Comprised of Rakuten, Inc. (hereinafter “Rakuten”) and its various subsidiaries and affiliates, the Rakuten Group (the “Group”) provides many different kinds of services. When you make use of these services, we collect, use, and store your information accordingly.

This Privacy Policy (the “Policy”) was created to help you understand why and how the Rakuten Group companies which adopted this Policy use your information, and the rights and choices you have in this regard. The Rakuten Group companies want to ensure that, no matter how you use the Rakuten Group’s services, you are empowered to make real choices about your information.

For more details, please also see «How is your information used?».

1.- What This Policy Covers

This Privacy Policy applies to your use of services (including related services, applications, tools, etc., hereinafter the “Services”) provided to you by Rakuten, and other Rakuten Group companies that have adopted this Policy (collectively, “we” or “us”). Please be aware that for certain services, we or the other Rakuten Group companies may provide you with privacy statements in addition to, or in place of, this Privacy Policy, as appropriate. The Rakuten Group aims to provide you with a unique and personalized experience when you interact with the Rakuten Group’s services. In order to achieve this goal, the Rakuten Group provides a unified ID program called “Rakuten ID,” which includes a single log-in function that makes it easy for you to access and use applicable services provided globally by the Rakuten Group companies. You may create your own Rakuten account (your “Account”), and use all related services (together, the “Membership Service”) in accordance with this Policy and the Rakuten Membership Terms & Conditions set forth separately by Rakuten. Please only use the Services or the Membership Service after you have carefully read and understood this Policy, the Rakuten Membership Terms & Conditions, and other applicable terms. In using the Services or the Membership Service, you represent that you understand the contents of this Policy describing our collection, use, transfer and retention of your information herein. If you have any questions or inquiries regarding this Policy, please contact us using the information provided in Section 9 («Contact Us»)

2.- The Information We Collect

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

2-1.- Your log-in information

Identifiers:
- Your user ID and password
- Your name and email address

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

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

2-3.- Device information and information obtained using Cookie Technologies

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

Such information may include:
- Device ID or other information that allows us to identify the device you are using;
- Operating system and internet connection related information;
- Geo-location information;
- Referring URL;
- IP Address;
- URLs viewed and time stamp of time viewed
- Server log information other than the above
- Information related to products and services displayed and searched For a more detailed explanation on the information we collect through the Cookie Technologies, please refer to the Cookie Policy webpage.

2-4.- Information we collect from other sources

Identifiers, protected characteristics, commercial information, internet or other electronic network activity information, geolocation data:
During your use of the Membership Service and the Services, we may request, collect and store your information from publicly available sources and third parties, such as your credit information and information necessary for fraud prevention and detection, as may be necessary from time to time and as permitted under applicable law. In addition, based on your separate consent, we may receive other personal information about you from third party sources.
Unless necessary for the purpose of providing you with the service in question or for another legally permissible reason, during your use of the Services or the Membership Service, we do not intentionally collect or use information of yours that may be considered sensitive, such as information relating to your race, religion, social status, medical or criminal history, or whether you were a victim of a crime (together, “Sensitive Information”). In the event that you voluntarily give your Sensitive Information to us, we will treat such information as information related to your use of the Membership Service and the Services (2-2) that has been provided to us with your express consent, and process it in accordance with this Policy.

2-5.- Inferences regarding preferences or other characteristics

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

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

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

3-1.- Use of Your Information

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

3-1-1.- To provide you with single log-in function as part of the Rakuten ID program:

To enable you to log into your Account across applicable services provided by the Rakuten Group companies

3-1-2.- To provide you with the Membership Service and the Services:

To enable your use of the Membership Service and the Services
For the provision of personalized services, content, and information related to the Membership Service and the Services
For the provision of incentive programs relating to the Membership Service, such as reward points, coupons and cashback rewards

3-1-3.- To provide you with advertisements, promotion and marketing content:

- To display or send to you advertising content, such as direct mail or email newsletters, with your consent, or via methods otherwise permitted under applicable law
- For the display, introduction, or advertisement of products and services offered by us, other Rakuten Group companies and our third party partners on our websites or on other advertising media that we manage or operate

3-1-4.- To undertake service improvement, research and development:

To improve existing services and conduct R&D for the development of new services

3-1-5.- To respond appropriately to customer inquiries:

So that we may respond appropriately to customer inquiries, complaints, or requests in relation to our services and advertisements

3-1-6.- To prevent and mitigate fraudulent or illegal activities:

For the prevention, identification and investigation of scams, cyber-attacks, and other potentially illegal or fraudulent activities, or in relation to any other activities necessary to protect the legal rights of the Rakuten Group and/or the rights of third parties

3.2- Legal Basis of the Use of Your Information

In the European Economic Area, we are obliged to have a legitimate reason (or legal basis) for each processing activity and in most cases, the basis on which we rely will be one of the followings:
- to fulfil our contractual obligations to you, for example to provide the Membership Service and the Services, which includes services for you and a Merchant to arrange a commercial transaction;
- to meet our legitimate interests, for example to understand how you use the Membership Services and the Services and to improve them and to provide tailored marketing messages to you via certain channels. Our legitimate interests to process your personal information consist of our missions and desires to provide you with a unique and personalized experience when you interact with the Rakuten Group’s services through your Rakuten ID.
Additionally, we may ask you to give us your consent to collect and use certain types of personal information, for example, when we would like to send you e-mail marketing messages and process Sensitive Information. If we ask for your consent to process your personal information, we will ensure that you may withdraw your consent at any time.

3.3- Retention of Your Information

The personal information collected to fulfill our obligations under the advent calendar campaign will be stored up to 6 months after the end of the campaign. Other information, such as Device information and information obtained using Cookie Technologies, will used and retained at maximum for 2 years after the collection. We will only retain your personal information after this time if we are required to do so to comply with the applicable laws, or if there are outstanding claims or complaints that will reasonably require your personal information to be retained.

4.- Disclosure of Information about You

4.1- Disclosure within the Rakuten Group

In order for the Rakuten Group to develop and provide you with ever more unique and attractive services, it is essential that the Rakuten Group companies are able to share information with one another.
For this reason, Rakuten centrally manages and stores the personal information that we collect in accordance with this Policy. Whilst Rakuten is responsible for centrally managing and storing your personal information, we, the Rakuten Group companies who have adopted this Policy, will have access to your personal information and will use it in accordance with the provisions of this Policy.
In addition, we may disclose your personal information to other Rakuten Group companies, including those located outside of Japan. These companies may access and use your information as set forth in the table below.

4.1.1- Disclosure and use of information by Rakuten Group companies operating services that support Rakuten ID.

Tipos de información
Your log-in information (identifiers) (2-1)

Purposes of Use
- To provide you with the single log-in function as part of the Rakuten ID program (3-1); and
- To respond appropriately to customer inquiries (3-5)

4.1.2- 4-1-2 Disclosure and use of information by Rakuten Group companies providing services that you requested, when you utilize your Account at, or link your Account with, an applicable Rakuten Group service.

Types of Information
- Your log-in information (identifiers) (2-1);
- Information related to your use of the Membership Service and the Services (identifiers, protected characteristics, commercial information, internet or other electronic network activity information) (2-2);
- Payment information and information used for personal identification (financial, medical, or health insurance information) (2-3); and
- Device information and information obtained using Cookie Technologies (internet or other electronic network activity information, geolocation data) (2-4)

Purposes of Use
The purposes of use are the provision of the requested service by the Other Rakuten Group Company and any other purpose described in the privacy policy of the Other Rakuten Group Company providing the service.

4.1.3- Disclosure and use of information by Rakuten Group companies that oversee R&D operations (See this page)

Types of Information
- Your log-in information (identifiers) (2-1);
Information related to your use of the Membership Service and the Services (identifiers, protected characteristics, commercial information, internet or other electronic network activity information) (2-2); and
Device information and information obtained using Cookie Technologies (internet or other electronic network activity information, geolocation data) (2-4)

Purposes of Use
To undertake service improvement, research and development (3-4)

4.1.4- Disclosure and use of information by all Rakuten Group companies

Types of Information
- Information related to your use of the Membership Service and the Services (protected characteristics, commercial information, Internet or other electronic network activity information) (2-2) (with specific contact information such as your birth date, phone number and addresses removed or masked so that you may not be contacted directly); and
- Device information and information obtained using Cookie Technologies (internet or other electronic network activity information, geolocation data) (2-4)

Purposes of Use
- To provide you with advertisements, promotion and marketing content (3-3); and
- To undertake service improvement, research and development (3-4)

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

4.3- Disclosure to Other Third Parties

In addition to the disclosures described above, we may also disclose your personal information to certain trusted third party service providers, including those located outside of the European Economic Area, where necessary to carry out our business operations. We have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected.
Please be assured that we will only disclose your personal information in compliance with the applicable law, and with the appropriate management and supervision of the relevant third parties.
On occasion, judicial or regulatory authorities may request access to or disclosure of information about you for law enforcement purposes. Such requests typically pertain to criminal investigations or other legal proceedings. Where they are necessary and legitimate, we will respond to such requests in accordance with our internal policies and applicable law.
Additionally, in cases where it is necessary to prevent and mitigate fraudulent or illegal activities (3-6), or to protect life, body, or property, we may disclose your personal information to another Rakuten Group company or to a third party.
Furthermore, we may share your personal information with any third party that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a transfer occur, we will use reasonable efforts to try to ensure that the entity to which we transfer your personal information uses it in a manner that is consistent with this Policy.
We may disclose any types your information in Section2(“The Information We Collect”) to the minimum necessity in order to achieve the purpose of the disclosure.
We will not use or disclose your information for purposes not set forth in this Policy without informing you and taking any necessary steps in advance as required under applicable law.

5.- Your Rights and Choices

5-1.- Your Rights

You may have certain rights regarding your personal information, subject to the applicable law. These may include the following rights to:
- access your personal information: you can request access the information about your personal information, such as the categories, the purposes of the processing or any other information required under the applicable law;
- rectify your personal information: you can rectify inaccurate personal information concerning you;
- erase your personal information: you can ask us to erase your personal information we have collected;
- restrict our use of your personal information;
- object to our use of your personal information: you can object to certain types of our processing of your personal information depending on the circumstances, such as profiling or any other processing required under the applicable law;
- data portability: receive your personal information in a usable electronic format and transmit it to an external party;
- learn more about the sources from which we collect information, the purposes for which we collect and share information, the information we hold, and the categories of parties with whom we share your information;
- opt out of “sales”: for California residents, opt out of certain disclosures of personal information that California law defines as “sales” even if no money is exchanged (you may exercise that right by contacting us as set out below under Section 9). We may “sell” your personal information in accordance with the following provisions:
-- Disclosure and use of information by Rakuten Group companies that oversee R&D operations (4-1-3)
-- Disclosure and use of information by all Rakuten Group companies (4-1-4);
-- Disclosure to Other Third Parties (4-3); and
-- Our Cookie Policy, Rakuten Global Market Cookie Policy, and Rakuten Global Express Cookie Policy;
- Where you intentionally direct us to do so, where we share your personal information for a business purpose or where any other circumstances permitted by the applicable law exist, such disclosures may not be considered as “sales.”
- We do not “sell” personal information of minors under 16 years of age without affirmative authorization;
- be free from discrimination: You can freely exercise these rights without fear of being denied goods or services.; and
- lodge a complaint: you can lodge a complaint to the Global Privacy Manager of Rakuten or a data protection authority in accordance with Rakuten's BCRs (https://corp.rakuten.co.jp/privacy/en/bcr.html).
If you would like to ask about or exercise such rights, please contact us in accordance with Section 9(“Contact Us”). You may use an authorized agent to exercise your rights in accordance with the applicable law. In that case, please ensure that you give the written permission to the agent.
Once we receive the request, we will verify your identity based on your personal information that we already have and that we may additionally require from you for the verification purpose.
Please note that we may also require additional information from you in order to respond your request appropriately.
We encourage you to contact us to update or correct your information if it changes or if the personal information we hold about you is inaccurate.
Please also note that your rights are not absolute, and there are some grounds where we may decline your request as permitted under the applicable law.

5-2.- Your Choices

As a principle, you will have a choice whether to provide information to us. However, where you have a choice and decide not to provide us with certain information, you may not be able to make use or take advantage of all the features provided by the Membership Service or the Services. You may also be unable to receive certain information that may otherwise benefit you, such as notifications of campaigns or promotions.
You can change your preferences for receiving promotional email and your preferred contact methods at any time by following the relevant instructions on our websites.

6.- Updating Your Information

We want to do all we can to keep your personal information accurately recorded in our system. To this end, we endeavor to provide you with easy access to your information. You are able to view, modify and remove most of the information that you have given to us through your Account management page. Please remember to update information about yourself that has become inaccurate or outdated. If you would like to access your information in written form, or through a means other than your Account management page, please contact us via the method described in Section 9 (“Contact Us”). Fees may apply. In some cases, depending on the nature of the information and how it is stored, it may not be possible for us to fulfill your request.

7.- Security and International Transfers

We are committed to handing your personal information in accordance with high security standards and in compliance with applicable law. We do so in order to prevent unauthorized access or unauthorized disclosure of your information, to maintain the accuracy of such information and, when necessary, to ensure its proper destruction. When collecting or transferring your personal information, we employ data encryption technology, and restrict access only to those persons who require it to fulfil their job responsibilities. We conduct periodic reviews of our practices to ensure that our safeguards are properly implemented and remain state of the art.
Please refer to this page for more details about our security practices.
Because of the global nature of our business, the information that we collect from you may be transferred to countries whose data protection laws are not as comprehensive as those from where you are based. When we transfer personal information overseas, we have put in place appropriate safeguards (such as contractual commitments) in accordance with applicable legal requirements to ensure that your data is adequately protected. For more information on the appropriate safeguards in place, please contact us at the details in accordance with Section 9(“Contact Us”). For global data processing within us, we put in place adequate measures including Binding Corporate Rules we implemented, a recognized European data protection standard. Binding Corporate Rules (the “BCRs”) provide for an appropriate level of protection. Our rules have been approved by the relevant European Union Authorities and these are also a strong commitment to protect your privacy around the world. Rakuten's BCRs are available here: https://corp.rakuten.co.jp/privacy/en/bcr.html In order to maintain the security of your Account it is essential that you take adequate measures to protect your password. You should not use the same password that you use for other services, and you should never share your password with anyone. Please treat any email or other communication requesting your password as unauthorized and suspicious and forward the communication to us, using the contact method provided in Section 9 (“Contact Us”).
If you do share your Rakuten password with a third party for any reason, including when the third party has promised to provide you additional services such as account aggregation, the third party will have access to your Account and your personal information. In such cases, to the extent that the liability is not attributable to us, we are not liable for any losses or damages that you may incur as a result of activities that take place on your Account. If you believe someone else has obtained unauthorized access to your password, please change it and contact us immediately.

8.- Changes to this Privacy Policy

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

9.- Contact Us

If you have any questions or concerns regarding the contents of this Policy or other aspects of how your personal information is handled, please contact us via below support e-mail address.
If you would like to discuss or exercise your rights granted by the applicable laws, please contact us through the following inquiry methods below. For example, the rights may include the right to opt out of “sales”, which is granted to California residents. For more description of your rights and the procedures, please see Section 5(“Your Rights and Choices”).

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