Rakuten Ready Privacy Policy

Updated: January 1, 2020

 

CONTENTS

What This Privacy Policy Covers

Collection of Information

Use of Information

Sharing of Information

Transfer of Information to the U.S. and Other Countries

Links to Third Party Sites

Advertising and Analytics Services Provided by Others

Your California Privacy Rights

Your Choices

Retention

Information Security

Changes to the Privacy Policy

Contact Us

  1. What This Privacy Policy Covers

This Privacy Policy explains how Curbside, Inc. d/b/a Rakuten Ready (“Rakuten Ready,” “we” or “us”) collects, uses, and discloses information.  Rakuten Ready is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company, Rakuten, Inc., based in Tokyo, Japan.

This Privacy Policy applies to all users of our websites, apps, features, or other services anywhere in the world. This Privacy Policy specifically applies to visitors to our website located at https://www.rakutenready.com (the “Site”), and to our business clients (“Clients”) and partners who use our services (collectively referred to as “Services”).    Our Services enable a Client to predictively detect when an individual that interacts with the Client’s services (“End Users”) is approaching a physical destination and to act in response. The actions taken upon End User arrival are product-specific and are entirely up to the Clients and the developers who envision difference scenarios for the Client’s service. Our Services are built into the mobile applications of many leading businesses, and Rakuten Ready provides a collection of software development tools called a software development kit (“SDK”) to enable Clients to offer order pick up features to their end customers. We may also provide an end-to-end mobile commerce solution to our Clients with brick and mortar stores to connect with online customers. In such case, Services may include website development and maintenance, order fulfillment, payment processing, customer rewards and loyalty program management, user account administration, and data analytics and insights.  We describe what information we receive from Clients about End Users in Section 2(C) below.

  1. Collection Of Information

A. Information You Provide to Us

  • Site visitors: We collect information you provide directly to us. For example, we collect information when you fill out a form or enter information through the Site, send us a message through the Site, or otherwise communicate with us.
  • Clients: If you are a Client or a prospective Client, we collect information when you sign up, and register for, the Services (“Client Information”), when you interact with us in relation to your use of our Services, or otherwise communicate with us. We may collect information such as first and last name, email address, phone number, company name, and any other information you choose to provide. You may also provide us with other information for us to deliver our Services, including transaction information.  In addition, when you use the Connect Pick & Pack App as a Client or employee or independent contractor of a Client, you may be asked to create or use your Rakuten ID to log-in and check customer order fulfillment status. As a Client, you may be asked to create a “Rakuten ID” in order to log-in. Rakuten ID is a unified ID program and a single login and sign-on function that allows users to connect to the services offered by the Rakuten Group companies (https://corp.rakuten.co.jp/privacy/en/rakuten-id.html) participating in the Rakuten ID program, without having to create a new account for each service or company.  For additional information on how your information is collected, used and disclosed through your use of the Rakuten ID service, please see Sections 4 (A).

B. Automatically Collected Information

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

  • Log Information: We collect information related to your access to and use of the Site, including the type of browser you use, app version, access times, pages viewed, and your IP address.
  • Device Information: We collect information about the computer or mobile device you use to access our Site, including the hardware model, operating system and version, unique device identifiers, and mobile network information.
  • Information Collected by Cookies and Similar Tracking Technologies: We (and our service providers) use different technologies to collect information, including cookies and web beacons. Cookies are small data files stored on your hard drive or in device memory that help us improve our Site and your experience, see which areas and features of our Site and Services are popular, count visits and times visited, see what products and services are displayed and searched, and collect server log information other than the above.  Web beacons (such as “pixel tags” or “clear GIFs”) are electronic images that may be used in our Site or Services or emails and help deliver cookies, count visits, and understand usage and campaign effectiveness. For more information about cookies and how to disable them, see Section 9(A) below.

C. Information We Receive from Our Clients

We refer to the information we receive from our Clients about their End Users in the course of us providing Services to Clients as “End User Information.”  We receive End User Information from an End User’s use of our Clients’ mobile applications and websites. End User Information we receive from Clients may include, name, email address, mailing address, telephone number, payment card information, transaction information, precise location information, device information (e.g., device ID), and website or application usage information.  This Privacy Policy does not apply to any information beyond End User Information in our Clients’ products, services and applications (“Client Services”). We are acting on behalf of the Clients, and we are not responsible for our Clients’ handling of information related to Client Services.  Our Clients have their own policies regarding the collection, use and disclosure of End Users’ personal information.  To learn about how a Client handles an End User’s personal information, we encourage you to read the Client’s privacy statement.  Our use of End User Information provided by our Clients in connection with our Services is subject to the written agreement between us and Client.

  1. Use Of Information

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

A. Provide Our Site and Services

  • We use information we collect from the Site visitors to operate our Site.
  • We use Client Information to provide our Services to Clients. For example, we use Client Information to create and manage Client accounts and to provide loyalty numbers and reward program information.
  • We use End User Information to facilitate our Clients’ provision of Client Services to End Users. For example, we use End User Information (e.g., location information) to support the processing and fulfillment of orders.

B. Communicate with Clients

We use Client Information to communicate with Clients about our products and services, and to provide news and information we think will be of interest to Clients. See Section 9(C) below for more information about how to opt-out of these communications at any time.

In addition, we use Client Information to communicate with you about your use of our Services, to provide you with the Services, and to fulfill your requests.

C. Customer Service

We use Client information in order to respond appropriately to inquiries, complaints, or requests in relation to our Site and Services.  Further, we may use your email address or mobile phone numbers to communicate service-related messages to you, such as changes to this Privacy Policy, system updates or any updates on terms of use applicable to the Services.

D. Site and Services Improvement

We use your information to help improve our Site and Services.  We use information obtained from analytics tools to improve our Site and Services and our product and service offerings and other business operations.

E. Research, Development, and Analytics

We may use your information for business purposes including to provide analytic services and for other strategic purposes.

F.Prevention and Mitigation of Fraudulent or Illegal Activities

We may use your information to prevent, identify, and investigate scams, cyber-attacks, and other potentially illegal or fraudulent activities, or in relation to any other activities necessary to protect the legal rights of Rakuten Ready and/or the rights of third parties.

G. For Network Security Purposes

We may use information to protect against spam, malware, malicious activities and/or security risks, and to improve and enforce our security measures.

H. To Protect You, Others and Our Business

We may use your information by actively monitoring, investigating, preventing and mitigating any alleged or actual prohibited, illicit or illegal activities on the Site or Services.  We also use your information investigate, prevent or mitigate violations of our internal terms, agreements or policies; enforce our agreements with third parties and business partners.

  1. Sharing Of Information

We may share information about you as follows or as otherwise described in this Privacy Policy.

A. With Our Affiliates and Subsidiaries

We may share information about you with our affiliates and subsidiaries or other Rakuten related entities in order to provide analytics services, for strategic purposes, or to provide other services.

In addition, if you are a Client and have a Rakuten ID account, your personal information is shared to another Rakuten service in the Rakuten ID program, only if you choose to connect the accounts. For additional information on how your information is collected, used and disclosed through your use of the Rakuten ID service, please see the Rakuten ID privacy policy (https://corp.rakuten.co.jp/privacy/en/rakuten-id.html).

B. Disclosure to Vendors

We disclose your personal information with vendors, service providers, and third parties that perform services for us, including business operation related services such as our IT providers, analytics providers, email marketing and management service providers, and data storage and hosting service providers.

C. To Comply with Law

In response to a request for information if we believe disclosure is in accordance with, or required by, any applicable law or legal process, including lawful requests by public authorities to meet national security or law enforcement requirements.

D. To Protect Rakuten Ready or Others

If we believe your actions are inconsistent with our user agreements or policies, if we believe you have violated the law, or to protect the rights, property, and safety of Rakuten Ready or others.

E.In Connection with a Business Transaction

In connection with, or during negotiations of, any merger, sale of company assets, financing or acquisition of all or a portion of our business by another company. If there are changes to the internal structure of our parent company so that another Rakuten Ready affiliate or subsidiary takes on the role of centrally collecting, using or disclosing personal information in accordance with this Privacy Policy, that affiliate or subsidiary will handle your information in accordance with this Privacy Policy in place of Rakuten Ready.

F. With Your Consent or at Your Direction

We may share Client Information when authorized by you or provide you with a service you have requested.

G. With our Clients

We share End User Information with the Client that furnished or made such information available to us to provide Services to that Client or as otherwise directed by that Client.

In addition to the above listed disclosures, we may also share aggregated or de-identified information that cannot reasonably be used by those third parties to identify you.

  1. Transfer of Information to the U.S. and Other Countries

Rakuten Ready is based in the United States and we process and store information in the U.S.  Therefore, we and our vendors or service providers may transfer your information to, or store or access it in, other jurisdictions. As a Rakuten Group company, Rakuten Ready relies on the Rakuten Group Binding Corporate Rules to legitimize international data transfers within the Group. The Rakuten Group Binding Corporate Rules can be found at https://corp.rakuten.co.jp/privacy/en/bcr.html.

  1. Links to Third Party Sites

Our Site or Services may contain links to other web sites, including but not limited to affiliated or co-branded web sites and sites of our subsidiary companies.  Other web sites which are not controlled by Rakuten Ready may reference or link to our Site or Services.  We encourage you to review the privacy policies of every web site that you visit that our Site or Services may link to or that may link to our Site or Services.  We are not responsible for the privacy practices or content of such other web sites or mobile applications.

  1. Advertising and Analytics Provided by Others

We may allow others to provide analytics services and serve advertisements on our behalf across the web and on the Site or through our Services.  These entities may use cookies, web beacons, device identifiers and other technologies to collect information about your use of the Site or our Services and other websites and applications (including the websites and mobile applications of our Clients), such as your IP address, web browser, mobile network information, pages viewed, time spent on pages, links clicked, and conversion information.  This information may be used by Rakuten Ready and others to, among other things, analyze and track data, determine the popularity of certain content, deliver advertising and content targeted to your interests on our Site or Services and other websites, and better understand your online activity.  For more information about interest-based ads, or to opt out of having your web browsing information used for behavioral advertising purposes, please visit www.aboutads.info/choices.

  1. Your California Privacy Rights

You have the right to privacy in line with the local laws that applies to you. For example, consumers residing in California are afforded certain additional rights with respect to their personal information under the California Consumer Privacy Act or (“CCPA”) (California Civil Code Section 1798.100 et seq.) and the “Shine the Light” Law (California Civil Code Section 1798.83).  If you are a California resident, this section applies to you.

A. Disclosures Related to the Collection, Use, Disclosure, and Sale of Personal Information

The following tables summarizes our personal information collection, use, and sharing practices in the preceding 12 months since we last updated this Privacy Policy on January 1, 2020.

<Site visitors or Clients>

Category of Personal InformationSources of Personal InformationWhy We Collect Personal Information?Who We Share Personal Information With?Did We Disclose the Personal Information for a Business or Commercial Purpose?Did We Sell the Personal Information?
Identifiers, e.g., email address, account information, name, or phone numberThe sources stated in Section 2, including:

• You

• Your mobile devices and computers used to access the Services

• Information received from our subsidiaries and affiliates, if you choose to connect your Rakuten ID account with another Rakuten service

The purposes stated in Section 3, including:

• Providing our Site and Services

•Communicating with you

• Providing customer service

• Improving the Site and Services

• Research, development and analytics

• Providing analytic services and for other strategic purposes

 

The entities stated in Section 4, including:

• Our subsidiaries and affiliates, if you choose to connect your Rakuten ID with another Rakuten service

• Vendors, and service providers, and third parties that perform services for us

 

YesNo
Commercial information such as records of services obtained or considered, or other consuming histories or tendencies.The sources stated in Section 2, including:

• You

 

The purposes stated in Section 3, including:

• Providing our Site and Services

•Communicating with you

• Providing customer service

• Improving the Site and Services

• Research, development and analytics

• Providing analytic services and for other strategic purposes

 

The entities stated in Section 4, including:

• Vendors, and service providers, and third parties that perform services for us

• Our subsidiaries and affiliates, if you choose to connect your Rakuten ID account with another Rakuten service.

YesNo
Internet or other electronic network activity information, including browsing history, search history and information on a consumer’s interaction with a website.The sources stated in Section 2, including:

• Your mobile devices and computers used to access the Services

• Information received from our subsidiaries and affiliates, if you choose to connect your Rakuten ID account with another Rakuten service.

The purposes stated in Section 3, including:

• Providing our Site and Services

•Communicating with you

• Providing customer service

• Improving the Site and Services

• Research, development and analytics

• Providing analytic services and for other strategic purposes

 

The entities stated in Section 4, including:

• Our subsidiaries and affiliates, if you choose to connect Rakuten ID account with another Rakuten service.

• Vendors, and service providers, and third parties that perform services for us

 

YesYes
Inferences, including information about your preferences.The sources stated in Section 2, including:

• Your mobile devices and computers used to access the Services

•  Information received from our subsidiaries and affiliates, if you choose to connect your Rakuten ID account with another Rakuten service.

The purposes stated in Section 3, including:

• Providing our Site and Services

•Communicating with you

• Providing customer service

• Improving the Site and Services

• Research, development and analytics

• Providing analytic services and for other strategic purposes

 

The entities stated in Section 4, including:

• Our subsidiaries and affiliates, if you choose to connect your Rakuten ID account with another Rakuten service.

• Vendors, and service providers, and third parties that perform services for us

 

YesYes

<End Users>

Category of Personal InformationSources of Personal InformationWhy We Collect Personal Information?Who We Share Personal Information With?Did We Disclose the Personal Information for a Business or Commercial Purpose?Did We Sell the Personal Information?
Identifiers, such as customer ID or account information on websites.The sources stated in Section 2, including:

• Our Clients

The purposes stated in Section 3, including:

• Providing the Service

• Improving the Service

• Research, development and analytics

• Other purposes as instructed by our Clients

The entities stated in Section 4, including:

• Vendors, and service providers, and third parties that perform services for us

 

YesNo
Commercial information such as your order details.The sources stated in Section 2, including:

• Our Clients

The purposes stated in Section 3, including:

• Providing the Service

• Improving the Service

• Research, development and analytics

• Other purposes as instructed by our Clients

The entities stated in Section 4, including:

• Vendors, and service providers, and third parties that perform services for us

YesNo
Internet or other electronic network activity information, including browsing history, search history and information on a consumer’s interaction with a website, and geo-location information.The sources stated in Section 2, including:

• Our Clients

The purposes stated in Section 3, including:

• Providing the Service

• Improving the Service

• Research, development and analytics

• Other purposes as instructed by our Clients

The entities stated in Section 4, including:

• Vendors, and service providers, and third parties that perform services for us

 

YesNo
Inferences, including information about your preferences.The sources stated in Section 2, including:

• Our Clients

The purposes stated in Section 3, including:

• Providing the Service

• Providing customer service

• Improving the Site and Services

• Research, development and analytics

• Other purposes as instructed by our Clients

 

The entities stated in Section 4, including:

• Vendors, and service providers, and third parties that perform services for us

 

YesNo

 

B. Your Privacy-Related Rights

You have various privacy-related rights (“Rights”) to have control over your personal information. For example, below is the list of Rights that California residents have under the CCPA regarding their personal information.  This Section describes your Rights and how to exercise those Rights.

Right to Know and Access:  You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months.  Once we receive and confirm your verifiable consumer request (see Exercising Right to Know, Access, and Delete below), we will disclose to you:

  • The categories of personal information we collected about you
  • The categories of sources for the personal information we collected about you
  • Our business or commercial purpose for collecting or selling that personal information
  • The categories of third parties with whom we share that personal information
  • The specific pieces of personal information we collected about you (also called a data portability request)
  • If we sold or disclosed your personal information for a business purpose, two separate lists disclosing:
  • sales, identifying the personal information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Right to Request Deletion:  You have the right to request that we delete any personal information we have collected from you and retained, subject to certain exceptions.  Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

Right to Opt-Out of Sale of Personal Information:  We do not sell your information for money, but we and our business partners use tracking technologies to help us to understand our customers and visitors to the Site or users of our Services, to enhance your online experience, and to customize our offerings in ways that may be deemed a “sale” of personal information under the CCPA.  This includes working with third parties such as ad networks which collect personal information via tracking technologies to serve personalized advertisements on and off our Services, provide us with data collection, reporting, ad response measurement.  To the extent we or our partners use such technologies on the Site or our Services, we offer an opt-out as discussed below in Section 8(D) (Opt-Out of Sale of Your Personal Information).

We offer an opt-out from the use of cookies and other tracking technologies in connection with our Site, which may in some cases constitute the sale of your personal information under the CCPA or other privacy laws.  To opt-out of the use of cookies and similar technologies through our Site or Services, please click Do Not Sell My Info (https://rakutenready.com/do-not-sell-my-personal-information/).  This will cause information to cease to be added to any cookies or other tracking technologies that have been set on our Site or Services or block them entirely.  Please note that you will need to opt out again if you visit our Site from a different device or browser of if you clear your cookies.

Right to Non-Discrimination:  We will not discriminate against you for exercising any of your CCPA rights.  Unless permitted by the CCPA, we will not:

  • Deny you goods or services.
  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
  • Provide you a different level or quality of goods or services.
  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

C. How to Exercise Your Right to Know, Access, and Request Deletion

To exercise your right to know, access, or delete as described above, you may submit a request to us by either:

  • Calling us at [(+1) 888 744 6030].
  • Completing the webform

You may only make a request to know or access twice within a 12-month period.

Your request must be verifiable.  For us to verify your identity, we will match two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification.  If your request is to know or access specific pieces of personal information, you will be required to sign a declaration under penalty of perjury that the you are the consumer whose personal information is the subject of the request.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

D. Authorized Agent

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.  We may require the agent to provide a written permission from you to submit a request on your behalf and to verify their identity, or demonstrate that he or she has power of attorney in connection with a request to know, access or delete.

E. Shine the Light

California law permits residents of California to request certain details about how their information is shared with third parties for direct marketing purposes.  We do not share your information with third parties for their direct marketing purposes.

F. California Do Not Track Disclosure

California Business & Professions Code Section 22575(b) (as amended effective January 1, 2014) provides that California residents are entitled to know how Rakuten Ready responds to “Do Not Track” browser settings.  Rakuten Ready does not currently take actions to respond to Do Not Track signals because a uniform technological standard has not yet been developed.  We continue to review new technologies and may adopt a standard once one is created.

  1. Your Choices

A. Cookies

Most web browsers are set to accept cookies by default.  If you prefer, you can usually choose to set your browser to remove or reject browser cookies.  Please note that if you choose to remove or reject cookies, this could affect the availability and functionality of the Site or Services.

B. Location Information

Clients: When you first launch our Connect Pick & Pack App that collects precise location information, you will be asked to consent to the App’s collection of this information.  If you initially consent to our collection of this location information, you can subsequently stop the collection of this information at any time by changing the preferences on your mobile device.  If you do so, our App, or certain features thereof, may no longer function properly.  You may also stop our collection of this location information by following the standard uninstall process to remove the App from your device.

End Users: For information on how to turn off location tracking through the websites or mobile applications of our Clients, we encourage you to read the Client’s privacy statement.

C. Mobile Push/Notification Alerts

Clients: With your consent, we may send promotional and non-promotional push notifications or alerts to your mobile device.  You can deactivate these messages at any time by changing the notification settings on your mobile device.

End Users: For information on how to turn off location tracking through the websites or mobile applications of our Clients, we encourage you to read the Client’s privacy statement.

D. Communications with Rakuten Ready

If you no longer wish to receive emails or text messages you may click on the hyperlink titled “Unsubscribe” at the bottom of any marketing related email sent to you by Rakuten Ready, and then follow the directions to unsubscribe from email.  Please note that if you opt out of receiving promotional communications from us, we may still send you transactional communications, including emails about your use of the Site or our Services.

  1. Retention

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

  1. Information Security

We have implemented technical and organizational measures to provide a level of security appropriate to the risk to the Personal Information that we process. These measures are aimed at preserving the ongoing integrity and protecting the confidentiality of users’ Personal Information. We evaluate these measures on a regular basis to confirm that it continues to maintain and apply an appropriate level of security.

  1. Changes to the Privacy Policy

We may change this Privacy Policy from time to time.  If we make changes, we will notify you by revising the date at the top of the policy and, in some cases, we may provide you with additional notice (such as adding a statement to our website homepage or sending you a notification).  We encourage you to review the Privacy Policy whenever you access the Site or Services or otherwise interact with us to stay informed about our information practices and the choices available to you.

  1. Contact Us

If you have any questions about this Privacy Policy, please contact us at:
Curbside, Inc. d/b/a Rakuten Ready
email: privacy@rakutenready.com
address: 800 Concar Drive, Suite 175, San Mateo, California, 94402, U.S.A
Tel: (+1) 888 744 6030