Roku Privacy Policy

Use & Processing · Company practice

Uploaded files may be reviewed by Roku, content moderation given as the example

The same sentence says Roku "may review" uploaded files and gives content moderation as its example. "May" makes review discretionary rather than promised or excluded, and "for example" means content moderation is illustrative — the same review could serve other ends the document does not name. A user cannot tell from this sentence whether a particular upload will be looked at, by whom, or how.

Supporting quotations

may review (for example, for content moderation purposes)

Qualifications & exceptions

• Review is discretionary ("may review") and the stated reason is only an example.

Not stated here

• The document does not say who reviews files, whether automated means are used, or what follows from a review.

Use & Processing · Company practice

Tracking technologies serve service improvement, personalization and ad measurement

Roku gives the uses of those technologies: they "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." The list runs from operations to advertising, so the same recognition data underlies both keeping the service working and measuring and personalizing ads; the document offers no separate control for the advertising half here.

Supporting quotations

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.

Qualifications & exceptions

• Purposes range from checking services function properly to personalizing and measuring advertisements.

Not stated here

• The text does not separate advertising use from operational use for any control purpose.

Use & Processing · Company practice

Advertisers give Roku data to personalize and measure ads

Advertisers running ads through Roku feed it data of their own: advertisers that show ads through Roku's advertising services may also provide data about individuals to Roku, to personalize and measure ads through those services, and for other purposes described in Part II. The stated uses are personalization and measurement, with Part II's broader purposes cross-referenced rather than repeated.

Supporting quotations

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, and for other purposes described in Part II.

Qualifications & exceptions

• Applies to advertisers that advertise through Roku's advertising services.
• Beyond personalizing and measuring ads, the purposes are those Part II lists.

Not stated here

• What kinds of individual-level data advertisers supply is not specified in this sentence.

Use & Processing · Company practice

Your information runs the Roku Services and fulfils your orders

The first listed use is operational: Roku uses the information to provide and maintain the Roku Services, and to process and fulfil the user's requests or orders. This is the baseline purpose that needs no separate permission — it covers keeping the service working and completing what the user asked for.

Supporting quotations

Support, Maintenance and Fulfillment. We use your information to provide and maintain the Roku Services, and to process and fulfill your requests or orders;

Qualifications & exceptions

• Limited to providing and maintaining the Roku Services and processing and fulfilling requests or orders.

Not stated here

• No retention period is given for information used this way.

Use & Processing · Company practice

Usage data improves Roku products and builds advertising correlations

Roku also uses the information to understand and analyse its user base and how the services are used, to improve and enhance them, and to develop new products, services, features and functionalities. Inside that purpose sits a specific advertising use, stated in parentheses: building correlations for use in Roku's advertising services in order to better serve its advertisers. Product improvement and the construction of advertising correlations therefore sit in the same stated purpose.

Supporting quotations

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;

Qualifications & exceptions

• Includes analysing the user base and service use, and developing new products, services, features and functionalities.
• Expressly includes building correlations for use in Roku's advertising services to better serve advertisers.

Not stated here

• What those correlations are built from is not specified beyond the collected information described earlier.

Use & Processing · Company practice

What you see on Roku is tailored from your information

A named purpose is personalization: Roku uses the information to personalize the user's experience on the Roku Services, including suggesting and offering relevant content and recommendations. Recommendations are therefore built on the collected information rather than being neutral listings.

Supporting quotations

Personalization. We use your information to personalize your experience on the Roku Services, including suggesting and offering you relevant content and recommendations;

Qualifications & exceptions

• Applies to the experience on the Roku Services; content suggestions and recommendations are the named example.

Not stated here

• The document does not offer a control for personalization at this point.

Use & Processing · Company practice

Ads, including personalized ones, are served on Roku and across other sites and devices

Roku uses the information to show ads, including personalized ads, through the Roku Services, on Third-Party Channels, and on third-party websites, mobile apps, platforms and devices. The same purpose covers creating online identifiers, measuring and understanding the reach, viewership and effectiveness of advertising, providing advertising analytics and reporting, and helping advertisers and advertising partners reach a desired audience and understand, measure and improve their campaigns.

Supporting quotations

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.

Qualifications & exceptions

• Includes personalized advertising, not only non-personalized placement.
• Extends to Third-Party Channels and third-party websites, mobile apps, platforms and devices.
• Covers measurement, analytics and reporting as well as ad delivery.

Not stated here

• No separate mechanism for limiting personalized advertising is given in this passage.

Use & Processing · Company practice

Roku markets to you by alert, email and text, including partner offers

Another listed purpose is marketing and promotion: sending alerts, notifications, emails and text messages about products, events, promotions and offers from Roku or its partners, and measuring and understanding the effectiveness of that marketing. Messages arrive through several channels and may carry partner offers, not only Roku's own.

Supporting quotations

We use your information 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;

Qualifications & exceptions

• Channels named are alerts, notifications, emails and text messages.
• Offers may come from partners as well as from Roku, and effectiveness measurement is included.

Not stated here

• How to opt out of these messages is not stated in this passage.

Use & Processing · Company practice

Business metrics are measured from your information

Analytics and performance is listed as its own purpose: Roku measures performance and analyses key metrics relevant to its business. It is stated generally, without naming which metrics or what is done with the results.

Supporting quotations

Analytics and Performance. We use your information to measure performance and analyze key metrics relevant to our business;

Qualifications & exceptions

• Framed as key metrics relevant to Roku's business rather than user-facing features.

Not stated here

• Which metrics Roku analyses is not stated.

Use & Processing · Company practice

Service messages and support run on your information too

Roku uses the information to communicate service information — confirmations, invoices, notices, updates, security alerts, user surveys, support and administrative messages — and to respond to comments and questions and provide customer service. Both transactional and support messaging therefore sit within the same purpose list.

Supporting quotations

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;

Qualifications & exceptions

• Covers confirmations, invoices, notices, updates, security alerts, surveys and support or administrative messages.
• Also covers responding to the user's own comments and questions.

Not stated here

• Whether service messages can be switched off is not stated here.

Use & Processing · Company practice

Roku sells measurement that tells other companies whether viewers share a household

Roku also provides measurement and analytics solutions to other companies through its advertising services. In doing so it analyzes and reorganizes those companies' ad campaign data and provides analytics reports to help them better understand the audience that viewed the company's ads and whether those viewers belong to the same household. So the household grouping described earlier is also a product feature: Roku tells other companies that different viewers share a home.

Supporting quotations

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.

Qualifications & exceptions

• Performed for other companies' campaigns through Roku's advertising services.
• Reports cover who viewed the ads and whether viewers belong to the same household.

Not stated here

• How Roku determines shared household membership is not stated.

Use & Processing · Company practice

Kids-area identifiers are limited to six named internal operations

For persistent identifiers and usage information from the protected parts, Roku states a closed purpose list it calls internal operations: maintaining or analyzing the functioning of the Roku Services; performing network communications; authenticating users of, or personalizing the content on, the Roku Services; serving contextual advertising on the Roku Services or capping the frequency of advertising; protecting the security or integrity of the user or the Roku Services; and ensuring legal or regulatory compliance. Personalization of content and contextual advertising are inside that list, while anything outside it is covered by the restriction described next.

Supporting quotations

Roku uses these voice commands to effectuate their instructions or requests, and the voice recordings that Roku collects are immediately deleted thereafter. Roku uses these persistent identifiers and usage information for the following internal operations:

Maintaining or analyzing the functioning of the Roku Services;

Performing network communications;

Authenticating users of, or personalizing the content on, the Roku Services;

Serving contextual advertising on the Roku Services or capping the frequency of advertising;

Protecting the security or integrity of the user or the Roku Services; and

Ensuring legal or regulatory compliance.

Qualifications & exceptions

• The six listed operations include content personalization and contextual advertising or frequency capping.
• Applies to persistent identifiers and usage information from the protected Kids & Family parts.

Not stated here

• How each operation is bounded in practice is not described.

Use & Processing · Company commitment

Kids-area data is walled off from behavioral advertising by policies and system restrictions

Roku states that it prevents these persistent identifiers and usage information from being used or disclosed for other purposes that do not constitute internal operations, giving behavioral advertising as the example, and it says this is done through internal policies and logic-based restrictions in its internal systems. As a concrete instance it says its behavioral advertising systems are configured to exclude personal information collected from those parts of the Roku Services. The control is therefore technical and internal rather than a user-facing switch.

Supporting quotations

Roku prevents these persistent identifiers and usage information from being used or disclosed for other purposes that do not constitute internal operations (such as behavioral advertising) through internal policies and logic-based restrictions in its internal systems.

Qualifications & exceptions

• The restriction covers use and disclosure for purposes outside the named internal operations.
• Behavioural advertising is named as an excluded use, with systems configured to exclude the data.
• Enforcement is described as internal policies plus logic-based restrictions in internal systems.

Not stated here

• The document does not describe any audit or external verification of these restrictions.

Use & Processing · Context

One listed purpose is providing the services and processing your orders

In the purposes column, Roku repeats its Part II purpose of providing and maintaining the Roku Services and processing and fulfilling requests or orders. The state notice therefore presents the same operational purpose as the basis for handling identifiers and the other listed categories.

Supporting quotations

To provide and maintain the Roku Services, and to process and fulfill your requests or orders.

Qualifications & exceptions

• Stated in the purposes column of the California categories table.

Not stated here

• The table does not tie individual purposes to individual categories on its face.

Use & Processing · Context

Improvement and advertising correlations appear as a listed purpose

Another row of the purposes column restates analysing the user base and service use, improving and enhancing the Roku Services — again including building correlations for Roku's advertising services to better serve advertisers — and developing new products, services, features and functionality. The advertising-correlation language from Part II is therefore carried into the state notice's purpose list.

Supporting quotations

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.

Qualifications & exceptions

• Stated in the purposes column of the California categories table.
• Advertising correlations are included in this purpose as in Part II.

Not stated here

• Which categories are processed for this purpose is not stated in the row itself.

Use & Processing · Context

Personalizing your experience is a listed purpose in the state notice

The purposes column also restates personalizing the user's experience on the Roku Services, including suggesting and offering relevant content and recommendations. The notice thus presents personalization as a purpose for processing the listed categories, consistent with Part II.

Supporting quotations

To personalize your experience on the Roku Services, including suggesting and offering you relevant content and recommendations.

Qualifications & exceptions

• Stated in the purposes column of the California categories table.

Not stated here

• No opt-out is attached to this purpose in the table itself.

Use & Processing · Context

The identifiers row lists targeted advertising and ad measurement as purposes

In the California categories table, the purposes column for identifiers includes showing ads, including targeted ads, through the Roku Services, on Third-Party Channels and on third-party websites, mobile apps, platforms and devices; measuring and understanding reach, viewership and advertising effectiveness; providing advertising analytics and reporting; and helping advertisers and advertising partners reach a desired audience and understand, measure and improve their campaigns. The same advertising language appears again later for other categories, so advertising purposes run across the listed categories rather than belonging to one row.

Supporting quotations

To show you ads (including targeted 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.

Qualifications & exceptions

• Given in the purposes column for the identifiers row and repeated for later categories.
• Includes cross-property targeted advertising and ad measurement and reporting.

Not stated here

• The table does not indicate which categories are used for each of these advertising purposes beyond their appearance in the row.

Use & Processing · Context

Marketing, business metrics, service messages, enforcement and fraud purposes are listed too

The same column also states marketing purposes, including alerts, notifications, emails and text messages about products, events, promotions and offers from Roku or its partners and measuring marketing effectiveness; measuring performance and analysing business metrics; sending service information such as confirmations, invoices, notices, updates, security alerts, surveys and support messages and responding to the user; enforcing terms and protecting the business, partners or users and complying with contractual and legal obligations; and protecting, investigating and deterring fraudulent, unauthorized, infringing or illegal activity including click fraud. The purposes therefore reproduce Part II's list inside the state notice.

Supporting quotations

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.

Qualifications & exceptions

• Each row restates a Part II purpose rather than adding a new one.
• Enforcement and fraud purposes are included alongside marketing and metrics.

Not stated here

• Nothing in the table distinguishes which categories each purpose applies to beyond the row structure.

Use & Processing · Context

Account registration information is processed for the same list of purposes

The purposes column repeats for the account registration row: providing and maintaining the services and fulfilling orders; understanding and analysing the user base and improving the services, including building correlations for Roku’s advertising services; personalizing the experience with relevant content and recommendations; marketing messages about Roku and partner offers; measuring performance and key business metrics; service communications and customer care; enforcing terms, protecting the business, partners or users and complying with contractual and legal obligations; and protecting, investigating and deterring fraudulent, unauthorized, infringing or illegal activity. Registration details are therefore not held to a narrower set of purposes than other categories.

Supporting quotations

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.

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.

Qualifications & exceptions

• Restates the Part II purpose list within the California categories table.
• Applies to the account registration information row, including payment method and card number.

Not stated here

• The table does not distinguish which of these purposes apply to which registration field.

Use & Processing · Context

Protected-classification and commercial information rows carry the same purposes again

The purposes column repeats for the protected-classification and commercial-information rows: providing and maintaining the services and fulfilling orders; understanding the user base and improving the services, again including building correlations for Roku’s advertising services; personalizing the experience with relevant content and recommendations; showing ads including targeted ads across Roku and third-party properties with measurement and reporting; marketing messages about Roku and partner offers; business metrics; and enforcing terms, protecting the business, partners or users and complying with contractual and legal obligations. The same purposes list therefore applies to sensitive and purchasing categories alike.

Supporting quotations

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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

To provide and maintain the Roku Services, and to process and fulfill your requests or orders.

Qualifications & exceptions

• Restates the Part II purpose list for categories C and D of the California table.
• Advertising correlations and cross-property targeted ads appear for these categories too.

Not stated here

• The table does not limit any purpose to a particular category.

Use & Processing · Context

Commercial information carries the full set of listed processing purposes

For the commercial-information row the purposes column runs from providing and maintaining the Roku Services and fulfilling requests or orders, through understanding the user base and improving the services (including building correlations for Roku's advertising services to serve its advertisers) and developing new products, to personalisation, advertising, marketing, business metrics, service communications and customer service, enforcing terms and legal obligations, and deterring fraud including click fraud. The advertising purpose is stated to reach the Roku Services, Third-Party Channels and third-party websites, apps, platforms and devices, and to include measuring reach, viewership and campaign effectiveness and helping advertisers reach and improve campaigns.

Supporting quotations

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 targeted 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.

Qualifications & exceptions

• Improvement and analysis is described as including correlations built for Roku's advertising services to better serve its advertisers.
• The advertising purpose extends beyond Roku's own surfaces to third-party websites, apps, platforms and devices.
• Fraud prevention names click fraud as the example.

Use & Processing · Context

Internet activity is tied to the same nine purposes in the state notice

The purposes column for category E repeats the pattern used for the earlier rows: providing and maintaining the services and fulfilling requests or orders; understanding and improving the services with advertising correlations and new product development; personalisation with suggested content; targeted advertising across Roku, Third-Party Channels and third-party properties with measurement and reporting; marketing messages from Roku or its partners; business metrics; service communications and customer service; enforcing terms and legal obligations; and deterring fraud and illegal activity. Reading the row together with its recipients shows browsing and app-interaction data feeding both advertising and the provider-facing recipient list.

Supporting quotations

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 targeted 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.

Qualifications & exceptions

• Each purpose is stated as a row entry without a stated legal basis in this table.

Use & Processing · Context

General geolocation supports service operation, improvement and personalisation

The purposes column for category F opens with providing and maintaining the Roku Services and fulfilling requests or orders, then understanding and improving the services with advertising correlations and new-product development, then personalising the experience with suggested content and recommendations. The row continues beyond these entries in the same table.

Supporting quotations

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.

Qualifications & exceptions

• These are the row's opening entries; the purposes list is not complete at this point in the table.

Use & Processing · Context

General geolocation also feeds advertising, marketing and business metrics

The rest of category F's purposes column adds targeted advertising across Roku, Third-Party Channels and third-party sites, apps, platforms and devices with measurement and campaign reporting; marketing messages and marketing-effectiveness measurement; business metrics; service communications and customer service; enforcement of terms and legal obligations; and fraud prevention including click fraud. Together with the opening entries read earlier, general geolocation is tied to the same full purpose list as the other broad categories.

Supporting quotations

To show you ads (including targeted 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.

Qualifications & exceptions

• The advertising purpose reaches third-party properties, not only Roku's own services.

Use & Processing · Context

Precise geolocation carries the shortest purpose list: service, personalisation and fraud

The purposes column for category G contains only three entries: providing and maintaining the Roku Services and fulfilling requests or orders, personalising the experience, and preventing, investigating and deterring fraudulent, unauthorised, infringing or illegal activity including click fraud. Unlike the rows around it, this row does not list advertising, marketing, business metrics, service communications or general improvement as purposes.

Supporting quotations

To provide and maintain the Roku Services, and to process and fulfill your requests or orders.

To personalize your experience on the Roku Services.

To protect, investigate, and deter against fraudulent, unauthorized, infringing or illegal activity, including click fraud.

Qualifications & exceptions

• The response is personalisation without the content-and-recommendations wording used in other rows.
• No advertising or marketing purpose appears in this row.

Not stated here

• The table does not explain why precise location has fewer purposes than general location.

Use & Processing · Context

Audio and visual data is listed for service, metrics, communications and security uses

The purposes column for category H lists providing and maintaining the services and fulfilling orders; understanding the user base and improving the services with advertising correlations and new-product development; business metrics; service communications and customer service; enforcing terms and legal obligations; and preventing fraud and illegal activity. Personalisation, targeted advertising and marketing do not appear in this row.

Supporting quotations

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 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.

Qualifications & exceptions

• The improvement entry still mentions correlations built for Roku's advertising services even though this row lists no advertising purpose.

Use & Processing · Context

Inferences carry the full nine-purpose list in the state notice

The purposes column for category I is the full list: providing and maintaining the services and fulfilling orders; understanding and improving the services, including advertising correlations and new products; personalisation with suggested content and recommendations; targeted advertising across Roku and third-party properties with measurement and reporting; marketing messages; business metrics; service communications and customer care; enforcement and legal obligations; and fraud prevention. The inferences row is thus tied to advertising as directly as the identifiers row.

Supporting quotations

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 targeted 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.

Qualifications & exceptions

• Advertising and marketing are both listed, so inferences are not confined to personalising content.

Use & Processing · Context

Employment information is also used for advertising, marketing and enforcement

The rest of category J's purposes column adds targeted advertising across Roku, Third-Party Channels and third-party properties with campaign measurement and reporting; marketing messages and marketing-effectiveness measurement; business metrics; and enforcement of terms and legal obligations. With the earlier entries, professional or employment information is tied to advertising and marketing, not only to workplace administration.

Supporting quotations

To show you ads (including targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Qualifications & exceptions

• Advertising here again extends to third-party websites, apps, platforms and devices.

Use & Processing · Context

Education information is processed for improvement, personalisation, ads and marketing

The purposes column for category K lists understanding and improving the services with advertising correlations and new products; personalisation with suggested content and recommendations; targeted advertising across Roku and third-party properties with measurement and reporting; marketing messages; business metrics; and enforcement of terms and legal obligations. Service communications, customer care and fraud prevention do not appear in this row.

Supporting quotations

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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Qualifications & exceptions

• This row lists advertising and marketing for education information.

Use & Processing · Context

Sensitive-category information is listed for advertising and marketing too

The purposes column for category L repeats the pattern: improvement and advertising correlations, personalisation, targeted advertising across Roku and third-party properties with measurement and reporting, marketing messages, business metrics and enforcement of terms and legal obligations. As written, the row does not carve these sensitive attributes out of advertising or marketing.

Supporting quotations

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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Qualifications & exceptions

• The row itself lists advertising and marketing; no exception for sensitive attributes appears in this row.
• Service communications and fraud prevention are absent from this row.

Not stated here

• Whether another part of the policy limits advertising use of these sensitive attributes is not stated in this row.

Cross-references

• qualified by (model-proposed): The California list covers know, access, correct, delete, opt out, limit and appeal — 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.

Use & Processing · Context

Credential and message data carries only service, enforcement and fraud purposes

The purposes column for category M is limited to providing and maintaining the Roku Services and fulfilling requests or orders, enforcing terms and protecting the business, partners or users and complying with contractual and legal obligations, and preventing, investigating and deterring fraudulent, unauthorised, infringing or illegal activity including click fraud. Advertising, marketing and personalisation do not appear for this category.

Supporting quotations

To provide and maintain the Roku Services, and to process and fulfill your requests or orders.

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.

Qualifications & exceptions

• No advertising, marketing or personalisation purpose is listed in this row.

Use & Processing · Context

Identifiers carry the nine processing purposes in the general state chart

The purposes column for identifiers lists service operation and order fulfilment; user-base analysis and service improvement with advertising correlations and new products; personalisation with suggested content; targeted advertising across Roku, Third-Party Channels and third-party properties with campaign measurement and reporting; marketing messages; business metrics; service communications and customer care; enforcement of terms and legal obligations; and fraud detection including click fraud.

Supporting quotations

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 targeted 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.

Qualifications & exceptions

• Each purpose is presented as a row entry without a stated legal basis in the chart.

Use & Processing · Context

Registration information also drives personalisation, marketing and metrics

The rest of category B's purposes column adds user-base analysis and service improvement with advertising correlations and new products; personalisation with suggested content; marketing messages and marketing-effectiveness measurement; business metrics; service communications and customer care; enforcement of terms and legal obligations; and fraud prevention including click fraud. Registration details are therefore used well beyond setting up and running an account.

Supporting quotations

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.

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.

Qualifications & exceptions

• Advertising and marketing are listed for account registration details.

Use & Processing · Context

Protected-classification data is used for advertising and marketing in this chart

The purposes column for category C lists service operation and order fulfilment; user-base analysis and service improvement with advertising correlations and new products; personalisation; targeted advertising across Roku and third-party properties with campaign measurement and reporting; marketing messages; business metrics; and enforcement of terms and legal obligations. Service communications and fraud prevention do not appear in this row.

Supporting quotations

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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Qualifications & exceptions

• Advertising and marketing are listed for this category.
• The row is already limited to data that is not sensitive under applicable state law.

Use & Processing · Context

Commercial information is processed for service, ads, marketing and communications

The purposes column for category D lists service operation and order fulfilment; user-base analysis and improvement with advertising correlations and new products; personalisation; targeted advertising with measurement and reporting; marketing messages and marketing-effectiveness measurement; business metrics; and service communications and customer care. Enforcement and fraud entries continue the same row below.

Supporting quotations

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 targeted 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.

Qualifications & exceptions

• The row continues beyond the entries quoted here.

Use & Processing · Context

Commercial information's purpose list ends with enforcement and fraud prevention

The last two purposes for category D are enforcing Roku's terms and protecting the business, partners or users while complying with contractual and legal obligations, and protecting against, investigating and deterring fraudulent, unauthorised, infringing or illegal activity including click fraud. These complete the nine-purpose list for commercial information in the general state chart.

Supporting quotations

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.

Qualifications & exceptions

• Fraud prevention names click fraud as the example.

Use & Processing · Context

Internet activity carries the nine purposes in the general state chart

The purposes column for category E lists service operation and order fulfilment; user-base analysis and improvement with advertising correlations and new products; personalisation; targeted advertising across Roku and third-party properties with campaign measurement and reporting; marketing; business metrics; service communications and customer care; enforcement of terms and legal obligations; and fraud prevention including click fraud.

Supporting quotations

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 targeted 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.

Qualifications & exceptions

• Advertising is listed alongside the service and security purposes.

Use & Processing · Context

General geolocation also serves marketing, metrics, messages and security

The rest of category F's purposes column adds marketing messages and marketing-effectiveness measurement; business metrics; service communications and customer care; enforcement of terms and legal obligations; and fraud prevention including click fraud. The row's purpose list therefore matches the full nine-purpose pattern used for identifiers and internet activity.

Supporting quotations

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.

Qualifications & exceptions

• Marketing messages are described as coming from Roku or its partners.

Use & Processing · Context

Audio and visual data is used for service, metrics, messages and security

Category H is audio, electronic, visual, thermal, olfactory or similar information, and its purposes column lists service operation and order fulfilment; user-base analysis and improvement with advertising correlations and new products; business metrics; service communications and customer care; enforcement of terms and legal obligations; and fraud prevention including click fraud. Personalisation, targeted advertising and marketing are not listed for this row.

Supporting quotations

H. Audio, electronic, visual, thermal, olfactory, or similar information

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 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.

Qualifications & exceptions

• The improvement entry still mentions correlations for Roku's advertising services although no advertising purpose is listed in this row.
• "Similar information" extends the category beyond the named types.

Not stated here

• The chart does not say which Roku features produce each type of audio or visual information.

Use & Processing · Context

Employment information's purpose list omits service operation and communications

Category J is professional or employment information. Its purposes column lists improvement of the services with advertising correlations and new products, personalisation, targeted advertising with measurement and reporting, marketing messages, business metrics and enforcement of terms and legal obligations. Unlike the earlier rows, it does not list service operation or order fulfilment, service communications, or fraud prevention.

Supporting quotations

J. Professional or Employment 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 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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Qualifications & exceptions

• No service-operation, service-communication or fraud-prevention purpose appears in this row.
• Advertising and marketing are listed for employment information.

Use & Processing · Context

Education information is listed for improvement, ads and marketing, without service use

Category K is education information. Its purposes column lists improvement with advertising correlations and new products, personalisation, targeted advertising with measurement and reporting, marketing messages, business metrics and enforcement of terms and legal obligations, and does not list service operation and order fulfilment, service communications, or fraud prevention.

Supporting quotations

K. Education 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 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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Qualifications & exceptions

• No service-operation, service-communication or fraud-prevention purpose appears in this row.

Not stated here

• The chart does not say how Roku obtains education information about a user.

Use & Processing · Company practice

Roku says user data may train its internal machine learning models unless the law forbids it

After the general state chart, Roku states that, unless prohibited by applicable law, data collected from the user or the user's devices may be used to improve Roku's internal machine learning models, which are used for purposes such as recommending content and apps, and that this may constitute "training" of "large language models" under certain applicable laws. The statement is qualified by law and describes internal models, not models belonging to third parties.

Supporting quotations

Unless prohibited by applicable law, data collected from you or your devices may be used to improve Roku’s internal machine learning models, which are used for purposes such as recommending content and apps to you. This may constitute “training” of “large language models” under certain applicable laws.

Qualifications & exceptions

• "Unless prohibited by applicable law" makes the practice conditional on the applicable legal regime.
• The models are described as Roku's internal models.
• The stated example purpose is recommending content and apps.

Not stated here

• The notice does not say which data categories are used for training or whether users can opt out of training.

Use & Processing · Context

The targeted-advertising chart lists nine purposes for identifiers

In the Iowa and Utah part's chart, category A is identifiers: device identifiers, internet protocol addresses, browser cookies and other unique online identifiers. Its purposes column lists service operation and order fulfilment, improvement with advertising correlations and new products, personalisation, targeted advertising across Roku and third-party properties with measurement and reporting, marketing, business metrics, service communications and customer care, enforcement and fraud prevention.

Supporting quotations

A. Identifiers, including, device identifiers, internet protocol addresses, browser cookies, and other unique online identifiers

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 targeted 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.

Qualifications & exceptions

• The examples of identifiers are network and device level rather than account details.

Use & Processing · Context

Registration information's purposes include advertising in the Iowa and Utah chart

Category B is account registration information: name, address, email address, telephone number, and payment method and card number. Its purposes column lists service operation and order fulfilment, improvement with advertising correlations and new products, personalisation, marketing, business metrics, service communications and customer care, enforcement and fraud prevention. The row as printed here does not repeat the targeted-advertising entry that appears in the identifiers row above it.

Supporting quotations

B. Account registration Information, i.e., name, address, email address, telephone number, and payment method and card number

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.

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.

Qualifications & exceptions

• Payment method and card number are treated as registration information.
• Advertising appears in a neighbouring row but not in this purposes list.

Use & Processing · Context

The Iowa and Utah chart lists personalisation, ads, marketing and metrics for protected-classification data

The rest of category C's purposes column adds improvement with advertising correlations and new products, personalisation, targeted advertising across Roku and third-party properties with measurement and reporting, marketing, business metrics and enforcement of terms and legal obligations. With the opening service purpose, the row carries seven purposes and no service-communication or fraud entry.

Supporting quotations

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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Qualifications & exceptions

• Targeted advertising and marketing are listed for this category in this chart.
• No service-communication or fraud-prevention purpose appears in this row.

Not stated here

• The chart does not say whether Iowa or Utah law treats any of these characteristics as sensitive, which the earlier general chart excluded from its category C.

Use & Processing · Context

Commercial information repeats the full purpose list in the Iowa and Utah chart

Category D is commercial information, including records of personal property, products or services purchased, obtained or considered, and other purchasing or consuming histories. Its purposes column is the full nine entries: service operation and order fulfilment, improvement with advertising correlations and new products, personalisation, targeted advertising with measurement and reporting, marketing, business metrics, service communications and customer care, enforcement and fraud prevention.

Supporting quotations

D. Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies

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 targeted 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.

Qualifications & exceptions

• Items considered but not purchased are included in the category.

Use & Processing · Context

Internet activity's purposes in the Iowa and Utah chart add ads, marketing and security

The rest of category E's purposes column adds targeted advertising across Roku and third-party properties with measurement and reporting; marketing; business metrics; service communications and customer care; enforcement of terms and legal obligations; and fraud prevention including click fraud. With the opening entries, the row carries all nine purposes.

Supporting quotations

To show you ads (including targeted 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.

Qualifications & exceptions

• Targeted advertising here extends to third-party websites, apps, platforms and devices.

Use & Processing · Context

General geolocation carries the nine purposes in the Iowa and Utah chart

Category F is general geolocation data, described as general location and geographical information including designated market area, country, province, state, city and postal code. Its purposes column lists service operation and order fulfilment, improvement with advertising correlations and new products, personalisation, targeted advertising with measurement and reporting, marketing, business metrics, service communications and customer care, enforcement and fraud prevention.

Supporting quotations

F. General geolocation data, such as general location and geographical information, including designated market area, country, province, state, city, and postal code

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 targeted 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.

Qualifications & exceptions

• The described data is coarse geographic information rather than precise coordinates.

Use & Processing · Context

Audio and visual data is used for service, improvement, metrics and security here

Category H is audio, electronic, visual, thermal, olfactory or similar information. Its purposes column lists service operation and order fulfilment, improvement with advertising correlations and new products, business metrics, service communications and customer care, enforcement and fraud prevention. Personalisation, targeted advertising and marketing do not appear in this row.

Supporting quotations

H. Audio, electronic, visual, thermal, olfactory, or similar information

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 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.

Qualifications & exceptions

• The improvement entry names advertising correlations although the row lists no advertising purpose.

Use & Processing · Context

Inferences carry the nine purposes in the Iowa and Utah chart

Category I is inferences drawn from Personal Information, including preferences, interests and other information used to personalise the experience. The purposes column lists service operation, improvement with advertising correlations, personalisation, targeted advertising with measurement and reporting, marketing, business metrics, service communications and customer care, enforcement and fraud prevention.

Supporting quotations

I. Inferences drawn from Personal Information, including your preferences, interests, and other information used to personalize your experience

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 targeted 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.

Qualifications & exceptions

• Targeted advertising and marketing apply to derived preferences and interests.

Use & Processing · Context

Employment information in the Iowa and Utah chart opens with improvement and personalisation

Category J is professional or employment information. Its purposes column begins with improvement of the services including advertising correlations and new products, personalisation with suggested content, targeted advertising with measurement and reporting, marketing, business metrics and enforcement of terms and legal obligations, and its disclosure column begins with service providers and vendors, advertisers, ad networks and advertising partners, and advertising measurement providers.

Supporting quotations

J. Professional or Employment 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 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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers

Qualifications & exceptions

• No service-operation, service-communication or fraud-prevention purpose appears in the quoted entries.
• The row continues below the entries quoted here.

Use & Processing · Context

Education information is listed for six purposes in the Iowa and Utah chart

Category K is education information. Its purposes column lists improvement with advertising correlations and new products, personalisation, targeted advertising with measurement and reporting, marketing, business metrics and enforcement of terms and legal obligations, without service operation, service communications or fraud prevention.

Supporting quotations

K. Education 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 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 targeted 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 enforce our terms and conditions or protect our business, partners or users, and comply with our contractual and legal obligations.

Qualifications & exceptions

• No service-operation, service-communication or fraud-prevention purpose appears in this row.