RAKUTEN KOBO INC.
PRIVACY POLICY
Last updated: November 22, 2018
Rakuten Kobo Inc., or in respect of residents of Europe, Kobo Europe S.A., (“Kobo”, “we”, “us” or “our”) operates an digital reading platform that enables customers to acquire and read written works through a variety of electronic devices and software applications (“Kobo Platform”). Kobo is part of the Rakuten Group, which includes the affiliates and subsidiaries of our parent company Rakuten, Inc., based in Tokyo, Japan. More information about Rakuten is available at http://global.rakuten.com/corp/about/company.
This Privacy Policy explains how Kobo, as data controller, collects, uses and shares personal information in association with the services we provide through the Kobo Platform, including the Kobo eReading service (the "Kobo Services") and the account you use to access the Kobo Services (the "Kobo Account").
Collection of personal information
"Personal information" (also referred to as "Personal Data" in some jurisdictions) is any information that can be used to identify you or that we can link to you.
We collect, process and use your personal information when you:
- register for a Kobo Account or log into an existing account;
- visit our website;
- order products or content from us;
- access the Kobo Platform or use the Kobo Services; or
- contact us for customer care.
The information we collect is typically related to the product or service you request and include:
- your name and title;
- address and email address;
- the nature of the product or service requested;
- connection and service usage details;
- payment information; and
- related information which we may need to fulfill your request.
Cookies and similar tools
We use browser cookies and similar technologies (collectively, "cookies") to collect and store certain information when you use, access or interact with Kobo Services. More information about our cookie policy is available.
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 we use the information we collect
(a) Managing your Kobo AccountWe collect your personal information to: (a) create and manage your Kobo Account; (b) monitor and manage your purchase transactions; including administration; provisioning; billing and reconciliation; verification of your identity, solvency and creditworthiness (c) comply with legal and regulatory requirements and with the competent judicial authorities in each geographical jurisdiction that Kobo operates in; (d) maintain, support and develop the products and services you purchase; and (e) perform statistical analysis. We also use your information to assess risk and detect and prevent fraud. Any fraudulent misuse of your Kobo Account or the Kobo Platform may result in the suspension or cancellation of your Kobo Account.
For example, this information allows us to ensure that digital content is sent to you in compliance with applicable geographic rights and usage limitations applicable to the content. We will also send you service, support and administrative messages, reminders, technical notices, updates, security alerts and information requested by you, such as in response to a request for customer assistance. Emails and messages concerning the administration and operation of your Kobo Account and/or the Kobo Services will be sent to you. If you opt out of receiving these communications, we may be unable to provide the services to you.
(b) Organizing contestsFrom 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, such as to determine your eligibility for the contest or to award a prize.
Kobo’s contests or promotion may be operated with other organizations. This will be identified in the contest rules. The contest rules will additionally identify if your personal information will be shared with the other organization and if so, the purposes for the disclosure and your privacy rights. This data collection and sharing may be necessary for the consideration of your participation.
(c) Sending newsletters and marketing emailsWith your permission we also want to provide you with the most up-to-date information about our services, products, and other information that might be of interest to you when using services from Kobo and/or our affiliates and partners.
To offer you more personalized offers and/or special offers, discounts and other information, Kobo may send you newsletters, discounts, promotion codes, and general information about the Rakuten Group including its affiliate companies (such as Viber and eBates), if you consent. Your consent is not required as a condition of using the Kobo Service, and you may withdraw it at any time.
How we may share the information we collect
We may share the information we collect, including your personal information, with third parties under the following circumstances (including intra-group transfers and transfers to entities in countries that do not provide statutory protections for personal information):
- Service providers and business partners. We may share your personal information with our service providers and business partners that perform marketing services and other business operations on our behalf and under our instructions. For example, we may partner with other companies to process secure payments, fulfill orders, optimize Kobo Services, send our newsletters and marketing emails, support email and messaging services and analyze information.
- Retailer partners. We may share your personal information with various retailer partners in the country where you live.
- Rakuten Group companies. Kobo works closely with its affiliated businesses and companies within the Rakuten Group. Subject to applicable law, we may share certain information about you and your activities on the Kobo Platform with other Rakuten Group companies for statistical aggregation, marketing purposes and internal reporting, and to incorporate your data into databases controlled by us or our affiliates or agents for the purpose of providing services revenue and customer analysis and reporting; market and customer use analysis.
- You may choose to identify yourself to Kobo by creating a new account or by using a third party identification verification and authentication service supported by Kobo. If you choose to create a new account with Kobo instead of using other credentials supported by a third party identification service, then your account credentials, consisting of your e-mail address and encrypted password, will be stored and processed by Rakuten Inc., which will also allow your account credentials to be used to access certain websites and services of other Rakuten Group companies. The other Rakuten Group websites and services may request personal information from you if you use their services, and if you provide this information, then it will be governed by their respective privacy policies and not this Rakuten Kobo privacy policy.
- Protection of rights and other legal purposes. 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.
- Asset purchases. 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.
Data transfers from the EU
If you are visiting from the European Union or other regions with laws governing data collection and use that may differ from E.U. or U.S. law, please note that you may be transferring your personal information to the Rakuten Group in the United States and in other countries around the world for the purposes described in the third bullet above under the heading “How we may share the information we collect”. We take great care in protecting your personal information and have put in place adequate mechanisms to protect it when it is transferred internationally.
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 with 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 bases for using your personal information
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 perform the Terms of Use under which we provide the Kobo Service to you and the Terms of Sale under which we sell goods to you.
- Consent – We will rely on your consent to use (i) technical information such as cookie data and geolocation data as described in our Cookie Policy; and (ii) your personal information for marketing purposes. You may withdraw your consent at any time by contacting us at the address that appears at the end of this Privacy Policy, or 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.
- If we need to further process (or engage data processors to further process) your personal information, we will let you know if there is a new purpose for that further processing that is not compatible with the notices and consents that we have from you, and we will provide you with any relevant further information.
Third party websites
The Kobo Platform may contain links to websites not owned or controlled by Kobo. Kobo does not have any control over these third-party websites. 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.
Security and data retention
We deploy administrative, technical, and physical safeguards designed to safeguard the information that 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. So, we cannot guarantee the absolute security of your information. 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 retain the information collected via the Kobo Services until such time as you choose to close your Kobo Account. After that time, we may anonymize and aggregate the data and retain the data in that form for the same analytical purposes stated above.
Your choices and your 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.
You can change information about your account by connecting to your Kobo Account and modifying the information listed in the “About Me” tab. 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.
Subject to local law, you may have certain rights regarding information that we have collected 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.
Consistent with legal requirements and limitations, you can also ask us:
- to see what personal information we hold about you;
- to erase your personal information;
- to port your personal information; and
- to restrict our use of your personal information.
Please note that we will likely require additional information from you in order to honor 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).
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 advise you in writing where we materially change these terms, 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.
Rakuten Kobo Inc., or in respect of residents of Europe, Kobo Europe S.A., (collectively, “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. This policy forms part of the Kobo Privacy Policy.
Cookies & Other Tracking Technologies: How We Use Them
Like most companies, we use cookies and other tracking technologies on our Services (referred to together from this point forward as “cookies,” unless otherwise stated).
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 (e.g., cookies) 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.
Our Services use the following categories of cookies:
- Strictly Necessary Cookies: 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: 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: 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: We may use cookies to deliver content, including ads, relevant to your interests on our Services.
By using our Services, you consent to the use of cookies and tracking technologies and the corresponding processing of information. You can withdraw your consent at any time by deleting placed cookies and disabling cookies in your browser.
Your Cookie Choices & How to Opt-Out
You have the choice whether to accept the use of cookies and we have explained how you can exercise your rights, below.
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. For more information about HTTP cookies and how to disable them, you can consult the information at http://www.allaboutcookies.org/manage-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 & Tracking Technologies Used on Kobo’s Services
The following table sets out details of the some of the individual cookies and tracking solutions we use with our devices, website and applications, including mobile applications, and the purposes for which we use them.
We provide the chart below as a courtesy for all users outside of Germany, but we are not obligated to maintain or update it. We are not responsible for third-party sites and their privacy practices as it relates to opt-outs from tracking activities. The following third-parties that collect information from you on our Services have provided notices that you may obtain information on their policies and practices, and in some instances, opt-out of certain of their activities, as follows:
| cookie: | .accounts.google.com |
| Service: | Google Analytics |
| Purpose: | Analytics and Performance Related |
| Privacy Choices: | http://www.google.com/intl/en/policies/privacy/ |
| cookie: | .facebook.com |
| Service: | Faceook |
| Purpose: | Targeting-Related |
| Privacy Choices: | http://www.facebook.com/about/privacy/ |
| cookie: | .google.com |
| Service: | Google Adwords |
| Purpose: | Targeting-Related |
| Privacy Choices: | http://www.google.com/policies/privacy/ |
| cookie: | .criteo.com |
| Service: | Criteo |
| Purpose: | Targeting-Related |
| Privacy Choices: | http://www.criteo.com/privacy/ |
| cookie: | .bat.bing.com |
| Service: | Bing |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://privacy.microsoft.com/en-us/privacystatement |
| cookie: | .crashlytics.com |
| Service: | Crashlytics |
| Purpose: | Analytics and Performance Related |
| Privacy Choices: | https://try.crashlytics.com/terms/privacy-policy.pdf |
| cookie: | .appier.net |
| Service: | Appier |
| Purpose: | Targeting-Related |
| Privacy Choices: | http://www.appier.com/privacy_policy/2/privacy_policy.html |
| cookie: | .doubleclick.net |
| Service: | Doubleclick / Floodlight |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://support.google.com/adsense/answer/2839090?hl=en |
| cookie: | .balao.de |
| Service: | Fyber |
| Purpose: | Targeting-Related |
| Privacy Choices: | |
| cookie: | .googleadservices.com |
| Service: | Google Adwords |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://support.google.com/adwords/answer/2549063?hl=en |
| cookie: | .googletagmanager.com |
| Service: | Google Tag Manager |
| Purpose: | Analytics and Performance-Related Cookies |
| Privacy Choices: | https://www.google.com/policies/privacy/ |
| cookie: | .hotjar.com |
| Service: | HotJar |
| Purpose: | Analytics and Performance-Related |
| Privacy Choices: | https://www.hotjar.com/privacy |
| cookie: | .supersonicads.com |
| Service: | ironSource |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://www.supersonic.com/privacy-policy/ |
| cookie: | .netaffiliation.com |
| Service: | NetAffiliation |
| Purpose: | Targeting-Related |
| Privacy Choices: | http://netaffiliation.com/privacy/netaffiliation-privacy-policy |
| cookie: | .pinterest.com |
| .pinimg.com | |
| Service: | |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://policy.pinterest.com/en/privacy-policy |
| cookie: | .linksynergy.com |
| Service: | Rakuten Linkshare |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://rakutenmarketing.com/legal-notices/website-privacy-policy.html |
| cookie: | shop.kobo.com |
| Service: | Responsys |
| Purpose: | Analytics and Performance-Related |
| Privacy Choices: | https://policy1.responsys.net/privacy.htm |
| cookie: | .dealtime.com |
| Service: | Shopping.com |
| Purpose: | Targeting-Related |
| Privacy Choices: | http://www.ebaycommercenetwork.com/pp.html |
| cookie: | .go2cloud.org |
| Service: | TapJoy |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://home.tapjoy.com/legal/#privacy-policy |
| cookie: | .twitter.com |
| Service: | |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://twitter.com/en/privacy |
| cookie: | .zanox.com |
| Service: | Zanox |
| Purpose: | Targeting-Related |
| Privacy Choices: | https://www.awin.com/us/legal/privacy-policy |
| Tracker: | yes |
| Service: | Google Analytics |
| Platform: | iOS/Android applications/eReaders/Kobo desktop applications |
| Purpose: | Understand feature usage, behavior, and flow within the app. |
| Privacy Choices: | https://policies.google.com/technologies/partner-sites https://www.google.com/analytics/terms/us.html |
| Tracker: | yes |
| Service: | Rakuten Kobo analytics |
| Platform: | iOS/Android applications/eReaders/Kobo desktop applications |
| Purpose: | Used to determine feature usage, improve recommendations, investigate application bugs |
| Tracker: | yes |
| Service: | Tune |
| Platform: | iOS/Android applications |
| Purpose: | Marketing campaign tracking: installation, registration, purchase, sign in, content preview, credit redemption |
| Privacy Choices: | https://www.tune.com/resources/data-and-privacy/privacy-policies/ |
| Tracker: | yes |
| Service: | Fabric |
| Platform: | iOS/Android applications |
| Purpose: | Crash reporting and usage information |
| Privacy Choices: | https://www.google.com/analytics/terms/us.html https://fabric.io/terms https://docs.fabric.io/apple/fabric/data-privacy.html |
| Tracker: | yes |
| Service: | Hockey App |
| Platform: | EPD - devices |
| Purpose: | Crash reporting and usage information |
| Privacy Choices: | https://www.hockeyapp.net/blog/2016/04/15/terms-of-service.html |
| Tracker: | yes |
| Service: | Firebase |
| Platform: | Android |
| Purpose: | Crash reporting and usage information |
| Privacy Choices: | https://policies.google.com/technologies/partner-sites https://www.google.com/analytics/terms/us.html https://firebase.google.com/support/privacy/ |
| Tracker: | yes |
| Service: | |
| Platform: | iOS/Android//eReaders/Kobo desktop applications |
| Purpose: | Marketing campaign tracking, including installation, registration, purchase (content, subscriptions, credits, KSP packages), sign in, content preview, credit redemption |
| Privacy Choices: | https://www.facebook.com/policy.php |
| Tracker: | yes |
| Service: | Google Adwords |
| Platform: | Android |
| Purpose: | Marketing campaign tracking, including installation, registration, purchase (content, subscriptions, credits, KSP packages), sign in, content preview, credit redemption |
| Privacy Choices: | https://policies.google.com/technologies/partner-sites https://www.google.com/analytics/terms/us.html |
| Tracker: | yes |
| Service: | Button SDK |
| Platform: | iOS/Android applications |
| Purpose: | Install and purchase tracking for affiliates |
| Privacy Choices: | https://www.usebutton.com/privacy-policy |
Reading Activity
We keep track of your reading activity to provide you with information such as reading stats, 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.