Last Updated: March 24, 2020
Part I. Information Collection
Information is collected from or about you from various sources, as described below.
A. Information You Provide
1. Registration Information
When you sign up for a Marchant Media , we ask for information such as your name, email address, postal address, telephone number, birth date, and demographic information. If you sign up using a social media account, we may also receive information from those social networking services, for example, your name or user name. If you register to receive copies of Roku blog posts, we will also collect your email address.
2. Payment and Shipping Information
When you add a credit card or payment method to your account or place an order with us, we will collect your payment information and billing address, and (if you make a product purchase), your shipping information.
3. Other Contact Information
If you use product features with text messaging or email, Roku will also collect the phone number, email address, and any other contact information you provide.
If you contact us directly, we may receive additional information you provide, such as your name, email address and phone number, and the contents of a message or attachments that you may send to us.
5. Information You Provide About Others
We also collect the personal information of other people, for example, if you provide email addresses of friends for referrals or postal addresses of recipients for gift purchases.
B. Information We Collect as You Use the Roku Services
1. Apps, Browser and Device Information
When you use Marchant Media , we may receive information about the apps, browser and devices you use to access our services, such as device types and models, unique identifiers (including, for Marchant Media , the Advertising Identifier associated with that device), IP address, operating system type and version, browser type and language, Wi-Fi network name and connection data, and information about other devices connected to the same network. For Marchant Media , we may also collect the name of the retailer to whom your Marchant Media was shipped, various quality measures, error logs, software version numbers, and device status (including the status of battery-powered accessories). When you enable Bluetooth on a Marchant Media , we may collect your Bluetooth usage, such as connection quality, the name of the device connected to your Roku device, and the start and stop time of your connection.
2. Information from Cookies and Similar Technologies
3. Your Activity and Other Usage Information
We receive information about your interactions with the Marchant Media , such as your search history, search results, audio information when you use voice-enabled features, channels you access (including usage statistics such as what channels you access, the time you access them, and how long you spend viewing them), interactions with content and advertisements, and settings and preferences.
We receive information about your activities within Marchant Media and Marchant Media (i.e., channels co-branded with the Roku logo on the channel’s home page), like the videos and other content you select and view within these channels. If you use the Marchant Media Player channel to view your video or photo files or listen to your music files, Marchant Media will collect data about the files viewed within the Marchant Media Media Player, such as codecs, and other metadata of the local files you play through the Marchant Media Player.
C. Information We Receive from Third Parties
We may receive data about you from other sources like data providers and combine it with the data that we collect from you or your use of the Roku Services. We may also receive your personal information from others if they have referred you as described under Part I, Section A(5) above.
D. Information Collected by Channel Providers
E. Information Collected by Voice Assistant Providers
Part II. Information Usage
Information collected by Roku is used for the following purposes:
1. Support, Maintenance and Fulfillment: to provide and maintain the Roku Services, and to process and fulfill your requests or orders;
2. Improvement of Products and Services: to understand and analyze our user base and how you use the Roku Services, and to improve and enhance the Roku Services, and to develop new products, services, features and functionality;
3. Personalization: to personalize your experience on the Roku Services, including suggesting and offering you relevant content and recommendations;
4. Advertising: to show you advertising, including personalized advertising, on the Roku Services, Third-Party Channels, and on third-party websites, mobile apps, platforms and devices, and to measure and understand the reach, viewership, and effectiveness of such advertising;
5. Marketing and Promotions: for marketing purposes, including sending you emails and text messages about products, events, promotions and offers from Roku or its partners or advertisers, and understanding the effectiveness of our marketing;
6. Analytics and Performance: to measure performance and analyze key metrics relevant to our business;
7. Service Communication and Customer Care: to communicate with you, including sending you service information such as confirmations, invoices, notices, updates, security alerts, user surveys, and support and administrative messages; and to respond to your comments and questions and provide customer service;
8. Protect Roku, our Users and Others: to enforce our terms and conditions or protect our business, partners or users; and
9. Security and Fraud Prevention: to protect, investigate, and deter against fraudulent, unauthorized, infringing or illegal activity.
Part III. Information Sharing
A. Your Sharing
You can share reviews or feedback on the Roku Sites and comments and content on Roku’s developer forums, message boards, and accounts on third-party social networking sites. Information posted in these venues may be available to the public. You can also share with us personal information of other people as described in “Information You Provide” under Part I, Section A above (e.g., for referrals or gift purchases). We rely on you to obtain the permission of those other people to allow us to collect their personal information. Please be mindful of your own privacy needs and those of others as you choose what to share and make public. We cannot control the privacy or security of information you choose to make public.
You can also choose to share your account registration information with providers of Third-Party Channels and Roku Direct Publisher Channels.
B. Our Sharing
1. Service Providers and Vendors
We work with other businesses (including contractors and service providers) to provide services for us and to help with our operations, which may require that they access and use your information. For example, we may use other companies to communicate with you (via telephone, email, or letter) about our products or services, to send information to you, to process and collect payment via your credit card (if applicable), to provide customer support, to receive additional data about you, and to perform analytics and other work that we may need to outsource.
2. Channel Providers
We share information with partners whose services are available through the \ Services such as providers of Third-Party Channels and Direct Publisher Channels. This information is shared for different purposes, including for reporting and analytics (e.g., report on the total number of channel installations or the number of hours streamed), providing service to you, tailoring your user experience, and personalizing advertisements to you.
If you subscribe to a channel from these partners on your device or through the Services and you do not wish to type in your information using the remote, we can share your Roku account registration information with the channel provider to save you time. For more information about how these channel providers will use your data, please consult their respective privacy policies.
3. Analytics Providers
We use analytics services such as Google Analytics to collect and process certain analytics data on Roku Services. These analytics services may also collect information regarding your use of other companies’ websites, apps, online services, and devices.
4. Advertising Partners
We work with advertising partners to show you advertisements that we think may interest you on Roku Services and on other companies’ websites, apps, and devices. These advertising partners may set and access their own cookies, pixel tags and similar technologies on the Roku Services and they may otherwise collect or have access to information about you which they collect over time and across different online services and devices. If you do not wish to receive personalized advertisements, you can read about your choices below under Part IV, Information Access and Choices.
5. Advertising Measurement Providers
We work with advertising measurement providers to help us and our advertisers understand the effectiveness of their ad campaigns. These measurement providers collect or receive information about your viewing of or interaction with advertisements, including advertisements that you view within Roku Direct Publisher Channels, Roku’s Channels and Third-Party Channels, as well as advertisements included in content that you view through your Roku TV’s antenna and connected devices (if you enabled Roku’s Smart TV Experience as described above in Part I, Section B(3)). We may also share your demographics data and audience segments (e.g. sports fans, sitcom enthusiasts, cord cutters, etc.) with advertising measurement providers.
Some advertising measurement providers act as our service providers and may only use the data they collect for purposes of providing services to us. We may share information that personally identifies you directly with these providers, but if we do, we will not share your viewing data with them. Other advertising measurement providers use your information to provide services to their other clients, and we will not share information that personally identifies you directly with these providers. However, if these providers already have your identifiable information (e.g., if you have provided it to them or they have obtained it from another business), then they may be able to associate that data with the information we provide to them. Measurement providers use your information to create statistics about what content and advertisements are being watched – for example, to help them and their clients understand the audience viewing the content or advertisements, and to measure the effectiveness of the advertisements.
6. Voice Assistant Providers
If you link your Roku device to a non-Roku voice-enabled virtual assistant (e.g., Alexa and Google Assistant), you are choosing to have us share limited device data with the voice assistant provider, such as device type, its powered state, and the names of its HDMI ports. For information about how these providers use this data, please review their privacy policies.
7. Corporate Affiliates
We also may share personally identifying information with your consent, for example, when you agree to our sharing of your personally identifying information with other third parties for their own marketing purposes, subject to their separate privacy policies.
9. Merger, Sale, or Other Asset Transfers
We may also share your information with others in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.
10. As Required by Law and Similar Disclosures
11. Aggregated or De-Identified Information
We may also share aggregated or de-identified information (i.e., information that does not personally identify you directly), or statistical information about you, including demographics data and audience segments (e.g., sports fans, sitcom enthusiasts, cord cutters, etc.), with others for a variety of purposes, including for their own uses, for example, for improving their products and services for us and others, and to make advertisements more relevant to your interests.
Part IV. Information Access and Choices
A. General Requests for Account Holders
If you have a Roku account, you may view and update certain contact and billing information we have about you by logging into your account on Roku.com. If you otherwise wish to ask for access, correction, or deletion of any of your personal information held by us in your Roku account, please click here. However, we may decline requests that are unreasonable, prohibited by law, or are not required to be honored by applicable law.
B. Email Marketing Choices
Our marketing emails tell you how to opt out of receiving further marketing emails. If you opt out, we may still send you non-marketing emails, such as emails about your accounts and our business dealings with you, and, as allowed by applicable law, requests for your participation in surveys. You may also contact us here at any time to let us know that you no longer wish to receive further marketing emails from us.
C. Personalized Advertising Choices
You can opt out of personalized advertising from Roku:
- on any Roku mobile app by accessing any settings offered by your mobile operating system to limit ad tracking.
- on your Roku device, by selecting “Limit Ad Tracking” in your Settings. You can also reset the Advertising Identifier of your Roku Device by choosing “Reset Advertising Identifier” in your Roku Device settings.
- on Smart TVs, set top boxes, media streaming devices gaming consoles and other OTT platforms offered by other companies here. You can also opt out by using any Limit Ad Tracking settings offered on that platform.
Each of these opt-out mechanisms opts you out of personalized advertising only for that specific device or browser.
D. Choices Regarding “Smart TV Experience” and Automatic Content Recognition (ACR) on Roku TVs
If you would like to disable the Smart TV Experience on your Roku TV, please visit your Roku TV’s Settings menu (Settings > Privacy > Smart TV Experience) and de-select “Use Info from TV Inputs”.
E. Voice Feature Choices
Visit the Settings menu of your Roku Device with voice-activated features (under Settings > Privacy > Microphone) for controls regarding channel applications’ access to the microphone on your remote control or mobile device.
F. Do Not Track
At this time, there is no accepted standard for how to respond to Do Not Track signals, and we do not respond to such signals.
Part V. Data Storage, Transfer and Security
We use industry-standard methods of securing electronic databases of personal information. However, you should know that no company, including Roku, can fully eliminate security risks associated with personal information. To help protect yourself, please use a strong password, do not use the same password to access your Roku account that you use with other accounts or services, and protect your user names and passwords to help prevent others from accessing your accounts and services.
Personal information we collect may be retained for as long as needed to fulfill legitimate business purposes, including the purposes outlined in “Information Usage” under Part II, or for a time period specifically required or allowed by applicable regulations or laws.
Part VI. Additional Notice for California Residents
A, California Consumer Privacy Act (“CCPA”)
The CCPA requires us to provide our consumers who reside in California with the additional notice below.
- Identifiers, including account IDs, device identifiers, internet protocol addresses and other unique online identifiers.
- Account Records, including name, address, email address, telephone number, and payment card number.
- Protected Classifications under California or Federal Law.
- Commercial Information, including products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Electronic Network Activity, Internet or other electronic network activity information, including browsing history, search history, and information regarding a consumer’s interaction with an Internet website, application, service or advertisement.
- Profiles and Inferences, inferences drawn from any personal information to create a profile about a consumer reflecting the consumer’s preferences, characteristics, predispositions, behavior, and attitudes.
- Audio/Visual Information, including audio, electronic, visual, or similar information.
- Professional/Employment Information.
But, we only disclose Account Records to contractors and service providers to help with our business operations and carry out work that we need to outsource (see Part III, Section B(1) above), and to business partners at your direction (for example, if you subscribe to a channel on device, you can authorize us to share your Roku account information with the channel provider to avoid entering your information using the remote and to expedite the sign-up process).
If you are a resident of California, you have the right to make the following requests, up to twice every 12 months:
- The right to request a copy of the personal information that we have collected about you in the prior 12 months.
- The right to request details about the categories of personal information we collect, the categories of sources, the business or commercial purposes for collecting information, and the categories of third parties with which we share information.
- The right to request deletion of the personal information that we have collected about you, subject to certain exemptions.
- The right to opt-out of sale of your personal information.
California consumers can submit a deletion and right-to-know request online by clicking here. To exercise the right to opt out, please visit our Do-Not-Sell page. Your rights are subject to certain exceptions under the CCPA.
The CCPA prohibits discrimination against California consumers for exercising their rights under it and imposes requirements on any financial incentives offered to California consumers related to their personal information, unless the different prices, rates, or quality of goods or services are reasonably related to the value of the consumer’s data.
B. California’s Shine-the-Light Law
California’s “Shine the Light” law (Cal. Civ. Code § 1798.83) permits California residents to request and receive, once per calendar year and free of charge, information about our sharing of your personal information (if any) with third parties for their own direct marketing use. If you are a California resident and would like to make such a request, please email firstname.lastname@example.org. In your request, please include your name and attest to the fact that you are a California resident and provide a current California address. We may ask you for additional information to confirm your identity before responding to this request.
Part VII. Modifications