Roku Privacy Policy

Account & Service Control · User right or choice

You can change Roku communication preferences in the account, the mobile app or some device settings

Roku gives the user a standing control: "You may modify your Roku communication preferences and settings at any time" by updating the information in the Roku account, in the relevant Roku mobile app, or "certain device settings". The control is offered at any time and through several places, but the last route is qualified — only some device settings carry it, and the text says which only by pointing to Roku's online support documentation.

Supporting quotations

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.

Qualifications & exceptions

• Available at any time, rather than only at signup or on request.
• Device-level controls are described as "certain device settings", so not every device setting necessarily carries the control.

Not stated here

• Which device settings include the control is left to Roku's online support documentation, which is not part of this document.

Account & Service Control · User right or choice

Location for Smart Home devices is presented as your choice to give

Alongside inference, Roku frames one location input as voluntary: "You may also choose to provide your location to enhance the functionality of your Smart Home Devices." The offer is tied to a benefit — making smart home features work better — and is worded as a choice, so it reads as opt-in rather than automatic.

Supporting quotations

You may also choose to provide your location to enhance the functionality of your Smart Home Devices.

Qualifications & exceptions

• Limited to location supplied for Smart Home device functionality.

Not stated here

• The document does not say what location granularity is shared or where the choice appears in the product.

Account & Service Control · Procedure

Questions about children's privacy go to Roku's Legal Department

For questions about Roku's processing of personal information described in the Children's Privacy Notice, Roku gives a contact route: its Legal Department at Roku, Inc. in San Jose, the privacy@roku.com address, and a telephone number. It is a postal, email and phone route rather than a form or portal, and it is stated specifically for the children's notice.

Supporting quotations

If you have any questions about our processing of personal information described in this Children’s Privacy Notice, you can contact Roku at:

privacy@roku.com

Qualifications & exceptions

• Stated for questions about the processing described in the Children's Privacy Notice.
• Contact routes given include Roku's Legal Department, an email address and a telephone number.

Not stated here

• No response time is promised.

Account & Service Control · User right or choice

You can ask to see, correct or delete your information, and Roku may refuse

Part V opens with access rights: a user with a Roku account may view and update certain contact and billing information by logging into the account on Roku.com, and may otherwise ask for access, correction or deletion of personal information Roku holds, through the linked privacy contact page. The right is qualified — Roku may decline requests that are unreasonable, prohibited by law, or not required to be honored by applicable law. So the route exists but the outcome depends on Roku's assessment and on the law that applies.

Supporting quotations

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.

Qualifications & exceptions

• Self-service covers certain contact and billing information only; other requests go through the privacy contact page.
• Requests may be declined where unreasonable, prohibited by law, or not required to be honored by applicable law.

Not stated here

• Which information is excluded from self-service, and what timelines apply, are not stated here.

Account & Service Control · User right or choice

Opting out of marketing email does not stop all email from Roku

Roku says its marketing emails explain how to opt out of further marketing emails, and offers a checkbox in the account to do so. Opting out has a stated limit: Roku may still send non-marketing email, examples being account and business-dealings messages and, where allowed by applicable law, survey invitations. So the choice removes marketing but leaves transactional and survey mail running.

Supporting quotations

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.

Qualifications & exceptions

• Non-marketing email continues: account and business-dealings messages, and survey requests where the law allows it.
• Two routes are named: instructions inside each marketing email and a checkbox in the account settings.

Not stated here

• Whether text-message marketing has an equivalent opt-out is not stated here.

Account & Service Control · User right or choice

A Personalized Ads setting can stop ad personalization while you use your account

A logged-in user can manage a preference for personalized ads from Roku through the Personalized Ads setting, reachable in the Privacy section of the Settings menu of Roku players and Roku TV models or on Roku's personalization page. Disabling it has a described effect: Roku will not personalize ads while the user is accessing its services using the Roku account, and ads continue but are less relevant. Roku explains what remains — contextual advertising, its own example being ads based on the subject matter being viewed or the time of day.

Supporting quotations

When you disable this setting, we will not personalize your ads while you are accessing our services using your Roku account. You will still see ads, but they will be less relevant to you.

Qualifications & exceptions

• Applies while accessing Roku services using the Roku account, not to unauthenticated use.
• Advertising continues, described as contextual — for example based on what is being viewed or the time of day.
• Reachable in device Settings privacy menus and through the Roku personalization page.

Not stated here

• Whether this setting changes Roku's other uses, such as measurement, is not stated here.

Account & Service Control · Restriction or exception

Third-Party Channels can ignore Roku's personalization setting

Roku warns that streaming a Third-Party Channel on a Roku player or Roku TV model may not respond to the Personalized Ads setting, and points the user to the app's own settings and the channel provider's privacy policy for choices there. The Roku-level control therefore does not guarantee the outcome inside another company's app.

Supporting quotations

If you are streaming a Third-Party Channel on a Roku player or Roku TV model, that app may not respond to this setting.

Qualifications & exceptions

• Applies to Third-Party Channels streamed on Roku players and Roku TV models.
• The channel may offer its own settings, and its privacy policy governs its choices.

Not stated here

• Which channels respond to the setting is not stated.

Account & Service Control · Procedure

The Advertising Identifier can be reset from device settings

Alongside the preference, Roku offers a reset: choosing Reset Advertising Identifier in the device settings resets the identifier of that Roku player or Roku TV model. This is a device-level action distinct from toggling personalization, and the document does not say what happens to previously collected activity once the identifier is reset.

Supporting quotations

You can also reset the Advertising Identifier of your Roku player or Roku TV model by choosing “Reset Advertising Identifier” in the device settings.

Qualifications & exceptions

• Applies to Roku players and Roku TV models through the device settings.

Not stated here

• Whether resetting removes prior profile associations is not stated.

Account & Service Control · User right or choice

Each ad opt-out covers only the one device or app it is set on

For use without logging in, or for other apps and devices where Roku provides advertising, Roku offers choices — and states their scope plainly: each mechanism opts the user out of Roku's personalizing of ads only for that specific device or app, and does not affect activity or personalized advertising on other apps or different devices. A user with several devices must therefore repeat the choice on each one.

Supporting quotations

Each of these opt-out mechanisms below opts you out of Roku’s personalizing of ads only for that specific device or app and will not affect activities or personalized advertising on other apps or different devices.

Qualifications & exceptions

• Limited to the specific device or app where it is exercised.
• Does not affect personalized advertising on other apps or devices.

Not stated here

• How many separate opt-outs an average household must make is not addressed.

Account & Service Control · User right or choice

On mobile apps the control is your operating system's limit ad tracking

One named route is the mobile operating system's own limit ad tracking setting, offered for advertising personalization in mobile apps. Roku points users to the platform's control rather than providing one of its own.

Supporting quotations

on mobile apps by using any limit ad tracking settings offered by your mobile operating system; and

Qualifications & exceptions

• Depends on the mobile operating system offering a limit ad tracking setting.

Not stated here

• What Roku does when no such setting exists is not stated.

Account & Service Control · User right or choice

On other companies' TVs and boxes, any limit ad tracking setting available

For Smart TVs, set top boxes, media streaming devices and other OTT platforms from other companies, Roku directs the user to that platform's limit ad tracking or similar setting, but only "if one is available". Where the platform offers nothing, this passage gives no alternative.

Supporting quotations

on Smart TVs, set top boxes, media streaming devices and other OTT platforms from other companies by using any limit ad tracking (or similar) settings offered by that platform, if one is available.

Qualifications & exceptions

• Applies to Smart TVs, set top boxes, media streaming devices and other OTT platforms made by other companies.
• Expressly conditional on that platform offering such a setting.

Not stated here

• What a user can do when no such setting exists is not stated.

Account & Service Control · User right or choice

The cookie opt-out for third-party ads works only in the browser you use

Roku offers its cookie consent tool to opt out of personalized ads from third parties on the Roku Sites, and states the limit: the tool opts the user out only for the specific browser used, and does not affect activity or targeted advertising on other browsers or different devices. Third-party personalized advertising on the Sites is therefore controlled browser by browser.

Supporting quotations

This tool opts you out of personalized advertising only for the specific browser from which you opt out and will not affect activities or targeted advertising on other browsers or different devices.

Qualifications & exceptions

• Limited to the specific browser used to opt out.
• Does not affect activity or targeted advertising on other browsers or devices.

Not stated here

• How long the opt-out persists in that browser is not stated here.

Account & Service Control · Company practice

The Roku Sites do not respond to Do Not Track signals

Roku addresses Do Not Track directly: because uniform standards for Do Not Track signals have not been adopted, the Roku Sites do not currently process or respond to them. A browser-level Do Not Track signal therefore produces no change on those sites, and Roku points users to an external explanation rather than offering an alternative.

Supporting quotations

Since uniform standards for “Do Not Track” signals have not been adopted, the Roku Sites do not currently process or respond to “Do Not Track” signals.

Qualifications & exceptions

• Applies to the Roku Sites rather than to Roku devices.
• The stated reason is the absence of adopted uniform standards, and the posture is described as current.

Not stated here

• Whether that position could change if standards are adopted is not promised.

Account & Service Control · User right or choice

ACR consent can be withdrawn from the Smart TV Experience settings

A user who enabled ACR can withdraw consent by going to the device's Settings, Privacy, Smart TV Experience menu and de-selecting Automatic Content Recognition (ACR). The withdrawal route is device-level, matching the earlier statement that ACR is something the user enables, and it is described as withdrawing consent rather than merely pausing collection.

Supporting quotations

you can withdraw your consent by going to Settings on your Roku device (Settings > Privacy > Smart TV Experience) and de-selecting “Automatic Content Recognition (ACR)”.

Qualifications & exceptions

• Requires access to Settings > Privacy > Smart TV Experience on the Roku device.
• Framed as withdrawal of consent to ACR.

Not stated here

• What happens to previously collected ACR data is not stated here.

Account & Service Control · User right or choice

Consent to disclose what you watch can be withdrawn, including title by title

The Content Viewing Disclosure setting can likewise be withdrawn in Settings > Privacy > Smart TV Experience by de-selecting it. Roku adds a narrower route for particular titles: emailing Roku at the Content Viewing Disclosure opt-out address. So a user can withdraw consent wholesale through the device, or ask about specific titles through an email request.

Supporting quotations

you can withdraw your consent by going to Settings on your Roku device (Settings > Privacy > Smart TV Experience) and de-selecting “Content Viewing Disclosure”.

If you wish to withdraw your consent to the disclosure of particular titles, email Roku at ContentViewingDisclosureOptOut@roku.com.

Qualifications & exceptions

• Device route withdraws consent generally; email route is described for withdrawing consent to disclosure of particular titles.

Not stated here

• What information the email request must contain, and how quickly it is actioned, are not stated.

Account & Service Control · User right or choice

Microphone access and Roku's retention of voice recordings can each be controlled

Voice controls sit under Settings > Privacy > Voice on Roku Devices with voice features, where the user governs apps' access to the microphone on the remote control or mobile device. Separately, Roku's own retention of voice recordings captured on a remote control or mobile device can be disabled from the Voice Settings page after logging into the account on Roku.com, and hands-free voice features on some remotes can be disabled as well. The controls therefore cover both microphone access and retention, but each is set in a different place.

Supporting quotations

Visit the Settings menu of your Roku Device with voice-activated features (under Settings > Privacy > Voice) for controls regarding apps’ access to the microphone on your remote control or mobile device.

You can also disable Roku’s retention of voice recordings captured on your remote control or mobile device by logging into your account on Roku.com and visiting the Voice Settings page.

Qualifications & exceptions

• Microphone access is managed in Settings > Privacy > Voice on the device.
• Retention of Roku's voice recordings is disabled through the account Voice Settings page on Roku.com.
• Hands-free voice features on some remotes can be disabled; instructions are left to product information or the support site.

Not stated here

• Whether disabling retention deletes recordings already held is not stated.

Account & Service Control · User right or choice

Smart Home device content, retention and transfer are managed in the app or webpage

Owners of Roku Smart Home devices can manage device settings and the retention and transfer of device content from the Roku Smart Home Mobile App or the Smart Home webpage. Roku also says users may be asked to provide video and audio recordings to help Roku and its partners improve products and services, but states that providing consent is not required. The consent request therefore exists without conditioning service on it.

Supporting quotations

You may be asked to provide video and audio recordings to help Roku and its partners improve their products and services but are not required to provide consent.

Qualifications & exceptions

• Covers device settings plus retention and transfer of device content.
• Contributing recordings is optional: consent is stated as not required.

Not stated here

• Default retention periods for smart home content are not stated here.

Account & Service Control · User right or choice

Cookie choices are per browser and device, and clearing cookies resets them

Many non-essential cookies served through a Roku Site can be managed or opted out of with the Cookie Consent Tool, but Roku spells out three limits: the choice applies only to the browser and device it was made on; rejecting or removing cookies may stop parts of the Sites working properly; and because the opt-out preference is itself stored in a browser cookie, deleting cookies, switching browsers or buying a new computer requires renewing the choice. The control is therefore self-limiting and can lapse without notice.

Supporting quotations

You may manage or opt-out of many non-essential cookies served through this Roku Site by using the Cookie Consent Tool provided. Your choices will apply only to the specific browser and device from which you opt out

Since your cookie opt-out preferences are also stored in a cookie in your website browser, please also note that if you delete all cookies, use a different browser, or buy a new computer, you will need to renew your opt-out choices.

Qualifications & exceptions

• Applies only to the specific browser and device, and not to Roku Devices or mobile devices.
• Rejecting or removing cookies may break features of the Sites.
• The opt-out preference is stored in a cookie, so clearing cookies or changing browser or computer reset it.

Not stated here

• Which cookies are classed as essential is not stated here.

Account & Service Control · User right or choice

The California list covers know, access, correct, delete, opt out, limit and appeal

The listed rights are: to know what Personal Information has been collected, including categories, sources, business or commercial purposes, third parties receiving it, categories sold or shared and the recipients of each, and categories disclosed for a business purpose with the service providers or contractors for each; to access specific pieces in a portable and readily usable format to the extent technically feasible; to correct inaccurate information; to request deletion; to opt out of the sale of Personal Information or its sharing for cross-context behavioral advertising; to limit use or disclosure of sensitive Personal Information where permitted by law; not to be retaliated against for exercising rights; and to appeal any decision on a privacy request.

Supporting quotations

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, the categories of Personal Information that the business sold or shared, and for each category identified, the categories of third parties to whom it sold or shared that particular category of Personal Information, and the categories of Personal Information that the business disclosed for a business purpose, and for each category identified, the categories of service providers or contractors to whom it disclosed that particular category of Personal Information.

The right to access the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format.

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.

The right to opt out of the sale of Personal Information, or the 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 to not be retaliated against for the exercise of your privacy rights.

The right to appeal any decision with regard to your privacy request

Qualifications & exceptions

• The access right is portable and readily usable only to the extent technically feasible.
• The right to limit sensitive Personal Information applies where permitted by law.
• The right to know extends to per-category recipient information for sale, sharing and business-purpose disclosure.

Not stated here

• The notice does not state here how an appeal is filed or how long Roku takes to decide one.

Cross-references

• qualifies (model-proposed): Sensitive-category information is listed for advertising and marketing too — The California chart lists targeted advertising and marketing for the category that reveals racial or ethnic origin, religion, union membership and health, while the same part's rights list offers a right to limit use or disclosure of sensitive Personal Information where permitted by law. The limit right is the control the reader has over the advertising use the row describes.

Account & Service Control · Procedure

Know, correct and delete requests go through an online form and identity checks

Requests to know, access, correct or delete are submitted through Roku's online form, and are subject to Roku's ability to reasonably verify identity where it has the right or obligation to do so. Account holders are verified by logging into the account; people without an account are asked for data elements Roku may already hold, such as device type, device ID and cookie ID, through the form or privacy@roku.com.

Supporting quotations

You can submit a right to know/access, correct, and deletion request to through our online form. Such requests are subject to our ability to reasonably verify your identity, where Roku has the right or obligation to do so under applicable law. 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 device type, device ID, and cookie ID.

Qualifications & exceptions

• Verification applies where Roku has the right or obligation to verify under applicable law.
• Without an account, Roku relies on data elements it may already hold to match the request.

Account & Service Control · Procedure

Opt-out and sensitive-data limits run through a choices page, device settings and GPC

Opting out of the sale of Personal Information or of sharing for cross-context behavioral advertising, and limiting use of sensitive Personal Information where permitted by law, can be done at Roku's Your Privacy Choices page or in the Privacy section of the Settings menu of Roku players and Roku TV models. For the Roku Sites, a browser Global Privacy Control signal is treated as a sale and sharing opt-out request; when logged in it applies to that account, and when not logged in or without an account it applies to the browser from which the signal is received, subject to Roku's ability to associate the signal with the user's information.

Supporting quotations

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, by visiting Roku’s Your Privacy Choices page or visiting the Privacy section of the Settings menu of your Roku players and Roku TV models. If you are visiting any Roku Site using a web browser with the Global Privacy Control (“GPC”) signal enabled, we will treat the GPC signal as a “sale” and “sharing” opt-out request. When you are logged into your Roku account, we honor a GPC signal as a request to opt out of the “sale” and “sharing” of personal information for that account. When you are not logged into a Roku account or you do not have a Roku account, we honor a GPC signal as a request to opt out of the “sale” and “sharing” of personal information for the browser from which the signal is received, subject to our ability to associate the signal with your information.

Qualifications & exceptions

• The sensitive-information limit is offered where permitted by law.
• The GPC treatment is stated for visits to a Roku Site using a browser with the signal enabled.
• The browser-level GPC opt-out is subject to Roku's ability to associate the signal with the person's information.

Not stated here

• The notice does not say how an opt-out set in device settings relates to an opt-out set on the choices page.

Account & Service Control · Procedure

An authorized agent needs signed permission and Roku may still verify the consumer

Where applicable law permits, another person may submit a request as the consumer's Authorized Agent through the same methods. The agent should submit proof of signed permission, and Roku may still require the consumer to verify identity directly and to confirm directly that the agent was authorized.

Supporting quotations

Where permitted by applicable law, 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.

Qualifications & exceptions

• Authority for an agent to act applies where permitted by applicable law.
• Roku keeps the option of direct verification and direct confirmation from the consumer.

Account & Service Control · User right or choice

The general rights list covers access, correction, deletion and the advertising opt-outs

The list includes a right to confirm whether Roku is processing Personal Information and to access the specific pieces collected in a portable and readily usable format to the extent technically feasible; a right to correct inaccurate information; a right to request deletion; a right to opt out of processing for targeted advertising; a right to opt out of the sale of Personal Information; and a right to limit collection, use or disclosure of sensitive Personal Information where permitted by law.

Supporting quotations

The right to confirm whether we are processing your Personal Information and to access the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format.

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.

The right to opt out of the processing of your Personal Information for targeted advertising.

The right to opt out of the sale of your Personal Information.

The right to limit our collection, use or disclosure of your sensitive Personal Information, where permitted by law.

Qualifications & exceptions

• Portable access is required only to the extent technically feasible.
• The sensitive-information limit applies where permitted by law.
• Targeted-advertising and sale opt-outs are separate rights in the list.

Account & Service Control · User right or choice

The list adds non-discrimination, appeal, a third-party list and a voice-and-face opt-out

The remaining rights in the list are freedom from discriminatory treatment for exercising privacy rights; the right to appeal any decision on a privacy request; the right to obtain a list of specific third parties, other than natural persons, to which Personal Information has been disclosed; and the right to opt out of any voice or facial recognition features.

Supporting quotations

The right to be free from discriminatory treatment for the exercise of your privacy rights.

The right to appeal any decision with regard to your privacy request.

The right to opt out of any voice or facial recognition features.

The right to obtain a list of specific third parties, other than natural persons, to which we have disclosed Personal Information.

Qualifications & exceptions

• The third-party list is limited to recipients other than natural persons.

Not stated here

• The list does not say how the voice and facial recognition opt-out is operated.

Account & Service Control · User right or choice

A profiling opt-out right is listed and Roku says it does not engage in that profiling

The list includes the right to opt out of profiling that furthers legal or significant decisions about the person, to query such a decision, be informed of the reasons and of what actions would secure a different outcome, review and correct inaccurate information used, and have the decision re-evaluated. The same entry then states that Roku does not engage in such profiling.

Supporting quotations

The right to opt-out of profiling in furtherance of producing legal or significant decisions concerning you, query the decision, be informed of reasons for the decision and what actions would secure a different decision, review and correct any inaccurate personal information used to make the decision, and have the decision re-evaluated. We do not engage in such profiling.

Qualifications & exceptions

• The right is described in detail and immediately followed by a denial that such profiling occurs.

Not stated here

• The notice does not say what happens to a profiling opt-out request if Roku considers that it does no such profiling.

Account & Service Control · Procedure

Access, correction, deletion and appeal requests go to a form or email with verification

Requests to access, correct, delete or appeal are submitted through Roku's online form or by email to privacy@roku.com, subject to Roku's ability to reasonably verify identity where it has the right or obligation to do so. Account holders verify by logging in; people without an account are asked for data elements Roku may hold, such as device type, device ID and cookie ID.

Supporting quotations

You can submit an access, correction, deletion, and appeal request through our online form or via e-mail at privacy@roku.com. Such requests are subject to our ability to reasonably verify your identity, where Roku has the right or obligation to do so under applicable law. 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 device type, device ID, and cookie ID.

Qualifications & exceptions

• Verification applies where Roku has the right or obligation under applicable law.

Account & Service Control · Procedure

Targeted-advertising and sale opt-outs use the choices page, device settings and required GPC

Opting out of processing for targeted advertising or of the sale of Personal Information is done at Roku's Your Privacy Choices page or in the Privacy section of the Settings menu of Roku players and Roku TV models. Where required by law, a browser Global Privacy Control signal on a Roku Site is treated as a request to opt out of targeted advertising and sale of Personal Information.

Supporting quotations

You can exercise your right to opt out of the processing of your Personal Information for targeted advertising or the “sale” of your Personal Information by visiting Roku’s Your Privacy Choices page or Privacy section of the Settings menu of your Roku players and Roku TV models. Where required by law, if you are visiting any Roku Site using a web browser with the Global Privacy Control (“GPC”) signal enabled, we will treat the GPC signal as a request to opt out of the use of your Personal Information for targeted advertising and the “sale” of your Personal Information.

Qualifications & exceptions

• The Global Privacy Control treatment is stated only where required by law, unlike the California part's unconditional treatment for Roku Sites.
• The opt-out covers targeted advertising and sale, with no separate sharing opt-out wording here.

Account & Service Control · Procedure

The general part also allows an authorized agent with signed permission

The general part repeats the authorized-agent mechanism: where permitted by applicable law, another person may submit a request on the consumer's behalf using the same methods, with proof of signed permission, and Roku may still require direct verification and direct confirmation from the consumer.

Supporting quotations

Where permitted by applicable law, 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.

Qualifications & exceptions

• Availability depends on applicable law permitting an agent.
• Direct verification of the consumer remains available to Roku.

Account & Service Control · User right or choice

Iowa and Utah residents get a separate sensitive-data opt-out sub-part

A short sub-part headed Iowa and Utah states that Iowa and Utah residents can opt out of Roku's processing of Personal Information that Iowa and Utah law consider sensitive, by visiting the Your Privacy Choices page or the privacy settings on a Roku device. This sub-part accounts for the two states that the general part's own list of seventeen states did not name.

Supporting quotations

C. Iowa and Utah

Iowa and Utah Residents: You can opt out of our processing of Personal Information that Iowa and Utah law considers to be sensitive by visiting Your Privacy Choices page or the privacy settings on your Roku device.

Qualifications & exceptions

• The opt-out is limited to information Iowa and Utah law treat as sensitive.
• Two routes are offered: the choices page and device privacy settings.

Not stated here

• The sub-part does not extend the general list of rights to Iowa and Utah residents in terms.

Cross-references

• qualified by (model-proposed): The general state part names seventeen states, without Iowa or Utah — The general state part lists seventeen states and leaves Iowa and Utah unnamed, and the later Iowa and Utah sub-part supplies the treatment for those two states: a sensitive-data opt-out rather than the general rights list. The two cards together account for the twenty states the notice's introduction names.

Account & Service Control · User right or choice

The Iowa and Utah list is shorter than the general rights list

The list contains rights to know what Personal Information has been collected, including categories, sources, business or commercial purposes and the categories of third parties to whom it is disclosed; to access specific pieces in a portable and readily usable format to the extent technically feasible; to correct inaccurate information; to request deletion; to opt out of the sale of Personal Information or of processing for targeted advertising; to limit use or disclosure of sensitive Personal Information where permitted by law; to be free from discriminatory treatment; and to appeal any decision on a privacy request. The profiling, voice-and-facial-recognition and specific-third-party-list rights that appear in the notice's general part are not repeated here.

Supporting quotations

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, and the categories of third parties to whom we disclose Personal Information.

The right to access the specific pieces of Personal Information we have collected about you in a portable and, to the extent technically feasible, readily usable format.

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.

The right to opt out of the sale of Personal Information, or the processing of Personal Information for targeted advertising.

The right to limit our use or disclosure of your sensitive Personal Information, where permitted by law.

The right to be free from discriminatory treatment for the exercise of your privacy rights.

The right to appeal any decision with regard to your privacy request

Qualifications & exceptions

• Portable access is required only to the extent technically feasible.
• The sensitive-information limit applies where permitted by law.
• The right to know here does not extend to per-category sale and sharing recipients as the California list does.

Not stated here

• The part does not say whether the profiling and recognition rights from the general part also apply to Iowa and Utah residents.

Account & Service Control · Procedure

Iowa and Utah access, correction and deletion requests go through the online form

Requests to know, access, correct or delete are submitted through Roku's online form and are subject to Roku's ability to reasonably verify identity where it has the right or obligation to do so. Account holders verify by logging in; people without an account are asked for data elements Roku may already hold, such as device type, device ID and cookie ID.

Supporting quotations

You can submit a right to know/access, correct, and deletion request to through our online form. Such requests are subject to our ability to reasonably verify your identity, where Roku has the right or obligation to do so under applicable law. 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 device type, device ID, and cookie ID.

Qualifications & exceptions

• Verification applies where Roku has the right or obligation under applicable law.
• The quoted sentence refers to the online form only, without the email alternative used in the California part.

Account & Service Control · Procedure

Iowa and Utah opt-outs and sensitive-data limits use the choices page or device settings

Opting out of the sale of Personal Information or of processing for targeted advertising, and limiting use of sensitive Personal Information where permitted by law, are done at Roku's Your Privacy Choices page or in the Privacy section of the Settings menu of Roku players and Roku TV models.

Supporting quotations

You can exercise your right to opt out of the “sale” of your Personal Information, or the processing of your Personal Information for targeted advertising, and limit our use of your sensitive Personal Information, where permitted by law, by visiting Roku’s Your Privacy Choices page or visiting the Privacy section of the Settings menu of your Roku players and Roku TV models. If you are visiting any Roku Site using a web browser with the Global Privacy Control (“GPC”) signal enabled, we will treat the GPC signal as a “sale” opt-out request.

Qualifications & exceptions

• The sensitive-information limit is offered where permitted by law.
• No Global Privacy Control treatment is stated in this paragraph, unlike the California and general parts.

Account & Service Control · Procedure

The Iowa and Utah part repeats the authorized-agent requirements

Where permitted by applicable law, an authorized agent may submit a request on the consumer's behalf using the same methods, with proof of signed permission, and Roku may still require the consumer to verify identity directly and confirm the agent's permission directly.

Supporting quotations

Where permitted by applicable law, 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.

Qualifications & exceptions

• Availability depends on applicable law permitting an agent.
• Direct verification of the consumer remains available to Roku.