Roku Privacy Policy

Sharing & Disclosure · Company practice

Third-party channel providers and their ad partners may collect from your Roku Device

Using a Third-Party Channel means dealing with that app's publisher directly, and Roku says that publisher "and its analytics and advertising partners may collect information from your Roku Device, including your device identifier and how you use their services". The collection runs from the device itself, so it happens whether or not Roku is involved in it; the named data points are the device identifier and the user's use of that app. The same passage notes that hybrid broadcast broadband (hbbtv) channels may exist in some regions, so which third-party channels are even reachable depends on where the viewer is.

Supporting quotations

the app provider and its analytics and advertising partners may collect information from your Roku Device, including your device identifier and how you use their services.

Qualifications & exceptions

• This follows from installing, accessing or streaming the third-party app; the document ties it to that interaction.
• Availability of hbbtv channels, one category of Third-Party Channel, varies by region.

Not stated here

• The text does not say what the app provider or its partners do with the device identifier afterwards, or list the analytics and advertising partners.

Sharing & Disclosure · Company practice

Subscribing to another company's streaming service can pass your registration details to it

When a subscription is bought through the Roku Services to a streaming service run by someone else — on Roku Sites, inside The Roku Channel, or for a Third-Party Channel on the device — Roku says "your Roku account registration information may need to be collected by the provider to create an account with that service". The recipient is that provider, acting to set up its own account for you, and Roku points to that provider's privacy policy rather than describing its handling. The wording is permissive ("may need to be"), not a flat statement that it always happens.

Supporting quotations

your Roku account registration information may need to be collected by the provider to create an account with that service.

Qualifications & exceptions

• Only when you subscribe to another provider's streaming service through the Roku Services, and only "as may be needed" to create the account.
• The receiving provider's own privacy policy governs what it does afterwards; this document does not describe it.

Not stated here

• Which registration fields are actually transferred, and whether the transfer is optional, are not stated here.

Sharing & Disclosure · Company practice

Participating merchants and their partners collect your details, including for unnamed "other purposes"

Roku connects users with merchants selling goods on the Roku Services through features such as shoppable ads. Interacting with a shoppable ad, or choosing to buy from these merchants, means "they and their partners will also collect information about you", named as name, billing address, shipping address, email address, phone number and payment information. The stated uses are processing the transaction, fulfilling and shipping the order — and then "and for other purposes", which the document leaves open, so the permitted uses extend past the ones enumerated. Roku tells the reader to review those companies' privacy policies, which this document does not substitute for.

Supporting quotations

they and their partners will also collect information about you or information you provide, including your name, billing address, shipping address, email address, phone number, and payment information, to process the transaction, fulfill and ship your order, and for other purposes.

Qualifications & exceptions

• Applies when you interact with a shoppable ad or choose to purchase from participating merchants on the Roku Services.
• Roku's own collection of purchase information sits alongside this and is stated separately.

Not stated here

• The "other purposes" for which merchants and their partners may use the information are not listed in this text.

Sharing & Disclosure · Company practice

Comments and reviews you post may be visible to the public

Roku invites comments, reviews and feedback on Roku Sites — developer forums, blogs, message boards, community pages — and on its third-party social networking accounts, and warns that "Information posted in these venues may be available to the public." The consequence is that anything written there leaves the boundary of Roku's own systems; because the venues include third-party social networks, the audience is not only Roku users.

Supporting quotations

Information posted in these venues may be available to the public.

Qualifications & exceptions

• Reaches comments, reviews and feedback on Roku Sites and Roku's third-party social networking accounts.
• Availability is stated as "may be available to the public", depending on the venue.

Not stated here

• The document does not say which posts are public and which are not.

Sharing & Disclosure · Permission or license

Asking a voice assistant to show Roku content authorises sharing it with that assistant

The same passage covers a specific disclosure: directing a virtual assistant to display content, given as the feed of the user's Roku home security camera, is described as authorizing Roku to provide that information to the virtual assistant provider to carry out the request. The authorization is the user's request itself, and the content can be sensitive in kind — a home security camera feed is the document's own example.

Supporting quotations

If you direct a virtual assistant to display content (such as the feed of your Roku home security camera), you are authorizing Roku to provide that information to the virtual assistant provider to carry out your request.

Qualifications & exceptions

• Triggered by directing a virtual assistant to display content; the document's example is a Roku home security camera feed.
• The stated purpose is carrying out that request.

Not stated here

• The text does not say whether the assistant provider keeps the content afterwards.

Sharing & Disclosure · Company practice

Contractors and service providers may access and use your information

Part III opens with vendors: Roku works with other businesses, including contractors and service providers, to provide services and help run its operations, and that may require them to access and use the user's information. The examples show how wide the access is — other companies communicating with the user by phone, email or letter, processing and collecting card payment, providing customer support, and obtaining additional data about the user. Support access is spelled out further: a chat feature managed by Roku's service providers means those providers receive the user's communications through it.

Supporting quotations

We work with other businesses (including contractors and service providers) to provide services for us and to help with our operations, which may require that they access and use your information.

including any chat feature managed by our service providers, who will receive your communications through the chat feature

Qualifications & exceptions

• Access follows from vendors providing services or helping with Roku's operations, not from any separate notice.
• Named examples include outsourced communications, payment processing, customer support and obtaining additional data about the user

Not stated here

• Roku does not say how it limits what vendors may do with the information, or list its vendors.

Sharing & Disclosure · Company practice

Outsourced analytics such as Google Analytics reach your use of other companies' sites and apps

Roku names Google Analytics as an example of analytics work it outsources, and says these analytics services may also collect information regarding the user's use of other companies' websites, apps, online services and devices. Roku gives two pointers rather than a control of its own: Google's partner privacy page for its practices, and a Google Analytics opt-out browser add-on. The opt-out is described as a browser add-on, so it is a browser mechanism rather than a Roku setting.

Supporting quotations

These analytics services may also collect information regarding your use of other companies’ websites, apps, online services, and devices.

Qualifications & exceptions

• Reaches the user's use of other companies' websites, apps, online services and devices.
• The offered opt-out is the Google Analytics browser add-on, not a Roku control.

Not stated here

• Whether Roku's own analytics use can be switched off is not stated in this passage.

Sharing & Disclosure · Company practice

App and content partners receive your registration and interaction information

Roku may disclose personal information to partners whose services are available through the Roku Services — providers of Third-Party Channels, media content or other services — and it says what that information may include: Roku account registration information, and information about the user's interactions with those providers, their services and the Roku Services. The disclosure is stated to serve different purposes, enumerated as reporting and analytics, helping the user subscribe to apps or access paid content, providing services to the user, tailoring the user experience, customizing searches and discovery, and personalizing ads. Registration details are therefore not confined to Roku, and title-level or provider-level interaction data leaves Roku too.

Supporting quotations

We may disclose personal information with partners whose services are available through the Roku Services such as providers of Third-Party Channels, media content, or other services on the Roku Services.

This information may include Roku account registration information, and information about your interactions with these providers, their services and the Roku Services, and it is disclosed for different purposes, including for reporting and analytics, helping you subscribe to apps or access paid content, providing services to you, tailoring your user experience, customizing your searches and discovery, and personalizing ads to you.

Qualifications & exceptions

• Recipients are partners whose services run through the Roku Services, including Third-Party Channel and media content providers.
• Enumerated purposes include personalizing ads and customizing searches and discovery, not only service delivery.

Not stated here

• The text does not say how much of the interaction record is disclosed, or let the user choose.

Sharing & Disclosure · Company practice

Ad networks set their own trackers on Roku and collect across services over time

Roku works with ad networks and other advertising partners to show ads for Roku's own products and for advertisers, both on the Roku Services and on other companies' websites, apps and devices, and it discloses information to those ad networks, advertising partners and advertisers. Those recipients may set and access their own cookies, pixel tags and similar technologies on the Roku Services, and may otherwise collect or have access to information about the user which they collect over time and across different online services and devices. The tracking is therefore the partners' own, accumulates over time, and is not confined to Roku's properties.

Supporting quotations

We disclose information to these ad networks, advertising partners and our advertisers, and they may set and access their own cookies, pixel tags and similar technologies on the Roku Services and they may otherwise collect or have access to information about you which they collect over time and across different online services and devices.

Qualifications & exceptions

• Recipients include ad networks, advertising partners and advertisers.
• Their own cookies, pixel tags and similar technologies may be set and accessed on the Roku Services.
• Their collection accumulates over time and across different online services and devices.

Not stated here

• The partners are not named, and no Roku-side control for this disclosure is offered here.

Sharing & Disclosure · Company practice

Measurement providers learn what content and ads you saw and how campaigns performed

Roku works with advertising measurement providers and their service providers to help itself, advertisers and others understand information about the content and ads viewed and the effectiveness of ad campaigns, including the audience that saw the ads and how those viewers responded. Measurement therefore covers both what was watched and how the viewer reacted, and it is shared outward rather than kept internal.

Supporting quotations

We work with advertising measurement providers and their service providers to help us, advertisers and others understand information about the content and ads viewed, and the effectiveness of ad campaigns, including the audience that saw their ads and how they responded.

Qualifications & exceptions

• Recipients are advertising measurement providers and their service providers, and they serve advertisers as well as Roku.
• Covers content and ads viewed plus audience response, not only aggregate counts.

Not stated here

• Whether the shared data is identified or aggregated is not stated.

Sharing & Disclosure · Company practice

Demographics and audience labels such as sports fan are disclosed to measurement providers

Beyond viewing data, Roku may disclose the user's demographics data and audience segments — its own examples being sports fans, sitcom enthusiasts and cord cutters — with advertising measurement providers and their service providers. These are assignments about the person rather than records of what they did, and they are handed to third parties.

Supporting quotations

We may also disclose your demographics data and audience segments (e.g., sports fans, sitcom enthusiasts, cord cutters, etc.) with advertising measurement providers and their service providers.

Qualifications & exceptions

• Named segments include sports fans, sitcom enthusiasts and cord cutters.
• Recipients are advertising measurement providers and their service providers.

Not stated here

• How Roku assigns a person to a segment is not explained here.

Sharing & Disclosure · Company practice

Reaching Roku's Channels through another company's device discloses your activity to it

Accessing Roku services such as Roku's Channels on media streaming devices, websites or mobile devices from other companies can lead Roku to disclose certain information to them: interactions with Roku's Channels and their content, IP address, device identifier, and the user's privacy settings. The stated uses are coordinating service provision, tailoring the experience and personalizing ads — so even privacy settings themselves travel with the disclosure.

Supporting quotations

we may disclose certain information to them, including information about your interactions with Roku’s Channels and their content, IP address, device identifier, and user privacy settings

Qualifications & exceptions

• Triggered by accessing Roku services through another company's device, website or mobile device.
• Disclosed items include channel interactions and content, IP address, device identifier and the user's privacy settings.

Not stated here

• Which companies receive this, and what they retain, is not named.

Sharing & Disclosure · Company practice

Buying through Roku discloses your information to the merchant, for stated and unspecified purposes

If the user buys goods or services on the Roku Services, Roku may need to disclose information about the user and information provided to the merchant, for processing the transaction, fulfilling and shipping the order — and, once more, for other purposes. The phrase repeats the open-ended tail seen earlier in the policy: uses beyond the transaction itself are permitted by the wording but not listed.

Supporting quotations

we may need to disclose information about you and information you provide to the merchant to process the transaction, fulfill and ship your order, and for other purposes.

Qualifications & exceptions

• Triggered by a purchase on the Roku Services.
• Beyond processing, fulfilment and shipping, other purposes are left open.

Not stated here

• The other purposes are not enumerated.

Sharing & Disclosure · Company practice

Current and future affiliates receive your information under this policy

Information may be disclosed to Roku's current or future affiliates, defined as a parent company and any subsidiaries, joint ventures or other companies under common control, and in that case Roku says it will require the affiliates to honor this Privacy Policy. The reach includes companies not yet affiliated at the time of reading, and the safeguard is contractual: the affiliates must honor this policy rather than being limited to particular uses.

Supporting quotations

We may disclose your information to our current or future affiliates (which means a parent company, and any subsidiaries, joint ventures, or other companies under common control), in which case we will require our affiliates to honor this Privacy Policy.

Qualifications & exceptions

• Reaches future affiliates, not only present ones.
• Roku states it will require those affiliates to honor this Privacy Policy.
• Affiliates are defined as parent, subsidiaries, joint ventures and other companies under common control.

Not stated here

• How compliance with the requirement is enforced is not stated.

Sharing & Disclosure · Permission or license

A consent setting can hand third parties what specific titles you requested and viewed

Alongside the disclosures Roku makes without asking, it may disclose personal information with consent, and its example is precise: agreeing to the disclosure of information about requests for and viewing of specific movies, programs, games and video services, either to personalize ads or to improve those companies' products, by enabling the Content Viewing Disclosure setting. Turning that setting on therefore shares named titles rather than patterns, and the stated recipients' uses include improving their own products.

Supporting quotations

For example, when you agree to our disclosure of information about your requests for and viewing of specific movies, programs, games, and video services to third parties to personalize ads or to improve their products by enabling the ‘Content Viewing Disclosure’ setting

Qualifications & exceptions

• Applies when the user enables the Content Viewing Disclosure setting, consenting to it.
• Covers requests for and viewing of specific movies, programs, games and video services.
• Stated purposes include personalizing ads and improving the recipients' products.

Not stated here

• Which third parties receive it under this setting is not named.

Sharing & Disclosure · Permission or license

Consent can also send identifying information to third parties for their own marketing

The same sentence covers a second consent case: agreeing to Roku providing personally identifying information to other third parties for their own marketing purposes, subject to those parties' separate privacy policies. Once given, the recipients' own policies govern rather than Roku's, so the protection the user relies on afterwards is the recipient's policy, not this document.

Supporting quotations

or when you agree to our provision of your personally identifying information to other third parties for their own marketing purposes, subject to their separate privacy policies.

Qualifications & exceptions

• Triggered by the user agreeing to it.
• Recipients use the information for their own marketing, under their own privacy policies rather than this one.

Not stated here

• Which third parties, and how consent is recorded or withdrawn, are not stated.

Sharing & Disclosure · Company practice

Your information can be disclosed during a merger, financing or sale of the business

Roku may disclose information to others in connection with, or during negotiation of, any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving the sale, transfer, divestiture or disclosure of all or part of its business or assets to another company. Disclosure during negotiation means it can happen before any deal completes, and the list of events reaches insolvency as well as a sale.

Supporting quotations

We may also disclose your information to others in connection with or during negotiation of any merger, financing, acquisition, bankruptcy, dissolution, transaction or proceeding involving sale, transfer, divestiture or disclosure of all or a portion of our business or assets to another company.

Qualifications & exceptions

• Covers negotiation as well as completion of the transaction.
• Reaches mergers, financing, acquisitions, bankruptcy, dissolution, transfers, divestitures and partial asset disclosures.

Not stated here

• The text does not say the recipient must keep honouring this policy, or that the user is notified.

Sharing & Disclosure · Company practice

Aggregated and de-identified data, including audience segments, is shared for others' own uses

Roku may disclose aggregated or de-identified information, described as information that does not personally identify the user directly, or statistical information about the user including demographics data and audience segments such as sports fans, sitcom enthusiasts and cord cutters. Recipients may use it for a variety of purposes including their own uses, given as improving their products and services for Roku and others and making ads more relevant to the user's interests. The carve-out is therefore narrower than it sounds: the same audience segments appear here as disclosed data, and recipients use it for themselves.

Supporting quotations

We may also disclose aggregated or de-identified information (i.e., information that does not personally identify you directly), or statistical information about you, including demographics data and audience segments (e.g., sports fans, sitcom enthusiasts, cord cutters, etc.), to others for a variety of purposes, including for their own uses, for example, for improving their products and services for us and others, and to make ads more relevant to your interests.

Qualifications & exceptions

• The qualifying language is "does not personally identify you directly", not a promise that no personal data is involved.
• Disclosed items expressly include demographics data and audience segments.
• Recipients use it for their own purposes, including improving products and making ads more relevant.

Not stated here

• How Roku de-identifies the data, and whether recipients may re-identify it, is not stated.

Sharing & Disclosure · Company practice

Posts, uploads and shared devices are visible to other Roku users

Roku may disclose information to other users of the Roku Services at the user's request, or when certain features are used. The examples are concrete: a comment or product review posted on the Roku Sites can be read by other users; content uploaded for others' access, such as comments, videos or audio files, and Roku Devices the user grants access to, become viewable by other users. Sharing features therefore put the material — and the device itself — in front of other account holders.

Supporting quotations

We may disclose your information to other users of the Roku Services at your request, or when you use certain features of our products and services.

If you upload content for access by others, including comments, videos or audio files, to the Roku Services, or if you grant access to your Roku Devices, these content and devices will be viewable by other users.

Qualifications & exceptions

• Triggered by the user's request or by use of particular sharing features.
• Reaches uploaded comments, videos and audio files, and granted access to the user's Roku Devices.

Not stated here

• What other users may do with the content afterwards is not stated here.

Sharing & Disclosure · Company practice

A direct message carries your user ID to the person you message

Direct messaging is spelled out separately: directing a message to another user through the Roku Services means Roku will disclose both the message and the user's user ID to that user. The recipient therefore learns the sender's identifier along with the content, and this is described as disclosure rather than mere delivery.

Supporting quotations

If you direct message another user through the Roku Services, then we will disclose your message and your user ID to that user.

Qualifications & exceptions

• Applies to direct messages to another user through the Roku Services.
• Discloses the message contents and the sender's user ID.

Not stated here

• Whether the user ID is a persistent account identifier is not explained.

Sharing & Disclosure · Company practice

Your information may be stored and processed anywhere Roku operates, including weaker-privacy countries

Roku describes itself as a global company whose processes and systems cross borders, and says information may be held on Roku Devices, on a mobile device using Roku's apps, or on Roku's servers, and may be transferred to, accessed from, or stored and processed globally in any country where Roku or its service providers maintain facilities or call centers. It names the consequence for the user: that includes jurisdictions whose data privacy laws may not give protections equivalent to those at home. Storage location is therefore not promised to be the user's own country.

Supporting quotations

may be transferred to, accessed from, or stored and processed globally in any other country where Roku or its service providers maintain facilities or call centers, including jurisdictions that may not have data privacy laws that provide protections equivalent to those provided in your home country.

Qualifications & exceptions

• May be held on the device, on the mobile app, or on Roku servers.
• Reaches any country where Roku or its service providers keep facilities or call centers.
• Roku acknowledges some of those countries may lack protections equivalent to the user's.

Not stated here

• Which countries are involved is not listed.

Sharing & Disclosure · Context

Advertising, app, content and platform recipients are named for sharing or sale

The recipients column names who receives the information for cross-context behavioral advertising or sale: advertisers, ad networks, advertising partners and ad measurement providers, to bring more relevant ads and report campaign effectiveness; app providers whose app is installed on the Roku Device and content providers from whom content is purchased or subscribed, for discovery, a tailored experience, the providers' own analytics and reporting, or relevant ads and campaign reporting; and third-party platforms and devices used to access the Roku Services, to help them bring more relevant ads and report effectiveness. The same recipient list recurs for later categories, so these recipients receive more than one category of information.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

App providers, where the app is installed on your Roku Device, and content providers from whom you purchase or subscribe to content (to help you discover content and provide a more tailored experience on the Roku Services, for analytics and reporting purposes by the providers, or to bring you more relevant ads and report on effectiveness of ad campaigns)

Third party platforms and devices you use to access the Roku Services (to help them bring you more relevant ads and report on the effectiveness of ad campaigns)

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• Given as recipients for cross-context behavioral advertising or sale.
• Recipients include the providers' own analytics use, not only Roku's.

Not stated here

• The table does not say whether each recipient receives every category.

Sharing & Disclosure · Context

Commercial information goes to advertisers and ad measurement providers

The recipients column for the commercial-information row names advertisers, ad networks, advertising partners and ad measurement providers, and states the reason in the row itself: to bring you more relevant ads and report on the effectiveness of ad campaigns. That connects buying and consumption histories with advertising recipients rather than only with the service.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of this disclosure is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Internet activity reaches app, content and platform providers as well as ad partners

Category E is the first row read here whose recipients column names three groups. Advertisers, ad networks, advertising partners and ad measurement providers receive it for relevant ads and campaign reporting. App providers whose app is installed on the Roku Device, and content providers from whom content is purchased or subscribed, receive it to help discover content and provide a tailored experience, for the providers' own analytics and reporting, or for relevant ads and campaign reporting. Third-party platforms and devices used to access the Roku Services receive it to bring more relevant ads and report campaign effectiveness.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

App providers, where the app is installed on your Roku Device, and content providers from whom you purchase or subscribe to content (to help you discover content and provide a more tailored experience on the Roku Services, for analytics and reporting purposes by the providers, or to bring you more relevant ads and report on effectiveness of ad campaigns)

Third party platforms and devices you use to access the Roku Services (to help them bring you more relevant ads and report on the effectiveness of ad campaigns)

Qualifications & exceptions

• The app-provider recipient is limited to an app installed on the Roku Device.
• Content providers are recipients only where the user purchases or subscribes to content from them.
• Each recipient group comes with its own stated purposes rather than one shared purpose.

Sharing & Disclosure · Context

General geolocation is disclosed to advertising and ad-measurement recipients

The recipients column for category F names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. The row pairs a coarse location category with advertising recipients rather than with service providers.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of this disclosure is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Inferences are disclosed to the same advertising recipients

The recipients column for category I names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. Because the category is derived preferences and interests, this row connects Roku's own inferences to advertising recipients.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of this disclosure is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Employment information goes to advertising and ad-measurement recipients

The recipients column for category J names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. The row therefore places employment information in the same disclosure channel as the consumer activity categories.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of this disclosure is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Education information is disclosed to advertising and ad-measurement recipients

The recipients column for category K names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of this disclosure is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Sensitive-category information is disclosed to advertising recipients

The recipients column for category L names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. Combined with the purposes column, the row connects sensitive attributes to advertising recipients.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of this disclosure is relevant ads and campaign-effectiveness reporting.

Not stated here

• The row does not distinguish recipients that act as service providers from those receiving the data for their own purposes.

Sharing & Disclosure · Company practice

Every chart category was disclosed to service providers and sold or shared in 12 months

After the chart, Roku states that over the past 12 months it has disclosed each chart category for a business purpose to service providers and contractors, and that over the same period it has collected, processed, disclosed, shared for cross-context behavioral advertising and sold each of those categories. The same passage limits the sale and sharing statement: Roku says it has no actual knowledge of selling or sharing the Personal Information of consumers under 16, and states that it does not collect genetic or biometric information, neural data, information on sex life or sexual orientation, or citizenship status.

Supporting quotations

Over the past 12 months, Roku has disclosed for a business purpose each of the categories of Personal Information as described in the chart above to service providers and contractors.

Over the past 12 months, Roku has collected, processed, disclosed, shared for cross-context behavioral advertising, and sold each of the categories of Personal Information as described in the chart above. Roku does not have actual knowledge that it sells Personal Information or shares for cross-context behavioral advertising the Personal Information of consumers under 16 years of age. Roku does not collect genetic or biometric information, neural data, information on sex life or sexual orientation, or citizenship or citizenship status.

Qualifications & exceptions

• The 12-month statements are limited to service providers and contractors for the business-purpose disclosure sentence.
• Roku denies actual knowledge of selling or sharing under-16 Personal Information rather than stating an absolute bar.
• Genetic and biometric information, neural data, information on sex life or sexual orientation, and citizenship status are stated as not collected.

Not stated here

• The chart does not say which named recipients act as service providers and which receive the information for their own purposes.

Sharing & Disclosure · Context

The general state table separates disclosures from recipients of sold information

The second categories chart is built on four columns: categories of Personal Information collected and processed; the purposes for processing; categories of third parties to whom the information is disclosed; and categories of third parties to whom the information is sold, together with the purpose. Splitting the third-party columns this way means a recipient named in the disclosed column is not necessarily a purchaser in the sold column.

Supporting quotations

Categories of Personal Information We Collect, Process and Disclose to Third Parties; and the Purposes of Processing

Categories of Personal Information Being Collected and Processed

The Purposes for Processing

Categories of Third Parties to Whom the Personal Information Is Disclosed

Categories of Third Parties to Whom the Personal Information is "Sold" and the Purpose

Qualifications & exceptions

• The sold column carries its own purpose statement, separate from the purposes column.
• Disclosure and sale are separate columns, so the same category can appear in one and not the other.

Sharing & Disclosure · Context

Identifiers are disclosed to ten groups, from vendors to other users and merchants

The disclosure column for identifiers names service providers and vendors; app and content providers; advertisers, ad networks and advertising partners; advertising measurement providers; third-party platforms and devices used to access the Roku Services; voice assistant providers; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; other users of the Roku Services; and merchants and their partners the person transacts with on the Roku Services. Unlike the California chart, this column names the recipient groups without adding a purpose beside each one.

Supporting quotations

Service providers and vendors

App and content providers

Advertisers, ad networks and advertising partners

Advertising measurement providers

Third party platforms and devices you use to access the Roku Services

Voice assistant providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Other users of the Roku Services

Merchants and their partners you transact with on Roku Services

Qualifications & exceptions

• Law enforcement is qualified to legal, security and safety matters, processes and requests.
• Merchant recipients are limited to merchants the person transacts with on the Roku Services.
• Other users appear as recipients of identifiers.

Sharing & Disclosure · Context

Identifiers listed as sold go to ad partners, installed-app providers and platforms

The sold column for identifiers names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign reporting; app providers where the app is installed on the Roku Device, and content providers from whom content is purchased or subscribed, for discovery, a tailored experience, the providers' own analytics and reporting, or relevant ads and campaign reporting; and third-party platforms and devices used to access the Roku Services, for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

App providers, where the app is installed on your Roku Device, and content providers from whom you purchase or subscribe to content (to help you discover content and provide a more tailored experience on the Roku Services, for analytics and reporting purposes by the providers, or to bring you more relevant ads and report on effectiveness of ad campaigns)

Third party platforms and devices you use to access the Roku Services (to help them bring you more relevant ads and report on the effectiveness of ad campaigns)

Qualifications & exceptions

• The app-provider entry is limited to apps installed on the Roku Device.
• Content providers are recipients only where the person purchases or subscribes to their content.

Not stated here

• The chart does not say whether the same recipients also appear in the disclosure column for identifiers.

Sharing & Disclosure · Context

Registration information goes to vendors, transacting providers, affiliates and authorities

The disclosure column for category B names service providers and vendors; channel and content providers from whom the person is purchasing or subscribing; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; and merchants and their partners the person transacts with on the Roku Services. The row lists no recipients in the chart's sold column, unlike the identifiers row above it.

Supporting quotations

Service providers and vendors

Channel and content providers from whom you are purchasing or subscribing

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Merchants and their partners you transact with on Roku Services

Qualifications & exceptions

• "Channel and content providers" here is limited to providers the person is purchasing or subscribing from.
• The row's sale column contains no entries.

Sharing & Disclosure · Context

Protected-classification data is disclosed to six groups including ad partners

The disclosure column for category C names service providers and vendors; app and content providers; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests.

Supporting quotations

Service providers and vendors

App and content providers

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Qualifications & exceptions

• The law-enforcement entry is limited to legal, security and safety matters, processes and requests.

Sharing & Disclosure · Context

Protected-classification data listed as sold goes to advertising and measurement recipients

The sold column for category C names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. Together with the row's advertising purpose, this places non-sensitive protected-classification data in the chart's sale column.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of the sale is relevant ads and campaign-effectiveness reporting.
• Applies only to the extent the information is not sensitive data under applicable state law.

Sharing & Disclosure · Context

Commercial information is disclosed to seven groups including merchants

The disclosure column for category D names service providers and vendors; app and content providers; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; and merchants and their partners the person transacts with on the Roku Services. The merchants entry is specific to this category, which covers purchasing histories.

Supporting quotations

Service providers and vendors

App and content providers

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Merchants and their partners you transact with on Roku Services

Qualifications & exceptions

• Merchant recipients are limited to merchants the person transacts with on the Roku Services.

Sharing & Disclosure · Context

Commercial information listed as sold goes to advertising and measurement recipients

The sold column for category D names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. Purchasing and consideration histories are therefore among the categories the chart places in its sale column.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of the sale is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Internet activity reaches nine groups, including other users and voice assistants

The disclosure column for category E names service providers and vendors; app and content providers; advertisers, ad networks and advertising partners; advertising measurement providers; third-party platforms and devices used to access the Roku Services; voice assistant providers; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; and other users of the Roku services when the person uses certain features, with Roku Community posts and uploaded product reviews or content given as examples.

Supporting quotations

Service providers and vendors

App and content providers

Advertisers, ad networks and advertising partners

Advertising measurement providers

Third party platforms and devices you use to access the Roku Services

Voice assistant providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Other users of the Roku services when you use certain features of our service (e.g., when you post on Roku Community, upload product reviews or content)

Qualifications & exceptions

• The other-users entry is limited to certain features, with posting in Roku Community and uploading reviews or content as the examples.
• The law-enforcement entry is limited to legal, security and safety matters, processes and requests.

Sharing & Disclosure · Context

Internet activity listed as sold goes to ad partners, app providers and platforms

The sold column for category E names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign reporting; app providers where the app is installed on the Roku Device, and content providers from whom content is purchased or subscribed, for discovery, a tailored experience, the providers' own analytics and reporting, or relevant ads and campaign reporting; and third-party platforms and devices used to access the Roku Services, for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

App providers, where the app is installed on your Roku Device, and content providers from whom you purchase or subscribe to content (to help you discover content and provide a more tailored experience on the Roku Services, for analytics and reporting purposes by the providers, or to bring you more relevant ads and report on effectiveness of ad campaigns)

Third party platforms and devices you use to access the Roku Services (to help them bring you more relevant ads and report on the effectiveness of ad campaigns)

Qualifications & exceptions

• The app-provider entry is limited to apps installed on the Roku Device.
• Content providers are recipients only where the person purchases or subscribes to their content.

Sharing & Disclosure · Context

General geolocation is disclosed to five groups and sold to advertising recipients

The disclosure column for category F names service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests. The sold column names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign-effectiveness reporting. App and content providers, platforms, voice assistants and other users, which appear for internet activity, do not appear for this row.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The law-enforcement entry is limited to legal, security and safety matters, processes and requests.
• The stated purpose of the sale is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Precise geolocation is limited to service, personalisation and fraud, with no sale column

For category G, the general state chart lists only three purposes: 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. Its disclosure column names only service providers and vendors, Roku's affiliates, and law enforcement or others involved in legal, security and safety matters, processes and requests, and the row has no entries in the sold column. The row therefore places precise location outside the advertising recipients and sale channel used for general geolocation.

Supporting quotations

G. Precise geolocation

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.

Service providers and vendors

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Qualifications & exceptions

• No advertising purpose appears for precise geolocation.
• No app, content, advertising, measurement, platform, voice-assistant or other-user recipient appears for this row.
• The row's sale column contains no entries.

Not stated here

• The chart does not say why precise location is treated more narrowly than general location.

Sharing & Disclosure · Context

Audio and visual data is disclosed to six groups including voice assistants

The disclosure column for category H names service providers and vendors; app and content providers; voice assistant providers; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; and other users of the Roku Services. Voice assistant providers and other users appear here even though the row lists no advertising purpose or advertising recipient.

Supporting quotations

Service providers and vendors

App and content providers

Voice assistant providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Other users of the Roku Services

Qualifications & exceptions

• Other users are listed without the feature examples attached to the internet-activity row.
• The law-enforcement entry is limited to legal, security and safety matters, processes and requests.

Sharing & Disclosure · Context

Inferences are disclosed to vendors, ad partners, measurement services and affiliates

The disclosure column for category I begins with service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers and services; and Roku's affiliates. The wording of the measurement entry differs from other rows, which name advertising measurement providers without adding "and services"; the row continues below in the same chart.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers and services

Our affiliates

Qualifications & exceptions

• The measurement entry is worded "advertising measurement providers and services" rather than naming providers only.
• The row continues beyond the entries quoted here.

Sharing & Disclosure · Context

Inferences reach law enforcement and are sold to advertising recipients

The disclosure column for category I closes with law enforcement or others involved in legal, security and safety matters, processes and requests. The sold column for the row names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose of the sale is relevant ads and campaign-effectiveness reporting.
• The law-enforcement entry is limited to legal, security and safety matters, processes and requests.

Sharing & Disclosure · Context

Employment information is disclosed to five groups and sold to ad recipients

The disclosure column for category J names service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests. The sold column names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• App and content providers and merchants do not appear as recipients for this row.
• The stated purpose of the sale is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Education information is disclosed to five groups and sold to ad recipients

The disclosure column for category K names service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests. The sold column names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The row names no app, content, platform, voice-assistant or other-user recipient.
• The stated purpose of the sale is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

A third chart names recipients of targeted advertising or sale separately

The Iowa and Utah part opens another categories chart with four headers: categories of Personal Information collected and processed; the purposes for processing; categories of third parties to whom Personal Information is disclosed; and categories of third parties to whom it is disclosed for targeted advertising or sold, together with the purpose. The fourth header uses the targeted-advertising wording instead of the earlier chart's sale wording.

Supporting quotations

Categories of Personal Information We Collect, Process and Disclose to Third Parties; and the Purposes of Processing

Categories of Personal Information Being Collected and Processed

The Purposes for Processing

Categories of Third Parties to Whom the Personal Information Is Disclosed

Categories of Third Parties to Whom the Personal Information is Disclosed for Targeted Advertising or "Sold" and the Purpose

Qualifications & exceptions

• The disclosure column and the targeted-advertising-or-sale column are separate.
• The sale column header pairs the recipient with a purpose.

Sharing & Disclosure · Context

Ten recipient groups receive identifiers under the targeted-advertising chart

The disclosure column for identifiers names service providers and vendors; app and content providers; advertisers, ad networks and advertising partners; advertising measurement providers; third-party platforms and devices used to access the Roku Services; voice assistant providers; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; other users of the Roku Services; and merchants and their partners the person transacts with on the Roku Services.

Supporting quotations

Service providers and vendors

App and content providers

Advertisers, ad networks and advertising partners

Advertising measurement providers

Third party platforms and devices you use to access the Roku Services

Voice assistant providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Other users of the Roku Services

Merchants and their partners you transact with on Roku Services

Qualifications & exceptions

• This is the disclosure column, separate from the targeted-advertising-or-sale column.
• The law-enforcement entry is limited to legal, security and safety matters, processes and requests.

Sharing & Disclosure · Context

Identifiers are disclosed for targeted advertising or sold to ad partners and platforms

Under the fourth header, which covers recipients of information disclosed for targeted advertising or sold together with the purpose, the row names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign reporting; app providers where the app is installed on the Roku Device, and content providers from whom content is purchased or subscribed, for discovery, a tailored experience, the providers' own analytics and reporting, or relevant ads and campaign reporting; and third-party platforms and devices used to access the Roku Services, for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Categories of Third Parties to Whom the Personal Information is Disclosed for Targeted Advertising or "Sold" and the Purpose

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

App providers, where the app is installed on your Roku Device, and content providers from whom you purchase or subscribe to content (to help you discover content and provide a more tailored experience on the Roku Services, for analytics and reporting purposes by the providers, or to bring you more relevant ads and report on effectiveness of ad campaigns)

Third party platforms and devices you use to access the Roku Services (to help them bring you more relevant ads and report on the effectiveness of ad campaigns)

Qualifications & exceptions

• The column covers both disclosure for targeted advertising and sale, without distinguishing which recipient receives which.
• The app-provider entry is limited to apps installed on the Roku Device.
• Content providers are recipients only where the person purchases or subscribes to their content.

Not stated here

• The chart does not say which of these recipients receive the identifiers by sale and which for targeted advertising.

Sharing & Disclosure · Context

Registration information goes to five groups and has no targeted-advertising entries

The disclosure column for category B names service providers and vendors; channel and content providers from whom the person is purchasing or subscribing; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; and merchants and their partners the person transacts with on the Roku Services. The row contains no entries under the targeted-advertising-or-sale header.

Supporting quotations

Service providers and vendors

Channel and content providers from whom you are purchasing or subscribing

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Merchants and their partners you transact with on Roku Services

Qualifications & exceptions

• Channel and content providers are recipients only where the person is purchasing or subscribing.
• The targeted-advertising-or-sale column contains no entries for this row.

Sharing & Disclosure · Context

Protected-classification data is disclosed to six groups and listed for targeted advertising or sale

The disclosure column for category C names service providers and vendors; app and content providers; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests. Under the targeted-advertising-or-sale header, the row names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Service providers and vendors

App and content providers

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The row is stated without the earlier general-part sensitive-data limitation.
• The stated purpose in the sale column is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Commercial information reaches seven disclosure groups and ad recipients in the sale column

The disclosure column for category D names service providers and vendors; app and content providers; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; and merchants and their partners the person transacts with on the Roku Services. Under the targeted-advertising-or-sale header, the row names advertisers, ad networks, advertising partners and ad measurement providers.

Supporting quotations

Service providers and vendors

App and content providers

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Merchants and their partners you transact with on Roku Services

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• Merchant recipients are limited to merchants the person transacts with on the Roku Services.

Sharing & Disclosure · Context

Internet activity reaches nine groups in the Iowa and Utah disclosure column

The disclosure column for category E names service providers and vendors; app and content providers; advertisers, ad networks and advertising partners; advertising measurement providers; third-party platforms and devices used to access the Roku Services; voice assistant providers; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; and other users of the Roku services when the person uses certain features, with Roku Community posts and uploaded product reviews or content as examples.

Supporting quotations

Service providers and vendors

App and content providers

Advertisers, ad networks and advertising partners

Advertising measurement providers

Third party platforms and devices you use to access the Roku Services

Voice assistant providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Other users of the Roku services when you use certain features of our service (e.g., when you post on Roku Community, upload product reviews or content)

Qualifications & exceptions

• The other-users entry is limited to certain features.
• The law-enforcement entry is limited to legal, security and safety matters, processes and requests.

Sharing & Disclosure · Context

Internet activity is also listed for targeted advertising or sale to ad partners and platforms

Under the targeted-advertising-or-sale header, the category E row names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign reporting; app providers where the app is installed on the Roku Device, and content providers from whom content is purchased or subscribed, for discovery, a tailored experience, the providers' own analytics and reporting, or relevant ads and campaign reporting; and third-party platforms and devices used to access the Roku Services, for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

App providers, where the app is installed on your Roku Device, and content providers from whom you purchase or subscribe to content (to help you discover content and provide a more tailored experience on the Roku Services, for analytics and reporting purposes by the providers, or to bring you more relevant ads and report on effectiveness of ad campaigns)

Third party platforms and devices you use to access the Roku Services (to help them bring you more relevant ads and report on the effectiveness of ad campaigns)

Qualifications & exceptions

• The header does not distinguish targeted-advertising disclosure from sale for a named recipient.
• The app-provider entry is limited to apps installed on the Roku Device.

Sharing & Disclosure · Context

General geolocation reaches five disclosure groups and ad recipients in the sale column

The disclosure column for category F names service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests. Under the targeted-advertising-or-sale header the row names advertisers, ad networks, advertising partners and ad measurement providers.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• App and content providers, platforms, voice assistants and other users do not appear in this row.

Sharing & Disclosure · Context

Precise geolocation's recipient list closes with law enforcement and has no ad column

The last entry in the category G disclosure column is law enforcement or others involved with legal, security and safety matters, processes and requests. With service providers and vendors and Roku's affiliates, that completes a three-group recipient list, and the row has no entries under the targeted-advertising-or-sale header.

Supporting quotations

Law enforcement or others involved with legal, security and safety matters, processes and requests

Qualifications & exceptions

• The row names no advertising, measurement, platform, voice-assistant or other-user recipient.
• The targeted-advertising-or-sale column contains no entries for this row.

Sharing & Disclosure · Context

Audio and visual data is disclosed to six groups and carries no ad-sale entries

The disclosure column for category H names service providers and vendors; app and content providers; voice assistant providers; Roku's affiliates; law enforcement or others involved in legal, security and safety matters, processes and requests; and other users of the Roku Services. The row lists no recipients under the targeted-advertising-or-sale header.

Supporting quotations

Service providers and vendors

App and content providers

Voice assistant providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Other users of the Roku Services

Qualifications & exceptions

• Voice assistant providers appear even though the row lists no advertising purpose.
• The targeted-advertising-or-sale column contains no entries for this row.

Sharing & Disclosure · Context

Inferences go to five disclosure groups and are listed for targeted advertising or sale

The disclosure column for category I names service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers and services; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests. Under the targeted-advertising-or-sale header the row names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers and services

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The measurement entry is worded "advertising measurement providers and services" rather than providers only.
• The stated purpose in the sale column is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Employment information reaches affiliates, law enforcement and ad recipients

The employment row's disclosure column closes with Roku's affiliates and law enforcement or others involved in legal, security and safety matters, processes and requests. Under the targeted-advertising-or-sale header, the row names advertisers, ad networks, advertising partners and ad measurement providers for relevant ads and campaign-effectiveness reporting.

Supporting quotations

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The stated purpose in the sale column is relevant ads and campaign-effectiveness reporting.

Sharing & Disclosure · Context

Education information goes to five disclosure groups and ad recipients for sale

The disclosure column for category K names service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests. Under the targeted-advertising-or-sale header the row names advertisers, ad networks, advertising partners and ad measurement providers.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The row names no app, content, platform, voice-assistant or other-user recipient.

Sharing & Disclosure · Context

Those sensitive attributes are disclosed to five groups and listed for ad sale

The disclosure column for category L names service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku's affiliates; and law enforcement or others involved in legal, security and safety matters, processes and requests. Under the targeted-advertising-or-sale header the row names advertisers, ad networks, advertising partners and ad measurement providers.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers

Our affiliates

Law enforcement or others involved with legal, security and safety matters, processes and requests

Advertisers, ad networks, advertising partners, and ad measurement providers (to bring you more relevant ads and report on effectiveness of ad campaigns)

Qualifications & exceptions

• The row carries no sensitive-data carve-out of its own.
• The stated purpose in the sale column is relevant ads and campaign-effectiveness reporting.