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, 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 username. We also may collect similar contact information if you register to receive products or services, or copies of Roku blog posts.
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 also 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. 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.
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 of recipients for gift purchases.
6. Uploaded Files
Roku collects any files, including photos, videos or audio files, that you choose to upload to the Roku Services.
B. Information We Collect Automatically Through the Roku Services
1. Device Information
We may receive information about the browser and devices you use to access the Internet, including our services, such as device types and models, unique identifiers (including, 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 on a Roku Device, 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 general geographic area).
2. Information from Cookies and Similar Technologies
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 channels on a Roku device or Roku’s Channels on other devices, we may receive information about your activities, like the channels you 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 view within these channels. If you use the Roku Media Player channel 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 receive 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 receive 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 apps, in addition to the other usage information described in this section, we also log whether you use a feature called Play on Roku, which allows you 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. 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 or your zip code to find an advertiser’s closest locations). For example, when Roku provides advertising services in Third-Party Channels, Roku receives information related to the ad, such as the name of the Channel and the genre, language, and rating of the content you are watching when Roku serves the ad.
When you visit websites, apps, channels, and connected devices (including Smart TVs) 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 and use it for advertising purposes, including ad targeting.
4. 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. Advertisers that show ads through Roku’s advertising services may also provide data about individuals to us to personalize and measure ads through Roku’s advertising services.
We may also receive your personal information from others if they have referred you as described under Part I, Section A(5) above.
5. Information Collected by Channel Providers
If you install, access or stream a Third-Party Channel or Roku Direct Publisher Channel (i.e., a channel co-branded with the Roku logo on the channel’s home page) or if you conduct a voice search in one of these channels, you may also be interacting with that channel directly, and the channel provider and its advertising partners may collect information about your Roku Devices (including unique identifiers, IP addresses, and device settings like language and time zone) and your usage of that channel (e.g., videos, ads and other content you search, select and view within their channels, and audio information when you use some of the voice-enabled features). Channels may collect some of the information described in this section when the Channel is installed but not actively streaming.
6. Information Collected by Voice Assistant Providers
Part II. Information Usage
Information collected by Roku is used for the following purposes:
- 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, and to improve and enhance the Roku Services (including building correlations in Roku’s advertising services in order to better serve our advertisers), and to develop new products, services, features and functionality;
- 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 provide advertising analytics and reporting. We also help advertisers and advertising partners reach the desired audience and understand 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 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;
- 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
- 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. Information Sharing
A. Your Sharing
You can share reviews or feedback on the Roku Sites and comments and content on 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. 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 Roku 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, including information about your interactions with the Roku Services, with partners whose services are available through the Roku Services such as providers of Third-Party Channels and Roku Direct Publisher Channels. This information is shared for different purposes, including for reporting and analytics, providing services to you, tailoring your user experience, customizing your content searches and discovery, and personalizing ads to you. For example, we share users’ device identifiers with channel providers to enable users to cast content from those providers’ services to their Roku Devices.
If you access or subscribe to a channel from these partners on your device or through the Roku 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 for Roku Services. These analytics services may also collect information regarding your use of other companies’ websites, apps, online services, and devices. For example, 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.
4. Advertisers and Advertising Partners
We work with 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 advertising partners in order to show you ads from advertisers on Roku Services and on other companies’ websites, apps, and devices. We share information with these 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.
5. 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 share 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.
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 and name, device identifiers, its state (e.g., whether the device is powered on, whether the device is playing video), names of installed channels, 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 ads more relevant to your interests.
12. Other Users of the Roku Services
We may share your information with 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, that content will be viewable by the users you invited to see the content.
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.
C. Personalized Advertising Choices
- You can ask Roku to stop personalizing your ads on mobile apps by accessing any settings offered by your mobile operating system to limit ad tracking.
- You can ask Roku to stop personalizing your ads on websites by accessing the opt-out here.
- To ask Roku to stop personalizing your ads on Smart TVs, set top boxes, media streaming devices and other OTT platforms offered by other companies, you can use the Limit Ad Tracking (or similar) setting on that platform, if one is available.
Each of these opt-out mechanisms opts you out of Roku’s personalizing of ads only for that specific device or browser and will not affect activities or personalized advertising on other browsers or different devices.
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, Transfers and Security
A. 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 usernames and passwords to help prevent others from accessing your accounts and services.
C. Retention: 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, household ID, device identifiers, internet protocol addresses, browser cookies, 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.
- Geolocation data.
- 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. If you use The Roku Channel on Smart TVs, set top boxes, media streaming devices or other OTT platforms offered by other companies without logging in to a Roku account, please visit the Do Not Sell page in the TRC settings menu to opt out of sales from that device. 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 [email protected]. 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