CCPA Compliance Options

Introduction

The California Consumer Privacy Act (CCPA) is intended to enhance privacy rights and consumer protection for residents of California in the United States. It allows consumers to opt out of data collection and grants them the right to ask advertisers to disclose what data they possess on the user and the right to request deletion of that data.

For more information on CCPA, review the legislation background or a Wikipedia overview of the legislation.

CCPA Requirements

Unlike the General Data Protection Regulation (GDPR), there is no opt-in notice required. This means consent management platforms (CMPs) are not the prevailing solution for CCPA. The law requires that consumers from California have the right to:

  1. Opt out of the sales of their personal information.
  2. Access what information has been collected on them.
  3. Request to have their data deleted.

Best Practices

You need to make your own determination on whether CCPA applies in your situation. However, regardless of your assessment of your status under CCPA, Rakuten Advertising has determined that we, Rakuten Advertising, qualify as a business that collects information that may be sold to third parties. As such, Rakuten Advertising is required to provide explicit notice and an opportunity to opt out at, or before, the point of data collection.

This means that a California resident needs to be presented with explicit notice and an opportunity to opt out of Rakuten Advertising tracking on the page where you place our provided tracking links.

The Publisher Membership Agreement has been updated to include the CCPA requirements. You will need to accept the updated agreement to continue as a publisher in our network.

 Warning

If you decline the agreement, you will need to delete your publisher account.

Rakuten Advertising requires that you implement a privacy rights link to a page that provides the necessary disclosures and the opt-out. This page can be provided by Rakuten Advertising or by the Digital Advertising Alliance. See the mockup image of the privacy rights link and page in the options listed below.

 Note

You will be relieved of this obligation if you can demonstrate that you geo-block California-based traffic or otherwise suppress California-based traffic from Rakuten Advertising’s tracking processes.

Enforcement

Failure to meet compliance requirements may result in:

  • Suspension of payments for publishers with California user transactions.
  • Potential termination of publisher relationship.

Your Options

To ensure CCPA compliance, you may choose to install or use one of the following options; click the + for more information:

Option 1: Affiliate Link Opt-Out Signals (Preferred Option)

Include a link to your company privacy policy on each page of your website. Your company privacy policy must reference Rakuten Advertising’s data collection as well as a link to the Rakuten Advertising privacy policy.

Sample language:

We partner with Rakuten Advertising, who may collect personal information when you interact with our site. The collection and use of this information is subject to the privacy policy located here.

You must also collect an opt-out signal from the consumer and pass consent information to Rakuten Advertising using the consent parameter cnst.

Mockup of privacy rights link and page:

mockup of link to privacy page.png

Option 2: CMP Integration
If you already use a CMP for GDPR, there may be integration opportunities with your existing tool. This depends on your CMP. Contact Customer Support to determine if there are integration opportunities with your existing CMP tool.
Option 3: Rakuten Advertising Disclosure and Opt-Out Link

Include a Your Privacy Rights link on each page of your website, which directs to a page that provides the following disclosure:

The below companies may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and application usage and how you interact with our properties and ads for a variety of purpose, such as personalization of offers or advertisements, analytics about how you engage with websites or ads, and other commercial purposes. For more information about the collection, use and sale of your personal data and your rights, please use the below links.

Mockup of privacy rights link and page:

mockup of link to privacy page.png

Option 4: Custom Option

This is an option we provide that has some flexibility to be adjusted to your preferences. You can use or adapt the text and table format below on your website:

The below companies may collect personal information when you interact with our digital property, including IP addresses, digital identifiers, information about your web browsing and application usage and how you interact with our properties and ads for a variety of purposes, such as: personalization of offers or advertisements; analytics about how you engage with websites or ads; and other commercial purposes. For more information about the collection, use, and sale of your personal information and your rights, please use the below links.

Company

Link to privacy policy/rights

Rakuten Advertising

https://rakutenadvertising.com/legal-notices/services-privacy-rights-request-form/

Company 2

Link to privacy policy/rights

Company 3

Link to privacy policy/rights

Next Steps

View instructions for handling delete requests.

Contact your Publisher Manager or Customer Support with any additional questions.

Was this article helpful? Leave feedback below.
19 out of 21 found this helpful

Comments

8 comments
  • likes

    0
  • Thanks for the like, Arip, we're glad the content is helpful!

    0
  • I'm a Rakuten/Linkshare affiliate member. I have added the "Privacy" link. Is there somewhere in our account info where we let you guys know where the privacy link is or are you guys going to just do a CTRL F on the page.

    0
  • Do I need this on my Youtube channel?

    0
  • Hi Kenjiro, I am checking with our compliance team to find the answer to your question. I'll update once I have that. Thank you!

    0
  • Hi Samuel, I am checking with our compliance team to find the answer to your question. I'll update once I have that. Thank you!

    0
  • Was there ever an answer about YouTube?

    0
  • Hi Samuel, Kenjiro and Christina, apologies for the delay in responding to your questions. For CCPA questions, please review the public information and documentation available and linked in the above article, discuss your individual situation with your own legal advisors, and then if you still have specific questions, you can contact our Customer Support team so they can try to assist you personally. You can reach them on the Support chat button on the lower right of this page. Hope that is helpful.

    0

Please sign in to leave a comment.