This Privacy Policy Was Last Updated on [August 20, 2024]
This Privacy Policy (the “Privacy Policy”) explains how MediaNews Group, Inc. and its Affiliates (“MNG”, “we”, “our” or “us”) collect, use, process, and share information about you when you use our Services or otherwise interact with us or receive a communication from us related to the Services. For certain Services, we may provide you with additional privacy policies and information that supplement this Privacy Policy.
PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE COLLECT AND HANDLE INFORMATION ABOUT YOU. BY ACCESSING OR USING OUR SERVICES, YOU ACKNOWLEDGE AND AGREE THAT YOU CONSENT TO THE PRACTICES AND POLICIES OUTLINED IN THIS PRIVACY POLICY AND THAT YOU HAVE READ AND UNDERSTAND THIS PRIVACY POLICY. THIS PRIVACY POLICY IS ALSO GOVERNED BY OUR TERMS OF USE. BY ACCESSING OR USING OUR SERVICES, YOU ALSO ACKNOWLEDGE AND AGREE THAT YOU CONSENT TO THE TERMS AND CONDITIONS SET FORTH IN OUR TERMS OF USE AND THAT YOU HAVE READ AND UNDERSTAND OUR TERMS OF USE.
If you do not agree with this Privacy Policy, do not access or use our Services or interact with any other aspect of our business. This Privacy Policy does not apply to the practices of companies that we do not own or control, or to individuals that we do not employ or manage.
This Privacy Policy is intended to help you understand:
- 1. Overview: What This Privacy Policy Covers.
- 2. Overview: When This Privacy Policy Applies.
- 3. The Information We Collect About You and How We Collect It.
- 3.1. Information That You Provide to Us Voluntarily.
- 3.1.1. For Subscription Registrations.
- 3.1.2. For Billing & Payment Matters.
- 3.1.3. Registration for Newsletters, Contests, Sweepstakes, or Promotion Offers.
- 3.1.4. For Participating in Voting, Polling, Surveys, or Similar Activities.
- 3.1.5. For Customer Service Matters & Subscriptions by Phone.
- 3.1.6. For User-Generated Content.
- 3.1.7. If You Apply to a Job Posting Offered by Us or Become Our Employee.
- 3.1.8. If You Provide Your Personal Information to Us For Any Other Reason.
- 3.2. Information That We Collect Automatically.
- 3.1. Information That You Provide to Us Voluntarily.
- 4. How Do We Use the Information We Collect About You?
- 5. With Whom Do We Share Your Information?
- 6. How Do We Use Online Analytics & Interest-Based Advertising?
- 7. How Do Third Parties Collect & Use Your Information Through Our Services?
- 8. What Are Your Rights & Choices?
- 9. Additional Privacy Rights and Choices of U.S. Residents
- 9.1 Your California Privacy Rights
- 9.2 Your Nevada Rights & Choices.
- 9.3 Your Virginia Rights & Choices.
- 9.4 Your Colorado Rights & Choices.
- 9.5 Your Connecticut Rights & Choices
- 9.6 Your Utah Rights & Choices
- 9.7 Your Texas Rights & Choices
- 9.8 Your Oregon Rights & Choices
- 9.9 Your Montana Rights & Choices
- 10. Use of The Services by Users from Outside The United States
- 11. How Can You Access, Correct, Or Update Your Personal Information?
- 12. What About Linked Third-Party Services, Sites, & Advertisements That I See Via The Services?
- 13. How Do We Protect Your Personal Information?
- 14. How Long Do We Retain Your Personal Information?
- 15. What Are the Requirements or Guidelines for The Use of Our Services By Children?
- 16. Changes to This Privacy Policy.
- 17. No Rights of Third Parties.
- 18. Complaints.
- 19. How Can You Contact Us?
1. Overview: What This Privacy Policy Covers.
This Privacy Policy sets out how we collect, use, disclose, share, sell, and protect your Personal Information when you use any of our Services. Additionally, this Privacy Policy explains your legal rights and choices that you have with respect to our collection, use, processing, sharing, and protection of your Personal Information. Furthermore, this Privacy Policy explains how you may exercise those legal rights and choices regarding how we use your Personal Information in connection with your receipt of the Services.
This Privacy Policy is a separate document from our Terms of Use, which are available here. This Privacy Policy modifies, and is supplementary to, our Terms of Use. Your use of the Services is also governed by our Terms of Use. By using the Services, you also expressly consent and agree to the terms and conditions of our Terms of Use.
MNG takes this Privacy Policy and the task of protecting and appropriately handling your information very seriously. We believe strongly in being open and transparent about our privacy-related policies and practices. If you have any questions about this Privacy Policy, or about exercising privacy-related rights and choices that may apply to you about your use of the Services, please let us know at [email protected].
1.1 What Does the Term “Personal Information” Mean in this Privacy Policy?
In this Privacy Policy, the term “Personal Information” means any information about you that can personally identify you, either on its own or when combined with other information.
1.2 What Does the Term “Services” Mean in This Privacy Policy?
In this Privacy Policy, the term “Services” means any of our:
- Platform;
- Websites;
- Applications;
- Online products and services that link to this Policy;
- The services that we offer you when you subscribe to a print, digital, electronic, or online subscription to any of our newspaper publications;
- The services that we offer to you when you sign up to receive any of our newsletters;
- SMS/Text Alerts and Mobile Web services; and
- All other services that we provide to you, together with all of the content, functionalities, and advertising services associated with these services.
1.3 What do the Terms “Affiliates”, “Applications” “Websites”, and “Platform” Mean in This Privacy Policy?
In this Privacy Policy, the following capitalized terms also have the following meanings:
“Affiliates” means MNG’s subsidiary entities and entities that MNG or its subsidiaries own or have an ownership interest in, collectively.
“Application” or “Applications” means any one or more of our mobile or tablet applications through which we may provide you with the Services.
“Website” or “Websites” means any one or more of the Internet websites owned by us through which we may provide you with the Services, such as, www.medianewsgroup.com.
“Platform” means, collectively, any of our Applications and/or Websites through which you may receive the Services from us.
2. Overview: When This Privacy Policy Applies.
This Privacy Policy applies when you use or access any of our Services. This Privacy Policy also applies regardless of how you use or access the Services. For example, this Privacy Policy would apply when:
- You use any of our Websites, Applications, or the Platform to view or receive content that we publish or otherwise make available via the Services, regardless of whether or not you are a subscriber;
- You subscribe to any of our Services;
- You subscribe to a print, digital, electronic, or online subscription for any of our newspaper publications, or other publications;
- You subscribe to any of our newsletters or otherwise agree to receive emails from us about our Services;
- You receive SMS/Text Alerts from us; or
- You interact with us or receive a communication from us related to the Services;
- You contact us or any of our third-party service providers to receive customer support or other assistance in connection with the Services we provide you.
This Privacy Policy may also apply in other circumstances when you use any of our Services. Some Services and Affiliates may have a specific, separate privacy policy that will govern use of those Services.
3. The Information We Collect About You and How We Collect It.
The information that we collect about you, and whether or not that information includes your Personal Information, depends on the Services you use, context, and any preferences that you have communicated to us. In order to make your visits to our Platform and use of the Services as worthwhile as possible, we may ask you to provide your Personal Information to us. Similarly, we may automatically collect your Personal Information when you use or access the Services via the Websites, Applications, or Platform.
We also may collect certain information – other than your Personal Information – from your web browser, computer, mobile device, or tablet each time you visit any of our Websites, Applications, or Platform or receive Services, such as, non-user specific, de-identified, or aggregated data about web traffic patterns on our Websites. For more information about non-user specific, de-identified, or aggregated information that we may collect when you use the Services, please see Section 4.1 of this Privacy Policy.
3.1. Information That You Provide to Us Voluntarily.
We collect Personal Information about you when you provide it to us voluntarily, in order for you to use the Services and during your use of the Services. The types of Personal Information that you may provide to us voluntarily depends on context and how you use the Services. However, examples of the types of Personal Information that you may provide to us voluntarily include, but are not necessarily limited to, your: name, mailing address, home phone number, mobile phone number, email address, username, password, payment information, gender, and date of birth. In Sections 3.1.1 – 3.1.8 below, this Privacy Policy describes circumstances where we collect Personal Information about you, which you voluntarily provide to us.
3.1.1. For Subscription Registrations.
When you register for a print, digital, electronic, or online subscription to any of our newspapers or other publications, you will voluntarily provide us with your Personal Information to enable us to set up your subscription. Once you are registered for a subscription, we will assign you an internal account ID number, which we will use in connection with the Services that we provide to you.
For some Services, you can sign-in or sign-up for your Subscription by providing us with, and linking your subscription to, your Apple, Google, or Facebook account. Please refer to Section 3.2.3 of this Privacy Policy for additional information.
3.1.2. For Billing & Payment Matters.
When you register for a paid subscription to any of our Services, we also will collect and use the payment information that you voluntarily provide to us. The payment information that you voluntarily provide to us is also your Personal Information. This payment information can include, but is not necessarily limited to, your: name, address, telephone number, date of birth, email address, credit card or debit card information, bank account information, and any other relevant Personal Information for billing and payment matters regarding your use of the Services.
3.1.3. Registration for Newsletters, Contests, Sweepstakes, or Promotion Offers.
When you register to receive any of our newsletters, we will also collect Personal Information about you that you voluntarily provide us. This Personal information can include, but is not necessarily limited to, your name, email address, date of birth, and telephone number.
Additionally, we will collect your Personal Information if you enter a contest or sweepstakes that we offer as part of the Services, or register for a promotional offer relating to our Services.
3.1.4. For Participating in Voting, Polling, Surveys, or Similar Activities.
We will also collect Personal Information that you voluntarily provided us, if you decide to participate in voting or polling, surveys, or similar activities relating to our Services where users like you are asked to respond to a variety of questions.
3.1.5. For Customer Service Matters & Subscriptions by Phone.
We will request that you voluntarily provide us with your Personal Information when you subscribe to any of our Services over the phone, or when you contact our official customer service telephone numbers or email addresses for our Services. Our official customer service telephone numbers and email addresses are provided on our Websites.
3.1.6. For User-Generated Content.
As part of the Services, you may be able to post or otherwise publish User-Generated Content that other people can read or interact with. In this Privacy Policy, the term “User-Generated Content” means your comments or posts on articles or message boards, photos, videos, audio, opinion and editorial content, reviews, feedback, testimonials, and any other content that you submit to us for publication on any of our Websites, Applications, Platform, or otherwise via our Services. We will collect your Personal Information when you voluntarily provide it to us in connection with any User-Generated Content that you submit to us. For example, you may submit information or content to us for editorial purposes, which you may request that we publish in our newspaper publications. Similarly, you may have the ability to post a comment on the Platform in response to a story that we offer as part of the Services. We may use your name and any stories or other User-Generated Content you provide us in articles that we publish online and in print as part of the Services. Your User-Generated Content, such as editorial content or your posts and comments on an article, that you provide us may be attributed to you, and we may include your username and any Personal Information that you provide in an open forum on our Websites and Applications to facilitate such attribution. Anyone can collect, use, share, and read any Personal Information that you provide us in connection with the User-Generated Content that you submit to us via the Services.
3.1.7. If You Apply to a Job Posting Offered by Us or Become Our Employee.
If you apply for a job posting offered by Us, or become an employee of Us, we collect the Personal Information about you that is necessary to process your application or retain you as an employee. Providing us with this Personal Information is required for employment. In the context of job applications and employment matters, in addition to the Personal Information that we collect from you directly, we may also receive information about you from other sources (including information containing your Personal Information). These other sources may include, but are not necessarily limited to, MNG’s Affiliates, business partners, publicly-available sources, and other third parties. For example, if you submit a job application or become an employee, we may conduct a background check.
If you are a California resident and our Employee, independent contractor, or are applying for a job with us, please refer to Section 8 (What Are Your Rights & Choices?) of this Privacy Policy and our California Resident Employee Privacy Policy for additional information about your privacy-related legal rights and choices that apply to you under applicable laws.
3.1.8. If You Provide Your Personal Information to Us For Any Other Reason.
We will also collect and use any other Personal Information that you voluntarily provide to us for any other reason in connection with the Services that we offer. For example, other circumstances where we collect Personal Information about you that you voluntarily provide us include, but are not necessarily limited to:
- When you sign-up to receive SMS (text message) notifications;
- When you sign-up to receive desktop (browser-based) or mobile push notifications;
- When you download or use one of our Applications;
- When you navigate any of our Websites and Applications; or
- When you connect with the Services via your “Social Media” (i.e., Facebook) or “Third-Party Services” (i.e., Apple or Google) accounts or otherwise allow us to access certain information about you via your Social Media or Third-Party Services accounts.
3.2. Information That We Collect Automatically.
We may automatically collect information about you, including your Personal Information, when you use the Services. The Personal Information that we collect automatically when you use the Services may include, but is not necessarily limited to:
- Device identifiers (i.e., information about the mobile, tablet, or computer device you use to access the Services);
- Advertising identifiers;
- Your IP address;
- Your location;
- The URLs of any pages you visit on our Website or Applications;
- Your browser, browser profile, and web browsing history;
- Your browser language;
- Your browser’s Cookies;
- Behavioral data about your interaction with the Services on Websites or Applications, including but not limited to information about articles you read or videos you watch on the Platform;
- The URLs of any pages you visit on our Platform, Websites, or Applications; and
- Other usage information.
In Sections 3.2.1 – 3.2.5 below, this Privacy Policy describes the circumstances where we may automatically collect Personal Information about you when you use the Services.
3.2.1 Device/Usage Information.
We may automatically collect certain Personal Information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect automatically and analyze your Personal Information such as: (a) IP addresses, geolocation information (as described in Section 3.2.2 below), unique device identifiers including mobile advertising identifiers, and other information about your mobile phone or other mobile device(s), browser types, browser language, operating system, the state or country from which you accessed the Services; and (b) information related to the ways in which you interact with the Services, such as referring and exit pages and URLs, platform type, clicked items, interaction with advertisements, domain names, landing pages, pages and content viewed and the order of those pages, the amount of time spent on particular pages, mouse hover data, including location and time spent on each area of the page, the date and time you used the Services, the frequency of your use of the Services, error logs, and other similar information and Personal Information about you. As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools and technologies, to assist in collecting and analyzing this information and Personal Information about you.
We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique MNG identifier for our internal use, in which case your MNG identifier will be considered aggregated and de-identified information owned by MNG, our use of which is governed by this Privacy Policy and applicable laws.
3.2.2. Location Information.
Some of our Applications may have the ability to provide content to you based on your GPS location, if you enable this feature. Your GPS location is your exact location. You choose whether to enable GPS features when you first install the Application. You can edit that setting on your device at any time. If you enable these features, your GPS location will be found by satellite, cellphone tower, or Wi-Fi and used by the Application. If you save a location-based search in your history, that data moves to our service provider’s servers.
If you do not enable GPS location-based services, or if a specific Application does not have location-based features, we do not collect your precise GPS location. However, we do collect your IP address, which can establish your approximate location. Ads on our Websites and Applications may be targeted based on this approximate location, but are not targeted based on your GPS location.
We may collect different types of information about your location, including general information (e.g., IP address, ZIP code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in a specific US State and city or region, the Services may be customized with information and advertisements relevant to that specific US State, city, or region.
3.2.3. Cookies & Other Information Technologies.
“Cookies” are small data files that are sent to, and stored by, your web browser software on your computer hard drive, tablet, mobile device, or other device. When you use or access the Services via the Internet, we and our third-party partners may use cookies and similar internet tracking technologies to do things, such as: (a) store your username and password to your accounts for the Services; (b) monitor and analyze the usage of our Applications, Websites, Platform, and/or Services by collecting the information discussed in Section 3.2 of this Privacy Policy; (c) customize the Services to your explicit and inferred preferences; and (d) deliver interest-based advertising displayed by the Applications, Websites, Platform, and Services, as well as advertisements that may be displayed on other websites or mobile applications. Please review our Cookie Policy to learn about our use – and our third-party service providers’ use – of cookies and similar Internet technologies on our Applications, Websites, Platform, and Services.
Additional Notes About Cookies & Your Rights & Choices:
- Depending on the jurisdiction in which you reside, cookies may constitute your Personal Information under applicable laws.
- For additional information about how we, and our third-party advertising partners, may use your cookies when you access the Services via the Internet, please refer to the following sections of our Privacy Policy: Section 6 (How Do We Use Online Analytics & Interest-Based Advertising?) and Section 7 (How Do Third Parties Collect & Use Your Personal Information Via The Services?).
- For additional information about your legal rights and choices regarding our and our third-party advertising partners’ collection and use of your cookies when you use the Services – including how you can opt-out or block the collection and use of your cookies by us and third parties – please refer to Section 8 (What Are Your Rights & Choices?), Section 9 (Additional Privacy Rights and Choices of U.S. Residents), and Section 10 (Use of The Services By Users From Outside The United States).
- We may sometimes target ads to you through ‘onboarded’ audiences: to do this, we may share information you have provided to us with service providers, who will de-identify the information and associate it with cookies that enable us to reach you with display media. We may also help these service providers place their own cookies, by deploying a cookie that is associated with a ‘hashed’ value associated with interest-based or demographic data, to permit advertising to be directed to you on other websites, applications, or services.
- We also may use cookies to collect information around and about abandoned shopping carts for purchases made by you on our services. A shopping cart is considered to be abandoned within one hour of inactivity/lack of purchase. For certain services and users, once a cart is considered abandoned, an SMS message will be sent as a reminder.
3.2.4. Personal Information About You That We Collect from Other Sources
i. Social Media Networks & Other Third-Party Services
In this Privacy Policy, “Social Media” includes Facebook, and “Third-Party Services” include Google and Apple.
You can link your Social Media account or other Third-Party Services account to the Services. By linking your Social Media account or other Third-Party Services account to the Services, you authorize us to collect, store, and use any information (including Personal Information about you) that they may give us (e.g., your name and email address). You can disconnect your Social Media account or other Third-Party Services account from the Services at any time.
We also collect information from you when you interact with our pages, groups, accounts, or posts on Social Media platforms. This information includes aggregate data on our follows (such as, location, gender, and age), awareness date (such as, number of impressions and reach), engagement data (such as, likes, comments, reposts, and clicks), and individual users’ public profiles.
Please refer to our Cookie Policy for additional information about our use of Social Media Cookies and similar technologies on our Applications, Websites, Platform, and Services.
ii. Private Databases.
Databases owned by private marketing, data analytics, and Social Media platforms also give us access to a range of information, such as public data, survey data, and other types of data. Sometimes the information that we receive from these sources may include your Personal Information, such as your mailing address, gender, age, household income, or other demographic data.
iii. Schools and Workplaces.
If your school or employer purchases a subscription to the Services that allows everyone within your organization, or certain people within your organization, to use the Services, your school or employer may provide us with your Personal Information to grant you access to the Services as a user (e.g., your name, work or school email address, and username).
iv. Information from Other Third Parties.
We may obtain additional Personal Information about you from other third parties, such as partners, researchers, data services companies (e.g., for data enhancement), and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or Services we provide.
3.2.5. Collection of Personal Information Across Devices & Applications.
Sometimes, we (or our service providers) may use the Personal Information we collect about you – for instance, log-in credentials, IP addresses, hashed email addresses, and unique mobile device identifiers – to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content, features, and advertising, and provide you with a seamless experience across the devices you use to access the Services.
4. How Do We Use the Information We Collect About You?
We use the Personal Information and other information that we collect about you for the following purposes:
- To provide you with the Services;
- For the purpose for which your Personal Information provided to us;
- To process payments that you make for the Services;
- To provide you with customer service regarding your use of the Services;
- To respond to your inquiries, requests, or complaints about the Services;
- To set up your account with us for the Services and to allow you to access your account;
- To advertise the Services to you;
- To send you messages, notices, emails, phone calls, or other communications about the Services;
- To send you alerts or other communications via SMS messages or other media or networks;
- To send you information about your relationship or transactions with us;
- To notify you about new features of the Services, special events, or products, services, and special offers;
- To administer sweepstakes and contests;
- To contact you with information that we believe will be of interest to you;
- To administer and troubleshoot the Services;
- To generate and review reports and data about our user base and usage patterns of the Services;
- To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services;
- To offer, manage, monitor, and improve the content and features of the Services or develop new Services;
- To allow us to personalize or otherwise provide the content and advertising that you see on the Services and on other websites and mobile applications and to understand how users interact with and use our Applications, Websites, Platform, advertisements, and Services
- To associate your activities, customize content, or deliver interest-based advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications, and websites);
- To send you offers and advertisements through various channels (which may include, for instance, display, email, direct mail, and TV), whether on our behalf or on behalf of marketing partners with whom we may engage;
- To enable you to link the Services with your Social Media account or other Third-Party Services account, as described above in Section 3.2.4.i of this Privacy Policy;
- To allow you to share User-Generated Content and to attribute the User Generated Content that you make available through the Services to you;
- To protect your Personal Information and comply with your legal privacy rights under applicable laws;
- To enforce the legal terms that govern your use of the Services; and/or
- For any other lawful purposes that we deem necessary or appropriate.
4.1. Our Use of Aggregated & De-Identified Information Based on Your Personal Information
We also may aggregate and de-identify the Personal Information that we collect about you via the Services or other sources, so that the aggregated and de-identified information derived from your Personal Information no longer constitutes Personal Information under applicable laws. To the maximum extent permitted by applicable laws, we may process, share, disclose, and otherwise use any aggregated and/or de-identified information based on your Personal Information in any manner that we see fit in our discretion.
5. With Whom Do We Share Your Information?
MNG may share your information, including your Personal Information, with our employees, agents, and Affiliates, in order to provide you with the Services and for the other purposes described in Section 4 of this Privacy Policy.
We may share or otherwise disclose your Personal Information to our service providers, (a) in order to provide you with the Services or products that you have requested from us, (b) when we have your permission, or (c) as is otherwise described in this Privacy Policy. We work with service providers to provide certain services and perform certain functions on our behalf, such as:
- Delivering your newspapers
- Shipping and fulfillment
- Fulfilling your orders and subscriptions
- Providing customer service to you
- Billing
- Sales
- Provision of content and features available via the Services
- Processing your payments
- Sending emails to you
- Marketing research
- Data analytics
- Serving and targeting ads
- Measuring ad performance
- Maintaining our IT infrastructure
- Data storage, fraud prevention, and security
- Conducting and analyzing surveys
- Legal services
- For other lawful purposes relating to our business and the Services
When performing the functions above, these service providers often have access to, and process, your Personal Information. We also may allow these service providers to use aggregated or de-identified information derived from your Personal Information for other purposes pursuant to applicable laws. When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers’, operators’, or sponsors’ privacy policies or practices.
We may share your information with non-affiliated third parties with whom we have a contractual relationship, including without limitation our event sponsors, if you attend an event, third-party advertisers, and advertising and list brokering networks, for their own and sometimes our own advertising and marketing purposes. Those third parties may combine Personal Information they receive from us with other information about you that they obtained from other sources or directly from you.
As described in this Privacy Policy, we may collect and share information about materials you accessed on the Platform, including but not limited to searches you conducted and articles and videos you requested and/or viewed. We may share this information with third parties, including our service providers, advertising networks, and business partners. By accessing these materials on the Platform, you consent to the collection and disclosure of information related to your searches on the Platform and your interaction with articles and videos on the Platform. In some situations, you may be able to limit disclosure of this information to third parties as described in this Policy.
We may access, disclose, transfer, and preserve your information when we have a good faith belief that doing so is necessary to:
- Protect our users and our legal rights, privacy, or safety and that of our subsidiaries, Affiliates, employees, agents, contractors, or other individuals, including by enforcing this Privacy Policy, our Cookie Policy, or our Terms of Use;
- Comply with the law, including with subpoenas, search warrants, court orders, and other legal processes; and respond to inquiries or requests from government, regulatory bodies, law enforcement, public authorities, or content protection organizations;
- Permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages that we may sustain; or
- Enforce this Privacy Policy, our Cookie Policy, or our Terms of Use.
We may share your information in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all of our assets, or a financing or acquisition of all or a portion of our business by another company.
To the maximum extent permitted by applicable laws, we may disclose any aggregated and/or de-identified information derived from the Personal Information that we collect about you to any third party for any purpose we deem necessary or appropriate.
6. How Do We Use Online Analytics & Interest-Based Advertising?
6.1. Our Use of Online Analytics.
We may use third-party web analytics services on our Services, such as those provided by Google Analytics, Adobe Omniture, The Trade Desk, and similar providers. These service providers use the sort of technology described in our Cookie Policy and Section 3.2.3 of this Privacy Policy to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by these technologies will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in Section 6.2 and Section 8.1 of this Privacy Policy and in our Cookie Policy. You can opt-out of Google Analytics as described in Section 8.2 of this Privacy Policy.
6.2. Our Use of Interest-Based Advertising.
When you use the Services, we may serve you with ads based on various factors such as the content of the page you are visiting, Personal Information and other information that you provide, such as, your age or gender, your searches, demographic and geographic data, User-Generated Content, and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be based on your interests.
When you use the Services, we may share information about you, such as a hashed version of your email address, your IP address, and information about your device settings with our third-party advertising technology providers. Those advertising technology providers may use that information to assign you a unique ID for the purpose of recognizing you on your devices. We may place this unique ID in our first-party cookie, or use a partner that places a third-party cookie and allows it to be used for online and interest-based ad targeting. Your unique ID may be shared by us or on our behalf with third-party advertisers for interest-based ad targeting.
Also, third parties, including without limitation those whose products or services are accessible or advertised via the Services, may place cookies, web beacons or pixel tags, or other similar tracking technologies (such as mobile ‘SDKs,’ which function like a mobile version of a browser cookie and are embedded in mobile applications) on your computer browser, mobile phone applications, or other device to collect information about your use of the Services, including your Personal Information, in order to: (i) inform, optimize, and serve ads based on past visits to our websites and other sites and mobile applications; and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our Websites, Applications, Platform, and the use of our Services. We also allow other third parties to serve interest-based ads to you via the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services so that interest-based ads may be delivered to you when you are using other websites and mobile applications. We also may share with third-party advertisers a hashed version of your email address, your IP address, and/or information about your browser or operating system, which may be identified by a service provider for purposes of delivering interest-based advertising on the Services, other websites, and/or mobile applications. We likewise may work with platform providers who serve advertising across devices. For instance, we may want to reach our web-based customers when they are on their mobile devices. This is done, generally, by correlating common attributes (such as IP addresses, other browser or device information, hashed email addresses, or unique ID) across devices, to infer a common identity across multiple channels.
Where a third party advertiser assigns you a unique ID, we may place this unique ID in our first party cookie, or use a partner that places a third party cookie and allows it to be used for online and interest based ad targeting. Your unique ID may be shared by us or on our behalf with third party advertisers for interest based ad targeting.
The third parties that use these technologies may offer you a way to opt-out of interest-based ad targeting, as is described in our Cookie Policy and in Section 8 (What are Your Rights & Choices?) [LN1] of this Privacy Policy. We do not maintain or control these opt-opt mechanisms, which are provided by non-affiliated third parties. Further, we do not control which third parties choose to participate in these opt-out mechanisms. Please note that opting out of interest-based advertising does not mean that you will no longer see advertising on the Services, but these ads may be less relevant to your interests.
You can opt-out of targeted or cross-contextual advertising, as those terms are defined in applicable privacy laws, by visiting our Do Not Sell/Share My Information page. For additional information about your legal rights regarding our collection and sharing, selling, or other disclosure of your Personal Information to third parties, please refer to the following Sections of this Privacy Policy: Section 8 (What Are Your Rights & Choices?), Section 9 (Additional Privacy Rights and Choices of U.S. Residents), and Section 10 (Use of The Services By Users From Outside The United States)[LN2] [LN3] [LN4] .[LN5]
7. How Do Third Parties Collect & Use Your Information Through Our Services?
As is described elsewhere in this Privacy Policy, for certain advertising, analytics, and other features that appear in the Services or that we provide via the Services, a third party, such as an advertiser, search engine, or other partner may collect your Personal Information, such as, your name, mailing address, device information, IP address, etc., in accordance with applicable laws. Subject to applicable laws, these third-party entities may use your Personal Information in any way they choose, including to market to you or to share your Personal Information with others. Subject to applicable laws, in those instances, your Personal Information may be covered by those third-party entities’ privacy policies. In some cases, these third-party entities may not have any online presence. Therefore, you should only submit your Personal Information in these cases when you are comfortable doing so given the conditions. If you have questions about the privacy practices of these third-party entities, we encourage you to contact them and review their privacy policies.
For additional information about third-party entities that may collect and use your Personal Information in connection with your use of the Services, and the rights and choices you have to control or limit the collection and use of your Personal Information by these third-party entities, please refer to our Cookie Policy and the following Sections of this Privacy Policy: Section 8 (Your Privacy Rights & Choices), Section 9 (Additional Privacy Rights of U.S. Residents), and Section 10 (Use of The Services By Users From Outside The United States)[LN6] .
8. What Are Your Rights & Choices?
This Section 8 of the Privacy Policy describes your legal rights and choices regarding how we use your Personal Information. This Section 8 of the Privacy Policy also describes how you exercise those rights and choices. We respect your privacy, and we will never discriminate against you for electing to exercise any privacy rights or choices that apply to you.
We provide a variety of ways for you to control the Personal Information we maintain about you, including choices about how we collect and use your Personal Information. In some jurisdictions, these controls and choices are enforceable as rights under applicable law. In addition to the privacy rights and choices detailed below in this Section 8 of this Privacy Policy, additional information about jurisdiction-specific privacy rights and choices that may apply to you can be found in the following Sections of this Privacy Policy:
- If you are a resident of certain U.S. states, you may have additional rights. Please see additional detail below in Section 9 of this Privacy Policy (Additional Privacy Rights and Choices of U.S. Residents);
- If you are a resident of the European Union, European Economic Area, the UK, or Switzerland, please see additional detail below in Section 10 of this Privacy Policy (Use of the Services By Uses From Outside of The United States);
If you are a California resident and (1) an employee of MNG or an Affiliate, (2) an independent contractor of MNG or an Affiliate, or (3) are applying for a job with MNG or an Affiliate, please refer to our California Resident Employee Privacy Policy.
8.1. Managing Your Account, Privacy Rights, & Choices.
i. Email
As part of the Services, we may offer customers like you a variety of different email newsletters and other commercial emails. The Services are supported by advertising revenue. We may send you commercial emails on behalf of ourselves, our Affiliates, and our third-party advertisers. You can unsubscribe to these emails by either following the instructions in the email for opting-out of receiving future emails, or by calling the official customer service number listed in the “Contact Us” webpage of the Website of the newspaper publication from which you are receiving emails and making a request to no longer receive emails.
ii. Promotions Via Mail or Telephone
Sometimes, we may contact you via mail or telephone with promotions for our Services. You can ask us to opt-out these mail or telephone solicitations. In certain jurisdictions, as is discussed elsewhere in this Privacy Policy, you may also have the right to instruct us to not share your Personal Information with third parties for direct marketing purposes. To opt-out of future mail or telephone solicitations regarding the Services, please call the official customer service number listed in the “Contact Us” webpage of the Website of the newspaper publication from which you are receiving mail or telephone solicitations and make a request to no longer receive them.
iii. SMS/Text Message Alerts
If you receive marketing-related SMS/text message alerts from us in connection with the Services, you can opt-out of receiving them by replying “STOP” or any alternate keyword that we have shared with you. We will work to implement your opt-out request quickly and within the timeframes required by applicable laws. However, please note that your opt-out request will not prohibit us from sending you important non-marketing SMS/text message alerts about your account or use of the Services.
iv. Push Notifications
You can opt-out of receiving push notifications from us by changing your settings on the device that is sending you push notifications from us, or by uninstalling the Application that is sending you push notifications from us.
v. Platform & Web Browser Controls
- Cookie Controls & Settings
As is discussed in Section 3.2.3 of this Privacy Policy in and our Cookie Policy, when you access the Services via the Internet or an Internet-connected device, we may place or collect “cookies” from your web browser or device, and we may use these cookies for various purposes. Depending on the jurisdiction in which you reside, some of these cookies may constitute your Personal Information under applicable law.
Most web browsers are set to accept cookies by default. However, you can configure the settings of your web browser to delete or reject cookies. Additionally, the Websites on which we provide the Services offer you the capability to choose certain cookie preferences about whether or not your web browser will accept – or instead will block/reject – certain cookies from our Websites. To implement your personal cookie preferences on our Websites, please click on the “Cookie Preferences” link at the bottom of the webpage of the Website to access the cookie preferences menu.
Once you have opened the cookie preferences menu, you can choose whether your web browser will accept or block/reject certain types of cookies from the Website. In the cookie preferences menu, you can also opt-out of certain uses of Personal Information we collect about you via cookies, such as our “sale” or use in targeted advertising. For additional information about opting-out of our “sales” or targeted advertising, please refer to Section 9 of this Privacy Policy (Your California Privacy Rights).
Please review, and be aware of, the following regarding your choice to delete, reject, or otherwise opt-out of cookies in connection with your use of the Services:
- If you choose to delete or reject cookies on your web browser or device, this could affect certain features or Services that we provide via our Websites and Applications;
- These cookie-blocking and opt-out mechanisms are unique to your computer, tablet, device, and web browser, which means that you will need to re-implement your cookie blocking our opt-out preferences on each such computer, tablet, device, and web browser that you use;
- If you clear or delete your cookies on your device or web browser after opting-out of cookies or configuring our cookie preferences menu to block or reject cookies, this will result in the deletion of the opt-out or blocking cookie on your web browser or device, meaning you will need to opt-out or configure our cookie preferences menu again after clearing or deleting the cookies (this may also apply to “Do Not Sell/Share My Personal Information” signals/preferences that you implement via our cookies preferences menu on our Websites); and
- After you opt-out of cookies or configure your personalized cookie preferences on our Websites to block/reject cookies, you may continue to receive advertising via our Services, but those ads may be less relevant to you.
For additional information about cookies, implementing your personalized cookie preferences on our Websites, and how we collect and use cookies, please refer to our Cookie Policy. Please also refer to Section 8.2 of this Privacy Policy (Your Additional Rights and Choices For Third Parties & Our Online Analytics & Interest-Based Advertising Practices) for additional information about how to opt-out of cookies and similar technologies using third-party opt-out mechanisms.
- Global Privacy Control (GPC)
Some web browsers and browser extensions support the Global Privacy Control (“GPC”), which can send a signal to the websites you visit that indicates your choice to opt-out of certain types of uses and disclosures of your Personal Information, including sales of your Personal Information. For users of the Services in certain jurisdictions, when we detect a GPC signal, we will make reasonable efforts to respect your privacy-related choices that are identified by the GPC signal we detected and the GPC setting you implemented, as required by applicable laws.
- Do Not Track (DNT)
Some web browsers offer a “Do Not Track” (“DNT”) setting that can send a signal to the websites that you visit, which indicates that you do not wish to be tracked by the websites. However, unlike the GPC signals described above, there is no common understanding of how to interpret such DNT signals as of the “Last Updated Date” of this Privacy Policy. As such, our Websites and Applications do not respond to web browser DNT signals. However, as is discussed above in this Privacy Policy, you may change the privacy preferences in your web browser to prevent or limit the use of cookies or similar technologies. To learn more about managing, blocking, and deleting cookies, please refer to our Cookie Policy. As is discussed above, blocking or deleting cookies or similar technologies may affect your browsing experience on our Websites and may prevent you from accessing or using certain of our Services, including some of the personalized features that we provide to users as part of the Services.
- Mobile Advertising ID Controls for iOS and Android Users
Mobile devices running on iOS and Android operating systems provide options about how to limit tracking and/or reset advertising IDs. You may be able to implement these options on your iOS or Android mobile device that you use to access the Services. For more information about advertising IDs and how to implement advertising ID controls and choices on your iOS or Android mobile device in connection with your use of the Services, please click here. Please refer to the bullet titled “Mobile Device Settings” under Section 8.2 of this Privacy Policy below for additional information.
8.2. Your Additional Rights & Choices for Third Parties & Our Online Analytics & Interest-Based Advertising Practices.
As is discussed above in Section 6 of this Privacy Policy, we use Google Analytics on our Services for various purposes, including for online analytics and interest-based advertising purposes. To prevent Google Analytics from using your Personal Information for analytics purposes, you may install the Google Analytics Opt-out Browser Add-on by clicking here. Click here for additional information about Google Analytics, and click here to view Google’s Privacy Policy and Terms of Service.
As is discussed elsewhere in this Privacy Policy and in our Cookie Policy, when you access or use our Services on the Internet via any of our Websites, Applications, or Platform, we use various third-party service providers and technologies to serve you tailored advertising for products, services, and content that we think you might be interested in. This interest-based advertising often uses your Personal Information (such as your cookies, browsing history, or IP address) to serve you relevant ads via our Services. These third parties that provide the interest-based advertising services and technologies we use on our Services may offer you a way to opt-out of interest-based ad targeting. We do not maintain or control these opt-out mechanisms, which are provided and controlled by non-affiliated third parties. Furthermore, we do not control which third parties participate in these opt-out mechanisms. Please note that opting out of interest-based advertising does not mean that you will no longer see advertising on the Services, but these ads may be less relevant to your interests.
To maximize the effectiveness of your opt-out for interest-based advertising, you should register your choice through all of these mechanisms and on each web browser and/or mobile device that you use to access the Services:
- General Third Party Opt-Out Mechanisms (Browser/Cookie-based). If you would like more information about interest-based advertising enabled via cookies and web browsers and how you can generally control cookies from being put on your computer for such advertising, please refer to our Cookie Policy. In addition to the steps described above in this Privacy Policy and in our Cookie Policy, you may opt out of certain targeted advertising from participating companies and entities as follows:
- US Based Opt-Outs. For US based opt-outs, you may visit and use the Network Advertising Initiative’s (NAI) Consumer Opt-out link (www.networkadvertising.org/choices), the Digital Advertising Alliance’s (DAA) Consumer Opt-Out link (https://optout.aboutads.info/?c=2&lang=EN), and TrustArc’s Advertising Choices Page (https://preferences-mgr.truste.com/)
- Canadian Based Opt-Outs. For Canadian based opt-outs, you may visit and use the opt-out mechanisms at https://youradchoices.ca/choices.
- European Based Opt-Outs. For European based opt-outs, you may visit and use the opt-out mechanisms at https://www.youronlinechoices.com/.
- LiveRamp. To opt-out of data collection, sharing, and use by our partner, LiveRamp, please click here.
- Criteo. To opt-out of data collection, sharing, and use by our partner, Criteo, please click here. You can read Criteo’s privacy policy here.
- Connatix. For information about how to opt-out of data collection, sharing, and use by our partner, Connatix, please visit Connatix’s Privacy Policy here.
- ID5. For information about how to opt-out of data collection, sharing, and use by our partner, ID5, click here. You can read ID5’s privacy policy here.
- The Trade Desk. To opt-out of data collection, sharing, and use by our partner, The Trade Desk, please click here.
- Facebook. For information about how to manage interest-based advertising and data collection, sharing, and use by our partner, Facebook, please click here.
- Google Analytics/Google Ads. If you have a Google account, we may use Google Analytics to serve and display advertising to you. You can opt-out of Google Analytics for display advertising or customize your Google display network ads by visiting the Google Ads Settings page. You will need to log in to Google via the Sign In link if you are not already logged in when you visit that page.
- Microsoft. Microsoft may also collect or receive your Personal Data to provide targeted advertising to you via the Services. For information about how to manage and control data collection, sharing and use by Microsoft, please refer to the “How to access and control your personal data” section of Microsoft’s Privacy Policy. To opt-out of data collection, use, and sharing by Microsoft, please click here. For information about Microsoft’s data collection and interest-based advertising practices, please visit Microsoft’s Privacy Policy
- Mobile Device Settings. You can also opt-out of “cross-app” advertising – interest-based advertising that is associated with your use of our or other mobile applications. To do so, please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. Each operating system (iOS for Apple devices, Android for Android devices, and Windows for Microsoft devices) provides its own instructions on how to prevent the delivery of interest-based in-application advertisements. We cannot guarantee that these instructions will not change, or that they will continue to be available, as they are controlled by each mobile platform and not us. For any other devices and/or operating systems, please visit the privacy settings for the applicable device or operating system or contact the applicable platform operator. Please also refer to the discussion above under the paragraph titled “Mobile Advertising ID Controls for iOS and Android Users” for additional information about your privacy rights and choices for iOS and Android mobile devices.
Please refer to Section 2 of our Cookie Policy for important information that you should review before choosing to opt-out, delete, or block cookies.
9. Additional Privacy Rights and Choices of U.S. Residents
9.1 Your California Privacy Rights
Notice For California Residents
The California Consumer Privacy Act (“CCPA”), as amended by the California Privacy Rights Act (“CPRA”) (the CPPA and CPRA, collectively the “California Privacy Laws”) gives California residents certain rights and choices about how we collect, use, and disclose their Personal Information. This Section 9.1 of this Privacy Policy (the “California Notice”) describes these additional rights and choices and provides disclosures required by the California Privacy Laws about how we collect, use, and disclose California residents’ Personal Information.
This California Notice applies to information of California residents that constitutes “Personal Information” under the California Privacy Laws to the extent that we handle such California Personal Information in our capacity as a business under the California Privacy Laws. For purposes of this California Notice Section of this Privacy Policy, the capitalized term “Personal Information” refers to information of California residents that constitutes “personal information” under the California Privacy Laws, as distinguished from the general definition of Personal Information set forth under Section 1.1 of this Privacy Policy. As a practical matter, if you are a California resident that uses the Services, there is likely little or no difference between Personal Information as used in this California Notice Section of the Privacy Policy and the definition of Personal Information provided above in Section 1.1. This California Notice does not apply to information exempt from, or otherwise not subject to, the requirements of the California Privacy Laws.
California Notice at Collection – The Personal Information That We Collect
We currently collect, and within the 12 months prior to the “Last Updated” date of this Privacy Policy have collected, the following categories of Personal Information:
- Identifiers, such as, a real name, alias, postal address, shipping address, email address, IP address, account name/number, online username, or telephone number.
- Unique personal identifiers, such as, a device identifier, cookies, beacons, mobile identifiers, or other similar technology.
- Internet or other electronic network activity information, such as: browsing history; search history; and information regarding consumers’ interactions with the Services, Websites, Platform, Applications, and ads served via the Services.
- Geolocation data.
- Physical characteristics or descriptions (i.e., photos of you that you provide to us),
- Characteristics of protected classifications under California or Federal law, such as age or gender.
- Commercial and financial information, such as, credit and debit card numbers, bank account numbers, payment information, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
- Audio, electronic, visual, thermal, olfactory, or other similar information.
- Inferences drawn from Personal Information to create a profile about a consumer.
- Sensitive Personal Information, such as a government-issued ID number or payment account information.
We also collect public content that you may provide to us voluntarily, such as, your comments, posts, reviews, survey responses, and User-Generated Content.
We collect Personal Information directly from California residents, Social Media or Third-Party Services platforms that customers use to login to and access our Services (i.e., Facebook, Google, and Apple – for additional information, please see Section 3.1.1 and Section 3.2.4. of this Privacy Policy), publicly available sources, public records databases, other uses and subscribers of the Services, our Affiliates, from your browser of device, data analytics providers, consumer data resellers, government entities, and data brokers. We do not collect all categories of Personal Information from all users or from all sources.
We currently collect, and have collected within the last 12 months, the above-listed categories of Personal Information for the following business or commercial purposes:
- Undertaking activities to improve, upgrade, or enhance our Services.
- Undertaking internal research for technological development and demonstration.
- Debugging to identify and repair errors that impair existing intended functionality.
- Protecting against malicious, deceptive, fraudulent, or illegal activity.
- Auditing related to a current interaction with the consumer and concurrent transactions, including, but not necessarily limited to, counting ad impressions to unique visitors on the Platform, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards.
- Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising and marketing services, providing analytics services, or providing similar services on behalf of the business or service provider.
- Short-term, transient use, including, but not limited to, non-personalized advertising shown as part of your current interaction with us.
- Helping to ensure the security and integrity to the extent the use of your Personal Information is reasonably necessary and proportionate for these purposes.
- Advancing our commercial or economic interests.
Sale, Sharing, & Disclosure of Personal Information
The table below identifies the categories of Personal Information that we sold or shared to third parties in the 12 months preceding the “Last Updated” date of this Privacy Policy, and the categories of third parties to whom we sold or shared each identified category of Personal Information:
Categories of Personal Information | Categories of Third Parties |
Unique personal identifiers (device identifiers, cookies, web beacons, pixel tags, mobile identifiers, or similar technology); Internet Protocol (IP) addresses, online identifiers; Geolocation data; Internet or other electronic network activity information (search history; browsing history; and information regarding a consumer’s interaction with any of our Services, Websites, Applications, Platform, or advertisements served to you via the Services, Websites, Applications, or Platform.); inferences drawn from Personal Information to create a profile about a consumer. | Advertising networks; advertising platforms; advertising technology providers; data analytics providers; Social Media platforms and Third-Party Services providers (e.g., Apple, Google, Facebook); and our Affiliates. |
As is discussed further below, we do not “sell” your Personal Information in the traditional sense (i.e., for money). However, the California Privacy Laws define “sale” and “share” broadly, and our disclosure of Personal Information to third parties to show you advertisements and provide data analytics services for our Websites, Applications, Platform, and Services may constitute a “sale” or “share” under the California Privacy Laws.
The table below identifies the categories of Personal Information that we disclosed to other recipients for a business purpose within the 12 months prior to the “Last Updated” date of this Privacy Policy, and the categories of recipients to whom we disclosed the identified categories of Personal Information:
Categories of Personal Information | Categories of Other Recipients |
Identifiers, such as, a real name, alias, postal address, shipping address, email address, IP address, account name/number, online username, telephone number, an individual’s written or electronic signature, and driver’s license or state identification card number | Our Affiliates; our newspaper delivery distributors; customer service providers; event sponsors; debt collectors; payment processors; telemarketers; Social Media platforms and Third-Party Services providers (e.g., Apple, Google, Facebook); advertising networks; advertising platforms; advertising technology providers; data analytics providers; list brokering networks; our security, fraud, and legal compliance partners and other individuals, entities, or service providers at your request. |
Unique personal identifiers (device identifiers, cookies, web beacons, pixel tags, mobile identifiers, or similar technology); Internet Protocol (IP) addresses, online identifiers; Geolocation data; Internet or other electronic network activity information (search history; browsing history; and information regarding a consumer’s interaction with any of our Services, Websites, Applications, Platform, or advertisements served to you via the Services, Websites, Applications, or Platform); inferences drawn from Personal Information to create a profile about a consumer. | Our Affiliates; Social Media platforms and Third-Party Services providers (e.g., Apple, Google, Facebook); advertising networks; advertising platforms; advertising technology providers; data analytics providers; list brokering networks; IT service providers; our security, fraud, and legal compliance partners; and other individuals, entities, or service providers at your request. |
Characteristics of protected classifications under California or Federal law, such as, age or gender. | Our Affiliates; payment processors; debt collectors; customer service providers, telemarketers; our newspaper delivery providers; our contest, sweepstakes, survey, or polling providers; Social Media platforms and Third-Party Services providers (e.g., Apple, Google, Facebook); advertising networks; advertising platforms; data analytics providers; list brokering networks; our security, fraud, and legal compliance partners; and other individuals, entities, or service providers at your request. |
Commercial and financial information, such as, credit and debit card numbers, bank account numbers, payment information, records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. | Our Affiliates; payment processors debt collectors; customer service providers; our security, fraud, and legal compliance partners; and other individuals, entities, or service providers at your request. |
Physical characteristics or descriptions (i.e., photos of you that you provide to us as User-Generated Content). | Our Affiliates; our third-party content licensing partners; our security, fraud, and legal compliance partners; and other individuals, entities, or service providers at your request. |
Audio, electronic, visual, thermal, olfactory, or other similar information (such as that included in User-Generated Content that you submit to us via the Services) | Our Affiliates; our third-party content licensing partners; our security, fraud, and legal compliance partners; and other individuals, entities, or service providers at your request. |
Sensitive Personal Information allowed for under California law, such as a government-issued ID number or a consumer’s debit or credit card numbers. | Our Affiliates; customer service providers; payment processors; our security, fraud, and legal compliance partners; and other individuals, entities, or service providers at your request. |
We do not knowingly collect, sell, share, or otherwise disclose Personal Information of consumers under 16 years of age. We currently do not use “Sensitive Personal Information” (as that term is defined by the California Privacy Laws) for purposes other than those the California Privacy Laws allow for.
Retention of Personal Information
We retain each of the above categories of Personal Information for as long as is necessary to: (1) fulfill the purposes for which we collect it (for example, for as long as is necessary to provide you with the Services that you have requested); and (2) satisfy any legal, accounting, contractual, record keeping, or reporting requirements that apply to us.
Please refer to Section 14 (How Long Do We Retain Your Personal Information?) of this Privacy Policy for additional information about our Personal Information retention practices.
CCPA Rights
The California Privacy Laws (i.e., the CCPA as amended by the CPRA) grants California residents the rights described below. These rights are not absolute and are subject to certain exemptions. As such, in certain cases, we may deny your requests regarding these rights as permitted by law.
- Right to Know. The right to know what Personal Information we have collected about you, including the categories of Personal Information, the categories of sources from which we collected Personal Information, the business or commercial purpose for collecting, selling or sharing (if applicable), the categories of third parties to whom we sell or share Personal Information (if applicable), and the specific pieces of Personal Information we collected about you;
- Right to Delete. The right to delete Personal Information that we collected about you, subject to certain exceptions;
- Right to Correct. The right to correct inaccurate Personal Information that we maintain about you;
- Right to Opt-Out. If we sell or share your Personal Information, the right for you to opt-out of the sale or sharing;
- Right to Limit. If we sell or disclose your Sensitive Personal Information for purposes other than those allowed by the CCPA and its regulations, the right to limit our use or disclosure of the Sensitive Personal Information; and
- Right to Not Receive Discriminatory Treatment. The right not to receive discriminatory treatment by us for the exercise of the privacy rights the CCPA confers.
You will not receive any discriminatory treatment from us for exercising any of the privacy rights granted to you by the CCPA. Similarly, we will not retaliate against any of our employees, job applicants, and independent contractors for exercising any privacy right available to them under the CCPA.
Right to Opt-Out. You have a right to opt-out from the sale or sharing of your Personal Information. As stated above, we do not “sell” your Personal Information in the traditional sense (i.e., for money). However, we may disclose your Personal Information in the following ways that may constitute a “sale” and/or “share” of your Personal Information within the legal definitions of those terms under the California Privacy Laws:
- Like many news media companies, we use services that help us deliver interest-based ads to you on our Websites, Applications, and Platform, such as the services associated with cookies described in this Privacy Policy and our Cookie Policy. Our use of these services may constitute a “sale” or “share” of your Personal Information for purposes of the California Privacy Laws, because the advertising partners we use that provide these services collect information from our users, including Personal Information, when users visit our Websites, Applications, or Platform (e.g., device data, cookies, online activity, IP address, as described above) to help serve ads to users that are more likely to be of interest to them.
For more information or to opt-out of any future selling or sharing of your Personal Information for the purposes above, please click here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected.
Additionally, if your browser supports it, you can turn on the Global Privacy Control (GPC) to opt-out of the “sale” or “sharing” of your Personal Information. Please refer to the “Global Privacy Control (GPC)” discussion above in Section 8.1 of this Privacy Policy for additional information.
Authorized Agent. If you are submitting a request on behalf of a California resident, please submit the request through one of the designated methods discussed in this Privacy Policy. After submitting the request, if the request is not subject to an exemption or exception, we will require additional information to verify that you have the authority to act on behalf of the California resident.
Methods for submitting requests under the CCPA/CPRA
- For additional information or to submit a CCPA/CPRA request, please fill out this form.
- You may also submit a request by sending an email to [email protected] with “California Privacy Rights” in the subject.
Identity verification
We will need to verify your identity to process your information, access, correction, and deletion requests and reserve the right to confirm your residency. Authentication into your online account with us (if applicable), government identification, declarations under penalty of perjury or other information may be required. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it. Please do not send us additional personal information for verification purposes unless we specifically request it.
Shine the Light
It is our policy not to disclose Personal Information (as defined in California’s Shine the Light Law, California Civil Code § 1798.83) provided to us by our customers (as defined in the Shine the Light Law) to third parties for their direct marketing purposes if the customer has exercised an option that prevents that information from being disclosed to third parties for those purposes. Such customers may exercise this option by submitting a CCPA opt-out request here.
Accessibility
We are committed to ensuring this Privacy Policy is accessible to individuals with disabilities. If you wish to access this Privacy Policy in an alternative format, please contact us as described below.
California Residents Under Age 18
California residents who are under age 18 and registered users of the Services can request removal of content that they have posted on the Services (including User-Generated Content) by emailing us at with your name, email address, and the material that you want removed and information that will help us locate it, with the subject line “California Removal Request”. Your request does not ensure complete removal of the material. For example, materials may be republished or reposted by another user or a third party. Please make all such requests via email to us at [email protected].
Notice of Financial Incentive
We offer programs, benefits, and other offerings to consumers that use the Services like you related to our collection and use of Personal Information that might be deemed a “financial incentive” or “price service difference” under the California Privacy Laws. These offerings may involve the collection of the following categories of Personal Information from consumers like you that participate: identifiers; customer records; protected class and demographic information; commercial information and preferences; Internet or other electronic network activity information and device information; audio, electronic, visual, and other sensory information; and inferences. We are providing you this information so that you may make an informed decision on whether to participate in our programs. Examples of the programs that we offer as part of the Services include:
- Free Newsletters. As part of the Services, we may offer users the opportunity to sign up for a free newsletter to our publications and Services. The specific newsletters offered via our Services usually vary based on the specific newspaper publication and Website from which a consumer user agrees to receive a newsletter. When a consumer user agrees to receive a newsletter from us, we typically provide the newsletter to the consumer user via email. As part of our newsletter program, we may collect and use your Personal Information, such as your email address, name, Internet or other electronic network activity information and device information, and inferences. No purchase is required to sign up for a free newsletter from us. Participation in our newsletter programs is governed by this Privacy Policy, our Terms of Use, and/or Cookie Policy in addition to any additional terms and conditions applicable to our newsletter program. For more information about how to sign up to our free newsletters, please visit our Websites and Applications from which you want to receive the Services and newsletters for additional information. You may cancel your subscription to any of our newsletters at any time by either following the instructions to cancel your subscription to receive email newsletters provided in the emails that deliver the newsletters to you, or by calling the official customer service number provided in the “Contact Us” webpage of the Website from which you receive emails and making a request to stop receiving the newsletters. Our good-faith estimate of the value of your Personal Information for participating in our newsletter program is the value of the benefit we offer you. We have calculated such value by using the expense related to the benefit.
- Surveys. We may offer users of the Services the opportunity to participate in surveys about the Services. In exchange for your participation in a survey, you may be offered a financial incentive, such as: free products or services; free or discounted Services that we offer; the opportunity to participate in other promotions; and other discounts or coupons. As part of these surveys, we may collect and use your Personal Information, such as, your name, mailing address, email address, telephone number, beliefs, opinions, preferences, inferences, experiences, protected class and demographic information, Internet or other electronic network activity information and device information, and any other information that you provide in response to the survey questions. Participation in any such survey is governed by the terms and conditions of this Privacy Policy, our Cookie Policy, and/or our Terms of Use in addition to the specific terms and conditions applicable to the survey. The specific terms and conditions applicable to the survey will also tell you how to participate in the survey. You can terminate your participation in the survey at any time as will be explained in the specific terms and conditions applicable to the survey or by unsubscribing to our Services. Our good-faith estimate of the value of your Personal Information for participating in our survey programs is the value of the benefit we offer you. We have calculated such value by using the expense related to the benefit.
- Limited Time Promotions, Contests, or Sweepstakes. From time-to-time, we also may offer you incentives limited to a specific time period, such as, limited-time promotions, contests, or sweepstakes. In exchange for your participation in these programs, you may be offered a financial incentive, such as, a prize or discount to receive the Services. As part of these limited-time programs, we may collect and use your personal information, such as, your name; mailing address; email address; telephone number; beliefs; customer records; opinions; preferences; inferences; experiences; Internet or other electronic network activity information and device information; protected class and demographic information; and audio, electronic, visual, and other sensory information. Participation in any such promotions, contests, or sweepstakes are governed by this Privacy Policy, Cookie Policy, and/or our Terms of Use in addition to any specific terms and conditions that apply to any such promotions, contests, or sweepstakes. You can terminate your participation in these promotions, contests, or sweepstakes at any time as will be explained in the specific terms and conditions applicable to the survey or by unsubscribing to our Services. Our good-faith estimate of the value of your Personal Information for participating in our promotions, contests, and sweepstakes program is the value of the benefit we offer you. We have calculated such value by using the expense related to the benefit.
- Free Internet Browsing of Our Services, Applications, or Websites. The content of most of our Applications and Websites through which consumers like you can access our Services on the Internet is usually protected by a paywall. This means that, typically, after you have browsed a pre-determined number of free articles or content on our Websites or Applications, the paywall will prevent you from further accessing our content and Services unless you sign up for a paid subscription. However, some of the Websites and Applications for certain of our newspaper publications may choose to either (1) not implement a paywall for any content on its Website or Application at all, or (2) not have the paywall functionality implemented for certain particularly time-sensitive or politically/socially relevant news articles or content. This means that you may be able to access and browse some of our Services on some of our Websites and Applications for free. This may be deemed a “financial incentive” or “price service difference” under the California Privacy Laws. By accessing and browsing any of our Services on any of our Websites or Applications for free over the Internet where our paywalls do not limit your access or browsing ability, you may be offered a financial incentive, such as free access over the Internet to select content, Websites, or Applications that we provide as part of our Services to paying customers. In exchange for your access to certain free content, Websites, or Applications that we provide as part of our Services, we may collect and use your Personal Information, such as: identifiers, IP Address, Internet or other electronic network activity information and device information, and inferences. Participation in our “free access to Services” programs is governed by this Privacy Policy, our Terms of Use, and our Cookie Policy. You can terminate your participation in these “free access to the Services” programs by not using our Services and opting-out of cookies (see in Section 8 of this Privacy Policy and our Cookie Policy for additional information about how to opt-out). Our good-faith estimate of the value of your Personal Information for participating in our “free access to our Services” is the value of the benefit we offer you. We have calculated such value by using the expense related to the benefit.
- SMS/Text Message Alert Programs. We may offer current or potential users of our Services the opportunity to sign up to receive marking-related SMS/Text Message notifications about the Services. As part of these programs, you may receive a financial incentive from us, such as special promotional offers or discounts regarding the Services or subscriptions for the Services. In exchange for your participation in these programs, we may collect your Personal Information, such as your mobile phone number, name, and email address. No purchase is required to sign up for a free newsletter from us, although standard text messaging rates and fees (as determined by your cellular network provider) may apply. Participation in these programs is governed by this Privacy Policy, our Terms of Use, our Cookie Policy, our Mobile Policy and the terms and conditions of any additional agreements provided to you before you sign up to participate in the program. You may cancel or terminate your participation in these programs at any time by following instructions you receive in the agreements and materials that we provide to you when you sign up to participate in the program, or by calling the official customer service number provided in the “Contact Us” webpage of the Website for our publication that is sending you the SMS/Text Message notification. You may also cancel or terminate your participation in these programs by following the instructions in the SMS/Text Message notifications that you receive from us. Our good-faith estimate of the value of your Personal Information for participating in our SMS/Text Message notification programs is the value of the benefit we offer you. We have calculated such value by using the expense related to the benefit.
How to Contact Us
To contact us for questions or concerns about our privacy policies or practices, please contact us using the contact information in Section 19 [LN8] of this Policy.
9.2 Your Nevada Rights & Choices.
Under Nevada law, if you are a resident of Nevada, you may opt-out of our “sale” of your “covered information”, as these terms are defined under Nevada law. For purposes of Nevada law, “covered information” includes your first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.
If you are a Nevada resident and have purchased or leased goods or services from us, you may submit a request to opt-out of any potential future “sales” by us of your “covered information” by clicking here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected. Please note that we will take reasonable steps to verify your identity and the authenticity of your request. Once verified, we will maintain your request in the event our practices change.
9.3 Your Virginia Rights & Choices.
This Section 9.3 applies to residents of Virginia. Virginia residents have the right to receive certain disclosures regarding the Personal Information we collect and use about them. For a discussion of the categories of Personal Information about that we collect and use, the categories of Personal Information that we share with third parties, and the categories of third parties with whom we share Virginia residents’ Personal Information, please refer Section 9.1 (Your California Rights) [LN9] of this Privacy Policy.
If you are a Virginia resident, you have the right to: (1) confirm whether or not we are processing your Personal Information and to access such Personal Information; (2) correct inaccuracies in your Personal Information, taking into account the nature of the Personal Information and the purposes of the processing of your Personal Information; (3) delete Personal Information you have provided or we have obtained about you; (4) obtain a copy of your Personal Information that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another controller without hindrance, where the processing is carried out by automated means; and (5) opt-out of the processing of your Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. Although we do not “sell” your Personal Information in the traditional sense (i.e., for money), our use of interest-based advertising cookies and tracking technologies could be considered a sale of your Personal Information under Virginia law. In some instances, it also may qualify as targeted advertising.
To exercise your rights, please click here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected. If we refuse to take action regarding your request to exercise your rights under Virginia law, you may appeal our decision by emailing us at [email protected].
9.4 Your Colorado Rights & Choices.
This Section 9.4 of this Privacy Policy describes Colorado residents’ privacy-related rights and choices.
You have the right to:
- Right to Opt-Out. As is described in greater detail below in this Section 9.4, you have the right to opt out of our processing of your Personal Information, if we process your Personal Information for any of the following three purposes: (A) targeted advertising, (B) the “sale” of your Personal Information, or (C) or profiling in furtherance of decisions that produce legal or similarly significant effects.
- Right to Confirm. You have the right to request our confirmation about whether we process Personal Information about you.
- Right to Access. If we process Personal Information about you, you have the right to access the Personal Information about you that we process.
- Right to Data Portability. If you exercise your right to access your Personal Information that we collect about you, you have the right to obtain the Personal Information we maintain about you in a portable (and to the extent technically feasible) readily available format that allows you to transmit that Personal Information to another entity without hinderance, subject to certain exceptions. You may exercise this “right to data portability” no more than twice per calendar year.
- Right to Correction. You have the right to correct inaccuracies in the Personal Information that we process about you, subject to certain exceptions.
- Right to Deletion. If we process Personal Information about you, you have the right to instruct us to permanently delete that Personal Information, subject to certain exceptions.
- Right to Consent to Processing of Sensitive Data. We do not currently process sensitive Personal Information, as defined in Colorado law. If we process your sensitive Personal Information, we will first obtain your consent.
You will not receive any discriminatory or retaliatory treatment from us for exercising any of the privacy rights granted to you.
If you are a Colorado resident, your authorized agent (i.e., a third party acting on your behalf with your express consent) may submit a request to us on your behalf to exercise any of the privacy-related rights above. If you are submitting a request on behalf of a Colorado resident, please submit the request through one of the designated methods discussed in this Privacy Policy. After submitting the request, if the request is not subject to an exemption or exception, we may require additional information to verify that you have the authority to act on behalf of the Colorado resident.
For a general discussion of the categories of Personal Information that we collect and use (i.e., process) about Colorado residents, the categories of Personal Information that we disclose to third parties, and the categories of third parties with whom we disclose Colorado residents’ Personal Information, please refer to Section 9.1 (Your California Rights) [LN10] of this Privacy Policy. Additional relevant information about the Personal Information that we collect about you when you use the Services, the purposes for which we process that Personal Information, and to whom we may disclose your Personal information can be found in Sections 3 – 8 of this Privacy Policy.
Colorado Residents: More Information About Your Right to Opt Out
As a Colorado resident, you have you have the right to opt out of our processing of your Personal Information, if we process your Personal Information for any of the following three purposes: (A) targeted advertising, (B) the “sale” of your Personal Information, or (C) or profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As is discussed in this Privacy Policy above, we do not “sell” the Personal Information of Colorado residents in the traditional sense (i.e., for money). However, in some instances, our use of interest-based advertising cookies and tracking technologies could be considered a “Sale” of your Personal Information under Colorado law. We do not use your Personal Information for profiling, as defined in Colorado law.
Colorado Residents: Methods for Exercising Your Rights
If you are a Colorado resident, to exercise your rights under the CPA, please:
- Click here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected.
- You may also submit a request by sending an email to [email protected] with “Colorado Privacy Rights” in the subject.
Colorado Residents: Appeal Process for Exercising Your Rights
If we refuse to take action regarding your request to exercise your rights, you may appeal our decision by emailing us at [email protected]. Your appeal of our refusal must include the words “PRIVACY RIGHTS APPEAL” in the subject line of the email and the following information to be deemed valid: (1) your name, (2) the email address associated with the privacy rights request to us that you are appealing, (3) your mailing address, (4) the right or rights under the CPA that you initially requested to exercise, (5) the date of your initial request, and (6) a sufficiently detailed explanation of the legal grounds or other reasons as to why we should grant your appeal.
Upon receipt of a valid written appeal from you, we will provide you with a written explanation in support of our response to your appeal within 45 days. Where permitted by law, we may extend our deadline for officially responding to your appeal by an additional 60 days. If you have concerns about the results of your appeal with us regarding your privacy rights and choices, you may contact the Colorado Attorney General. Information about how to contact the Colorado Attorney General about your appeal can be found on the Colorado Attorney General’s website here.
9.5 Your Connecticut Rights & Choices
This Section 9.5 of this Privacy Policy describes the privacy-related rights and choices available to Connecticut residents.
You have the right to”
- Right to Opt Out. As is described in greater detail below in this Section 9.5, you have the right to opt out of our processing of your Personal Information, if we process your Personal Information for any of the following three purposes: (A) targeted advertising, (B) the “sale” of your Personal Information, or (C) or profiling in furtherance of decisions that produce legal or similarly significant effects.
- Right to Confirm. You have the right to request our confirmation about whether we process Personal Information about you.
- Right to Access. If we process Personal Information about you, you have the right to access the Personal Information about you that we process.
- Right to Data Portability. If you exercise your right to access your Personal Information that we collect about you, you have the right to obtain the Personal Information we maintain about you in a portable (and to the extent technically feasible) readily available format that allows you to transmit that Personal Information to another entity without hinderance, subject to certain exceptions.
- Right to Correction. You have the right to correct inaccuracies in the Personal Information that we process about you, subject to certain exceptions.
- Right to Deletion. If we process Personal Information about you, you have the right to instruct us to permanently delete that Personal Information, subject to certain exceptions.
- Right to Consent to Processing of Sensitive Data. We do not currently process sensitive Personal Information, as defined in Connecticut law. If we process your sensitive Personal Information, we will first obtain your consent. If you have given us your prior informed consent to the processing of your sensitive Personal Information, you will have the right to revoke this consent.
You will not receive any discriminatory or retaliatory treatment from us for exercising any of the privacy rights granted to you.
Your authorized agent (i.e., a third party acting on your behalf with your express consent) may submit a request to us on your behalf for you to exercise any of the privacy-related rights above. If you are submitting a request on behalf of a Connecticut resident, please submit the request through one of the designated methods discussed in this Privacy Policy. After submitting the request, if the request is not subject to an exemption or exception, we may require additional information to verify that you have the authority to act on behalf of the Connecticut resident.
For a discussion of the categories of Personal Information that we collect and use (i.e., process) about Connecticut residents, the categories of Personal Information that we disclose to third parties, and the categories of third parties with whom we disclose your Personal Information, please refer to Section 9.1 (Your California Rights) [LN11] of this Privacy Policy. Additional relevant information about the Personal Information that we collect about you when you use the Services, the purposes for which we process that Personal Information, and to whom we may disclose your Personal information can be found in Sections 3 – 8 of this Privacy Policy.
Connecticut Residents: Methods for Exercising Your Rights
If you are a Connecticut resident, to exercise your rights, please:
- Click here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected.
- You may also submit a request by sending an email to [email protected] with “Connecticut Privacy Rights” in the subject.
Connecticut Residents: Appeal Process for Exercising Your Rights
If we refuse to take action regarding your request to exercise your rights, you may appeal our decision by emailing us at [email protected]. Your appeal of our refusal must include the following information: (1) your name, (2) the email address associated with the privacy rights request to us that you are appealing, (3) your mailing address, (4) the right or rights that you initially requested to exercise, (5) the date of your initial request, and (6) a sufficiently detailed explanation of the legal grounds or other reasons as to why we should grant your appeal. Upon receipt of a valid written appeal from you, we will provide you with a written explanation in support of our response to your appeal within 60 days. If you have concerns about the results of your appeal with us regarding your privacy rights and choices, you may contact the Connecticut Attorney General. Information about how to contact the Connecticut Attorney General about your appeal can be found on the Connecticut Attorney General’s website here.
9.6 Your Utah Rights & Choices
This Section 9.6 of the Privacy Policy describes the privacy-related rights and choices available to Utah residents.
If you are a Utah resident, you have the following rights:
- Right to Know: You have the right to confirm whether or not we are processing your Personal Information.
- Right to Access: If we process Personal Information about you, you have the right to access the Personal Information about you that we process.
- Right to Data Portability: If you exercise your right to access the Personal Information that we maintain about you, you have the right to obtain such Personal Information in a format that is (to the extent technically feasible) portable and readily usable, and that allows you to transmit that Personal Information to another entity without impediment, subject to certain exceptions.
- Right to Deletion: If we have collected Personal Information from you, you have the right to instruct us to delete that Personal Information.
Right to Opt-Out: You have the right to opt-out of the processing of your Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) the processing of sensitive Personal Information.
You will not receive any discriminatory or retaliatory treatment from us for exercising any of your privacy rights.
For information about the categories of Personal Information that we collect and use (i.e., process) about Utah residents, the categories of Personal Information that we disclose to third parties, and the categories of third parties to whom we disclose Personal Information, please refer to Section 9.1 (Your California Rights) [LN12] of this Privacy Policy. Additional relevant information about the Personal Information that we collect about you when you use the Services, the purposes for which we process that Personal Information, and to whom we may disclose your Personal information can be found in Sections 3 – 8 of this Privacy Policy.
Utah Residents: More Information About Your Right to Opt-Out
As a Utah resident, you have the right to opt-out of our processing of your Personal Information for the following purposes: (1) targeted advertising, (2) the “sale” of your Personal Information, or (3) the processing of your sensitive Personal Information. We do not sell your Personal Information, nor do we process your sensitive Personal Information, as defined in Utah privacy law.
Methods of Exercising Your Rights
If you are a Utah resident, you can exercise your rights by:
- Clicking here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected.
- You may also submit a request by sending an email to [email protected] with “Utah Privacy Rights” in the subject.
9.7 Your Texas Rights & Choices
This Section 9.7 of the Privacy Policy describes the privacy-related rights and choices that apply to residents of Texas.
If you are a Texas resident, you have the following rights:
- Right to Know: You have the right to confirm whether or not we are processing your Personal Information.
- Right to Access: If we process Personal Information about you, you have the right to access the Personal Information about you that we process.
- Right to Data Portability: If you exercise your right to access the Personal Information that we maintain about you, you have the right to obtain such Personal Information in a format that is (to the extent technically feasible) portable and readily usable, if we maintain your Personal Information in a digital format.
- Right to Correction. You have the right to correct inaccuracies in the Personal Information that we process about you, subject to certain exceptions.
- Right to Deletion: You have the right to instruct us to delete certain Personal Information we maintain about you.
- Right to Opt-Out: You have the right to opt-out of the processing of your Personal Information for purposes of (i) targeted advertising, (ii) the sale of Personal Information, or (iii) use of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects concerning you.
- Right to Consent to Processing of Sensitive Data. We do not currently process sensitive Personal Information, as defined in Texas law. If we process your sensitive Personal Information, we will first obtain your consent.
You will not receive any discriminatory or retaliatory treatment from us for exercising your privacy rights.
For information about the categories of Personal Information that we collect and use (i.e., process), the categories of Personal Information that we disclose to third parties, and the categories of third parties to whom we disclose Personal Information, please refer to Section 9.1 (Your California Rights) [LN13] of this Privacy Policy. Additional relevant information about the Personal Information that we collect about you when you use the Services, the purposes for which we process that Personal Information, and to whom we may disclose your Personal information can be found in Sections 3 – 8 of this Privacy Policy.
Texas Residents: More Information About Your Right to Opt-Out
You have the right to opt-out of our processing of your Personal Information for the following purposes: (1) targeted advertising, (2) the “sale” of your Personal Information, or (3) the use of your Personal Information in profiling, if it produces a significant legal effect. We do not engage in profiling as defined by Texas privacy law.
Methods of Exercising Your Rights
If you are a Texas resident, you can exercise your rights by:
- Clicking here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected.
- You may also submit a request by sending an email to [email protected] with “Texas Privacy Rights” in the subject.
Texas Residents: Appeal Process for Exercising Your Rights
If we refuse to take action regarding your request to exercise your rights, you may appeal our decision by emailing us at [email protected]. Your appeal of our refusal must include the following information: (1) your name, (2) the email address associated with the privacy rights request to us that you are appealing, (3) the right or rights that you initially requested to exercise, (4) the date of your initial request, and (5) a sufficiently detailed explanation of the legal grounds or other reasons as to why we should grant your appeal. If you have concerns about the results of your appeal regarding your privacy rights and choices, you may contact the Texas Attorney General. Information about how to contact the Texas Attorney General about your appeal can be found on the Texas Attorney General’s website here.
9.8 Your Oregon Rights & Choices
This Section 9.8 of the Privacy Policy describes the privacy-related rights and choices that apply to residents of Oregon.
If you are an Oregon resident, you have the following rights:
- Right to Know: You have the right to confirm whether or not we are processing your Personal Information. You also have the right to know: (i) the categories of Personal Information that we process, and (ii) a list of specific third parties to which we disclose Personal Information.
- Right to Access: If we process Personal Information about you, you have the right to access the Personal Information about you that we process.
- Right to Data Portability: If you exercise your right to access the Personal Information that we maintain about you, you have the right to obtain such Personal Information in a format that is (to the extent technically feasible) portable and readily usable.
- Right to Correction. You have the right to correct inaccuracies in the Personal Information that we process about you, subject to certain exceptions.
- Right to Deletion: You have the right to instruct us to delete certain Personal Information we maintain about you.
- Right to Opt-Out: You have the right to opt-out of the processing of your Personal Information for purposes of (i) targeted advertising, (ii) the “sale” of Personal Information, or (iii) use of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects.
- Right to Consent to Processing of Sensitive Data. We do not currently process sensitive Personal Information, as defined in Oregon law. If we process your sensitive Personal Information, we will first obtain your consent.
You will not receive any discriminatory or retaliatory treatment from us for exercising your privacy rights.
For information about the categories of Personal Information that we collect and use (i.e., process), the categories of Personal Information that we disclose to third parties, and the categories of third parties to whom we disclose Personal Information, please refer to Section 9.1 (Your California Rights) [LN14] of this Privacy Policy. Additional relevant information about the Personal Information that we collect about you when you use the Services, the purposes for which we process that Personal Information, and to whom we may disclose your Personal information can be found in Sections 3 – 8 of this Privacy Policy.
Oregon Residents: More Information About Your Right to Opt-Out
You have the right to opt-out of our processing of your Personal Information for the following purposes: (1) targeted advertising, (2) the “sale” of your Personal Information, or (3) the use of your Personal Information in profiling, if it produces a significant legal effect. We do not engage in profiling as defined by Oregon privacy law.
Methods of Exercising Your Rights
If you are an Oregon resident, you can exercise your rights by:
- Clicking here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected.
- You may also submit a request by sending an email to [email protected] with “Oregon Privacy Rights” in the subject.
Oregon Residents: Appeal Process for Exercising Your Rights
If we refuse to take action regarding your request to exercise your rights, you may appeal our decision by emailing us at [email protected]. Your appeal of our refusal must include the following information: (1) your name, (2) the email address associated with the privacy rights request to us that you are appealing, (3) the right or rights that you initially requested to exercise, (4) the date of your initial request, and (5) a sufficiently detailed explanation of the legal grounds or other reasons as to why we should grant your appeal. If you have concerns about the results of your appeal regarding your privacy rights and choices, you may contact the Texas Attorney General. Information about how to contact the Oregon Attorney General about your appeal can be found on the Oregon Attorney General’s website here.
9.9 Your Montana Rights & Choices
This Section 9.9 of the Privacy Policy describes the privacy-related rights and choices that apply to residents of Montana.
If you are a Montana resident, you have the following rights:
- Right to Know: You have the right to confirm whether or not we are processing your Personal Information.
- Right to Access: If we process Personal Information about you, you have the right to access the Personal Information about you that we process.
- Right to Data Portability: If you exercise your right to access the Personal Information that we maintain about you, you have the right to obtain such Personal Information in a format that is (to the extent technically feasible) portable and readily usable, if we maintain your Personal Information in a digital format.
- Right to Correction. You have the right to correct inaccuracies in the Personal Information that we process about you, subject to certain exceptions.
- Right to Deletion: You have the right to instruct us to delete certain Personal Information we maintain about you.
- Right to Opt-Out: You have the right to opt-out of the processing of your Personal Information for purposes of (i) targeted advertising, (ii) the “sale” of Personal Information, or (iii) use of your Personal Information for profiling in furtherance of decisions that produce legal or similarly significant effects.
- Right to Consent to Processing of Sensitive Data. We do not currently process sensitive Personal Information, as defined in Montana law. If we process your sensitive Personal Information, we will first obtain your consent.
You will not receive any discriminatory or retaliatory treatment from us for exercising your privacy rights.
For information about the categories of Personal Information that we collect and use (i.e., process), the categories of Personal Information that we disclose to third parties, and the categories of third parties to whom we disclose Personal Information, please refer to Section 9.1 (Your California Rights) [LN15] of this Privacy Policy. Additional relevant information about the Personal Information that we collect about you when you use the Services, the purposes for which we process that Personal Information, and to whom we may disclose your Personal information can be found in Sections 3 – 8 of this Privacy Policy.
Montana Residents: More Information About Your Right to Opt-Out
You have the right to opt-out of our processing of your Personal Information for the following purposes: (1) targeted advertising, (2) the “sale” of your Personal Information, or (3) the use of your Personal Information in profiling, if it produces a significant legal effect. We do not engage in profiling as defined by Montana privacy law.
Methods of Exercising Your Rights
If you are a Montana resident, you can exercise your rights by:
- Clicking here or the “Do Not Sell/Share My Personal Information” link on the bottom of the webpage where your Personal Information is being collected.
- You may also submit a request by sending an email to [email protected] with “Montana Privacy Rights” in the subject.
Montana Residents: Appeal Process for Exercising Your Rights
If we refuse to take action regarding your request to exercise your rights, you may appeal our decision by emailing us at [email protected]. Your appeal of our refusal must include the following information: (1) your name, (2) the email address associated with the privacy rights request to us that you are appealing, (3) the right or rights that you initially requested to exercise, (4) the date of your initial request, and (5) a sufficiently detailed explanation of the legal grounds or other reasons as to why we should grant your appeal. If you have concerns about the results of your appeal regarding your privacy rights and choices, you may contact the Montana Attorney General. Information about how to contact the Montana Attorney General about your appeal can be found on the Montana Attorney General’s website here.
10. Use of The Services by Users from Outside The United States
We have worked hard to ensure that our business complies with applicable international consumer data privacy laws, such as the European Union’s General Data Protection Regulation (“GDPR”), the United Kingdom’s General Data Protection Regulation (the “UK GDPR”), and others. Under applicable law in the European Economic Area, UK, and Switzerland, MNG is considered a “data controller” of the Personal Information that we handle under this Privacy Policy. In other words, MNG is responsible for deciding how to collect, use, and disclose this Personal Information, subject to applicable law. Our contact information appears at the end of this Privacy Policy. Under applicable laws, if you are a resident of certain jurisdictions outside of the United States and use the Services, you may be able to request one or more individual rights set forth in the “Your EU, EEA, UK, and Switzerland Rights & Choices” Section of this Privacy Policy below.
10.1 Your EU, EEA, UK, & Switzerland Rights & Choices.
For purposes of this Privacy Policy, we are a data controller of your Personal Information. We are headquartered in the United States, where we store and process information relating to the use of the Services, including your Personal Information. If you are located outside of the United States, your Personal Information is collected in your country and then transferred to the United States – or another country in which we (or our service providers) operate.
If we transfer your Personal Information outside of the European Economic Area, we implement at least one of the following safeguards:
- We transfer your Personal Information to countries that the European Commission has determined provide an adequate level of data protection (a full list of these countries can be found here).
- We take steps to ensure that the recipient of your Personal Information is bound by contractual obligations, including the EU Standard Contractual Clauses (“SCCs”) and additional safeguards to protect your Personal Information (you may review the EU SCCs that came into effect in September 2021 here).
The courts, law enforcement agencies, regulatory agencies, or security authorities in these countries may sometimes be entitled to access your Personal Information under applicable laws.
If you are a resident of the EU, EEA, UK, or Switzerland, you have certain privacy rights under applicable laws, which include:
- Your right to access and copy certain Personal Information that we maintain about you;
- Your right to correct or update Personal Information that we maintain about you information that is incorrect or outdated;
- Your right to prevent the processing of your Personal Information for direct marketing purposes (including direct marketing processing based on profiling);
- Your right to delete certain Personal Information that we maintain about you;
- Your right to transfer the Personal Information that we hold about you to a third-party service provider;
- Your right to restrict the way we process and disclose certain of your Personal Information; and
- Your right to revoke your consent to the processing of your Personal Information.
If you reside in a country other than one of those listed above, you may be able to make a request to us to exercise one or more of the rights listed above under applicable laws. In order to make such a request to us, you may contact us at [email protected]. So that we may respond to your request, we may need to verify your identity, country of residence, or require that you provide us with additional information.
If applicable, if you think your rights have been violated, you may make a complaint to the data protection supervisory authority in the country in which you reside or seek a remedy through the local court system. However, we encourage you to first contact us with any questions or concerns if you feel your rights have been violated.
Your Additional Marketing & Interest-Based Advertising Choices
Our Cookie Policy has information about how to manage your cookies and other choices that may be available to you with respect to personalized advertising. Additional information about how to op-out of cookies and similar technologies that we use on the Services for online analytics and interest-based advertising purposes is also detailed in Section 8.2 of this Privacy Policy (Your Additional Rights & Choices For Third Parties & Our Online Analytics & Interest-Based Advertising Practices).
If you reside in the EU, EEA, UK, Canda, or Switzerland you may opt-out of (i.e., withdraw your consent to) receiving marketing emails from us by following the instructions in such emails. You may also withdraw your consent to our use of your email to provide you with special offers via email and through certain other means (such as Social Media) by emailing us at [email protected].
What is Our Legal Basis?
In certain jurisdictions, like the European Union and the European Economic Area, we may only collect, use, or share Personal Information about you if we have a valid reason (i.e., a “lawful basis”). A valid reason (i.e., a “lawful basis”) is one of the following:
- You provide us with your consent at the point of collection of your Personal Information;
- The performance of a contract that we have with you;
- Our compliance with a legal obligation that we are subject to;
- Our legitimate interests or the legitimate interests of a third party. A “legitimate interest” is a special legal term under international privacy laws, like the GDPR, which essentially means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights. The term “legitimate interest” can also refer to our use of your Personal Information in ways that you would reasonably expect and that have a minimal impact on your privacy rights.
We have legitimate interests in gathering and processing Personal Information. Our legitimate interests include, but are not necessarily limited to: administering and conducting business within MNG; ensuring that our networks, Services, Websites, Applications, Platform, and information are secure; conducting our marketing activities; and preventing fraud.
IAB EU Transparency and Consent Framework
We participate in the IAB Europe Transparency & Consent Framework and comply with its Specifications and Policies. We use the Consent Management Platform with the identification number 279.
11. How Can You Access, Correct, Or Update Your Personal Information?
You may request that we provide you with access to the Personal Information that we have about you, or that we update or correct the Personal Information that we have about you. Depending on the jurisdiction in which you reside, you may have a legal right to request access to the Personal Information we have about you under applicable laws. Depending on the jurisdiction in which you reside, you also may have a legal right under applicable laws to request that we correct or update certain Personal Information that we have about you. Some of our Websites may allow you to access, correct, or update some of your Personal Information directly (i.e., user profile information) by logging in to the relevant portions of the Services where such information may be updated. In accordance with applicable laws, you may also request access to the Personal Information that we have about you and/or request that we correct or update certain Personal Information that we have about you by emailing us at [email protected].
Unless otherwise prohibited by applicable laws, even if you request that we update, correct, or delete Personal Information that we hold about you, we may need to retain certain of your Personal Information to comply with our legal obligations or otherwise for our legitimate record-keeping and business purposes. Please refer to Section 14 of this Privacy Policy (How Long Do We Retain Your Information?) for additional information.
12. What About Linked Third-Party Services, Sites, & Advertisements That I See Via The Services?
Some of the Services may sometimes contain links to third-party websites, resources, vendors, advertisers, and other products and services. These are not part of the Services we provide to you. We do not control (and are not responsible for) the privacy practices, websites, content, and goods or services of these third parties.
As is discussed elsewhere in this Privacy Policy, these third parties may independently collect and solicit Personal Information about you directly from you. The Personal Information that you provide to them directly is not covered by this Privacy Policy. These third parties have their own privacy policies and practices, which may include what (if any) of your Personal Information they share with us, your privacy rights and choices with respect to their services and devices, and whether they process and store information in the United States or outside of the United States. As such, we encourage you to familiarize yourself with their privacy policies, practices, and terms of use and to contact them if you have any questions, concerns, or want to opt-out or limit how they collect or use your Personal Information.
13. How Do We Protect Your Personal Information?
We have endeavored to protect the privacy, security, and integrity of your Personal Information using what we believe to be appropriate administrative, technical, organizational, and physical security controls and measures (collectively, “Security Measures”). These Security Measures may vary based on a variety of factors, including, the sensitivity of the Personal Information about you that we process and maintain, the state of technology, and applicable laws.
The purpose of our Security Measures is to protect your Personal Information from accidental or unauthorized access, alteration, destruction, disclosure, loss, use, or illegal processing. Although we take maintaining the security and integrity of the Personal Information that we hold about you extremely seriously, we cannot guarantee that our Security Measures will provide your Personal Information with absolute security or that your Personal Information will never be used in a manner that is inconsistent with this Privacy Policy. Unauthorized entry or use, hardware or software failure, and other factors, may compromise the security and integrity of the Personal Information that we maintain about you at any time. In accordance with applicable law, we will notify you electronically, in writing, by telephone, and/or by other means in the event that we become subject to a data breach involving the unauthorized or unlawful use of the Personal Information about you that we maintain.
Safeguarding Communications
From time to time, via the Services, we may send you emails, text messages, mobile device push notifications, or other communications, which communications may contain your Personal Information or Sensitive Personal Information (such as your name, email address, password to your account for the Services, or billing or payment information). Safeguarding any such Personal Information or Sensitive Personal Information contained in any such communications by us to you is solely your responsibility. We are not responsible for safeguarding any such communications once they are sent to you.
14. How Long Do We Retain Your Personal Information?
We retain your Personal Information for as long as is necessary to: (1) fulfil the purposes for which we collect it (for example, for as long as is necessary to provide you with the Services that you have requested); and (2) satisfy any legal, accounting, contractual, record keeping, or reporting requirements that apply to us. This means that we might retain your Personal Information even after you close your account with us.
After the applicable retention period for your Personal Information, we will either delete or anonymize your Personal Information in accordance with applicable laws. If deletion or anonymization of your Personal Information is not possible, in accordance with applicable laws, we will securely store your information and isolate it from any further use until deletion is possible.
If you stop visiting our Websites for at least 13 months, we may mark your account for removal. In that case, your account information will remain for another 12 months and then may be removed.
15. What Are the Requirements or Guidelines for The Use of Our Services By Children?
We are committed to protecting the privacy of children. The Services are not intended to be accessed or used by persons under the age of 18. By using the Services, you hereby represent that you are at least 18 years of age. We will not knowingly or intentionally collect or solicit any Personal Information online from children under the age of 18. If you are under the age of 18, please do not attempt to register for an account or other subscription to the Services from us. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories likewise shall have no bearing on this limitation.
If you believe that a child under age 16 has provided us with Personal Information, please contact us immediately via email at [email protected]. Once received, we will take appropriate action with respect to that child’s Personal Information in accordance with our obligation under applicable laws.
16. Changes to This Privacy Policy.
MNG may update this Privacy Policy at our discretion at any time. Please check this Privacy Policy periodically to review any changes or updates to this Privacy Policy and our privacy-related practices. In the event of any material changes or updates, we will post the updated version here and will update the “Last Updated” date at the top of this Privacy Policy.
17. No Rights of Third Parties.
This Privacy Policy does not create rights for the benefit of, or enforceable by, any third parties.
18. Complaints.
We take your privacy very seriously. Depending on the jurisdiction in which you reside, if you believe we have violated your privacy rights, you may have the right to lodge a complaint against us with the appropriate data protection supervisory authority in the jurisdiction in which you reside. However, we encourage you to first contact us via email to [email protected] should you have any questions, concerns, or complaints about our privacy-related practices.
Additional information about how to contact us about matters concerning this Privacy Policy and our privacy-related practices is provided in the following Section 19 of this Privacy Policy.
19. How Can You Contact Us?
If you have any questions or complaints concerning this Privacy Policy, or about exercising privacy-related rights and choices that may apply to you, please do not hesitate to contact us via email to [email protected].
Website: Medianewsgroup.com
You may also contact us by postal mail at the following address:
MediaNews Group, Inc.
5990 N. Washington Street
Denver, Colorado 80216
United States of America
Attention: Legal Department