Marchant Media Network respects and values the privacy of our users. This Privacy Policy describes the information that Marchant Media Network and our affiliated companies other than TOH Intermediate Holdings, LLC and its subsidiaries (“Marchant Media Network ,” “we,” or “us”) collect about consumers (“you” and “your household”) and how we use and disclose that information. 

Scope of this Privacy Policy 

This Privacy Policy applies to information collected by Marchant Media Network through the “Marchant Media Network”, which includes:  Roku websites (“Marchant Media Network ”), Marchant Media Network products and certain other products utilizing Marchant Media Network’s streaming platform or operating systems (including Roku players, Roku TVs, Roku Smart Home devices, speakers and other audio-enabled products) (collectively, “Roku Devices”), certain Roku co-branded channels (“Roku Direct Publisher Channels”), Roku’s mobile apps (including the Roku Mobile App and Roku Smart Home App), Roku branded channels like the Roku Media Player and The Roku Channel (“Roku’s Channels”), Roku’s advertising services, Roku emails and newsletters, and Roku’s accounts on third-party social networking sites. 

Using our products and services, you can access channels provided by Marchant Media Network

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 Roku account, we ask for information such as your name, email address, postal address, telephone number, birth date, gender and other 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 username. We also may collect similar contact information if you register to use or receive other products or services offered through Roku, or copies of Roku blog posts. 

When you subscribe to a streaming service from another provider through the Roku Services (e.g., when you subscribe to a streaming service on Roku Sites or within The Roku Channel, or to a Third-Party Channel on a Roku Device), your Roku account registration information may need to be collected by the provider to create an account with that service.  For more information about how these providers will use your data, please see their respective privacy policies.

2. Purchase, Payment and Shipping Information

When you add a credit card or payment method to your account or place an order with us, we will also collect your payment information and billing address, and (if you make a product purchase), other information that may be needed to complete your purchase, such as your shipping address. 

We connect you with merchants who partner with us to offer goods and services for sale on the Roku Services, through features such as shoppable ads. If you interact with a shoppable ad or if you choose to make a purchase on the Roku Services from these participating merchants, they and their partners will also collect information about you or information you provide, including your name, billing address, shipping address, email address, phone number, and payment information, to process the transaction, fulfill and ship your order, and for other purposes.  You should review the privacy policies of the merchants whom you choose to transact with to understand how your data will be used by them. Roku will also collect your purchase 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 to communicate with you in accordance with your account preferences and device or service settings. You may modify your Roku communication preferences and settings at any time by updating this information in your Roku account, in the relevant Roku mobile app, or certain device settings. Please consult the relevant online support documentation here for more information.

4. Communications

If you contact us directly, we will receive additional information you provide, such as your name, email address and phone number, and the contents of any message or attachments that you send to us. You may also provide us with information if you subscribe to marketing communications from us or to obtain content such as product information, whitepapers and reports. If you message other users on the Roku Services like Roku Community, we will receive the contents of those messages.

5. Information You Provide About Others

We also collect the personal information of other people. For example, if you invite or refer our products or services to families and friends by providing their names or email addresses, or if you provide the postal addresses and other contact information of recipients for gift purchases. Personal information about other people may be collected and used when you use Roku Smart Home devices and services. For instance, your Smart Home Devices may capture videos, images or voice content of other individuals.  

We rely on you to obtain any required permissions in advance to allow us to collect their personal information.

6. Uploaded Files

Roku collects any files, including photos, videos or audio files, that you choose to upload to the Roku Services.

7. Comments, Reviews and Feedback

You can provide comments, reviews and feedback on Roku Sites (e.g., Roku’s developer forums, blogs, message boards, community pages), and accounts on third-party social networking sites. Information posted in these venues may be available to the public.  Please be mindful of your own privacy needs and those of others as you choose what to disclose and make public. We cannot control the privacy or security of information you choose to make public.

B. Information Collected Automatically Through the Roku Services

1. Device Information

We may receive information about the browsers and devices you use to access the Internet, including our services, such as device types and models, unique identifiers including advertising identifiers (e.g., for Roku Devices, the Advertising Identifier associated with that device), MAC address, 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. We may also gather the WiFi MAC addresses and broadcast signal strengths of your router and other Wi-Fi routers in your area. For Roku Devices, we may also collect the name of the retailer to whom your Roku Device was shipped, various quality measures, error logs, software version numbers, and device status (including the status of battery-powered accessories). When you enable Bluetooth while using Roku Services, 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. 

We may infer your general location information and internet service provider from the device information we collect (for example, IP address and MAC address may be used to infer your geographic area). You may also choose to provide your location to enhance the functionality of your Smart Home Devices.

2. Information from Cookies and Similar Technologies

We and our business partners, such as analytics and advertising partners, collect information about your online activities over time and across different online services. For example, we use cookies, pixel tags, web beacons, SDK, device identifiers or similar technologies to recognize you when you use Roku Services, and to collect information such as the number of visits, which features, pages, or content are popular, and to measure your browsing activities. These technologies allow us to optimize the operation of our services, including by allowing us to ensure our services are functioning properly, improve and personalize the services, and to provide, personalize, and measure advertisements. 

3. Activity, Location, and Usage Information on Roku Services

We receive information about your interactions with the Roku Services, such as your browsing history, search history, search results, audio information when you use voice-enabled features, interactions with content and ads, and settings and preferences. When you access streaming services on a Roku device or Roku’s Channels on other devices, we may collect information about your activities, like the channels you install or access (including usage statistics such as what channels you access, the time you access them, and how long you spend viewing them), and information about the videos and other content you select and stream within these streaming services. If you use the Roku Media Player to view your video or photo files or listen to your music files, Roku will collect data about the files viewed within the Roku Media Player, such as codecs, and other metadata of the local files you play through the Roku Media Player.  

When you use a Roku TV with the Smart TV experience enabled, we use Automatic Content Recognition (“ACR”) technology to receive information about what you watch via the Roku TV’s antenna (including live television content and ads), and via devices connected to your Roku TV (including streaming players, consoles and cable and satellite set top boxes). For example, we collect TV viewing information such as the programs, commercials, and channels you view, the date, time and duration of the viewing, and how you use the on-screen TV guide. We collect TV viewing information both when you access live TV directly through your Smart TV’s interface and when you access live TV from within a Third-Party Channel. If the Smart TV experience is enabled on your Roku TV, we will use this information to personalize your TV viewing experience and ads. 

If you use Roku’s mobile app as a remote control or to otherwise interact with another device (e.g., using Play on Roku to play videos, photos and music stored on your mobile device on your Roku TV or a TV with a Roku streaming player connected to it), we will collect the device identifier of the device with which the mobile app interacts. For features like Play on Roku, Roku’s mobile apps may need permissions to access the content and other information stored on your mobile device. 

Through Roku’s advertising services, we receive information about when, where and how an ad was displayed, the content you were viewing when the ad was served, and your clicks and any other information you provide when you interact with the ad (such as your phone number in order to receive a coupon code, your zip code to find an advertiser’s closest locations or information related to the purchases you make through our shoppable ads). For example, when Roku provides advertising services in Third-Party Channels, Roku receives information related to the ad, such as the name of the Third-Party Channel and the genre, language, and rating of the content you are watching when Roku serves the ad. 

When you visit websites, apps, channels, streaming services, and connected devices (including Smart TVs and mobile devices) to which Roku provides advertising or measurement and analytics services, we may receive information about your activities, including the content you view, the date and time of your visits, how you interact with these websites, apps and devices, and how you interact and respond to ads. We may also receive your precise geolocation information (including from ad networks and advertising partners) and use it for advertising purposes, including ad targeting.

• Support, Maintenance and Fulfillment. We use your information to provide and maintain the Roku Services, and to process and fulfill your requests or orders; 
• Improvement of Products and Services. We use your information to understand and analyze our user base and how you use the Roku Services, to improve and enhance the Roku Services (including building correlations for use in Roku’s advertising services in order to better serve our advertisers), and to develop new products, services, features and functionalities; 
• Personalization. We use your information to personalize your experience on the Roku Services, including suggesting and offering you relevant content and recommendations; 
• Advertising Services. We use your information to show you ads (including personalized ads) through the Roku Services, on Third-Party Channels, and on third-party websites, mobile apps, platforms and devices. We use your information to measure and understand the reach, viewership, and effectiveness of advertising, and to provide advertising analytics and reporting. We also help advertisers and advertising partners reach the desired audience and understand, measure and improve their ad campaigns. We associate the browsers and devices (such as smartphones, tablets, streaming players, connected TVs, and computers) used by the same individual or household for purposes of advertising to that individual or household on different browsers or devices. This allows, for example, ads you see on your tablet to be based on activities you engaged in on your Roku TV. 
• Marketing and Promotions. We use your information for marketing purpose, including to send you alerts, notifications, emails and text messages, about products, events, promotions and offers from Roku or its partners, and to measure and understand the effectiveness of our marketing; 
• Analytics and Performance. We use your information to measure performance and analyze key metrics relevant to our business; 
• Service Communication and Customer Care. We use your information 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; 
• Protect Roku, our Users and Others. We use your information to enforce our terms and conditions or protect our business, partners or users, and to comply with our contractual and legal obligations; and 
• Security and Fraud Prevention. We use your information to protect, investigate, and deter against fraudulent, unauthorized, infringing or illegal activity, including click fraud. 

Part III. Our Disclosure of Information 

A. 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 instance, we may use other companies to communicate with you (including 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 and other services, to obtain additional data about you, and to perform analytics and other work that we may need to outsource — such as using  Google Analytics to collect and process certain analytics data for Roku Services. These analytics services may also collect information regarding your use of other companies’ websites, apps, online services, and devices. You can learn about Google’s practices by going to https://www.google.com/policies/privacy/partners, and opt out of them by downloading the Google Analytics opt-out browser add-on, available at https://tools.google.com/dlpage/gaoptout.

B. Channel and Content Providers

We may disclose personal information (including Roku account registration information when you sign up with the channel or content provider, and information about your interactions with their content and the Roku Services), with partners whose services are available through the Roku Services such as providers of Third-Party Channels, Roku Direct Publisher Channels and other content providers on the Roku Services. This information is disclosed for different purposes, including for reporting and analytics (for example, to understand content popularity, viewership and use of the partners’ services), helping you subscribe to channels or access paid content, providing services to you, tailoring your user experience, customizing your content searches and discovery, and personalizing ads to you. 

C. Advertisers, Ad networks and other Advertising Partners

We work with ad networks and other advertising partners to show you ads that we think may interest you for Roku’s products and services on Roku Services and on other companies’ websites, apps, and devices. We also work with them to show you ads from advertisers on Roku Services and on other companies’ websites, apps, and devices. We disclose information to these ad networks, advertising partners and our advertisers, and they 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. 

D.  Advertising Measurement Providers and Services

We work with advertising measurement providers and their service providers to help us and our advertisers understand information about the content and ads viewed, and the effectiveness of ad campaigns, including the audience that saw their ads and how they responded. These measurement providers collect or receive information about your viewing of or interaction with content and ads, including ads that you view within Roku Direct Publisher Channels, Roku’s Channels and Third-Party Channels, as well as ads 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)), and ads you view on other websites, mobile apps, and connected devices (including Smart TVs) to which Roku provides advertising services. We may also disclose your demographics data and audience segments (e.g., sports fans, sitcom enthusiasts, cord cutters, etc.) with advertising measurement providers and their service providers. 

Measurement providers use your information to create statistics about what content and ads are being watched – for example, to help them and their clients understand the audience viewing the content or ads, and to measure the effectiveness of the ads. 

Roku, through its advertising services, provides measurement and analytics solutions to other companies. In providing these services, we analyze and reorganize ad campaign data from these companies and provide analytics reports to help them better understand the audience that viewed the company’s ads and whether those viewers belong to the same household. 

E.  Third-Party Platforms and Devices You Use

If you access our services, such as Roku’s Channels, on media streaming devices or mobile devices from other companies, we may disclose certain information to them, including information about your interactions with Roku’s Channel and its content, IP address, device identifier, and user privacy settings to coordinate on the provision of services to you, tailor your user experience, and personalize ads to you.  

F.  Participating Merchants

If you buy goods or services on the Roku Services, we may need to disclose information about you and information you provide to the merchant to process the transaction, fulfill and ship your order, and for other purposes. 

J.  Merger, Sale, or Other Asset Transfers

We may also disclose your information to 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. 

K.  As Required by Law and Similar Disclosures

We may also disclose your information (1) to comply with laws or to respond to lawful requests and legal process, (2) to protect the rights and property of Roku, our employees, agents, customers, and others, including to enforce our agreements, policies, and terms of use, (3) in an emergency to protect the personal safety of Roku, its employees or customers, or any person, or (4) to investigate, prevent, or take action regarding illegal or suspected illegal activities. 

L.  Aggregated or De-Identified Information

We may also disclose 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.), to 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 ads more relevant to your interests. 

M.  Other Users of the Roku Services

We may disclose your information to other users of the Roku Services at your request, or when you use certain features of our products and services. For instance, if you post comments or publish a review of a Roku product on the Roku Sites, other users of the Roku Sites will be able to read your review. If you upload content, including comments, videos or audio files, to the Roku Services, or if you grant access to your Roku Devices, these content and devices will be viewable by other users.  If you direct message another user through the Roku Services, then we will disclose your message and your user ID to that user. 

Part IV. Information Access and Choices

A. General Requests

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, 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.

A. California Consumer Privacy Act (“CCPA”)

For the purpose of this section, “Personal Information” means information that identifies, or could reasonably be associated with, you, your device or household, or as otherwise defined by the CCPA. Personal Information does not include information that is:  

• Publicly available, as defined by the CCPA.
• Deidentified or aggregated.
• Otherwise excluded from the scope of the CCPA.  

1. Sources of Personal Information We Collect  

We collect Personal Information from you when you provide it to us or automatically through the Roku Services. We may also obtain information about you from other sources, such as third-party platforms, devices and services used to access the Roku Services,  Third Party Channels, Roku Direct Publisher Channels, content providers, data providers, ad networks and advertising partners, advertisers, service providers (including payment service providers), participating merchants and their partners, and other users if they have referred you to the Roku Services or provided your information to us.  

2. Categories of Personal Information We Collect and Disclose to Third Parties  

Over the past 12 months, Roku has collected and disclosed each of the categories of Personal Information as described in the chart above. Roku does not have actual knowledge that it sells Personal Information or shares for cross-context behavioral advertising the Personal Information of consumers under 16 years of age. 

3. Purposes of Processing Personal Information  

We collect, use, or disclose your Personal Information for the purposes, including the business and commercial purposes, below:   

• To provide and maintain the Roku Services, and to process and fulfill your requests or orders. 
• To understand and analyze our user base and how you use the Roku Services, and to improve and enhance the Roku Services (including building correlations for use in Roku’s advertising services in order to better serve our advertisers), and to develop new products, services, features and functionality.
• To personalize your experience on the Roku Services, including suggesting and offering you relevant content and recommendations.
• To show you ads (including personalized ads) through the Roku Services, on Third-Party Channels, and on third-party websites, mobile apps, platforms and devices. We use your information to measure and understand the reach, viewership, and effectiveness of advertising, and provide advertising analytics and reporting. We also help advertisers and advertising partners reach the desired audience and understand, measure and improve their ad campaigns.
• For marketing purposes, including to send you alerts, notifications, emails and text messages, about products, events, promotions and offers from Roku or its partners, and to measure and understand the effectiveness of our marketing.
• To measure performance and analyze key metrics relevant to our business.
• 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.
• To enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.
• To protect, investigate, and deter against fraudulent, unauthorized, infringing or illegal activity, including click fraud. 

4. Retention 

Personal information we collect may be retained for as long as needed to fulfill legitimate business purposes, including the purposes outlined in Section 3, Purposes of Processing Personal Information, in this CCPA subsection, or for a time period specifically required or allowed by applicable regulations or laws. 

5. Your California Privacy Rights  

If you are a California resident, you may exercise the following rights: 

• The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which the Personal Information is collected, the business or commercial purpose for collecting, selling, or sharing Personal Information, the categories of third parties to whom we disclose Personal Information, and the specific pieces of Personal Information we have collected about you. 
• The right to correct inaccurate Personal Information that we maintain about you. 

• 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 the sale of Personal Information or sharing of Personal Information for cross-context behavioral advertising.  
• The right to limit our use or disclosure of your sensitive personal information, where permitted by law. 
• The right not to receive discriminatory treatment for the exercise of your CCPA privacy rights, subject to certain exceptions.  

For California residents, you can submit a request to know, correct, and delete your Personal Information through our online form . Such requests are subject to our ability to reasonably verify your identity. If you have a Roku account, we will verify your identity by asking you to log into your account. If you don’t have a Roku account, we will attempt to verify your identity by asking you to provide (through the online form or via privacy@roku.com)  data elements that we may have collected about you, such as your name, email address, device type, device ID, and cookie ID. You can exercise your right to opt out of the “sale” of your Personal Information or the “sharing” of your Personal Information for cross-context behavioral advertising, and limit our use of your sensitive personal information, where permitted by law here.  

You may authorize another person (your “authorized agent”) to submit a request on your behalf through the methods described above. Your authorized agent should submit proof that you gave the agent signed permission to submit the request. We may still require you to directly verify your identity and directly confirm that you have provided the authorized agent permission to submit the request.

B. California’s Shine-the-Light Law. 

California’s Shine the Light law 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 privacy@roku.com. 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.

C. Virginia Consumer Data Protection Act (“VCDPA”)

For the purpose of this section, “Personal Data” means any information that is linked or reasonably linkable to an identified or identifiable natural person. Personal Data does not include de-identified data, publicly available information (as these terms are defined under the VCDPA) or any other Personal Data otherwise excluded from the scope of the VCDPA. 

If you are a Virginia resident, you may exercise the following rights with respect to your Personal Data:  

• To confirm whether or not we process your Personal Data and request access to such data; 
• To delete Personal Data you have provided to us or that we have obtained about you, subject to exceptions; 
• To correct inaccuracies in your Personal Data; 
• To opt out of the processing of your Personal Data for purposes of: (i) targeted advertising; (ii) the sale of Personal Data; and (iii) the processing of your Personal Data for certain types of profiling in furtherance of decisions that produce legal or similarly significant effects; 
• To obtain a copy of your Personal Data in a portable and, to the extent technically feasible, readily usable format; 

• To appeal any decision with regard to your privacy request. 

Please note that there are exceptions and limitations to each of the rights listed above. If you are a Virginia resident, to exercise your right to opt out of the processing of your Personal Data for purposes of targeted advertising or the sale of Personal Data, where permitted by law, click here. To exercise any other privacy rights described above, please submit your request via our online form. 

Part VII. Modifications 

We may amend this Privacy Policy at any time by posting the amended version on the applicable Roku Site or by providing such notice about or obtaining consent to changes as may be required by applicable law.