Ad-fraud vendors supply IP addresses used to flag suspicious activity
The same sentence names a second operational source: ad fraud vendors provide IP addresses to help Roku identify potentially suspicious activities. The purpose is screening rather than marketing, and nothing here says what Roku does once activity is flagged.
Details
Why
identify potentially suspicious activities
Supporting quotations
ad fraud vendors that provide IP addresses to help us identify potentially suspicious activities
Qualifications & exceptions
Used to identify potentially suspicious activity, not to personalize content or ads.
Not stated here
What counts as potentially suspicious, and what follows from a flag, are not stated.
Fraud and abuse prevention is another stated use, including click fraud
The last purpose Roku lists for using information is security: protecting, investigating and deterring fraudulent, unauthorized, infringing or illegal activity, with click fraud named as an example. The purpose covers investigation as well as prevention, so it reaches looking into suspected conduct, and "unauthorized or infringing" activity goes beyond fraud alone.
Details
Why
protect, investigate and deter fraudulent, unauthorized, infringing or illegal activity
Supporting quotations
Security and Fraud Prevention. We use your information to protect, investigate, and deter against fraudulent, unauthorized, infringing or illegal activity, including click fraud.
Qualifications & exceptions
Includes investigating and deterring, not only preventing.
Click fraud is named as an example of the activity covered.
Not stated here
What triggers an investigation, or what follows one, is not described here.
Security & Safeguards · Company practice
Roku says it uses industry-standard security and that risk cannot be removed
Roku states that it uses industry-standard methods to secure electronic databases of personal information, and immediately qualifies this: no company, including Roku, can fully eliminate security risks associated with personal information. The advice that follows puts part of the burden on the user — a strong password, not reusing the password from other accounts or services, and protecting usernames and passwords. So the safeguard is described by standard rather than specifics, and residual risk is acknowledged.
Details
Exception
security risk cannot be fully eliminated
Supporting quotations
We use industry-standard methods of securing electronic databases of personal information. However, you should know that no company, including Roku, can fully eliminate security risks associated with personal information.
Qualifications & exceptions
Described as industry-standard methods applied to electronic databases of personal information.
Roku states expressly that no company can fully eliminate security risks.
Not stated here
The document does not describe the specific safeguards used.
Security & Safeguards · Company practice
Once abroad, your information is subject to that country's law and possible government access
Roku states the legal consequence of the transfer: while information is outside the user's country of residence it is subject to the laws of the country where it is held, and may be subject to disclosure to the governments, courts, or law enforcement or regulatory agencies of that country under its laws. Against that, Roku commits to protect all personal information it obtains in accordance with this Privacy Policy and to take reasonable steps to ensure it is treated lawfully. The commitment is expressed without naming any transfer mechanism.
Details
Why
treatment in accordance with this policy and reasonable steps for lawfulness
Supporting quotations
While such information is outside of your country of residence, it is subject to the laws of the country in which it is held, and may be subject to disclosure to the governments, courts or law enforcement or regulatory agencies of such other country, pursuant to the laws of such country.
We will protect all personal information we obtain in accordance with this Privacy Policy and take reasonable steps to ensure that it is treated lawfully.
Qualifications & exceptions
Applies while the information is outside the user's country of residence.
Possible disclosure is to governments, courts, or law enforcement or regulatory agencies of the holding country.
Roku's stated safeguard is protecting the information per this policy plus reasonable steps for lawful treatment.
Not stated here
No transfer mechanism or contractual safeguard is identified.