RAKUTEN KOBO INC.

PRIVACY POLICY

Last updated: December 18, 2019

Rakuten Kobo Inc. and its subsidiaries are part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company Rakuten, Inc., based in Tokyo, Japan (hereafter, “Kobo”, “we” “our” and/or “us”). More information about Rakuten is available at http://global.rakuten.com/corp/about/company.

We operate websites, mobile applications, a digital reading platform that enables customers to acquire and read or listen to written works (through ebooks, audiobooks or podcasts) using a variety of electronic devices, software applications , and other services (collectively, the "Kobo Services") and the account you use in association with the Kobo Services (the "Kobo Account").

This Privacy Policy (“Policy”) describes how we collect, use, and disclose Personal Information (as defined below) about you when you use your Kobo Account or any Kobo Services that link to this Policy, including Kobo Writing Life, the author self-publishing service.

Collection of personal information

"Personal Information" is any information or a combination of pieces of information that can reasonably permit you to be identified, or that can reasonably be linked to you. Information that is aggregated or de-identified so it is no longer reasonably associated with an identified or identifiable natural person is not Personal Information and may be used for any business purpose.

We collect Personal Information about you from a variety of sources. We collect information from you directly (e.g., when you contact us or create an account with us), automatically, (e.g., data collected via cookies and similar technologies when you use the Kobo Services), and from other sources, including commercially available sources, such as public databases (where permitted by law).

For example, we collect, process and use your Personal Information when you:

  • register for a Kobo Account or log into an existing account;
  • interact with the Kobo Services;
  • order products or content from us;
  • use the Kobo Services to access electronic content; or
  • contact us for customer care.
Registration and account information

When you create an account, you voluntarily provide us with certain Personal Information, such as your email address, and password.

Profile information

You may also complete an optional registration profile, which may include your name, gender, birth date, contact phone number and any additional optional information you choose to provide.

Payment information

We collect your payment information when you purchase e-content or sign up for subscription-based services.

Communications

We may also collect information you provide in your communications to us, such as when you respond to polls or surveys, write a review, or contact us with a question, comment, or request. You may choose to provide us with certain information when you upload e-content to the Services as a member of Kobo Writing Life, fill out a form, submit a request to our customer care team, respond to a survey, submit ratings and reviews or participate in promotions or contests.

Information we collect from your use of the Kobo Services.

Usage information

We collect Personal Information when you use or otherwise interact with the Kobo Services. For example, we collect information about how you use the Kobo Services, such as pages you view, the rate at which you consume e-content (how often and for how long), genres, authors or subject matter you prefer and searches you make or share, the ebooks or audiobooks you have liked, comments you have left and also websites you have viewed through links in the comments. We collect this information across the various devices, applications, and other tools via which you access and interact with the Kobo Services.

Device information

We collect certain technical information about your device - such as your IP address, device type, device model and manufacturer, device identifier and your device operating system type and version.

Transactional information

We automatically collect certain information about your transactions on the Services such as amount charged, date and time, and use of promotions.

Information we collect from other sources.

We may receive additional information about you from third party service providers and/or retail partners, such as demographic data, your activities on and off the Kobo Services through partnerships and our third-party advertisers. We may supplement the information we collect with information received from data suppliers and commercially available resources (e.g. demographic information and additional contact information).

Additionally, we may draw inferences about your preferences and characteristics from any of your Personal Information that we collect to develop a record of your potential preferences, characteristics, predispositions, behaviour, attitudes, intelligence, abilities, and aptitudes. We may automatically process your personal information to make decisions or conduct 'profiling' about you. This involves using software that is able to evaluate your personal aspects and predict risks or outcomes. We may carry out this automatic processing, for example, for the purposes of customer segmentation and pricing, and may involve decisions about you that relate to, for example, your browsing preferences. We may also make automated decisions about you based on your personal information in order to select personalized offers, discounts or recommendations to send you based on your shopping history, browsing history, preferences, or reviews. These types of decisions will not have legal or similar effects for you, but you can still contact us for further information.

Registration through third parties

We provide you with the option to sign in to the Kobo Services using an account you already have with another provider (such as: Facebook, Google or Rakuten ID).

Categories of information we collect.

The information we collect via the methods described above includes:

  • Identifiers: For example, your name, email address, postal address, username, IP address, and online identifiers.
  • Demographics: Such as your age and gender.
  • Transactional information: Such as the products you purchase, access, or review; subscriptions; payment methods; and discount programs.
  • Online activities: For example, browsing and search history; interactions with web or other digital content; whether you open, interact with, or forward our electronic communications; and how you interact with advertisements offered by us or third parties.
  • Billing location information: Based on the information you provide or inferred from your IP address, to ensure we have the right to sell you the books you wish to purchase .
  • Inferences: As noted above, we may use the information we collect to identify your potential preferences, characteristics, psychological trends, predispositions, behaviours, attitudes, intelligence, abilities, and aptitudes.

Children under 16 years of age.

Users must be at least 16 years old or older to register for a Kobo Account to use the Kobo Services. Kobo does not knowingly collect any Personal Information from children under the age of 16. If a parent or guardian believes that Kobo has in its database the Personal Information of a child under the age of 16, please contact us at privacy@kobo.com and we will use our best efforts to remove the information from our records.

How and why we use the information we collect.

We may use your Personal Information for the following purposes:

  • Identification and authentication: We use your identifiers to verify your identity when you access your account and to ensure the security of your Personal Information;
  • Operating the Kobo Services: We process your Personal Information to provide you with access to the Kobo Services and to process your transactions, as you have requested. We use Personal Information, such as your location to identify whether content is available in your region. And we use information to provide and improve the Kobo Services, identify and troubleshoot errors, and analyze the Kobo Services;
  • Managing your account: We use Personal Information to create, maintain, and monitor your account.
  • Improving the Kobo Services: We analyze information about how you use the Kobo Services to provide an improved experience for all users;
  • Communicating with you: We may use your Personal Information to communicate with you, for example if we are providing information about changes to the terms and conditions, to issue security alerts or reminders, or if you contact us with questions;
  • Marketing: We may use your Personal Information to learn about the interests of our customers, to build a profile about you and place you into particular marketing segments, and to identify the devices you use to access digital content and the Kobo Services in order to understand your preferences better and to appropriately personalize the marketing messages we send to you. We may also use your identifiers to send you marketing communications about the Kobo Services and other products or services that may be of interest to you, subject to any consent that may be required under applicable law. This may include information regarding services and offers associated with (i) our affiliates (within the Rakuten Group) and (ii) our retail partners (collectively, “third party business partners”). We will not require you to consent to receive marketing as a condition of receiving the Kobo Services, and you may withdraw any consent you have provided at any time;
  • Personalized Advertising and Re-marketing: Kobo uses Personal Information to: (1) serve you with targeted advertising that may interest you based on your device activity and inferred interests (2) measure the effectiveness of targeted advertising, and (3) understand the usage of our Services. Kobo’s third party advertisers may use Personal Information (such as cookies, platform device identifiers, software agents, and IP address), to deliver targeted advertisements, measure their effectiveness, and to understand the usage and visitation of our Services and the other applications and websites tracked by these companies. We do not have access to or control over cookies, platform device identifiers, software agents, or other technologies that they may use. You can manage your consent to how such data is collected and how Kobo shares Personal Information for re-marketing or re-targeting advertising using the Privacy Controls and Preference Centre here.;
  • Managing contests: From time to time, Kobo may invite you to enter various contests or promotions. If you choose to participate in a contest or promotion, your Personal Information may be used to administer the contest, as specified in applicable terms.
  • Exercising our rights: We may use your Personal Information to exercise or protect our legal rights where it is necessary to do so, for example to detect, prevent and respond to fraud claims, intellectual property infringement claims or violations of law or our terms and conditions, to respond to requests from law enforcement or other third parties, and to secure the Kobo Services;
  • Complying with our obligations: We may process your Personal Information to comply with legal or regulatory requirements, where this is required by law, such as in response to court orders or to comply with privacy or financial regulations;
  • Customizing your experience: When you use the Kobo Services, we may use your Personal Information to improve your experience, such as by providing interactive or personalized elements and providing you with content based on your interests; and
  • Protecting against harm: We may use Personal Information as necessary to protect the rights and safety of us, you, or others.

In addition, we may link together your activity across the Kobo Services and the devices you use to access them along with the accounts you may use across Rakuten services. We may associate your activities and accounts under a single Rakuten ID. And we combine information we have about you with information we obtain from business or retail partners or other companies, such as your activities on other sites and apps.

How we may share the information we collect with others.

We may disclose certain Personal Information with service providers, business partners or affiliates, or by selling it to third parties where such sales are compliant with applicable law. As used in this Policy, the “sale” of Personal Information refers to sharing your Personal Information with a third party for monetary or other valuable consideration, subject to any exceptions under applicable law.

In association with our personalized advertising and re-marketing activities, we may share Personal Information with advertisers, digital advertising companies, and other entities that support digital advertising activities. These third parties may have rights to use the information noted below for their own purposes, which is why we treat such a disclosure as a sale, even though no money changes hands.

If you would like to no longer have your personal information shared in this way, please visit our Privacy Preference Center, located at https://www.kobo.com/privacy

  • Identifiers: For example, your name, email address, postal address, username, IP address, and online identifiers.
  • Demographics: Such as your age and gender.
  • Online activities: For example, interactions with web or other digital content; whether you open, interact with, or forward our electronic communications; and how you interact with advertisements offered by us or third parties.
Retailer partners

We may share your Personal Information with our retailer partner(s) in the country where you live. Our retailer partners on the list are third party business partners that have integrated their online catalogues and purchase paths with the Kobo Platform. Here is a list of our retail partners, as at the update date first written above:

Partner: Bol.Com BV
Country: Netherlands
Contact URL: https://www.bol.com/nl/
Partner: FNAC-Darty
Country: France
Contact URL: http://www.fnacdarty.com
Partner: Grandes Almacenes FNAC España S.A.U.
Country: Spain
Contact URL: https://www.fnac.es/
Partner: FNAC PORTUGAL - Actividades Culturais e Distribuição de Livros, Discos, Multimédia e Produtos Técnicos Lda
Country: Portugal
Contact URL: https://www.fnac.pt/
Partner: Doğan Müzik Kitap Mağazacilik Pazarlama A.Ş.
Country: Turkey
Contact URL: http://turkyaybir.org.tr/
Partner: Librerie Feltrinelli Srl
Country: Italy
Contact URL: https://www.lafeltrinelli.it/
Partner: Walmart Inc.
Country: United States
Contact URL: https://www.walmart.com/cp/books
Partner: Booktopia Pty Ltd.
Country: Australia
Contact URL: https://www.booktopia.com.au/
Partner: Livraria Cultura S.A.,
Country: Brazil
Contact URL: https://www.livrariacultura.com.br/

For any additional or other terms disclosed to you in association with a particular country’s retail partner, please follow the relevant links on the list and review Annex 1 to this policy, below. These partners maintain a separate billing channel for users in the country in which they operate. In each case, they have entered joint-controllership agreements with Kobo to maintain a level of data handling and security standards that complies with applicable law.

Personal Information we Disclose

To support our business purposes, we disclose your Personal Information to service providers and business partners who are data processors. We disclose your Personal Information with our service providers that perform business services and/or operations on our behalf or under our instructions.

For example, we may partner with other companies to process secure payments, provide authentication services, optimize Kobo Services, fulfill orders, perform analytics, send our newsletters and marketing emails, support email and messaging services, administer our promotions, provide targeted advertising services as a processor to Kobo, and provide sweepstakes, contests, and surveys. Some of our service providers or business partners may engage their own service providers or business partners to further assist us. Unless otherwise specified, we require these companies to use Personal Information only for the purposes described in this Policy.

We may share your account credentials and other related Personal Information (such as, username, email address, encrypted password, first and last name) with the Rakuten Group companies. The Rakuten Group aims to provide you with a unique service experience through the “Rakuten ID” or Kobo “Global ID”. Rakuten ID is a unified program that allows you to easily connect to other Rakuten services by a single log-in function, share your account information or join a loyalty program with the Rakuten group companies jointly participating in the Rakuten ID program https://corp.rakuten.co.jp/privacy/en/rakuten-id.html . Your data will only be shared if you chose to connect to another Rakuten ID service. By connecting to another Rakuten ID service, you direct the Rakuten ID services to share your data for the purposes explained in our joint privacy policy here: https://corp.rakuten.co.jp/privacy/en/rakuten-id.html. We share your account credentials and profile information (address and date of birth, where provided) with the Rakuten ID services. This service is jointly provided by the Rakuten ID Services as directed by you, if you sign up with another Rakuten ID Service.

Law enforcement agencies, courts, regulators and government authorities

We may share the information we collect, including Personal Information, with law enforcement or to otherwise comply with any statutory or regulatory requirement or the order of a court or other public authority agency, regulator, government authority or other third party 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.

In the context of a transaction

We may share the information we collect, including 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 Privacy Policy.

Legal basis for using your Personal Information.

Data Transfer

We may transfer your Personal Information to Rakuten Group entities and service providers located outside of your home country, including to countries outside the EEA for the purposes described in the subsections above (“How we may share the information we collect”). Your Personal Information may need to be processed in countries where data protection and privacy regulations may not offer the same level of protection as in your home country. Please note that we may be transferring your Personal Information to the United States of America, Canada, Mexico, France, the Netherlands, Ireland and Japan as well as other countries where we have active retailer partners and third-party business partners or service providers who may be data processors. In such cases, we will require the recipient to provide appropriate protection for the Personal Information disclosed to it, in compliance with applicable data protection laws.

We take great care in protecting your Personal Information and have put in place mechanisms to protect it when it is transferred internationally, consistent with applicable law.

As part of the Rakuten Group, Kobo relies on the Rakuten Binding Corporate Rules to legitimize international data transfers within the group. The Rakuten Binding Corporate Rules have been approved by the Data Protection Authority of Luxembourg acting as the lead authority and can be found at https://corp.rakuten.co.jp/privacy/en/bcr.html.

Additionally, for the transfers to Canada we rely on the Commission Decision 2002/2/EC granting adequate protection for personal data in Canada pursuant to the Personal Information Protection and Electronic Documents Act, S.C. 2000, c.5., as amended (“PIPEDA”), and Canada’s anti-spam legislation, amending the Canadian Radio-television and Telecommunications Commission Act, the Competition Act, PIPEDA and the Telecommunications Act (S.C. 2010, c. 23), as well as the Digital Privacy Act (S.C. 2015, c. 32) and certain provincial legislation deemed substantially similar to PIPEDA.

Legal basis for processing your Personal Information if you are in the EEA

If you use the Kobo Services while in the EEA, we must have a legal basis to process your Personal Information for the purposes above, including data received from social media platforms, data received from other sources used for statistics or data shared with third party advertisers. There are different legal bases that we rely on to use your Personal Information, namely:

  • Performance of a contract – The use of your Personal Information may be necessary to send you Emails and messages concerning the administration and operation of your Kobo Account and/or the Kobo Services.
  • Consent – We will rely on your consent to use (i) technical information; and (ii) your Personal Information for marketing and advertising purposes. You may withdraw your consent at any time by following an unsubscribe link in any marketing communication you receive from us.
  • Legitimate interests – We may use your Personal Information for our legitimate interests to improve our products and services and the content available on the Kobo Platform. These improvements are dependent on analyzing (for example) how you use the Services, such as pages you view, the rate at which you consume e-content (how often, and for how long), genres, authors or subject matter you prefer and searches you make or share, the ebooks or audiobooks you have liked, comments you have left, websites you have viewed through links, the success rate(s) of any promotion or event, certain technical information about your device, or when you access our application through a certain device, purchase path or transactional data and customer care interactions. We will also use your Personal Information for security purposes, and to share information with our affiliates for internal administration based on legitimate interest.
  • Legal obligation and public interest – Where compelled by applicable law, we may also have a legal obligation to collect your Personal Information, or may otherwise need your Personal Information to protect your vital interests or those of another person.

If we need to further process your Personal Information, we will let you know if there is a different legal basis for that further processing that is not compatible with the notices and consents that we have already from you, and we will provide you with any relevant further information and consent options.

Your choices and your rights over your Personal Information.

If you are visiting a Kobo website from the EEA or any other jurisdiction with laws similar to the General Data Protection Regulation (GDPR), you may have certain rights, in accordance with applicable domestic law and limitations, including:

  • Right to restrict our use of your Personal Information;
  • Right to rectify the Personal Information we hold about you;
  • Right to access Personal Information: Users exercising this right may request access to the categories and specific pieces of their Personal Information we hold;
  • Right to data portability: Users exercising this right may receive their Personal Information in a usable electronic format and transmit it to a third party;
  • Right to object to our use of your Personal Information;
  • Right to disclosure: Users exercising this right can receive additional information regarding the sources from which we collect information, the purposes for which we collect and share Personal Information, the information of theirs we hold, and the categories of parties with whom we share their information;

Additional Rights of California, USA residents

  • Right to opt-out of sales: You may register your opt-out (Do Not Sell My Personal Information) by using the opt-out function at the bottom of our website pages.
  • Right to know about processing of Personal Information: If you reside in California, USA, you may request that we inform you of the categories of Personal Information we have collected about you; the categories of sources from which we collected the information; our purpose for collecting or selling the information; and the categories of third parties with which we share personal information.
  • Right to learn about certain disclosures: If you reside in California, USA and have provided your personally-identifiable information to us, you may 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 in writing at the following email address: privacy@kobo.com; and
  • Right to be free from discrimination: California residents may freely exercise these rights without fear of being denied goods or services. We may, however, provide a different level of service or charge a different rate reasonably relating to the value of your data.

You may in some cases have the option to decline providing us information. However, your choice to not provide information may impact your use of certain features or services. You may also have other rights in relation to your Personal Information under local law. In the event you reside in such a jurisdiction and would like to exercise one of your rights, please contact us at privacy@kobo.com. Please note that we may require additional information from you in order to honour your request, and we may decline your request as permitted under applicable law.

If contacting us does not resolve your complaint, you may have the right to make a complaint to your data protection authority (if one exists in your country).

User rights

You can unsubscribe or opt-out of receiving marketing communications from Us in your settings by clicking “Account Settings” under “My Account” once logged into your Kobo account. Or you can click the “Unsubscribe” link at the bottom of an automatic email. You can also deactivate your Kobo Account at http://www.kobo.com/help/deactivateaccount. Please note that even if you opt-out of receiving marketing communication, we may continue to send you non-marketing emails and other types of communications, as permitted by law, such as response to your support requests, or service email relating to your account.

You can change information about your account by connecting to your Kobo Account and modifying the information listed in the “Account Settings” function at www.kobo.com. Some of this information is optional and you are not required to provide it to us, however other information such as payment information is required for Kobo to be able to provide you with our services. You are not required to provide any information to us that is unnecessary to provide the Kobo Services.

You may control the use of cookies at the browser level. If you choose to disable cookies, it may limit your use of certain features or functions on our Services. For more information on how we use cookies and how you can manage them please see our Cookie Policy.

Third party Websites.

The Kobo Services may contain links to websites not owned or controlled by Kobo. We encourage you to be aware of these other third-party websites and their privacy statements, as we cannot control and are not responsible for privacy policies or practices of third-party websites. This Privacy Policy applies solely to the information collected by Kobo. Please review the Terms of Use for more information.

Do Not Track Signals.

We do not currently respond to web browser “do not track” signals or other mechanisms that provide a method to opt out of the collection of information across websites or other online services. If we do so in the future, we will update this privacy policy.

Security and Data Retention.

We care about the security of your Personal Information. We deploy administrative, technical, and physical measures designed to ensure a level of security appropriate to the risk to the Personal Information we collect. We evaluate these safeguards on an ongoing basis to help minimize risks from new security threats as they become known. However, no information system can be 100% secure. Moreover, we are not responsible for the security of information you transmit to us over networks that we do not control, including the Internet and wireless networks. We need your help too: it is your responsibility to make sure that your Personal Information is accurate and we encourage you to ensure that your password is unique, secure and not shared with third parties.

We retain the information collected via the Kobo Services for as long as we have a relationship with you, and until such time as you choose to close your Kobo Account. After that time, we will only retain your Personal Information if we are required to do so to comply with local law, or if there are outstanding claims or complaints that will reasonably require your Personal Information to be retained. We may also anonymize and aggregate the data and retain the data in that form for analytical purposes.

Changes to this Privacy Policy.

We may update this Privacy Policy from time to time. The effective date of the current Privacy Policy is noted at the top of this page. We may notify you in writing where we materially change these terms, for example, by posting a banner on the Services, however we encourage you to periodically review this page for updated terms.

How to contact us.

If you would like to contact us with questions about our privacy or data protection practices, please contact us at privacy@kobo.com

Annex 1 - PRIVACY POLICY ADDITIONAL PARTNER TERMS

If you are a Kobo by Fnac User

In addition to this Kobo Privacy Policy (if you have a Kobo account) and to FNAC’s 1.0 privacy policy at https://www.fnac.com/Help/donneesPersonnelles#bl=footer, (if you have a FNAC account) the following applies where you are a user of "Kobo by FNAC", an e-book download service jointly offered by Kobo and FNAC DARTY PARTICIPATIONS ET SERVICES, 9 rue des bateaux-lavoirs, 94200 Ivry-sur-Seine, France). You can access the service “Kobo by FNAC” with a Kobo account or a FNAC account. Your information and data are collected and processed electronically by Kobo and FNAC acting as joint controllers, regardless of the account used for access. In this context, Kobo and FNAC will share some of your information for the purpose of allowing your authentication and delivering the Kobo by FNAC services. This information will then be used by each of Kobo and FNAC for their own purposes.

Your information and data collected within the framework of the Kobo by FNAC services are contractually required in order to provide the services associated with your account and, pursuant to our legitimate interest, to monitor and manage the services, for security purposes, and (unless you do not consent ) , to enable Kobo and FNAC, as applicable, to improve and personalize the services offered to you and the information sent to you. This information will be processed by Kobo and by FNAC, respectively, for up to 3 years for client communication purposes and 5 years for data retention purposes.

Depending on the choices made when creating your account or access to your account, you can receive offers from FNAC or Kobo. If you no longer wish to receive these offers, you can at any time ask to no longer receive them, change your choices in the management of your account or ask Kobo or FNAC, as the case may be, to make the necessary changes to your account.

Whether you use the Kobo by FNAC service with your Kobo or FNAC account, your information will be made available to Kobo in Europe and Canada (countries whose legislation on the protection of personal data has been recognized as adequate by the European Commission on December 20 2001), Japan (the country whose legislation on the protection of personal data was recognized as adequate by the European Commission on 23 January 2019), the United States and Brazil (on the basis of Rakuten's binding corporate rules which have been approved by the Luxembourg Data Protection Authority and are summarized at https://corp.rakuten.co.jp/privacy/en/bcr.html). FNAC will also transfer your data outside Europe, including Morocco, Madagascar and the United States (based on the appropriate guarantee mechanism of the European Commission's standard contractual clauses).

In accordance with the regulation 2016/679 of 27 April 2016 relating to the processing of personal data (RGPD) and the Data Protection Act of 6 January 1978, you have a right of access, rectification, erasure, limitation of treatment, opposition, portability, and, if you reside in France, to define the processing of personal data held by FNAC or Kobo, as the case may be, after your death. Most of these rights can be exercised on your account. You can also write us.

by e-mail at the following addresses:

by mail to the following address:

  • Rakuten Kobo Inc., 135 Liberty Street, Suite 100, Toronto, ON M6K 1A7
  • FNAC customer service, customer service, the Flavia - 9 rue des Bateaux Lavoirs, 94768 Ivry-sur-Seine France.

Please include your name, e-mail address and / or postal address (depending on how you wish us to respond) and your customer reference number, if applicable. If so, please include a summary of the reasons for exercising your rights under the law). An answer will be sent to you within one month of receiving your request.

If you have any other questions or concerns regarding the use of your data in the "Kobo by FNAC" service, please contact one of the respective Data Protection Officers (DPOs) as follows:

You can submit a complaint to a data protection authority in France: CNIL - website www.cnil.fr.

If you are a user of an integrated partner service in Italy

Personal information is collected and processed electronically by Kobo and our Italian business partners, each for their account, regardless of the account used to log in. This information is requested by Kobo and our partners in Italy for the management of services, the monitoring of commercial and security relationships and to allow Kobo and our partners to improve and personalize the services offered and the information that is sent.

Depending on the choices made when you create your account or when you log into your account, you may receive offers from our partners. If you no longer wish to receive such offers, you can at any time request us to make the necessary changes to your account. Information collected directly by Kobo during the provision of the Service in Italy will be sent to our partners for the purpose of managing, monitoring the e-book download service and administering business relationships with each partner.

In accordance with the Regulation (EU) 2016/679 of the European Parliament and of the Council of 27 April 2016 on the protection of individuals with regard to the processing of personal data, as well as the free movement of such data and repealing Directive 95/46 / EC (general data protection regulation - GDPR) you have the right to access, rectify, cancel, limit the processing, portability and objection to your personal data held by our partners and Kobo.

RAKUTEN KOBO INC.

COOKIE AND TRACKING TECHNOLOGIES POLICY

Last updated: December 18, 2019

Rakuten Kobo Inc. (“Kobo,” “we,” "our,” or “us”) maintain our websites including www.kobo.com, www.kobobooks.com, and our other related websites, mobile applications, eReaders, and other services (collectively, the “Services”). We, along with our vendors, use a variety of technologies to learn more about how people use the Services. You can find out more about these technologies and how to control them in the information below and by reviewing our Privacy Policy here.

Cookies & Other Tracking Technologies: How We Use Them

Like most companies, we use cookies and similar technologies such as cookie IDs and settings, and tracker software tools (“cookies”).

We may use cookies for a variety of purposes and to enhance your online experience, for example, by remembering your log-in status.

We use both session and persistent tracking technologies. Tracking technologies can either be persistent (i.e., they remain on your computer until you delete them) or temporary (i.e., they last only until you close your browser).

We also use first and third-party cookies. First party cookies are used and controlled by us to provide services for the Services. Third-party cookies are controlled by third-parties, mostly for analytics purposes.

We and our third-party service providers or business partners may collect information about you automatically through the use of cookies and similar technologies, including information over time and across different websites or online services. We may collect such information when you access content, advertising, sites, interactive widgets, applications, and other products (both on and off of our Kobo Services) where Kobo’s data collection technologies (such as web development tools, cookies and other technologies) are present, including in the emails we send to you. We use browser cookies and similar technologies such as cookie IDs and settings, and tracker software tools (collectively, "cookies") to collect and store certain information when you use, access or interact with Kobo Services. These data collection technologies allow us to understand your activity on and off our Kobo Services and to collect and store information when you interact with Kobo Services we offer to partners. We and our retail partners automatically collect information from cookies and similar technologies to recognize you, learn how you interact with the Kobo Services and use your devices, and to serve you with surveys, tailored promotions and other marketing and content recommendations. You may limit our ability to automatically collect certain types of information by adjusting the cookie settings on your web browsers.

Subject to local law, you may have certain rights regarding information that we have collected from cookies and that is related to you. We encourage you to contact us to update or correct your information if it changes or if you believe that any information that we have collected about you is inaccurate. Please note that we will likely require additional information from you in order to honour your requests. If you would like to discuss or exercise such rights, send us an email at privacy@kobo.com. Alternatively, you may have a right to complain to your local data protection authority (if one exists in your country).

Our Services use the following categories of cookies:

  • Strictly Necessary Cookies (Class A): These are cookies which are needed to provide services and features you have specifically requested. We may use cookies and tracking technologies for system administration and/or to allow you to make use of shopping-cart functionality. We are not required to obtain your consent for cookies that are strictly necessary.
  • Analytics and Performance-Related Cookies (Class B, Class C): We may use cookies to assess the performance of our Services, including as part of our analytics practices to improve the selection of content recommended to you through the Services.
  • Functionality-Related Cookies (Class B, Class C): We may use cookies to tell us, for example, whether you have visited the Services before or if you are a new visitor and to help us identify the features in which you may have the greatest interest.
  • Targeting-Related Cookies (Class D): We may use cookies to deliver content, including ads, relevant to your interests on our Services.
Type: Class A: Essential Usage
Gathered: Only during the execution of core use cases necessary for the running of the service or through explicitly entered preferences by the user.
Used: Only during the execution of core use cases necessary for the running of the service.
Examples:
  • Authentication and Session management.
  • Explicitly Entered Preferences
  • Tracking consent status
  • Shopping Cart Functionality
  • Purchase Records
  • Entitlement state
  • User generated data (notes, highlights, bookmarks etc.)
Type: Class B: First Party Personalization
Gathered: Inferred from data gathered during core use cases or explicitly entered by the user
Used: Only during the executing of personalization features in the Kobo website or apps or for during communications with the customer from Kobo
Examples:
  • Personalized Recommendations
  • Personalized Lists or Page Layouts
  • CRM Emails and Push Messaging from Kobo
Type: Class C: First Party Analytics
Gathered: Data tracked by Kobo during usage of the kobo website or apps
Used: Offline for analytical purposes within Kobo or to offer personalized experiences within the Kobo experience
Examples:
  • Click tracking
  • A/B testing
  • Product usage analytics
Type: Class D: Third Party Analytics
Gathered: Data tracked by 3rd parties during the usage of kobo’s website or applications or Class A, B, or C data passed to third parties.
Used: Offline for analytical purposes outside of Kobo or to offer personalized experiences outside of the Kobo ecosystem
Examples:
  • Pixel tracking
  • Ad retargeting
  • Social tracking

You can withdraw your consent to the use of these cookies in whole or part, at any time, by deleting placed cookies and disabling cookies in your browser.

Your Cookie Choices

You have the choice whether to accept the use of cookies.

Most browsers are initially set up to accept HTTP cookies. The “help” feature of the menu bar on most browsers will tell you how to stop accepting new cookies, how to receive notification of new cookies and how to disable existing cookies. Controlling the HTML5 local storage on your browser depends on which browser you use. For more information regarding your specific browser please consult the browser’s website (often in the Help section). Please note, however, that without HTTP cookies and HTML5 local storage, you may not be able to take full advantage of all the features of our Services and some parts of the Services may not function properly.

You can also disable analytics for mobile apps from the settings screen on your mobile device.

Cookies and Tracking Technologies Used on Kobo’s Services

Table A below sets out details of the individual cookies and tracking solutions that we use with our devices, website and applications, including mobile applications, and the purposes for which we use them.

We provide the chart in Table A as a courtesy for all users independent of any rights you may have to consent to the use of cookies, otherwise. We are not obligated to maintain or update it, nor do we warrant it will be up-to-date, or the linked third party information will be up-to-date when you view it. We are not responsible for third-party sites and their privacy practices as they relate to any opt-outs from tracking activities that may exist on these sites, many of which may not be compliant for users on our sites who are from the European Economic Area. Table A contains a list of third-parties that collect information from you on Our Services and that have provided notices where you may obtain information on their policies and practices and in some instances, opt-out of certain of their activities directly.

Reading Activity

We keep track of your reading activity to provide you with information such as reading statistics, and improve personalized book recommendations. If you would like to turn it off on your eReader, you may do so via Settings >Energy saving and privacy > Uncheck – Help improve our App.

Contact Us

For any queries in relation to this Cookies and Tracking Technologies Policy please contact us at privacy@kobo.com.

TABLE A - COOKIES LIST

Third Party: Google Adwords / DoubleClick
Service: Advertising
For More Information: http://www.google.com/doubleclick/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.google.com/intl/en/policies/privacy/
To opt-out, visit: To opt out go to: https://adssettings.google.com/
Third Party: Facebook Connect
Service: Widgets, Social
For More Information: http://developers.facebook.com/docs/guides/web/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.facebook.com/about/privacy/
To opt-out, visit: https://www.facebook.com/help/211829542181913
Third Party: Google Analytics
Service: Google Analytics for Display Advertisers, Ads Preferences Manager, and Google Analytics Opt-out Browser Add-on
For More Information: http://support.google.com/analytics/bin/answer.py?hl=en&topic=2611283&answer=2700409
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.google.com/intl/en/policies/privacy/
To opt-out install the plug-in: https://tools.google.com/dlpage/gaoptout
Third Party: Google Tag Manager
Service: Widgets, Tag Manager
For More Information: http://www.google.com/tagmanager/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.google.com/policies/privacy/
Third Party: Google+ Platform
Service: Widgets, Social
For More Information: http://plus.google.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.google.com/intl/en/policies/privacy/
Third Party: Twitter Button
Service: Widgets, Social
For More Information: http://twitter.com/about
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://twitter.com/privacy
To opt-out, visit: https://help.twitter.com/en/rules-and-policies/twitter-cookies
Third Party: Adjust
Service: Installs of applications, in app usage, conversion tracking, fraud prevention
For More Information: https://www.adjust.com/company/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.adjust.com/privacy_policy/
To opt out: https://www.adjust.com/opt-out/
Third Party: Maxymiser
Service: Beacons, A/B Testing, Site Optimization
For More Information: https://www.oracle.com/ca-en/marketingcloud/products/testing-and-optimization/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.oracle.com/ca-en/legal/privacy/
Third Party: Crashlytics
Service: App performance tracker
For More Information: http://try.crashlytics.com/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://try.crashlytics.com/terms/privacy-policy.pdf
Third Party: Hotjar
Service: Website tracking
For More Information: https://www.hotjar.com/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://help.hotjar.com/hc/en-us/articles/115011789248-Hotjar-Cookies
To opt out, visit: https://www.hotjar.com/legal/compliance/opt-out
Third Party: Facebook
Service: Advertising
For More Information: https://www.facebook.com/business/ads
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.facebook.com/about/privacy/
Third Party: Criteo
Service: Advertising
For More Information: https://www.criteo.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.criteo.com/privacy/
Third Party: Bing
Service: Advertising
For More Information: https://ads.microsoft.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://privacy.microsoft.com/en-us/privacystatement
Third Party: Appier
Service: Advertising
For More Information: https://www.appier.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.appier.com/privacy_policy/2/privacy_policy.html
Third Party: Fyber
Service: Advertising
For More Information: https://fyber.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.fyber.com/privacy-policy/
Third Party: Net Affiliation
Service: Advertising
For More Information: https://netaffiliation.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://netaffiliation.com/privacy/netaffiliation-privacy-policy
Third Party: Pinterest
Service: Advertising
For More Information: https://ads.pinterest.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://policy.pinterest.com/en/privacy-policy
Third Party: Rakuten Linkshare
Service: Advertising
For More Information: https://rakutenmarketing.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://rakutenmarketing.com/legal-notices/website-privacy-policy.html
Third Party: Tapjoy
Service: Advertising
For More Information: https://www.tapjoy.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://home.tapjoy.com/legal/#privacy-policy
Third Party: Twitter
Service: Advertising
For More Information: https://ads.twitter.com/login
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://twitter.com/en/privacy
Third Party: Awin
Service: Advertising
For More Information: https://www.awin.com/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.awin.com/us/legal/privacy-policy
Third Party: Branch
Service: Advertising
For More Information: https://branch.io
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://branch.io/policies/#privacy
To opt-out, visit: https://branch.app.link/optout
Third Party: Fabric
Service: App - Crash reporting and usage information
For More Information: https://fabric.io/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://docs.fabric.io/apple/fabric/data-privacy.html
Third Party: Hockey App
Service: EPD - Crash reporting and usage information
For More Information: http://hockeyapp.net
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.hockeyapp.net/blog/2016/04/15/terms-of-service.html
Third Party: Firebase
Service: App - Crash reporting and usage information
For More Information: https://firebase.google.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://firebase.google.com/support/privacy/
Third Party: Button
Service: Advertising
For More Information: https://www.usebutton.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.usebutton.com/privacy-policy
Third Party: Rakuten Marketing
Service: Advertising
For More Information: https://rakutenmarketing.com
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://rakutenmarketing.com/legal-notices/services-privacy-policy
Third Party: LinkedIn
Service: Advertising
For More Information: https://business.linkedin.com/marketing-solutions/ads
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.linkedin.com/legal/privacy-policy
Third Party: Motive
Service: Advertising
For More Information: https://motiveinteractive.com
Use of Tracking Technologies: Yes
Privacy Choices: For more information, go to: https://www.motiveinteractive.com/platform-privacy-policy
Third Party: Drop
Service: Advertising
For More Information: https://www.earnwithdrop.com/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.earnwithdrop.com/pages/privacy
Third Party: iChannel
Service: Advertising
For More Information: http://www.ichannels.com.tw
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: http://www.ichannels.com.tw/main-privacy.php?member=5880412
Third Party: Responsys
Service: Advertising
For More Information: https://www.oracle.com/ca-en/marketingcloud/products/cross-channel-orchestration/
Use of Tracking Technologies: Yes
Privacy Choices: For privacy information, go to: https://www.oracle.com/ca-en/legal/privacy/
Third Party: eBay
Service: Advertising
For More Information:
Use of Tracking Technologies: Yes
Privacy Choices:
Third Party: OATH (WalmartHybrid)
Service: Advertising
For More Information: https://developer.yahoo.com/nativeandsearch/guide/audience-management/dottags/
Use of Tracking Technologies: Yes
Privacy Choices: