Table of Contents

1. Overview
2. How Do We Collect Personal Information
3. The Types of Personal Information We May Collect From You
4. How We Use Your Personal Information
5. How We Disclose Personal Information
6. Children’s Privacy
7. Links to Third Party Websites
8. CCTV
9. Your Advertising Choices
10. Information Security
11. Cookies and Similar Technology
12. Your Marketing Preferences

13. Additional Information for Residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Other U.S. States with Similar Privacy Laws

    1. Information for POLITICO Users
    2. Information for POLITICO Pro and E&E Users
    3. Information for AgencyIQ Users
    4. Notice of Financial Incentive
14. International Data Transfers
15. Shine the Light Disclosure
16. Updates to the Policy
17. Contact Us

Overview

This Privacy Policy explains how POLITICO, POLITICO Pro, E&E News, AgencyIQ, our subsidiaries and affiliates, and any other digital properties that display authorized links to this policy (“us”, “our”, or “we”) process personal information when you interact with us online, via our websites and apps, and offline, in person (collectively, “Services”).

How Do We Collect Personal Information

From you. We may collect personal information and other information that you voluntarily provide when you take certain actions, such as when you register for one of our Services (such as when you become a POLITICO Pro subscriber), request information about available subscription options, order a subscription to our Services, pay your bill online, sign up for our newsletters, sign up for our author alerts, respond to our surveys, or otherwise use our Services.

From devices you use when you interact with us online. This includes information collected through our Services and automatically from devices you use to connect to our Services. For more information about this, please see our “Cookies and similar technologies” section below.

From third parties and publicly available sources. This includes personal information we collect from other public sources, including, but not limited to, websites that enable social sharing, social media sites, and websites from our service providers, vendors, our affiliates, or other individuals and businesses.

From you in person.

The Types of Personal Information We May Collect From You

Depending on how you interact with us, we may collect the following information:

• Contact Information, such as your name, company, title, zip code, country, work address, email address, telephone number, or other similar identifiers.
• Subscription-related Information, such as type of employment, organization name, organization type, field of interest, and locations of interest.
• Biographic and Demographic Information, such as age and gender.
• Financial and Payment Information, such as credit card details, bank account number, financial information, and payment preferences.
• Account Information, such as a user name and password, profile details you choose to provide, and feedback and reviews you may provide on our Services.
• Activity Information, such as information we collect when you access and interact with our Services, including browser or device model and settings, operating system, and unique identifiers, clickstream data, cookies and localStorage, browsing history, search history, web-based location, IP address, geolocation, and any other Internet usage information our Services may automatically record when you visit. For more information about cookies and similar technologies, please refer to the section “Cookies and Similar Technologies” below.
• Inferences, such as inferences drawn from any of the personal information identified and discussed in this Privacy Policy.
• Other Personal Information you provide, such as the content provided either in your job application or in your communications with us, including interactions with us online, in-person, or on the phone.

How We Use Your Personal Information

We may use your information for the following reasons, depending on your relationship with us:

• To provide you the products and services requested.
• To communicate with you, such as when we send a welcome email and to verify email ownership, respond to your inquiries and send you communications, including our newsletter and subscriptions, and any other communications regarding our products and services. This may also include when we send you administrative e-mail notifications, such as security, or support and maintenance advisories.
• To serve you targeted advertising or content.
• To provide, market, and develop our products and services, including to maintain our websites and mobile applications, troubleshoot, provide customer and technical support, conduct data analysis, test and research, and better understand the interests of our users, readers, and subscribers who use our services and products.
• To conduct marketing research.
• To understand how you interact with our Services and personalize the product experience and content (including advertising and messaging campaigns).
• To maintain the safety, security, and integrity of our Services, for example, by authenticating users and providing account security and fraud detection. We may also use your information to monitor, detect, and prevent fraud and improper or illegal activity.
• To debug our systems, to secure our online services, including our network and websites, and to debug our online services.
• To send you surveys, news and/or marketing communications (by email, phone, or text) subject to your marketing preferences and choices, including information about us or third party offerings we think may be of interest to you.
• To conduct market research and develop quality assurance, including to study, develop, and improve our products and services. This may include measuring and analyzing audience traffic, including tracking user interests, trends, and patterns. We may also aggregate, anonymize, and/or de-identify personal information we collect and use it for any purpose, including product development and improvement activities.
• To comply with legal requirements and/or to investigate or address claims or disputes relating to your use of our Services. This would include the use of your information to comply with our legal and regulatory obligations, to defend ourselves in litigation and investigations, and to prosecute litigations.
• To facilitate the creation and maintenance of, as well as to secure, your membership and/or subscription account.
• To help recognize you as a previous visitor and save and remember your preferences and settings and deliver to you appropriate interest-based content.
• To deliver video content to you in the ordinary course of our business.
• To conduct internal business purposes, including for data analysis, audits, and enhancing our services. We may also use inferences drawn from personal information to create a profile reflecting your preferences, so we can tailor our services to you.
• To collect analytics in order to understand how our Services are used and to improve them over time.
• To process and complete transactions, including collecting payment and contact information to process your transactions and deliver our Services to you.

How We Disclose Personal Information

We may disclose some or all of the personal information collected from or about you with any of the following entities and for any of the following purposes:

• Advertising Partners. We may provide personal information to third parties, such as advertising partners or other marketing partners who provide services to us.  
• Service Providers and Company Affiliates. We may provide personal information to vendors, payment processors, contractors, and business and service partners who provide services to us, including analysis firms and others. We may also disclose some or all of your information to our parent company, subsidiaries, joint ventures, or other companies under a common control (“Company Affiliates”), in which case we will require our Company Affiliates to honor this Privacy Policy. We may disclose some of the information that we collect from or about you with other parties in order to process and fulfill your requests for video content offered through the our Services, including to provide you with access to localized content and video content recommendations.
• Social Networks. Some features of our Services may enable you to post content to social networking services (“SNSs”). If you choose to do this, we will provide information to such SNSs in accordance with your elections. You acknowledge and agree that you are solely responsible for your use of those websites and that it is your responsibility to review the terms of use and privacy policy of the third party provider of such SNSs. We will not be responsible or liable for: (i) the availability or accuracy of such SNSs; (ii) the content, products or services on or availability of such SNSs; or (iii) your use of any such SNSs.
• Government, regulatory, or law enforcement agencies. We reserve the right to disclose your information to respond to valid information requests from government authorities and judicial requests, to investigate potential fraud, or where otherwise required by law. We may disclose your personal information where we believe the disclosure is necessary or appropriate to comply with regulatory or legal requirements, or to protect the safety, rights, or property of ourselves and others and to exercise, establish, or defend our legal rights.
• In connection with a merger, acquisition, or business transfer. If we sell all or a part of our company, are part of a merger, consolidation, restructuring, and/or sale of assets or other corporate change, your information may be transferred as part of that transaction.
• At your direction. We may disclose your personal information at your direction or with your consent.
• Collaborators. We may disclose personal information with collaborators with whom we jointly develop or promote our services, including sponsorships and co-branded opportunities and promotions.
• The General Public. We may disclose personal information with the general public if you choose to disclose personal information when contributing content to our Services through forums, blogs, social features, or the like.
• Aggregate Data. We may disclose your personal information in an aggregated or non-identifying form or otherwise in a form that cannot reasonably be used to identify you.

Children's Privacy

You must be 18 years or older to use our Services. Our Services are for a general audience, are not targeted to children, and do not knowingly collect personal information from children under 18 years of age.

Links to Third Party Websites

We may provide links to websites and other third party content (e.g., social media platforms) that are not owned or operated by us. The websites and third party content to which we link may have separate privacy notices or policies. We are not responsible for the privacy practices of these websites.

If you provide any personal information through a third party site, your interaction and your personal information will be collected by and controlled by the privacy policy of that third party site. We recommend that you familiarize yourself with the privacy policies and practices of any such third parties, which are not governed by this Privacy Policy.

CCTV

We use CCTV video recording to protect the physical security of our property and Services in line with applicable laws. We do this to comply with our contractual obligations (e.g., with customers and insurers) and our internal physical security policies to safeguard our properties, workplaces, people, and data.

Your Advertising Choices

When you use our Services, our third party advertising partners, social media providers, and analytics providers may collect personal information about your online activity on our Services and on third party websites.

These providers may set web tracking tools (e.g., cookies and web beacons, as discussed further below) to collect information regarding your online activity. In addition, our advertising partners may use this information to deliver advertisements to you when you visit third party websites within their networks. If you would like more information about this practice, and to know your choices with respect to it, please either visit the Digital Advertising Alliance’s opt out page (currently available at http://www.aboutads.info/choices/) or the Network Advertising Initiative’s opt out page (currently available at http://www.networkadvertising.org/choices/). Please note that you may continue to receive generic ads that are not based on your preferences.

Additionally, we may collaborate with our service providers and identity partners ("Identity Resolution Partners") to deliver targeted advertising and identify the different devices and browsers you may use to access our Services. We and our Identity Resolution Partners may facilitate identity resolution by creating probabilistic and deterministic identifiers. These identifiers may use personal information, including your name, email address, phone number, and Activity Information to generate an online identifier reasonably linkable to you and/or your device or browser. For example, we may disclose hashed email address, phone number, or other information about your device to our Identity Resolution Partners, whom may, in turn, return an online identifier that we may store in a first party cookie or similar technology and disclose to our advertising partners to provide you a more personalized advertising experience. These identifiers also help us with fraud detection and security, enforce our Terms of Service, among other things. We are not responsible for the privacy practices of our Identity Resolution Partners, which are separate from our own and not covered by this Privacy Policy.

You may have additional rights related to these technologies depending on your state of residency, as outlined in Section 13 below.

Information Security

We use commercially reasonable administrative, technical, personnel, and physical measures designed to safeguard information in its possession against loss, theft, unauthorized use, disclosure, or modification. However, the confidentiality of information transmitted over the Internet cannot be guaranteed. We urge you to exercise caution when transmitting personal information over the internet. We cannot guarantee that unauthorized third parties will not gain access to your information; therefore, when submitting personal information to us, you do so at your own risk.

Cookies and Similar Technology

We and our partners use various tools to collect data when you visit our sites and apps, including cookies, pixels, localStorage, and other similar technologies. Some of these technologies store data in the browser or on your device. Other technologies may use network-related or other information to recognize your device (e.g., IP address). Our Services use these technologies, for example, when you first request a web page and data is then stored on your computer or other device so the website or mobile application can access personal information when you make subsequent requests for pages from that Service. These technologies may also be used to collect and store information about your usage of the Services, such as pages you have visited, other content you viewed, and search history. Additionally, we may these technologies to collect analytics and measure the use of our Services.

We and our partners may also use these technologies to gather personal information about how you view and use our Services and content and to connect your activity with other data we store about you. We and our partners may collect your personally identifiable information about your online activities over time and across different websites when you use the Services. The use of these technologies helps us serve you better by understanding what you are interested in, tracking trends, measuring the effectiveness of ads, saving your preferences, and storing information you may want to retrieve on a regular basis. We also allow specific, approved partners to collect data from your browser or device for advertising and measurement purposes using their own similar tools.

Your web browser can be set to allow you to control these technologies, such as whether you will accept cookies, reject cookies, or to notify you each time a cookie is sent to your browser. If your browser is set to reject cookies, websites that are cookie-enabled will not recognize you when you return to the website, and some website functionality may be lost. The Help section of your browser may tell you how to prevent your browser from accepting these technologies, such as cookies. To find out more about cookies, visit https://www.aboutcookies.org. Depending on the make and model of your phone, you may be able to use device settings to opt out of the use of certain device IDs for targeted advertising. For more information about Google Analytics, please review the site “How Google uses data when you use our partners’ sites or apps,” located at https://www.google.com/policies/privacy/partners/. To opt out of Google Analytics specifically, please go to https://tools.google.com/dlpage/gaoptout.

Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to websites that the user visits indicating that the user does not wish to be tracked over time and across websites. Because there is not yet a common understanding of how to interpret DNT, we do not currently respond to the DNT signal on our websites. We do, however, respond to global privacy preferences when required by law.

Your Marketing Preferences

We may periodically send promotional materials or notifications related to our Services. If you no longer wish to receive promotional marketing materials from us, you may opt out of receiving such materials. You may unsubscribe from receiving marketing or other commercial emails from us by following the instructions included in the email.

There are certain service notifications and other non-promotional emails that you may not opt out of, such as notifications of changes to our Services or policies.

Additional Information for Residents of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and Other U.S. States with Similar Privacy Laws

Depending on where you live, you may have certain additional rights regarding your personal information. This section provides information for consumers residing in California, Virginia, Colorado, Connecticut, Utah, Texas, and Oregon in connection with the laws in those states, and other states with similar privacy laws (“Applicable Laws”). Under these Applicable Laws, and for purposes of this Section, “Personal Data” and/or “Personal Information” generally mean information that identifies, relates to, or describes a resident or household in one of the Applicable States, and, for Oregon residents, may also include information that is linkable or linked to a device. Personal Information and/or Personal Data does not include publicly available information; lawfully obtained, truthful information that is a matter of public concern; information that has been deidentified or aggregated; or other information covered by certain sector-specific privacy laws, as consistent with state law. We do not reidentify Personal Data and/or Personal Information that has been deidentified. We and our adverting partners use certain Personal Data and/or Personal Information to deliver online advertisements to you on your devices tailored to your interests. This may be considered “sharing” or “selling” under California law, "selling" under Colorado, Connecticut, Texas, and Oregon law, and "targeted advertising" under Virginia, Colorado, Connecticut, Utah, Texas, and Oregon law. This Section provides details about the categories of Personal Data and/or Personal Information of consumers in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, and other U.S. states with similar privacy laws that we have collected, disclosed, processed for purposes of targeted advertising, “shared”, or “sold” during the last 12 months, as well as rights consumers have under Applicable Laws.

Categories of Personal Data and/or Personal Information Collected, Disclosed, “Shared”, “Sold”, or Processed for Targeted Advertising: 

The categories of Personal Data and/or Personal Information that we collected, disclosed, “shared” (under the California law), processed for purposes of targeted advertising (under the Virginia and Utah laws) or “sold” (under the California, Colorado, Connecticut, Texas, and Oregon laws) are below, along with the purposes for processing, and categories of third parties to whom each category of Personal Data and/or Personal Information was disclosed, “shared”, “sold”, or processed for the purpose of targeted advertising. Please note that we process some categories of Personal Data and/or Personal Information in connection with targeted advertising, which could be considered “sharing” under the California law or “selling” under the California, Colorado, Connecticut, Texas, or Oregon laws. Depending on how you interact with us, we may not have processed Personal Information about you for each (or any) of these purposes. Additionally, we do not knowingly sell, share, or process Personal Data and/or Personal Information of children under 13 years of age.

We have provided detailed descriptions below on the data collection, use, and disclosure practices of our companies depending on which service you use.

POLITICO Users

The below chart applies to POLITICO.com and the POLITICO mobile app.

Please note that we may process Personal Data and/or Personal Information in each of the above categories in order to protect ours and others’ rights, and/or to complete a merger or sale of assets or other corporate transaction. Please note that we do not sell Personal Data and/or Personal Information for monetary consideration.

Under California, Colorado, Virginia, Connecticut, Utah, Texas, and Oregon laws, “sale” (and “share” in California) does not include, for example, the transfer of Personal Data and/or Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving all or any portion of our business.

Sensitive Personal Information.  We do not process “sensitive” Personal Information for purposes other than those permitted by applicable law (such as, in California, to provide the services and for security purposes). Additionally, we may process “sensitive” Personal Data for approved purposes under Applicable Laws, such as to provide you with the product or services you requested or prevent, detect, and respond to security incidents.

Data Retention.  We will retain Personal Data and/or Personal Information from or about you as reasonably necessary and proportionate to achieve the purpose(s) for which the Personal Information was collected or processed as outlined in this Section unless a longer retention period is required or allowed by law.

Purposes

We may use this personal information for the following purposes, including commercial purposes:

• to operate, manage, and maintain our business;
• to provide our Services;
• to accomplish our business purposes and objectives;
• to develop, improve, repair, and maintain our Services;
• to engage in marketing and targeted advertising;
• to conduct research and analytics;
• to take quality assurance and safety assurance measures;
• to conduct risk assessments and effectuate security controls;
• to detect and prevent fraud;
• to verify your identity;
• to conduct audits and other internal functions;
• to comply with the law, legal process, and internal policies;
• to maintain records; and
• to exercise and defend legal claims.

Depending on your interactions with us, we may not have used Personal Data and/or Personal Information collected about that resident for each (or any) of these purposes.

Sources of Personal Information

In general, we only collect Personal Data and/or Personal Information that is reasonably necessary for and proportional to the purposes for which we process it. We collect this Personal Data and/or Personal Information directly from California, Virginia, Colorado, Utah, Connecticut, Texas, and Oregon residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to our website); referrals; joint marketing, co-branding, co-promotional, or advertising partners; and sources of demographic and other information, including through devices you used to interact with us through our Services. All sources of personal information collected are noted in the “How Do We Collect Personal Information” and “The Types of Personal Information We May Collect From You” sections above.

Your Privacy Rights Under Applicable State Law 

If you are a resident of California, Virginia, Connecticut, Utah, Colorado, Texas, or Oregon you may have the following rights with respect to any information about you that constitutes “Personal Information” under California law and “Personal Data” under other state laws, as described below.

We are required by law to verify your identity in connection with any request in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by applicable law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request.

Right to Know and Access: You may request to access the following information we have collected and maintain about you:

• The specific pieces of Personal Data and/or Personal Information we collected about you;
• The categories of Personal Data and/or Personal Information we collected about you and the categories of sources;
• The business or commercial purpose for collecting, disclosing, or selling Personal Data and/or Personal Information about you; and,
• The categories of Personal Data and/or Personal Information about you that we sold, shared, or otherwise disclosed and the categories of third parties to whom we sold, shared, or otherwise disclosed that Personal Data and/or Personal Information.

Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Right to Delete: You may request that we delete the Personal Data and/or Personal Information we have collected from you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Opt Out of “Sale”, “Shares”, and Targeted Advertising: Depending on the state you reside in, you have the right to opt out of the “sale” of your data, the disclosure of your data for cross-context behavioral advertising/targeted advertising (known as a “share” in California), and profiling in furtherance of solely automatized decisions that produce legal or similarly significant effects. We also honor alternative opt-out signals, such as the GPC. We process opt-out preference signals in a frictionless manner. Please note that we do not sell Personal Information for monetary consideration.

Right to Correction: You have a right to request the correction of inaccurate Personal Data and/or Personal Information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Right to Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your above-listed rights under the CCPA.

Right to Appeal: Depending on your state of residence, you may have the right to request an appeal our action in response to a consumer request.

CCPA Request Metrics for 2022:

• Number of requests to delete that were received, complied with in whole or in part, and denied; 2
• Number of requests to correct that were received, complied with in whole or in part, and denied; 0
• Number of requests to opt-out of sale/sharing that were received, complied with in whole or in part, and denied; 1,032,403
• The median or mean number of days it took to substantively respond (i.e not the 10 day “confirmation of receipt” window); 32.67

To Exercise Rights:

In order to exercise your Right to Opt Out of “Sales”, “Shares”, and Targeted Advertising, please visit our "Do Not Sell or Share My Personal Information and Opt Out of Targeted Advertising" page.

Depending on your state of residence, in order to exercise your Right to Appeal our action in response to your request, please email us using the email address in the “Contact Us” section below. In order to exercise your other rights described above, please call us at (571) 489-5203 or submit a request through the linked form at https://go.politico.com/your-privacy-rights.html. Additionally, we may need to obtain information about you or your specific request in order to verify your identity and respond.

Authorized Agent

Depending on your state of residence, you have the right to submit a request through an authorized agent. If you are an authorized agent acting on behalf of a resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of a consumer, please contact us at the contact information below with supporting verification information, which includes proof that you have access to the consumer’s interface and proof of your own identify.

POLITICO Pro and E&E Users:

The below chart applies to the POLITICO Pro and E&E News websites and associated mobile apps.

POLITICO Pro and E&E News provide business-to-business services. This means that Personal Data and/or Personal Information we collect, other than from California residents, is excluded from certain U.S. state privacy laws. While we are not required by Applicable Laws to respond to consumer requests from residents of those applicable states, we will, as a courtesy, endeavor to reply to consumer requests from residents of Virginia with business-to-business data so long as doing so does not conflict with applicable law or a legitimate purpose allowing or requiring us to protect the Personal Information from disclosure. We also reserve the right to verify your identity in conjunction with any such Virginia resident courtesy request.

The below applies to California residents and their Personal Information for the above services:

Please note that we may process Personal Information in each of the above categories in order to protect ours and others’ rights, and/or to complete a merger or sale of assets or other corporate transaction.

Under California, “sale” and “share” do not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving all or any portion of our business.

Sensitive Personal Information.  We do not process “sensitive” Personal Information for purposes other than those permitted by applicable law (such as, in California, to provide the services and for security purposes).

Data Retention.  We will retain Personal Information from or about you as reasonably necessary and proportionate to achieve the purpose(s) for which the Personal Information was collected or processed as outlined in this Section unless a longer retention period is required or allowed by law.

Purposes

We may use this personal information for the following purposes, including commercial purposes:

• to operate, manage, and maintain our business;
• to provide our Services;
• to accomplish our business purposes and objectives;
• to develop, improve, repair, and maintain our Services;
• to engage in marketing and targeted advertising;
• to conduct research and analytics;
• to take quality assurance and safety assurance measures;
• to conduct risk assessments and effectuate security controls;
• to detect and prevent fraud;
• to verify your identity;
• to conduct audits and other internal functions;
• to comply with the law, legal process, and internal policies;
• to maintain records; and
• to exercise and defend legal claims.

Depending on your interactions with us, we may not have used Personal Information collected about that resident for each (or any) of these purposes.

Sources of Personal Information

We collect this Personal Information directly from California residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to our website); referrals; joint marketing, co-branding, co-promotional, or advertising partners; and sources of demographic and other information, including through devices you used to interact with us through our Services. All sources of personal information collected are noted in the “How Do We Collect Personal Information” and “The Types of Personal Information We May Collect From You” sections above.

Your Privacy Rights Under Applicable State Law

California residents have certain rights with respect to their Personal Information, as described below. As described above, we will, as a courtesy, endeavor to reply to consumer requests from residents of Virginia with business-to-business data so long as doing so does not conflict with applicable law or a legitimate purpose allowing or requiring us to protect the Personal Information from disclosure.

We are required by law to verify your identity in connection with any request in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by applicable law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request.

Right to Know and Access Personal Information: You may request to access the following information we have collected and maintain about you:

• The specific pieces of Personal Information we collected about you;
• The categories of Personal Information we collected about you and the categories of sources;
• The business or commercial purpose for collecting, disclosing, or selling Personal Information about you; and,
• The categories of Personal Information about you that we sold, shared, or otherwise disclosed and the categories of third parties to whom we sold, shared, or otherwise disclosed that Personal Information.

Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Deletion of Personal Information: You may request that we delete the Personal Information we have collected from you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

“Do Not Sell or Share” Personal Information: As noted above in this section, we disclose some categories of Personal Information in connection with certain types of advertisements that may be considered a “share” or “sale” under the CCPA. We also honor alternative opt-out signals, such as the GPC. We process opt-out preference signals in a frictionless manner. Please note that we do not sell Personal Information for monetary consideration.

Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate Personal Information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your above-listed rights under the CCPA.

To Exercise Rights:

If you are a California resident, please visit our "Do Not Sell or Share My Personal Information and Opt Out of Targeted Advertising" page in order to exercise your Right to Opt Out of the Sale or Sharing of your Personal Information.

In order to exercise your other rights described above, please call us at (571) 489-5203 or submit a request through the linked form at https://go.politico.com/your-privacy-rights.html. Additionally, we may need to obtain information about you or your specific request in order to verify your identity and respond.

Authorized Agent

California residents may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California resident acting in their business capacity to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of a California resident acting in a business capacity, please contact us at the contact information below with supporting verification information, which includes proof that you have access to the consumer’s interface and proof of your own identify.

AgencyIQ Users

The below chart applies to the AgencyIQ website.

AgencyIQ provides a business-to-business services. This means that Personal Information we collect, other than from California residents, is excluded from certain U.S. state privacy laws.

The below applies to California residents and their Personal Information:

Please note that we may process Personal Information in each of the above categories in order to protect ours and others’ rights, and/or to complete a merger or sale of assets or other corporate transaction.

Under California law, “sale” and “share” do not include, for example, the transfer of Personal Information as an asset that is part of a merger, bankruptcy, or other similar transaction involving all or any portion of our business.

Sensitive Personal Information.  We do not process “sensitive” Personal Information for purposes other than those permitted by applicable law (such as, in California, to provide the services and for security purposes).

Data Retention.  We will retain Personal Information from or about you as reasonably necessary and proportionate to achieve the purpose(s) for which the Personal Information was collected or processed as outlined in this Section unless a longer retention period is required or allowed by law.

Purposes

We may use this Personal Information for the following purposes, including commercial purposes:

• to operate, manage, and maintain our business;
• to provide our Services;
• to accomplish our business purposes and objectives;
• to develop, improve, repair, and maintain our Services;
• to engage in marketing and targeted advertising;
• to conduct research and analytics;
• to take quality assurance and safety assurance measures;
• to conduct risk assessments and effectuate security controls;
• to detect and prevent fraud;
• to verify your identity;
• to conduct audits and other internal functions;
• to comply with the law, legal process, and internal policies;
• to maintain records; and
• to exercise and defend legal claims.

Depending on your interactions with us, we may not have used Personal Information collected about that resident for each of these purposes.

Sources of Personal Information

We collect this Personal Information directly from California residents themselves, as well as from social media platforms (e.g., if the individual has connected a social media account to our website); referrals; joint marketing, co-branding, co-promotional, or advertising partners; and sources of demographic and other information, including through devices you used to interact with us through our Services. All sources of personal information collected are noted in the “How Do We Collect Personal Information” and “The Types of Personal Information We May Collect From You” sections above.

Your Privacy Rights Under Applicable State Law 

California residents have certain rights with respect to their Personal Information, as described below.

We are required by law to verify your identity in connection with any request in order to prevent unauthorized access of your data. Failure to verify your identity may result in your request not being processed. Where required by applicable law, we will notify you if we deny your request and notify you of the reasons we are unable to honor your request.

Right to Know and Access Personal Information: You may request to access the following information we have collected and maintain about you:

• The specific pieces of Personal Information we collected about you;
• The categories of Personal Information we collected about you and the categories of sources;
• The business or commercial purpose for collecting, disclosing, or selling Personal Information about you; and,
• The categories of Personal Information about you that we sold, shared, or otherwise disclosed and the categories of third parties to whom we sold, shared, or otherwise disclosed that Personal Information.

Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Deletion of Personal Information: You may request that we delete the Personal Information we have collected from you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

“Do Not Sell or Share” Personal Information: As noted above in this section, we disclose some categories of Personal Information in connection with certain types of advertisements that may be considered a “share” or “sale” under the CCPA. We also honor alternative opt-out signals, such as the GPC. We process opt-out preference signals in a frictionless manner. Please note that we do not sell Personal Information for monetary consideration.

Correction of Inaccurate Personal Information: You have a right to request the correction of inaccurate Personal Information that we may have on file about you. Please note that, in some instances, we may decline to honor your request or only honor your request in part, where, for example, we are unable to verify your identity or an exception to this right applies.

Non-Discrimination: You have the right to be free from unlawful discrimination for exercising your above-listed rights under the CCPA.

To Exercise Rights:

If you are a California resident, please visit our "Do Not Sell or Share My Personal Information and Opt Out of Targeted Advertising" page in order to exercise your Right to Opt Out of the Sale or Sharing of your Personal Information.

In order to exercise your other rights described above, please call us at (571) 489-5203 or submit a request through the linked form at https://go.politico.com/your-privacy-rights.html. Additionally, we may need to obtain information about you or your specific request in order to verify your identity and respond.

Authorized Agent

California residents may use an authorized agent on their behalf to exercise a privacy right discussed above. If you are an authorized agent acting on behalf of a California resident to communicate with us or to exercise a privacy right discussed above, you must be able to demonstrate that you have the requisite authorization to act on behalf of the resident and have sufficient access to their laptop, desktop, or mobile device to exercise these rights digitally. If you are an authorized agent trying to exercise rights on behalf of an AgencyIQ consumer, please contact us at the contact information below with supporting verification information, which includes proof that you have access to the consumer’s interface and proof of your own identify.

Notice of Financial Incentive

We offer customers the ability to participate in a registration program ("Program"). Depending on your state of residence, the Program may be considered a financial incentive or loyalty program. Participation in the Program is entirely voluntary. If you would like to participate in the Program, please opt-in by signing up. If you sign up, you will receive:

• Access to article and newsletter content on POLITICO’s website. You will also receive an exclusive email newsletter offered only to registered users.

When you decide to participate in the Program, we will collect your email address, job title, and employer (depending on which you voluntarily provide to us) (collectively, "Registration Information"). Registration Information may also be disclosed to service providers or other providers or partners that support our operational business purposes. By voluntarily opting in to this Program, you will receive free access to politico.com article and newsletter content and an exclusive email newsletter, and you may also receive content from us through emails.

Depending on your state of residence, if you decide you no longer wish to participate in the Program, you may withdraw at any time. You may exercise this right to withdraw using the following method, depending on the information you have provided to us:

• Email [email protected] to request withdrawal from the Program, using the same email address you used for registration. To process your withdrawal request, we will need to delete your account. Before deleting your account to honor your withdrawal request, we will send you an email requesting that you explicitly acknowledge and confirm your decision to delete your account. This step is essential to ensure that the account deletion aligns with your intentions and helps mitigate unauthorized actions. Once we receive your confirmation, your account will be deleted, and you will be withdrawn from the Program. You may also unsubscribe from our newsletters at any time by visiting our Preferences page or by clicking “unsubscribe” at the bottom of the email. Visit the FAQ page for more information.

We estimate that the value of your data is equal to the value of the subscription to our services. Registration Information enables us to deliver personalized content, offers, subscription services, and value to you, which enables us to establish a relationship with you, and is valued by us in order to facilitate a positive customer experience. In determining the value of the Registration Information, we consider the profit generated from our advertising partners that includes personal information, which is reasonably correlated to the value provided to you through personalized content, discounts, or offers.

International Data Transfers

We are based in the United States. Any information you provide to us through use of the Services may be stored and processed, transferred between, and accessed from the United States and other countries which may not guarantee the same level of protection of personal information as the one in which you reside. We may need to send your personal information overseas as part of our normal business operations. Provided the data protection laws of these other countries differ from those in the United States, please be assured that we take reasonable steps to ensure that your privacy is protected.

Shine the Light Disclosure

We do not disclose personal information as defined by California Civil Code § 1798.83 (the “Shine the Light Law”) with third parties, other than our affiliates, for their direct marketing purposes absent your consent. If you are a California resident, you may request information about our compliance with the Shine the Light Law by sending an email to [email protected] or by sending a letter to 1000 Wilson Blvd, 8^th Floor, Arlington, VA 22209. Any such request must include “Request for California Privacy Information” in the subject line and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through the email address or mailing address referenced above.

Updates to the Policy

We may update this policy from time to time. To the extent permitted by law, any changes to our Privacy Policy will be posted to the websites and will become effective upon posting. Any changes will be effective only after the effective date of the change and will not affect any dispute arising prior to the effective date of the change.

Contact Us

We welcome all requests, suggestions and questions concerning our use of your personal Information. All such communication should be directed to [email protected] or call us at (571) 489-5203.