1. Personal Information and Personal Data Definition
For purposes of this Privacy Policy, unless a different definition is noted in a particular instance, “Personal Information” (or “Personal Data” as used in Section 9) means any information that identifies, relates to, describes, references, or is reasonably capable of being associated with an identified or identifiable natural person.
Personal Information for purposes of this Privacy Policy does not include your name, photo and/or other information about you included in news or editorial content.
2. Personal Information We Collect
We may collect the following types of Personal Information about you as described below:
- Personal Information we may automatically collect, and
- Personal Information we may receive from third parties.
Personal Information We May Automatically Collect About You
Our Media Properties and Services may automatically collect certain Personal Information about you. This Personal Information may include (the examples provided are illustrative and not intended to be exhaustive):
- IP address, which is the number associated with the service through which you access the Internet, such as through your ISP (Internet service provider);
- Date and time of your visit or use of our Media Properties or Services;
- Domain server from which you are using our Media Properties or Services;
- Type of computer, web browsers, search engine used, operating system, or platform you use;
- Data identifying the web pages you visited prior to and after visiting our Media Properties or using our Services;
- Your movement and activity within the website, which is aggregated with other Personal information;
- Geo-location information through the use of any of our mobile applications;
- Mobile device information, including the type of device you use, operating system version, and the device identifier (or “UDID”); and
- Mobile application identification and behavior, use, and aggregated usage, performance data, and where the application was downloaded from.
- If you sign up for text messaging, cookies or other tracking devices may be used to personalize your experience (for example, to send you personalized text message offers).
Personal Information We May Receive from Third Parties
We may collect additional Personal Information about you from third-party websites, social media platforms, such as, but not limited, to Facebook, Twitter, Instagram, SnapChat (“Social Media Platforms”), third party data providers, and sources providing publicly-available Personal information (e.g., from the U.S. postal service) for the purposes described in Section 3 below.
Personal Information we may access from Social Media Platforms may include, but is not limited to:
- Your Social Media Platform login information
- Your location data
- Your profile information
- Your list of contacts, friends or followers
- Certain Personal Information about your activities on the Social Media Platform
Please keep in mind that when you provide Personal Information to us on a third-party website or platform (for example, via our applications), the Personal Information you provide may be separately collected by the third-party website or the Social Media Platform. Please review the privacy policies of the applicable third-party website or Social Media Platform for their privacy practices.
3. How We Use Personal Information
A. Use and Purpose of Processing Your Personal Information
We use and process your Personal Information for the following types of purposes (the examples provided are illustrative and not intended to be exhaustive).
- To provide you with the relevant news, and related promotions, newsletters and information you request
- To respond to your inquiries and provide you with requested information and other communications, including by email, chat or text messages, and including alerts, notification of promotions, contests, and events
- For marketing and advertising purposes, including sending you promotional material or special offers on our behalf or on behalf of our marketing partners and/or their respective affiliates and other third parties, provided that you have not already opted-out of receiving such communications
- For billing and payment processing
- To deliver personalized advertising and content
- To fulfill contracts we have with you
- To manage, improve and foster relationships with third-party service providers, including vendors, suppliers, and parents, affiliates, subsidiaries, and business partners
- To maintain, improve, customize, or administer the Media Properties and Services, perform business analyses, or other internal purposes to improve the quality of our business, the Media Properties and the Services, resolve technical problems, or improve security or develop other products and services
- To perform analytics for business purposes and business intelligence, such as monitoring traffic to our Media Properties, counting ad impressions, and auditing legal and regulatory compliance
- To maintain the safety, security, and integrity of our Media Properties, products and Services, databases and other technology assets and our business, including preventing fraud, detecting security breaches and prosecuting violators
- To identify and repair errors in our functionality
- 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
- To comply with any applicable laws and regulations and respond to lawful requests; and/or
- For any other purposes disclosed to you at the time we collect your Personal Information and/or pursuant to your consent
If we decide to use the Personal Information for materially different purposes, we will update this Privacy Policy.
B. Disclosing Your Personal Information to Other Parties
We may disclose your Personal Information to other parties, including:
- 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 our business
- Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or Services we provide to you
In order to provide advertisements and content that are more relevant to you, we and our advertising and content providers may collect certain types of Personal Information when you use our Media Properties (such as, by way of example, your email, the IP address of your device, the identifier on your mobile device, or cookies stored on your device). We or our advertising and content providers may combine this information with other information we have, or that we collect through other sources, and may share the information we collect with third parties to provide interest based or targeted advertising.
If we decide to disclose Personal Information to additional categories of parties, we will update this Privacy Policy.
4. DO WE USE “COOKIES”?
Yes. Cookies, SDKs, tracking pixels and similar technologies are small files that a website or mobile application stores on your device that recognizes the user’s browser or device and captures and remembers certain information.
In general, we and our third-party providers and advertisers, use these technologies to optimize the functionality of the website.
If you sign up for text messaging, cookies or other tracking devices may be used to personalize your experience (for example, to send you personalized text message offers).
In addition, you may opt out of certain interest-based advertising by using the following resources:
- You may opt-out of having your activity on our website made available to Google Analytics by installing the Google Analytics opt-out add-on for your web browser by visiting: https://tools.google.com/dlpage/gaoptout for your web browser.
5. THIRD PARTY LINKS
Our website may contain links to other websites, applications or services that are not owned or controlled by us, including links to social media platforms, or may redirect you off our Media Property or away from our Services to other locations for information or other services. We are not responsible for the privacy and security practices of other websites, applications or social media platforms or the information they may collect (which may include IP address or device identifiers). You should refer to such third parties’ privacy policies on their sites to determine their respective privacy practices. Links to any other websites, applications, social media platform or content do not constitute or imply an endorsement or recommendation by us of the linked website, application, social media platform, and/or content.
6. SECURITY
We use commercially reasonable procedures and various technical, administrative and physical safeguards to help protect the confidentiality of your Personal Information. However, you should assume that no data transmitted over the Internet or stored or maintained by us or our third-party service providers can be 100% secure. Therefore, although we believe the measures implemented by us reduce the likelihood of security problems to a level appropriate to the type of data involved, we do not promise or guarantee, and you should not expect, that your Personal Information or private communications will always remain private or secure. We do not guarantee that your Personal Information will not be misused by third parties. We are not responsible for the circumvention of any privacy settings or security features.
7. ACCESSING, CORRECTING, OR DELETING YOUR PERSONAL INFORMATION
As required by applicable laws, and subject to any permitted exceptions and limitations, we will comply with any verified consumer request you submit with respect to your Personal Information.
8. TRANSFERS
Your Personal Information may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside the United States, and may have different data protection laws than in the United States.
9. AGGREGATE AND DE-IDENTIFIED INFORMATION
We may aggregate and/or de-identify any information collected through the Media Properties and Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use Aggregate/De-Identified Information for any purpose, including without limitation for research and marketing purposes, and may also share such data with any third parties, including advertisers, promotional partners, and sponsors, in our discretion.
10. PRIVACY POLICY FOR CALIFORNIA RESIDENTS
This Privacy Policy does not apply to California residents. If you are a California resident, CCPA rules apply.
11. INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA), OR UK
This Section 11 is included in this Privacy Policy to comply with the requirements of the General Data Protection Regulation (“GDPR”). It applies only to individuals coming to our Media Properties from within the EEA, Switzerland or the UK and applies only (1) if we collect through the Media Property any Personal Data of those individuals or (2) if we track individuals in the EEA, Switzerland or the UK who access our Media Properties.
Rights of Individuals Based in the EEA
Subject to applicable law, you may be able to exercise any of the following rights in relation to your Personal Data:
- Right to know what information we have about you: This is known as the “right of access” and gives you the right to find out what, if any, Personal Data we have about you, how we process it, and to request a copy of the Personal Data.
- Right to correct your information: This is known as the “right of rectification” and gives you the right to ask that we correct or complete any Personal Data we have about you.
- Right to delete your information: This is known as the “right to erasure” or “right to be forgotten” and gives you the right to ask us to delete your Personal Data.
- Right to change how we use your information: This is known as the “right to restrict processing” and gives you the right to ask us to change how we use your Personal Data in certain circumstances, such as where you contest the accuracy of the data or object to us using it in a certain way.
- Right to move your information: This is known as the “right to data portability” and gives you the right to ask to receive your Personal Data from us in a structured, commonly used and machine-readable format or to have it transmitted to another controller.
- Right to stop us from using your information: This is known as the “right to object” and gives you the right to ask us to stop using your Personal Data when applicable.
- Rights relating to how we use your information to categorize you or make decisions about you: This is known as the “right in relation to automated decision-making and profiling”: You have the right to be free from decisions we may make that are based solely on automated processing of your Personal Data, including profiling, if they produce a significant legal effect on you, unless such decision-making or profiling is necessary for entering into or performing a contract between you and us, or is made with your explicit consent.
- Right to withdraw consent: If we rely on your consent to use your Personal Data, you have the right to withdraw that consent at any time. This will not affect our use of your data before we received notice that you wished to withdraw your consent.
- Right to file a complaint with the supervisory authority
You may exercise your rights by contacting us as indicated under the “Contact Us” section below.
The requests above will be considered and responded to in the time period stated by applicable law. Certain information may be exempt from such requests. We may require additional information from you to confirm your identity in responding to such requests.
11.3. Legitimate Interests
“Legitimate interests” means the interests of our company in conducting and managing our organization. For example, and without limitation, we have a legitimate interest in processing your Personal Data to analyze how the Media Property and our products and Services are being used, to administer our contractual relationships, fulfil legal obligations, process employee data, prevent fraud or criminal activity or misuse of our products or services, ensure the security of our IT systems, architecture and networks, and meet our corporate and social responsibility objectives, and/or effectively and efficiently operate our business and provide you with the services offered through our Services, as described in this Privacy Policy. When we process your Personal Data for our legitimate interests, we make sure to consider and balance any potential impact on you, and your rights under data protection laws. Our legitimate interests do not automatically override your interests.
11.4. Data Transfers
Gannett is based in the United States, and we use service providers (described above) based in the United States to operate our business and our relationship with you. When you use our Site and the Services, you acknowledge that your Personal Data may be transmitted, stored, processed by us and our service providers’ servers in the United States to provide you with the services that you requested, administer our contract with you or to respond to your requests as described in this Privacy Policy.
11.5. Data Retention
We will keep your Personal Data only for as long as is reasonably necessary for the purposes outlined in this Privacy Policy based on the context in which you provided it, or for the duration required by law, whichever is the longer.
12. CHILDREN’S ON-LINE PRIVACY INFORMATION
In general, the website is not intended for use by children under the age of 13, or 16 where applicable.
13. CHANGES TO THIS PRIVACY POLICY
We may amend this Privacy Policy at our discretion and at any time. When we make changes to this Privacy Policy, we will post the updated notice on our Media Properties and update the notice’s “Last Updated” date. Where permitted by applicable law, your continued use of our Website and/or Services following the posting of changes constitutes your acceptance of such changes.