Rakuten Insight Global, Inc., incorporated in Japan with its head office at 1-14-1 Tamagawa, Setagaya-ku, Tokyo 158-0094 and its affiliates worldwide ("Rakuten Insight" or "we") provide various companies and organizations ("Clients") with consumer awareness information and opinions regarding services and products, which are gathered from market research surveys conducted and coordinated by Rakuten Insight ("Surveys").
Such information from Surveys, reflecting the past and present, will enable Clients with Rakuten Insight to gain insight into and make good decisions about the future. We believe that each of your contributions to the Surveys from each perspective will empower society as well as Clients. This is why Rakuten Insight seeks to gather various opinions and feelings of different persons with different standpoints. Variety of opinions and feelings is the key value we deliver to society.
Throughout the operation of our business, Rakuten Insight understands and respects the privacy and private life of all users (including members of Rakuten Insight as well as visitors of Rakuten Insight websites and collectively "Users" or "you"). In conducting the above business, with respect to privacy and protection of personal data, Rakuten Insight will comply with any applicable laws concerning the handling of personal data and also the ICC/ESOMAR Code, which is the code of conduct for the marketing research industry.
Personal data means any information about you or your household, as well as a combination of pieces of information that could reasonably allow you or your household to be identified ("Personal Data"). Some categories of Personal Data will reveal the User’s information as to indicate the physical or mental health or condition, race, political opinions, religious beliefs or other beliefs of a similar nature, the commission or alleged commission by the User of any offence, and such personal data ("Sensitive Personal Data") can be used in a discriminating way and therefore must be highly protected.
By creating an account, the User hereby acknowledges and agrees to the processing of the User’s Personal Data in accordance with this Policy and where applicable, the terms of the Member Agreement.
- The types of Personal Data Rakuten Insight collects include:
- "Basic profile", which consists of User’s contact details (such as e-mail address, name, date of birth, gender, physical address, phone number, and if necessary payment information) and basic attribute information suggesting your lifestyle or relating to your life stage (such as relates to your family, education, income, employment, and, only when absolutely necessary, race);
- "Detailed Profile", which contains more detailed information about your lifestyle and life stage than Basic Profile;
- "Survey Data" of the answers you made in a Survey;
- Records and history of your usage of Rakuten Insight services, including which surveys you answered and when, how many points have been received and consumed;
- Inquiry and opinions to Rakuten Insight; and
- Cookie data (see the following section for details.) and server logs which Rakuten Insight automatically collects when its services are accessed.
- Rakuten Insight may collect directly from a User Sensitive Personal Data, especially racial information in Basic Profile in some countries (e.g. Singapore, Malaysia, India, and U.S.), and health information in Detailed Profile and Surveys, where permitted under applicable local laws and if the collection is absolutely necessary. In that case, Rakuten Insight will obtain explicit consent from the User before collecting Sensitive Personal Data unless otherwise permitted by local laws for the processing of such Sensitive Personal Data.
- Rakuten Insight does not collect Personal Data of persons less than 16 years of age, as Rakuten Insight’s services are not directed at persons less than 16 years of age.
Overview on data collected:
|Category||Relevant provisions in Section "What Types of Personal Data Rakuten Insight Collects"||Data source||Examples of information|
|Identifiers||1-(1) "Basic Profile"|
1-(2) "Detailed Profile"
|Directly from you||Your user ID, password, name, email address, telephone numbers, address, date of birth, zip code, online identifiers, IP address|
|Protected characteristics||1-(1) "Basic Profile"|
1-(2) "Detailed Profile"
|Directly from you||Gender, age, sex, race, marriage|
|Financial, medical, or health information||1-(1) "Basic Profile"|
1-(2) "Detailed Profile"
|Directly from you||e-money related account information, income information, health status|
|Internet or other electronic network activity information||1-(4) "Records and history of your usage of Rakuten Insight services"|
1-(6) "Cookie data and server logs"
|- Directly from you|
- Automatically through the use of Cookie Technologies
|Page viewing, Information derived from Cookie Technologies such as URLs viewed, time stamp of time viewed, information related to products and services displayed and searched|
|We, just as a service provider, may collect and process more kinds of personal information other than those listed above by sending Surveys on behalf of Clients. In addition, we may also collect personal information you provide in your communications to us, such as when you contact us with a question or request.|
|Employment Information||1-(1) "Basic Profile"|
1-(2) "Detailed Profile"
|Directly from you||Employment status, job description, job title, industry you belong to|
|Education Information||1-(1) "Basic Profile"||Directly from you||Academic background|
We may collect all the categories of personal information for the purposes in Section "How Rakuten Insight uses Personal Data".
- Rakuten Insight and, in case (4), Clients will use Personal Data for the following purposes:
- Create and maintain your membership, using your Basic Profile;
- Screen and send appropriate surveys to candidates, using your Basic Profile;
- Further screen and choose such candidates, using your Detailed Profile;
- Conduct a survey, which may be initiated by Rakuten Insight and/or Clients, collect and analyze your answers in a survey to find insights;
- Provide you with rewards Rakuten Insight offers, using your Basic Profile and Records;
- Respond to your inquiries, when Rakuten Insight receives them;
- Develop and improve the services of Rakuten Insight, using various Personal Data we obtain; and
- Prevent fraud, malicious activities, and any losses associated with such, using various Personal Data we have.
- The Personal Data contained in a Survey, including Basic Profile and Detailed Profile, will be processed and used after aggregation or pseudonimization by deleting at least such direct identifiers as names, addresses, e-mail addresses, etc., so that Rakuten Insight and the Client will not be able to and will not link any other data source and reach Users directly through that processed information. However, when such direct identifiers or contact details are necessary, Rakuten Insight and/or Client may collect and use in that specific Survey with appropriate communication with you including notification to draw the User’s special attention beforehand.
- In addition to paragraph 1 and 2 of this section, we also notify you of our legal basis for the processing (the legitimate reason required in the General Data Protection Regulation) as follows:
- Our performance of a contract;
- Our and/or Client’s legitimate interests; and
- Your consent in some cases especially for the paragraph 1 (3) of this section.
If we ask for your consent to process your Personal Data, we will ensure that you receive all the necessary information about the processing and the relevant purpose before your consent and that you may withdraw your consent at any time.
- Our legitimate interests to process the Personal Data consist of our mission to conduct fair Surveys, in which we are to collect various and different opinions and feelings, and to get insight in the market and society.
- Because Rakuten Insight and our Clients are different and independent businesses, Rakuten Insight cannot be held responsible for any Client’s misuses, leakages, and other data breaches beyond reasonable controls of Rakuten Insight. Rakuten Insight strongly recommends that Users carefully read through privacy statements and policies of the Client and acknowledge the controller(s), the purposes of use of your Personal Data, and your rights before answering a Survey.
- Your provision of Personal Data to Rakuten Insight is voluntary; however, in the event that you choose not to provide Rakuten Insight with certain Personal Data necessary for our performance of the contract and our legitimate interests, you will not be able to gain access to our services and/or enjoy the benefits of having your membership.
- Your Basic Profile and Detailed Profile can be edited, corrected, and for Detailed Profile, deleted at any time when you have access to your account on My Page. Rakuten Insight will always respect your choice regarding what kinds of Personal Data you would like us to base our candidate screening process on; However, the more information we have about you, the greater number of opportunities you will receive to respond to Surveys and receive rewards from Rakuten Insight.
- If requested in the way described in "Inquiries/Complaints", Rakuten Insight will provide you with the registered data of your Basic Profile and Detailed Profile in a portable format.
- Additionally, you may exercise your rights to make requests in writing and in the manner described in the "Inquiries/Complaints" section, and Rakuten Insight will respond to your requests such as the following:
- Requesting disclosure and receipt of a copy of your Personal Data;
- Notification of the purposes of Rakuten Insight’s use of your Personal Data;
- Requesting to change, stop using, and delete your Personal Data which is incorrect or misused;
- Objecting to processing of Personal Data; and
- any other request which the applicable laws grant to you the right to make.
- Notwithstanding the provisions hereof, Rakuten Insight may not be able respond to your requests related to the personal data processed in accordance with paragraph 2 of the preceding section, because such data will not be able to identify you afterwards.
- Rakuten Insight will retain your Personal Data for as long as is necessary for the purposes for which it is collected and further processed.
- More specifically, the Basic Profile and any other necessary Personal Data for the performance of the contract will be retained for 10 years after your account has been closed. The retention period of the Detailed Profile will be up to your choice. Survey Data will be required for as long as necessary for our services, including for our Clients, after which it will be deleted without undue delay.
- Personal Data of those who have made a preliminary registration but not completed their registration of the Member Agreement will be deleted after 6 months, and Rakuten Insight will cease using the account of any User who has been inactive for 1 year until the account is reactivated by logging into the service again.
- Clients; 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 sale or 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.
- Affiliates; we may share your personal information with our affiliates and group companies that purchases, or to which we transfer, all or substantially all of our assets and business. Should such a sale or 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. In addition, in cases where it is necessary to prevent and mitigate fraudulent or illegal activities or to protect life, body or property, we may share your personal information with our affiliates and group companies.
- Service providers and business partners; we may share your personal information with our service providers and business partners, including but not limited to, internet service providers, data analytics providers, operating systems and platforms, that perform marketing services and other business operations for us. For example, we may partner with other companies to process secure payments, fulfil orders, send newsletters and marketing emails, support email and messaging services;
- Law enforcement agencies, courts, regulators and government authorities; we may share your personal information with these parties where we believe this is necessary to comply with a legal or regulatory obligation, or otherwise to protect our rights or the rights of any third party;
- We are committed to handling your Personal Data 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 Personal Data, to maintain the accuracy of such information and, when necessary, to ensure its proper destruction. When collecting or transferring your Personal Data, 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.
- Because of the global nature of Rakuten Insight’s business, the Personal Data that we collect may be transferred to countries whose data protection laws are not as comprehensive as those in which Users are based. When Rakuten Insight transfers Personal Data overseas, we put in place appropriate safeguards to ensure or to make any third parties ensure protection of your privacy and security of your Personal Data as required under applicable laws. Appropriate data protection contractual clauses and certified Privacy Shield can be such appropriate safeguards to legitimize the international transfers of Personal Data.
- As part of Rakuten group, Rakuten Insight protects your Personal Data around the world through Rakuten’s global privacy standard. In particular, Rakuten has implemented Binding Corporate Rules, a recognized European data protection standard. Binding Corporate Rules (the "BCRs") provide for an appropriate level of protection for global data processing within us. 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
Contact us through the online inquiry form (https://us.m.aipsurveys.com/inquiry) or send mail to our registered address.
The User may also 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).
The special provisions are intending to supplement the main body of the Policy for California residents. Please be aware of the contents before you read and understand the below.
Information We "Sell"
California law requires that we describe certain disclosures of personal information that involve monetary or other valuable consideration. California law treats such disclosures as "sales" even if no money is exchanged. We might "sell" some of your personal information listed in section "What Types of Personal Data Rakuten Insight Collects" for behavior analyses and trend analyses based on your registered attribute data, which is specific to market research business.
However, in the situation where you intentionally direct us to do so, we have a business purpose to do so, or any other circumstances permitted by California law exist, such disclosures may not be considered as a "sale."
We do not exchange your personal information with money unless you give us an affirmative authorization.
We do not "sell" your personal information of minors under 16 years of age without affirmative authorization.
When we disclose your personal information in accordance with the following provisions, we may "sell" your personal information:
- "How Rakuten Insight uses Personal Data" in this Policy;
- "Disclosing Personal Data to Third Parties" in this Policy; and
All the categories of your personal information listed in section "What Types of Personal Data Rakuten Insight Collects" may be sold with the following parties to achieve business purposes:
- Affiliates; and
Your Rights Over Your Personal Information
You may have rights in relation to your personal information under California law. Below is a general description of the rights you may hold. In the event you would like to exercise one of your rights, please contact us in accordance with Section "Inquiries/Complaints" or send an email to "rig-DoNotSellMyPI@mail.rakuten.com". If you use an authorized agent to exercise your rights, please also provide us the written permission to do so. Please note that we may require additional information from you in order to honor your request, and we may decline your request as permitted under applicable law.
- Right to access personal information: By exercising this right, you can request access to the categories and specific pieces of your personal information we hold;
- Right to data portability: By exercising this right, you can receive your personal information, when provided electronically, in a readily-useable format;
- Right to deletion: By exercising this right, you can ask us to delete your personal information we have collected;
- Right to disclosure: By exercising this right, you can receive additional information regarding the sources from which we collect information, the purposes for which we collect and share your personal information, the information of yours we hold, and the categories of parties with whom we share your information;
- Right to opt-out of sales: By exercising this right, you can direct us to stop "selling" your personal information. You can exercise your right to opt-out of sales at the online inquiry form (https://us.m.aipsurveys.com/inquiry) or by sending an email to "rig-DoNotSellMyPI@mail.rakuten.com";
- Right to learn about certain disclosures: If you reside in California and have provided your personally identifiable information to us, you can request information once per calendar year about our disclosures of certain categories of your personally identifiable information to third parties for their direct marketing purposes. Such requests must be submitted to us at the online inquiry form (https://us.m.aipsurveys.com/inquiry);
- Right to be free from discrimination: You can freely exercise these rights without fear of being denied services. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your data; and
- Right to erasure: If you are under the age of 18, you can ask us to remove content or personal information you have posted to the Services at the online inquiry form (https://us.m.aipsurveys.com/inquiry). Please note that your request does not ensure complete or comprehensive remove of the content or information as, for example, some of your content may have been reposted by another user.
* GeoTrust Japan Inc. is an internet certification body, which has been adopted both in Japan and overseas.