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CCPA Compliance Options for Publishers

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What is the CCPA?

The California Consumer Privacy Act (CCPA) is intended to enhance privacy rights and consumer protection for residents of California in the United States. (We expect other states to follow with similar legislation in the future.) The CCPA provides consumers with the ability to opt-out, the right to ask advertisers to disclose what data they possess on the user, and the right to request deletion of that data.

Review the CCPA legislation background and text here.

Review a Wikipedia overview of the legislation here. 

Download a PDF version of the key information in this article.

Review CCPA Q&A with our general counsel

What does CCPA require?

Unlike the GDPR (General Data Protection Regulation), there is no opt-in notice required so 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

What do publishers need to do?

Publishers will need to make their own determination on whether CCPA applies in their situation. However, regardless of a publisher’s assessment of their status under CCPA, Rakuten Advertising has determined that it, (Rakuten Advertising), qualifies 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 that the publisher places our provided tracking links.

The Publisher Membership Agreement has been updated to include the CCPA requirements, and you will need to accept the new agreement to continue as a publisher in our network, or decline and delete your publisher account.

Beginning January 1, 2020, Rakuten Advertising will require that publishers implement a privacy rights link to a page (either Rakuten Advertising provided or Digital Advertising Alliance [DAA] provided) that provides the necessary disclosures and the opt-out. See the mock-up image of the privacy rights link and page below.

In addition, if a publisher has implemented Rakuten Advertising tracking pixels, we will require that the publisher also send signals indicating the consumer’s opt-out status consistent with the IAB Signals Framework.

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

Publisher Rollout and Enforcement

CCPA laws go into effect on January 1, 2020 with enforcement beginning July 1, 2020. Given this timeline, the Rakuten Advertising network quality team will begin auditing implementation in Q1 2020. Failure to meet compliance requirements may result in:

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

Publishers Have Three Options for CCPA Compliance

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.

Publishers must also collect an opt-out signal from the consumer and pass consent information to Rakuten Advertising using the consent parameter “cnst.” Instructions are available in the attached technical document, "Passing CCPA Opt-Out in Affiliate Links".

Mock-up of Privacy Rights Link and Page

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Option 2: CMP Integration

If you are already using a consent management platform (CMP) for GDPR, there may be integration opportunities with your existing tool, depending on your CMP. You can contact the publisher support team at uspubsupport@rakuten.com to determine if there are integration opportunities with your existing CMP tool.

The quick reference chart below may help you understand how your CMP tool handles CCPA requirements. 

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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 app 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.”

Mock-up of Privacy Rights Link and Page

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Custom Option: This is a Rakuten Advertising-provided option and has some flexibility to be adjusted to a publisher’s 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 app 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-policy/

Company 2

Link to privacy policy/rights

Company 3

Link to privacy policy/rights

As well as a link to our user rights / opt-out page: https://rakutenadvertising.com/legal-notices/subject-requests/ 

Download a PDF version of the key information in this article.

Please reach out to uspubsupport@rakuten.com with any additional questions. 

 

Still have more questions? Use the SUPPORT tab at the top of the page or this link to find the email or phone Customer Support contacts for your location.



Was this article helpful?
15 out of 16 found this helpful

Please leave us a comment below and let us know how we can make this article more helpful.

  • Avatar
    arip thofib

    likes

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    Tricia - Customer Education Specialist

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

  • Avatar
    Kenjiro Yagi

    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.

  • Avatar
    Samuel Robinson

    Do I need this on my Youtube channel?

  • Avatar
    Tricia - Customer Education Specialist

    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!

  • Avatar
    Tricia - Customer Education Specialist

    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!

  • Avatar
    Christina Williams

    Was there ever an answer about YouTube?

  • Avatar
    Sally Anne - Customer Experience Manager

    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.