US State Law Privacy Notice (CA Privacy Notice)

Sharing & Disclosure · Company practice

Identifiers shared for cross-context behavioural advertising or sold to advertisers and ad measurement providers

For the identifiers category, the table’s third column lists the categories of third parties to whom Personal Information is “shared” for cross-context behavioural advertising or “sold”: advertisers, ad networks, advertising partners, and ad measurement providers. The stated purpose attached to that cell is to bring the reader more relevant ads and to report on the effectiveness of ad campaigns. The column heading covers both sharing for cross-context behavioural advertising and selling, and the cell does not say which recipients fall on which side of that line.

Supporting quotations

Categories of Third Parties to Whom the Personal Information is "Shared" for Cross-Context Behavioral 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)

Qualifications & exceptions

• Categories of Third Parties to Whom the Personal Information is "Shared" for Cross-Context Behavioral Advertising or "Sold" and the Purpose

Not stated here

• The table groups recipients that receive information for cross-context behavioural advertising and recipients that buy it in one column, and does not state which individual recipients are a “sale” rather than a “share”.

Cross-references

• contrast (model-proposed): Multistate identifiers are “sold” to advertisers, app and content providers, and third-party platforms and devices — The same three recipient cells for identifiers appear under a California column labelled “Shared” for cross-context behavioural advertising or “Sold” and under a multistate column labelled only “Sold”. The readers of each chart see a different label for the same recipients.

Sharing & Disclosure · Company practice

Identifiers also shared with app and content providers and with third-party platforms and devices

Still in row A (identifiers) of the California table, two further recipient cells list, for the “shared” for cross-context behavioural advertising or “sold” column: app providers, where the app is installed on the reader’s Roku Device, and content providers from whom the reader purchases or subscribes to content, to help the reader discover content and provide a more tailored experience on the Roku Services, for analytics and reporting by those providers, or to bring more relevant ads and report on campaign effectiveness; and third-party platforms and devices the reader uses to access the Roku Services, to help them bring more relevant ads and report on ad effectiveness.

Supporting quotations

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

• where the app is installed on your Roku Device
• Third party platforms and devices you use to access the Roku Services

Sharing & Disclosure · Company practice

Protected-classification characteristics shared with advertisers, ad networks and ad measurement providers

For row C, the third column lists advertisers, ad networks, advertising partners and ad measurement providers as the categories of third parties to whom the information is “shared” for cross-context behavioural advertising or “sold”, for the purpose of bringing more relevant ads and reporting on ad campaign effectiveness. This is the same recipient list the table gives for identifiers in this 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

• for cross-context behavioural advertising or “sold”

Not stated here

• The table gives the same recipient categories as for identifiers and does not say whether protected-classification characteristics are shared or sold to each of them.

Sharing & Disclosure · Company practice

Commercial information shared with advertisers, ad networks, advertising partners and ad measurement providers

For row D, the table’s third column lists advertisers, ad networks, advertising partners and ad measurement providers as the categories of third parties to whom commercial information is “shared” for cross-context behavioural advertising or “sold”, to bring the reader more relevant ads and report on ad 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)

Qualifications & exceptions

• for cross-context behavioural advertising or “sold”

Not stated here

• The table does not say which of these recipients receive commercial information as a “share” and which as a “sale”.

Sharing & Disclosure · Company practice

Network activity shared with advertisers, app and content providers, and third-party platforms and devices

For row E, the table lists three recipient cells for the column covering categories of third parties to whom information is “shared” for cross-context behavioural advertising or “sold”: advertisers, ad networks, advertising partners and ad measurement providers; app providers, where the app is installed on the reader’s Roku Device, and content providers from whom the reader purchases or subscribes to content, for content discovery and a tailored experience, provider analytics and reporting, or more relevant ads and campaign-effectiveness reporting; and third-party platforms and devices the reader uses to access the Roku Services, for more relevant ads and ad-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

• where the app is installed on your Roku Device
• Third party platforms and devices you use to access the Roku Services

Not stated here

• The table does not say which recipients receive network activity as a “share” and which as a “sale”.

Sharing & Disclosure · Company practice

General geolocation shared with advertisers, ad networks and ad measurement providers

For row F, the third column lists advertisers, ad networks, advertising partners and ad measurement providers as the categories of third parties to whom general geolocation data is “shared” for cross-context behavioural advertising or “sold”, to bring more relevant ads and report on ad 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)

Qualifications & exceptions

• for cross-context behavioural advertising or “sold”

Not stated here

• The table does not say which recipients receive general geolocation as a “share” and which as a “sale”.

Sharing & Disclosure · Company practice

Inferences shared with advertisers, ad networks and ad measurement providers

For row I, the third column lists advertisers, ad networks, advertising partners and ad measurement providers as the categories of third parties to whom inferences are “shared” for cross-context behavioural advertising or “sold”, to bring more relevant ads and report on ad 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)

Qualifications & exceptions

• for cross-context behavioural advertising or “sold”

Not stated here

• The table does not say which recipients receive inferences as a “share” and which as a “sale”.

Sharing & Disclosure · Company practice

Professional or employment information shared with advertisers, ad networks and ad measurement providers

For row J, the third column lists advertisers, ad networks, advertising partners and ad measurement providers as the categories of third parties to whom professional or employment information is “shared” for cross-context behavioural advertising or “sold”, to bring more relevant ads and report on ad 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)

Qualifications & exceptions

• for cross-context behavioural advertising or “sold”

Not stated here

• The table does not say which recipients receive professional or employment information as a “share” and which as a “sale”.

Sharing & Disclosure · Company practice

Education information shared with advertisers, ad networks and ad measurement providers

For row K, the third column lists advertisers, ad networks, advertising partners and ad measurement providers as the categories of third parties to whom education information is “shared” for cross-context behavioural advertising or “sold”, to bring more relevant ads and report on ad 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)

Qualifications & exceptions

• for cross-context behavioural advertising or “sold”

Not stated here

• The table does not say which recipients receive education information as a “share” and which as a “sale”.

Sharing & Disclosure · Company practice

Sensitive beliefs and health data shared with advertisers, ad networks and ad measurement providers

For row L, the third column lists advertisers, ad networks, advertising partners and ad measurement providers as the categories of third parties to whom this sensitive information is “shared” for cross-context behavioural advertising or “sold”, to bring more relevant ads and report on ad campaign effectiveness. The table thus places the sensitive categories in the same recipient column as the other rows.

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

• for cross-context behavioural advertising or “sold”

Not stated here

• The table does not say which recipients receive these sensitive categories as a “share” and which as a “sale”, or whether any consent step applies before that sharing.

Sharing & Disclosure · Company practice

Over the past 12 months, every listed category was disclosed for a business purpose to service providers and contractors

Below the table, Roku states that over the past 12 months it has disclosed for a business purpose each of the categories of Personal Information described in the chart to service providers and contractors. The statement does not give a per-category breakdown of those disclosures.

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.

Qualifications & exceptions

• Over the past 12 months
• to service providers and contractors

Not stated here

• The Notice does not itemise which service providers or contractors received which category.

Sharing & Disclosure · Company practice

Roku reports collecting, processing, disclosing, sharing and selling every category over 12 months

Roku states that over the past 12 months it has collected, processed, disclosed, shared for cross-context behavioural advertising, and sold each of the categories of Personal Information described in the chart above. The statement covers every category in the chart equally and gives no per-category figures, volumes or recipients beyond those in the chart.

Supporting quotations

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.

Qualifications & exceptions

• Over the past 12 months

Not stated here

• The statement gives no per-category figures or identification of recipients for the sale or sharing.

Sharing & Disclosure · Company commitment

Roku states it has no actual knowledge that it sells or shares the Personal Information of consumers under 16

Roku states that it does not have actual knowledge that it sells Personal Information, or shares Personal Information for cross-context behavioural advertising, of consumers under 16 years of age. This is a statement about Roku’s knowledge; the sentence does not say that no such sale or sharing occurs.

Supporting quotations

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.

Qualifications & exceptions

• does not have actual knowledge

Not stated here

• The statement does not describe what checks Roku runs to establish that knowledge.

Sharing & Disclosure · Context

The multistate chart separates third parties a category is disclosed to from those it is “sold” to

The multistate chart has four columns: categories of Personal Information being collected and processed, the purposes for processing, “Categories of Third Parties to Whom the Personal Information Is Disclosed”, and “Categories of Third Parties to Whom the Personal Information is "Sold" and the Purpose”. Unlike the California chart, which combines sharing for cross-context behavioural advertising and selling in one column, this chart keeps disclosure recipients and sale recipients in separate columns, and only the sale column states a purpose.

Supporting quotations

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

Not stated here

• The chart does not define “disclosed” or “sold” itself, and neither column says whether a particular recipient receives a category for a business purpose only.

Sharing & Disclosure · Company practice

Multistate identifiers are disclosed to service providers, platforms, advertisers, affiliates, authorities and merchants

For row A, the disclosure column names ten recipient groups to whom identifiers are disclosed: 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 with legal, security and safety matters, processes and requests; other users of the Roku Services; and merchants and their partners the reader transacts with on the Roku Services. The column does not describe what each recipient receives or the purpose of each disclosure.

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

• Third party platforms and devices you use to access the Roku Services
• Merchants and their partners you transact with on Roku Services

Not stated here

• The disclosure column does not attach a purpose to each recipient or say what each one receives.

Sharing & Disclosure · Company practice

Multistate identifiers are “sold” to advertisers, app and content providers, and third-party platforms and devices

In the sale column of the multistate chart, three recipient groups are named for identifiers, each with its purpose: advertisers, ad networks, advertising partners and ad measurement providers, to bring more relevant ads and report on campaign effectiveness; app providers where the app is installed on the reader’s Roku Device, and content providers the reader purchases or subscribes to content from, for content discovery, a tailored experience, provider 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 ad-effectiveness reporting. The same three groups appear in the California chart under a combined “shared” for cross-context behavioural advertising or “sold” heading.

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

• where the app is installed on your Roku Device

Cross-references

• contrast (model-proposed): Identifiers shared for cross-context behavioural advertising or sold to advertisers and ad measurement providers — The same three recipient cells for identifiers appear under a California column labelled “Shared” for cross-context behavioural advertising or “Sold” and under a multistate column labelled only “Sold”. The readers of each chart see a different label for the same recipients.

Sharing & Disclosure · Company practice

Multistate account registration information disclosed to providers, affiliates, authorities and merchants

For row B, the disclosure column names five recipient groups: service providers and vendors; app and content providers from whom the reader is purchasing or subscribing; Roku’s affiliates; law enforcement or others involved with legal, security and safety matters, processes and requests; and merchants and their partners the reader transacts with on the Roku Services. The chart as supplied lists no “sold” recipients for account registration information.

Supporting quotations

Service providers and vendors

App 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

• App and content providers from whom you are purchasing or subscribing
• Merchants and their partners you transact with on Roku Services

Not stated here

• The chart does not attach a purpose to each disclosure of account registration information.

Sharing & Disclosure · Company practice

Multistate protected classifications disclosed to providers, advertisers, affiliates and law enforcement

For row C, the disclosure column names six recipient groups: 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 with legal, security and safety matters, processes and requests. The column states no purpose for these disclosures.

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

Not stated here

• The chart does not attach a purpose to each disclosure of these characteristics.

Sharing & Disclosure · Company practice

Multistate protected classifications also appear in the “sold” column with six groups and no stated purpose

For row C, the “Sold” column repeats the same six recipient groups as the disclosure column: 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 with legal, security and safety matters, processes and requests. Although the column heading says “and the Purpose”, these cells state no purpose, and the chart does not say which of these groups buys the information, which only receives it, or on what basis a service provider or law enforcement agency counts as a sale recipient.

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

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

Not stated here

• The cells state no purpose for the sale, and the chart does not explain how service providers and vendors or law enforcement recipients come within a “sold” column.

Sharing & Disclosure · Company practice

Multistate commercial information disclosed to providers, advertisers, affiliates, authorities and merchants

For row D, the disclosure column names seven recipient groups: 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 with legal, security and safety matters, processes and requests; and merchants and their partners the reader 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

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

• Merchants and their partners you transact with on Roku Services

Not stated here

• The chart does not attach a purpose to each disclosure of commercial information.

Sharing & Disclosure · Company practice

Multistate commercial information sold to advertisers, ad networks and ad measurement providers

For row D, the sale column names advertisers, ad networks, advertising partners and ad measurement providers, with the purpose of bringing more relevant ads and reporting on ad campaign effectiveness. This is the only recipient cell in that column for this row.

Supporting quotations

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

Sharing & Disclosure · Company practice

Multistate network activity disclosed to nine recipient groups, including other users for community features

For row E, the disclosure column names nine recipient groups: 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 with legal, security and safety matters, processes and requests; and other users of the Roku services when the reader uses certain features, such as posting on Roku Community or uploading product reviews or content.

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

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

Not stated here

• The chart does not attach a purpose to each disclosure of network activity information.

Sharing & Disclosure · Company practice

Multistate network activity sold to advertisers, app and content providers, and third-party platforms and devices

For row E, the sale column names the same three recipient groups as the other sold rows: advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign reporting; app providers where the app is installed on the reader’s Roku Device, and content providers the reader purchases or subscribes to content from, for content discovery, tailored experience, provider analytics and reporting, or relevant ads; and third-party platforms and devices used to access the Roku Services, for relevant ads and ad-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

• where the app is installed on your Roku Device

Sharing & Disclosure · Company practice

Multistate general geolocation data disclosed to providers, advertisers, affiliates and law enforcement

For row F, the disclosure column names five recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests. The column does not include app and content providers or merchant recipients 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

Not stated here

• The chart does not attach a purpose to each disclosure of general geolocation data.

Sharing & Disclosure · Company practice

Multistate general geolocation sold to advertisers, ad networks and ad measurement providers

For row F, the sale column names advertisers, ad networks, advertising partners and ad measurement providers, with the purpose of bringing more relevant ads and reporting on ad 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)

Sharing & Disclosure · Company practice

Multistate precise geolocation disclosed to service providers and affiliates

The disclosure cells supplied for row G name two recipient groups: service providers and vendors, and Roku’s affiliates. This packet supplies only those two disclosure cells for precise geolocation; the rest of that row is not stated here.

Supporting quotations

Service providers and vendors

Our affiliates

Not stated here

• Only two disclosure recipients are supplied for row G in this packet; the card does not say whether further recipients or a sale column entry follow.

Sharing & Disclosure · Company practice

Precise geolocation also disclosed to law enforcement and safety recipients; no sale entry for this row

Row G of the multistate chart closes its disclosure column with law enforcement or others involved with legal, security and safety matters, processes and requests. Together with service providers and vendors and Roku’s affiliates, that gives three disclosure recipients for precise geolocation, and the chart as supplied has no “sold” entry for this row.

Supporting quotations

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

Not stated here

• The chart as supplied has no sale-column entry for precise geolocation, and does not say why this category is absent from that column.

Sharing & Disclosure · Company practice

Multistate audio and similar information disclosed to providers, voice assistants, affiliates and others

For row H, the disclosure column names six recipient groups: service providers and vendors; app and content providers; voice assistant providers; Roku’s affiliates; law enforcement or others involved with legal, security and safety matters, processes and requests; and other users of the Roku Services. The chart as supplied shows no “sold” entry for this row.

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

Not stated here

• The chart does not attach a purpose to each disclosure, and shows no sale entry for this row.

Sharing & Disclosure · Company practice

Multistate inferences disclosed to providers, advertisers, measurement services, affiliates and authorities

For row I, the disclosure column names five recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers and services; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests.

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.

Not stated here

• The chart does not attach a purpose to each disclosure of inferences.

Sharing & Disclosure · Company practice

Multistate inferences sold to advertisers, ad networks and ad measurement providers

For row I, the sale column names advertisers, ad networks, advertising partners and ad measurement providers, for the purpose of bringing more relevant ads and reporting on ad 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).

Sharing & Disclosure · Company practice

Multistate professional or employment information disclosed to service providers, advertisers and measurement providers

The disclosure cells supplied for row J in this section name three recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; and advertising measurement providers. This packet supplies only those three disclosure cells for this row.

Supporting quotations

Service providers and vendors

Advertisers, ad networks and advertising partners

Advertising measurement providers

Not stated here

• Only three disclosure recipients are supplied for row J here; the card does not say whether further recipients or a sale entry follow.

Sharing & Disclosure · Company practice

Multistate professional information also disclosed to affiliates and authorities, and sold to advertisers

Row J closes its disclosure column with Roku’s affiliates and law enforcement or others involved with legal, security and safety matters, processes and requests, and its sale column names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. With the three cells carded earlier, that gives five disclosure recipients and one sale recipient group for professional or employment information.

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)

Sharing & Disclosure · Company practice

Multistate education information disclosed to providers, advertisers, measurement providers, affiliates and authorities

For row K, the disclosure column names five recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests.

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

Not stated here

• The chart does not attach a purpose to each disclosure of education information.

Sharing & Disclosure · Company practice

Multistate education information sold to advertisers, ad networks and ad measurement providers

For row K, the sale column 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)

Sharing & Disclosure · Company practice

Multistate credentials and government identifiers disclosed to providers, affiliates, authorities and merchants

For row L, the disclosure column names four recipient groups: service providers and vendors; Roku’s affiliates; law enforcement or others involved with legal, security and safety matters, processes and requests; and merchants and their partners the reader transacts with on the Roku Services. The chart as supplied has no sale-column entry for this row.

Supporting quotations

Service providers and vendors.

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

• Merchants and their partners you transact with on Roku Services.

Not stated here

• The chart does not attach a purpose to each disclosure, and shows no sale entry for these credentials.

Sharing & Disclosure · Company commitment

Roku states it has no actual knowledge that it sells the Personal Information of consumers under 16

For the multistate group, Roku states that it does not have actual knowledge that it sells Personal Information of consumers under 16 years of age. This sentence is narrower than the California statement, which covers both selling and sharing for cross-context behavioural advertising. It is a statement about Roku’s knowledge, not a statement that no such sale occurs.

Supporting quotations

Roku does not have actual knowledge that it sells Personal Information of consumers under 16 years of age.

Qualifications & exceptions

• does not have actual knowledge

Not stated here

• The Notice does not describe the checks Roku uses to establish that knowledge.

Sharing & Disclosure · Context

Iowa and Utah chart: four columns, with targeted advertising and “sold” combined in the last column

The Iowa and Utah section repeats the categories, purposes and disclosures chart with four column headings: “Categories of Personal Information Being Collected and Processed”, “The Purposes for Processing”, “Categories of Third Parties to Whom the Personal Information Is Disclosed”, and “Categories of Third Parties to Whom the Personal Information is Disclosed for Targeted Advertising or "Sold" and the Purpose”. The heading of the last column combines disclosure for targeted advertising with selling, which differs from the multistate chart’s separate disclosure and sale columns.

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

Sharing & Disclosure · Company practice

Iowa and Utah identifiers disclosed to ten recipient groups, from providers to merchants

For row A, the disclosure column names ten recipient groups: 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 with legal, security and safety matters, processes and requests; other users of the Roku Services; and merchants and their partners the reader 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

• Third party platforms and devices you use to access the Roku Services
• Merchants and their partners you transact with on Roku Services

Not stated here

• The chart does not attach a purpose to each disclosure of identifiers.

Sharing & Disclosure · Company practice

Iowa and Utah identifiers disclosed for targeted advertising or sold to three recipient groups

For row A, the combined “Disclosed for Targeted Advertising or "Sold"” column 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 reader’s Roku Device, and content providers the reader purchases or subscribes to content from, for content discovery, tailored experience, provider analytics and reporting, or relevant ads; and third-party platforms and devices used to access the Roku Services, for relevant ads and ad-effectiveness reporting. The heading merges targeted advertising and sale, so the cells do not say which activity applies to which recipient.

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

• where the app is installed on your Roku Device

Not stated here

• The column heading combines disclosure for targeted advertising with sale, and the cells do not say which recipients receive identifiers for which of the two.

Sharing & Disclosure · Company practice

Iowa and Utah account registration information disclosed to providers, affiliates, authorities and merchants

For row B, the disclosure column names five recipient groups: service providers and vendors; app and content providers from whom the reader is purchasing or subscribing; Roku’s affiliates; law enforcement or others involved with legal, security and safety matters, processes and requests; and merchants and their partners the reader transacts with on the Roku Services. The chart shows no combined targeted advertising or sale entry for this row.

Supporting quotations

Service providers and vendors

App 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

• App and content providers from whom you are purchasing or subscribing
• Merchants and their partners you transact with on Roku Services

Not stated here

• The chart does not attach a purpose to each disclosure, and shows no targeted advertising or sale entry for this row.

Sharing & Disclosure · Company practice

Iowa and Utah protected classifications disclosed to providers, advertisers, affiliates and authorities

For row C, the disclosure column names six recipient groups: 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 with 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

Not stated here

• The chart does not attach a purpose to each disclosure of these characteristics.

Sharing & Disclosure · Company practice

Iowa and Utah protected classifications disclosed for targeted advertising or sold to advertisers

For row C, the combined “Disclosed for Targeted Advertising or "Sold"” column names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. The heading does not say which recipients receive the characteristics for targeted advertising and which buy them.

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

• Disclosed for Targeted Advertising or "Sold"

Not stated here

• The combined heading leaves open which recipients receive these characteristics for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah commercial information disclosed to seven recipient groups, including merchants

For row D, the disclosure column names seven recipient groups: 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 with legal, security and safety matters, processes and requests; and merchants and their partners the reader 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

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

• Merchants and their partners you transact with on Roku Services

Not stated here

• The chart does not attach a purpose to each disclosure of commercial information.

Sharing & Disclosure · Company practice

Iowa and Utah commercial information disclosed for targeted advertising or sold to advertisers

For row D, the combined “Disclosed for Targeted Advertising or "Sold"” column names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. The heading does not say which recipients receive the information for targeted advertising and which buy it.

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

• Disclosed for Targeted Advertising or "Sold"

Not stated here

• The combined heading leaves open which recipients receive commercial information for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah network activity disclosed to nine recipient groups, including other users for community features

For row E, the disclosure column names nine recipient groups: 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 with legal, security and safety matters, processes and requests; and other users of the Roku services when the reader uses certain features, such as posting on Roku Community or uploading product reviews or content.

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

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

Not stated here

• The chart does not attach a purpose to each disclosure of network activity information.

Sharing & Disclosure · Company practice

Iowa and Utah network activity disclosed for targeted advertising or sold to advertisers

For row E, the combined “Disclosed for Targeted Advertising or "Sold"” column 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

• Disclosed for Targeted Advertising or "Sold"

Not stated here

• The combined heading leaves open which recipients receive network activity for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah network activity: app and content providers and platforms complete the combined column

The combined “Disclosed for Targeted Advertising or "Sold"” column for row E also names app providers, where the app is installed on the reader’s Roku Device, and content providers the reader purchases or subscribes to content from, for content discovery, tailored experience, provider analytics and reporting, or relevant ads; and third-party platforms and devices used to access the Roku Services, for relevant ads and ad-effectiveness reporting. With the advertisers carded earlier, that gives three recipient groups in that column for this row.

Supporting quotations

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

• where the app is installed on your Roku Device

Not stated here

• The combined heading still does not say which recipients receive network activity for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah general geolocation disclosed to providers, advertisers, affiliates and authorities

For row F, the disclosure column names five recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests.

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

Not stated here

• The chart does not attach a purpose to each disclosure of general geolocation data.

Sharing & Disclosure · Company practice

Iowa and Utah general geolocation disclosed for targeted advertising or sold to advertisers

For row F, the combined “Disclosed for Targeted Advertising or "Sold"” column 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

• Disclosed for Targeted Advertising or "Sold"

Not stated here

• The combined heading leaves open which recipients receive general geolocation for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah precise geolocation disclosed to providers, affiliates and authorities

For row G, the disclosure column names three recipient groups: service providers and vendors; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests. The chart shows no combined targeted advertising or sale entry for this row.

Supporting quotations

Service providers and vendors

Our affiliates

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

Not stated here

• The chart shows no targeted advertising or sale entry for precise geolocation and does not explain why.

Sharing & Disclosure · Company practice

Iowa and Utah audio and similar information disclosed to providers, voice assistants, affiliates, authorities and users

For row H, the disclosure column names six recipient groups: service providers and vendors; app and content providers; voice assistant providers; Roku’s affiliates; law enforcement or others involved with legal, security and safety matters, processes and requests; and other users of the Roku Services. The chart shows no combined targeted advertising or sale entry for this row.

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

Not stated here

• The chart does not attach a purpose to each disclosure, and shows no targeted advertising or sale entry for this row.

Sharing & Disclosure · Company practice

Iowa and Utah inferences disclosed to providers, advertisers, measurement services, affiliates and authorities

For row I, the disclosure column names five recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers and services; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests.

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

Not stated here

• The chart does not attach a purpose to each disclosure of inferences.

Sharing & Disclosure · Company practice

Iowa and Utah inferences disclosed for targeted advertising or sold to advertisers

For row I, the combined “Disclosed for Targeted Advertising or "Sold"” column 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

• Disclosed for Targeted Advertising or "Sold"

Not stated here

• The combined heading leaves open which recipients receive inferences for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah professional or employment information disclosed to providers, advertisers, affiliates and authorities

For row J, the disclosure column names five recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests.

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

Not stated here

• The chart does not attach a purpose to each disclosure of professional or employment information.

Sharing & Disclosure · Company practice

Iowa and Utah professional or employment information disclosed for targeted advertising or sold

For row J, the combined “Disclosed for Targeted Advertising or "Sold"” column 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

• Disclosed for Targeted Advertising or "Sold"

Not stated here

• The combined heading leaves open which recipients receive professional or employment information for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah education information disclosed to providers, advertisers, affiliates and authorities

For row K, the disclosure column names five recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests. The packet supplies these five disclosure cells for the row; any next cell is not stated here.

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

Not stated here

• Only these five disclosure recipients and no combined targeted advertising or sale entry are supplied for row K in this packet.

Sharing & Disclosure · Company practice

Iowa and Utah education information disclosed for targeted advertising or sold to advertisers

Row K’s combined “Disclosed for Targeted Advertising or "Sold"” cell names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. With this cell, row K is complete in the chart.

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

• Disclosed for Targeted Advertising or "Sold"

Not stated here

• The combined heading leaves open which recipients receive education information for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah sensitive beliefs and health data disclosed to providers, advertisers, affiliates and authorities

For row L, the disclosure column names five recipient groups: service providers and vendors; advertisers, ad networks and advertising partners; advertising measurement providers; Roku’s affiliates; and law enforcement or others involved with legal, security and safety matters, processes and requests.

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

Not stated here

• The chart does not attach a purpose to each disclosure, or state any consent step before these disclosures of sensitive information.

Sharing & Disclosure · Company practice

Iowa and Utah sensitive beliefs and health data disclosed for targeted advertising or sold

For row L, the combined “Disclosed for Targeted Advertising or "Sold"” column names advertisers, ad networks, advertising partners and ad measurement providers, for relevant ads and campaign-effectiveness reporting. The chart therefore places these sensitive categories in the same combined column as the other rows.

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

• Disclosed for Targeted Advertising or "Sold"

Not stated here

• The combined heading leaves open which recipients receive these sensitive categories for targeted advertising and which as a sale.

Sharing & Disclosure · Company practice

Iowa and Utah credentials disclosed to providers, affiliates, authorities and merchants

For row M, the disclosure column names four recipient groups: service providers and vendors; Roku’s affiliates; law enforcement or others involved with legal, security and safety matters, processes and requests; and merchants and their partners the reader transacts with on the Roku Services. The chart shows no combined targeted advertising or sale entry for this row.

Supporting quotations

Service providers and vendors

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

• Merchants and their partners you transact with on Roku Services

Not stated here

• The chart does not attach a purpose to each disclosure, and shows no targeted advertising or sale entry for these credentials.