CCPA User Subject Rights and Delete Requests

(CCPA is effective as of January 1, 2020)

CCPA Requirements

CCPA (California Consumer Privacy Act) provides consumers with the right to opt out of sales, the right to request access to their data, and the right to request deletion. Users frequently request access to data or request data deletion after a transaction occurs, and the request applies to their historical data, so these requests occur outside of the signals framework used for opting out of the sale. Publishers may send requests for data access or data deletion to Rakuten Advertising, and requests with the necessary information provided will be honored within the required deadline of 45 days.

PI Captured

At Rakuten Advertising, we prioritize user privacy. We do not collect any user’s personal information (PI) from publishers at any point in our process. This includes directly identifiable information such as user name, email address, mailing address, or phone number. Our commitment to user privacy is unwavering. 

When a click on an affiliate link occurs, or when a programmatic ad serves an impression, we create our own user ID, the RMUID, which is associated with that user, and which is considered PI under CCPA.

Publishers or advertisers may pass Rakuten the following information that may be considered PI under CCPA when linked to an RMUID:

  • RMUID (RM-generated)

  • U1 – unique click ID (from publisher)

  • Order ID (from Advertiser)

How do I submit a User Subject Rights or Delete Request to Rakuten Advertising?

When submitting a delete request, it's crucial to include the user’s U1 (click ID) or RMUID. These identifiers are essential for us to locate and delete records associated with that user. We kindly request our publishers to refrain from transmitting any other user personal information (such as name, address, e-mail address or phone number) to Rakuten Advertising. This is to protect user privacy and ensure compliance with CCPA. 

Send subject rights requests and delete requests to:

Once we receive a delete request, our dedicated team swiftly reviews our databases. We verify whether we have personal data associated with the deleted users. If we can sufficiently verify that we have those users’ personal data, we promptly delete the identifiers. This ensures that any information remaining is fully anonymized, in line with CCPA requirements.


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