Effective Date: December 2019
Information We Collect - We collect various information about you when you use our services, including:
- information you provide to us;
- information about how you use our websites, mobile applications, and other online services;
- information about the computers and devices you use to access our services;
- information about your online activities and your interests;
- information about how you respond to our communications;
- information about the location of your mobile device based on the location of nearby Wi-Fi networks or, subject to your consent, information accessed via the location functionality of your device; and
- information about you from publicly or commercially available sources.
How We Use Information - We use information:
- to provide you with products and services, respond to your requests, manage sweepstakes and contests, and to personalize the content on our services;
- for research purposes;
- to communicate with you about your account; learn about you; and send you or provide you with ads, offers, or other content based on your interests;
- to resolve disputes; and
- to improve, maintain, and troubleshoot our services.
Sharing Information - We share information:
- with third parties, including service providers that process information on our behalf, to facilitate transactions and provide you with services;
- with our affiliates;
- to facilitate interest-based advertising; and
- in association with a transfer of a business or related assets; when there is a legal obligation to disclose your information; or to protect our legal rights, the public, or others.
You may update or delete the account information you provide us for any of our services in the account information page for that service.
You may indicate your preferences regarding marketing communications on our Newsletter Management page.
We use reasonable security measures to protect your information.
Our services are not intended for children under 13 years of age.
We are not responsible for any third-party products or services you access via our services.
- What Information Do We Collect?
- How We Use the Information We Collect
- How We Share the Information We Collect
- Third-Party Links and Content
- Interest-Based Advertising
- Children's Privacy
- Your Choices
- Notice to California Residents - Your California Privacy Rights
- International Transfers of Information
- Contact Information
- Definitions of Certain Terms
WHAT INFORMATION DO WE COLLECT?
Information that you provide to us: We and our service providers collect information that you provide when you use our services. For example, to access certain parts of our services, you may have to register or subscribe for an account. During registration we may collect your name, address, username, password, and email address. You may also provide us with information when you post a message on our services; sign up to receive communications from us; register for sweepstakes, contests, or other promotions; register for an event; participate in surveys, voting or polling activities, or other interactive areas of our services; purchase a subscription or classified ad; or contact us with a question, comment, or request. The information that you may provide us includes but is not limited to:
- Mailing address
- Email address
- Date of birth
- Telephone number
- Payment information, including account or card number
Passive data collection: Like most companies that offer services online, we and our service providers may automatically collect certain technical information from your computer, tablet or mobile device when you use our services or interact with us. The information we may collect includes but is not limited to:
- IP address
- Operating system
- Device type
- Device manufacturer
- Device identifier
- Browser type
- Content viewed on our services
- Pages viewed immediately before and after you access our websites
- Which ads or content from us or our affiliated companies you view, access, or click on
- Your activities over time and across websites and apps within the Newsday network and within the network of websites and apps serviced by the ad networks, advertisers, service providers, and other companies with which we do business, following your use of one of our websites or apps
- Whether you open our electronic communications and where you click within them
- Features of our services that you use
- Name and location of your Internet Service Provider
- Amount of time spent on our pages and how many pages you viewed during your visit
Location Information - Our mobile applications may collect precise information about the location of your mobile device via your device’s GPS or cellular connectivity, but only with your express consent. Once you have consented to the collection of such precise location information via your mobile device, you may adjust this consent by managing your Location Services preferences through the settings of your mobile device. We may also be able to infer your location from other information that you provide or information that we collect passively, such as the known locations of nearby Wi-Fi networks.
HOW WE USE THE INFORMATION WE COLLECT
We may use the information we collect for a number of purposes, including, but not limited to:
- providing you with and communicating with you about the products, services, or information you request or purchase;
- providing you with information and important updates about your account or subscription, or our products and services;
- using your location information to deliver location-based services that you request or location-based offers that may be of interest to you;
- personalizing your experience when using our services and providing content based on your interests or other demographics;
- allowing you to share content and information from our publication via social media, email, and other means;
- improving or troubleshooting our services;
- determining whether you are eligible for sweepstakes, contests, or other promotions;
- generating and analyzing statistics about how you use our services and respond to our communications;
- linking your activities across the devices you use to access the services so that we can learn about how you use the services and the devices you use, contact you across devices, and provide you with a consistent experience across devices;
- creating compiled, aggregate, and anonymous information about the users of our services and how our users interact with our services ("Aggregated Information");
- safeguarding your information;
- helping our advertisers and other companies better understand our users; and
- detecting, preventing, and responding to potential fraud, intellectual property infringement, violations of our Terms of Service, violations of law, or other misuse of our services. [LINK TO newsday.com/terms]
We may combine or aggregate any of the information we collect from our services and elsewhere for any of these purposes.
HOW WE SHARE THE INFORMATION WE COLLECT
We may disclose information about you:
- to service providers that process payments, handle marketing communications, provide technical support, conduct surveys, or perform other services for us;
- to business partners when you have elected to receive communications from them;
- to business partners that engage in interest-based advertising;
- as required by law, such as to comply with a subpoena or other legal process;
- as necessary to process transactions and provide you with the services, products, or information you request or purchase;
- when we have a good faith belief that disclosure is necessary to protect the rights or property of our affiliates or us, or to protect the safety of you or others;
- to detect, prevent, or respond to potential fraud, intellectual property infringement, violations of our Terms of Service, violations of law, or other misuse of our services
- to proceed with the negotiation or completion of a merger, acquisition, sale, or other transfer of all or part of our assets; or
- subject to your consent.
We do not share your credit card information or other financial information with third parties for their marketing purposes or other independent use. When we share information with third parties for processing credit card or other payments, we require those third parties to comply with applicable Payment Card Industry standards.
We may share Aggregated Information with third parties that provide content and services for us. We may also share Aggregated Information with advertisers and others so that they can better understand our audience. For example, we might disclose the gender, age, or geographical breakdown of our user base.
You should know that when you voluntarily disclose personal information publicly on our services (for example, when commenting on articles), that information may be collected and used by others and you may receive unsolicited communications from other people. Public activities may be included in our RSS feeds, APIs, and other distribution formats. As a result, your public activities may appear on other websites, blogs, or feeds. When you share information via features offered on our services by other companies (sometimes known as “third-party plugins”), the privacy settings of the other companies for those features govern how the information will be shared. When you are logged into our services, depending on the service you are logged into, your name may be displayed, and your email address and contact information may be viewed. Be sure to log out of your account and take other steps to ensure that others cannot view that information without your knowledge.
THIRD-PARTY LINKS AND CONTENT
Our services and communications may contain links to or content from websites or other online services provided by third parties. We expect our partners and third-party providers to respect your privacy, but you acknowledge and agree that we are not responsible for the collection and use of your information by websites and other services that are not under our control. The privacy practices of third parties are governed by their privacy policies, and we encourage you to review the privacy policies of all websites and online services that you use, view, or visit.
Some of our services and communications may contain tiny electronic images known as web beacons. We use web beacons to assist us in delivering cookies on our services and to allow us to count users who have visited those pages. We also include web beacons in promotional email messages in order to determine whether messages have been opened and acted upon.
To help ensure that you receive ads that are relevant to your interests on our services, our advertisers’ services, and elsewhere on the Internet, we and third-parties (including service providers, advertisers, and advertising companies) may collect information about your online activities over time and across different websites, apps, and devices. We and third parties may use that information to help understand audience segments. Advertisers may use the segments to determine the audience groups to which they wish to deliver particular ads. Through this process, we do not use information that directly identifies you.
You may opt out of tracking and receiving tailored advertisements on your mobile device by some mobile advertising companies and other similar entities by downloading the App Choices app at www.aboutads.info/appchoices. You may opt out of receiving permissible targeted advertisements by using the NAI opt-out tool available at https://optout.networkadvertising.org/?c=1 or visiting About Ads at https://optout.aboutads.info.
Opting out does not mean you will no longer receive advertising. It means that the company or companies from which you opted out will no longer deliver ads tailored to your web preferences and usage patterns.
If you have reason to believe that a child under the age of 13 has provided personal information, please contact us as provided in the Contact Information section below, and provide sufficient detail to enable us to delete that information from our databases.
In general, if you register to use any of our services, you may update the information you have provided to us for any of our services by visiting the account information page of that service.
When you register for our services, you may be able to indicate your preferences regarding marketing communications. On our Newsletter Management page, you may be able to change those preferences and select the categories of communications that interest you. When we or our affiliates send you emails containing offers that may be of interest of you, those emails may contain links via which you may opt out of receiving those communications. If you experience difficulty with the “unsubscribe” process, please contact us at email@example.com and provide your email address along with the name of the newsletter from which you would like to unsubscribe.
You will not be able to opt out of receiving certain service-related or transactional communications relating to our services unless you cancel your registration or subscription.
While we strive to maintain reasonable administrative, technical, and physical safeguards to protect your information, no information system can be 100% secure. We cannot guarantee the absolute security of your information. Moreover, we cannot be responsible for information that you transmit over networks that we do not control or information that you choose to publicly disclose. You are solely responsible for maintaining the secrecy of any passwords or other account information.
We make reasonable efforts to secure the account information pages and other registration locations for our services, such that they can be accessed only by our authorized personnel or by logging in with your username and password.
We endeavor to protect the security of your payment information during transmission by using technology that encrypts information you submit.
NOTICE TO CALIFORNIA RESIDENTS - YOUR CALIFORNIA PRIVACY RIGHTS:
California Civil Code Section 1798.83, also known as the “Shine The Light” law, permits consumers who are California residents, to request and obtain from us once a year, free of charge, information about the categories of personal information (as defined in the Shine the Light law), if any, that we disclosed in the preceding calendar year to third parties for those third parties’ direct marketing purposes. Our disclosure requirements apply only if we share our consumers’ personal information with third parties for them to directly market their own products to those consumers, instead of assisting us with our own business. If you are a California resident and would like to make such a request, please contact us as provided in the Contact Information section below.
As a California resident, in addition to your rights under the California “Shine the Light” law, the California Consumer Protection Act of 2018 (CCPA) may provide additional rights. Continue reading to learn more.
Personal Information We Collect
We may have collected personal information in the following categories from consumers within the last twelve (12) months. The categories and examples provided in the chart below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact collected but reflects our good faith belief to the best of our knowledge that some of that information may have been collected about consumers. We will update this disclosure from time to time as appropriate.
|A. Identifiers.||A name, postal address, unique personal identifier, online identifier, IP address, email address, account name, or other similar identifiers.|
|B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).||A name, physical characteristics or description, address, telephone number, education, employment, employment history, credit card number, debit card number, or any other financial information. Some personal information included in this category may overlap with other categories.|
|C. Protected classification characteristics under California or federal law.||Age (40 years or older) and gender.|
|D. Commercial information.||Records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.|
|E. Internet or other similar network activity.||Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.|
|F. Geolocation data.||Physical location or movements.|
|G. Inferences drawn from other personal information.||Profile reflecting a person’s preferences, characteristics, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.|
Sources of Personal Information
- Directly from you. For example, during account registration from forms you complete, subscriptions you purchase or comments you provide on our services.
- Indirectly from you. For example, from observing your actions on our services.
- From third parties. For example, third party social networking providers and advertising companies, our affiliates and service providers who provide services or information to us. If you do not want us to collect information from social networks, you should review and adjust your privacy settings on those networks as desired before linking or connecting them to our services.
- From publicly available sources. For example, online database searches.
Use and Disclosure (“Sale”) of Personal Information
We may have “sold” (as that term is defined in the CCPA) personal information in the following categories from consumers within the last twelve (12) months. Please note that the CCPA uses an expanded definition of the term, in which “sell” means:
“Selling, renting, releasing, disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer’s personal information by the business to a third party for valuable consideration; or (B) sharing orally, in writing, or by electronic or other means, a consumer’s personal information with a third party, whether for valuable consideration or for no consideration, for the third party’s commercial purposes.”
When we disclose that we may have sold personal information, it means that we may have received some kind of benefit to our company in return for sharing personal information, but not necessarily received any money in exchange.
The categories below are those defined in the CCPA. This does not mean that all examples of that category of personal information were in fact “sold” but reflects our good faith belief to the best of our knowledge that some of that information may have been shared for value in return. We will update this disclosure from time to time as appropriate.
- Personal information categories listed in the California Customer Records statute.
- Protected classification characteristics under California or federal law.
- Commercial information.
- Internet or other similar network activity.
- Geolocation data.
- Inferences drawn from other personal information.
Use of Personal Information for Business Purposes or Commercial Purposes
We may use or disclose personal information we collect for “business purposes” or “commercial purposes” (as defined under the CCPA), which may include the following examples. The examples provided are illustrative and not intended to be exhaustive.
- Auditing Interactions with Consumers. For example: monitoring traffic to our services, counting ad impressions, and auditing legal and regulatory compliance.
- Security. For example, maintaining the safety, security, and integrity of our websites, products and services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators, and responding to law enforcement requests and meeting requirements of applicable law, court order, or governmental regulations.
- Debugging/Repair. For example, identifying and repairing errors in our services’ functionality.
- Certain Short-term Uses. For example, ad customization that does not involve or contribute to profiling.
- Performing Services. For example, creating, maintaining, customizing and securing your account with us, processing your purchases, transactions, and payments, hosting our websites, fulfilling subscription orders, managing databases, performing analyses, billing, and marketing services such as managing sweepstakes, contests, and other promotions.
- Internal Research for Tech Development. For example, testing, research, analysis, and product development, including to develop and improve our websites, products, and services.
- Quality and Safety Maintenance and Verification. For example, improving, upgrading, enhancing, and verifying the quality and safety of our services.
- Other Commercial Purposes. For example, as described to you when collecting your personal information such as for promotions, or to evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, in which personal information we hold is among the assets transferred.
Disclosing Personal Information to Other Parties
We may disclose your personal information to the following categories of other parties for a business purpose or commercial purpose, as those terms are defined in the CCPA:
- Our affiliates
- Service providers
- Advertisers, advertising technology companies, analytics companies and other third parties with whom we have business relationships
- Government regulators
- Our legal advisors and parties involved in a legal process
- To an entity involved in the sale of all or part of our business
- Third parties to whom you or your agents authorize us to disclose your personal information in connection with services we provide to you
Your CCPA Privacy Rights and Choices
The CCPA provides California residents with specific rights regarding their personal information as described below.
- Right to Know about Personal Information Collected or “Sold”
You have the right to request that we disclose certain information to you about our collection and use of your personal information over the past 12 months. After we receive and confirm your verifiable consumer request, we will disclose to you within the time required by the CCPA, the relevant information, which may include:
- The categories of personal information we collected about you.
- The categories of sources for the personal information we collected about you.
- Our business or commercial purpose for collecting or selling that personal information.
- The categories of third parties with whom we share that personal information.
- The specific pieces of personal information we collected about you (also called a data portability request).
- If we sold your personal information, or disclosed your personal information for a business purpose, two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.
- Right to Request Deletion of Personal Information
You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions, including if we need the personal information for a reason related to our business, such as:
- providing goods or Services to you;
- detecting and resolving issues related to security or functionality;
- complying with legal obligations;
- conducting research in the public interest;
- exercising free speech or ensuring another’s exercise of free speech; or
- using the information for internal purposes that a consumer might reasonably expect.
After we receive and confirm your verifiable consumer request, we will delete your personal information from our records within the time period required by the CCPA, unless an exception applies.
Exercising Your Rights
To exercise the rights described above, please submit a verifiable consumer request to us through this web form. You may make a verifiable consumer request for access or data portability only twice within a 12-month period.
The verifiable consumer request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative, which may include: providing your email and phone verification, known customer information, and/or account sign-up authentication or other information needed to verify your identity depending on the sensitivity of the personal information in question.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
Response Timing and Format
We use good faith efforts to respond to a verifiable consumer request within forty-five (45) days after its receipt. If we need more time (up to 90 days), we will inform you of the reason and the needed extension period in writing.
Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. If we cannot comply with any portion of a request, the response we provide will also explain why, if applicable. For data portability requests, we will select a commercially reasonable format to provide your personal information that is commonly useable and should allow you to transmit the information from one entity to another entity without hindrance, but we do not guarantee that all formats are useable in all media. We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Non-Discrimination for the Exercise of CCPA Privacy Rights
We will not discriminate against you for exercising any of your CCPA rights. In particular, we will not:
- Deny you goods or services
- Charge you different prices for goods or services, whether through denying benefits or imposing penalties
- Provide you with a different level or quality of goods or services
- Threaten you with any of the above
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt-in consent, which you may revoke at any time.
We currently do not offer any financial incentive, benefit, or price differences in return for the disclosure, deletion, or sale of personal information. However, in general, our business model is based on providing a certain amount of free content to readers, after which we may require that additional content access must be paid for.
Do Not Sell My Personal Information
The CCPA requires businesses to provide a webpage where consumers can opt out of the “sale” of their personal information. The link to our Do Not Sell web form is located here.
INTERNATIONAL TRANSFERS OF INFORMATION
Call us at 1-800-NEWSDAY (1-800-639-7329)
Email us at firstname.lastname@example.org
DEFINITIONS OF CERTAIN TERMS
IP Address - the identifier assigned to facilitate communications over the Internet. Depending on how you connect to the Internet, your IP address may always be the same, or it may change each time you access the Internet. An IP address does not in and of itself disclose your name, email address, or home or work address.
Service Providers - unaffiliated companies that perform services on our behalf, such as printing, mailing, processing payments, managing the delivery of advertisements, collections, data processing, or communications. We strive to limit the amount of users’ personally identifiable information shared with service providers. We ask these service providers to keep confidential the information that we provide to them, and we require them to not share, sell, or rent any information collected from our users that directly identifies our users.