A. TYPES OF INFORMATION COLLECTED
In addition, non-personal information, such as which pages on the Site are accessed, what information is downloaded, what type of browser and operating system are being used, which Internet service provider is being used, and other information of this general type may be collected about visitors to the Site. This information does not allow us to personally identify the Site visitor. By collecting this information we learn how best to develop our website to meet the needs and desires of our visitors.
B. METHODS OF INFORMATION COLLECTION
- Registration, Forms, and Other Times You Actively Provide Your Personal Data to Us
We collect personal data about you when you actively provide it to us. For example, when you fill in your contact information in a form to open an account with us, submit comments in response to one of our stories (we may require that you include some identifying information with your comments), submit photos or other information to us, sign up to receive information from us, subscribe to the Services, enter a contest, respond to a survey, email us, purchase something through the Services, or at other times in which we alert you that you must submit personal data.
- Information from Devices
- Social Media Login
- Public Information and Posts
Any personal data that you post or submit to our Site or other Services, such as when posting comments in response to stories or submitting photos or videos, may be collected by us, and may be viewed by other people (including search engines), over whom we have no control. You are responsible for the information you choose to post or otherwise make available in such public areas, and you acknowledge that this information may be collected and used by third parties.
- Payment Processing
If you purchase something through our Services, we may collect your name, address, credit card information, and other personal data in order to process the purchase, deliver the goods or services that you purchased to you, and handle any other issues related to your purchase. If you use third party payment providers, such as PayPal, to pay for or receive payment from us, that site may pass information to us including your name, email address, billing or other address, phone number (if applicable), date of sign-up, the number of payments you have received from verified PayPal users, whether you have been verified to have control of a bank account and any other information you agree they can share.
- Advertisers and Other Third Parties
CPP has a number of affiliates or related entities. We may sometimes share personal data with our affiliates/related entities and they may sometimes share it with us when consent has been given to do so or there is a legitimate interest in doing so.
- Other Sources
C. HOW WE USE YOUR PERSONAL DATA
- Provide Products and Services that Are Relevant to You, Improve Your Experience, and Manage our Relationship with You. If you sign up for an account with us, then we may use your personal data to maintain your account and to correspond with you. We may use your personal data to provide you with products and services you have asked for, including allowing you to interact, comment, and participate in contests. We may use your information to monitor, improve and protect our products, content, services and websites, both online and offline. We may also provide you with help and support where we believe it is required.
- Send You Product-Related and Similar Product and Services Communications. If you email us, submit information to us, or ask to be placed on a mailing list that we maintain, then we may contact you and send information to you. We may send you information, exclusive offers and promotions about similar products and services to those that you have already engaged with or purchased, if you have previously given your consent. We may send you service messages by email, SMS, social media, postal mail, or other methods, containing important information about changes to our services or your account. To opt-out of receiving product–related and similar product and services communications, please follow the instructions in the communication, change your account settings or email us at firstname.lastname@example.org.
- Conduct Market Research and Perform Analytics. We may use your personal data to improve our marketing and promotional efforts, as part of a statistical usage analysis, and/or to improve our features and content. Specifically and among other methods, we may use Google Analytics, which collects user information using first-party cookies (such as the Google Analytics cookie) or other first-party identifiers and third-party cookies (such as Google advertising cookies) and or other third-party identifiers. For more information about how Google collects and processes your data, please visit: https://www.google.com/policies/privacy/partners/. If you wish to opt-out of Google Analytics, we direct you to Google’s opt-out mechanism at https://tools.google.com/dlpage/gaoptout/.
- Gain Audience Insights. We may provide our commercial customers and partners with information about the effectiveness and reach of advertising campaigns that they have planned or carried out. This information will not identify you directly without your consent. For example, we may tell advertisers how many customers their advertisements can reach based on demographic criteria they select or how many times an advertisement was viewed. To opt-out of having your information used for audience insights, please email email@example.com.
- Detect Ad Blockers. When you visit the Site, we may check (using cookies, code, script or other technical means) to see if you have an ad blocker installed on your device or if your internet browser settings allow advertisements. If we detect that your device or internet browser is using an ad blocker, we may ask you to “whitelist,” trust or pause blocking advertisements while you visit the Site. If you continue to use an ad blocker this may have an impact on the content you are able to see on the Site.
- Allow Third-Party Advertising. In some instances, targeted advertising may be displayed on the Site by third parties. Please be aware that the CP’s advertisers, business partners, sponsors, service providers, vendors and third parties accessible through the Site may have their own privacy practices. CPP is not responsible for any actions or policies of such third parties. You should check the applicable privacy policies of the third parties when providing information to them. These third parties may provide your personal data to CPP and may also use the information in accordance with their own privacy practices.
- Disclose Information as Permitted or Required by Law. Your personal data may be disclosed where we are permitted or required by law to do so, such as pursuant to a court order, warrant, subpoena, or discovery request. We may also disclose your personal data where we are allowed by law in cases where we believe in good faith that it is necessary to prevent a crime, an injury or financial loss to ourselves or to third parties.
- Sale of Our Business or Bankruptcy. In conjunction with the sale or offering for sale of some or all of CPP or in the event of CPP’s bankruptcy, assignment for the benefit of creditors, or similar financial circumstances, your personal data may be part of the assets disclosed.
- Process Payments and Check Your Identity. Customer personal data will be used to take payment for products and services and may be used to verify credit details related to this payment. Permission to do so is implicit in providing financial details to process payment. Direct debit or continuous payment authority information, including card details, may be retained in accordance with our regulatory requirements, by us or our payment processors for ease of renewal of services. Additionally, we may receive updated payment details from your bank or payment provider from time to time, which we may use to ensure that your details are kept up to date and to allow us to take future payments. Financial institutions, such as those which process credit card orders, are subject to federal privacy laws. If we provide a service to you that is dependent on age or residency, and we have an obligation to verify this information, then we may pass your details to a third party to carry out the verification for us.
- Ensure Our Products and Services Conform With Industry Standards. We may share your personal data with auditors for the purposes of verifying that we comply with relevant standards. This may require them to access your information in our systems.
- Share Between Our Affiliates for Analytics, Analysis, Audience Insights, Business Efficiencies, Content Personalization, and Delivery of Relevant Advertising. CPP may rely on our legitimate interests as an advertising-funded organization to share your information with our affiliates to perform analytics and analysis of how you interact with the Site, develop relevant products and services, deliver more relevant advertising and show you relevant affiliate content. To opt-out of sharing your information with such affiliates, please email firstname.lastname@example.org. Please bear in mind that opting-out will relate to any future sharing and not to information already shared.
D. OUR LEGAL BASES FOR USING YOUR PERSONAL DATA
- Legal Bases
There are a number of legal grounds that enable us to collect and use your personal data. Below are the most relevant:
- With Your Consent (“Consent”)
There are some activities where we process personal data with your consent, such as asking permission to send you marketing materials by email. You can opt-out or withdraw consent at any time. However, if you opt-out or withdraw consent, we may not be able to provide the product or service you have requested.
- To Fulfill a Contract (“Contract”)
We may process your personal data in order to fulfill a contract we have with you. For example, we would use your information to provide you with access to your digital subscription or other products you have signed up for or to provide information regarding contests you have entered (such as to notify you if you win a prize to which you are entitled).
- For a legitimate interest (“Legitimate Interest”)
We may use your information where there is a legitimate reason to do so and only if it is fair and lawful. When we rely on legitimate interests as the basis for collecting your information, we will balance our legitimate interests versus your privacy rights.
Our legitimate interests include:
- Support for a free press, including journalist activities of societal importance;
- Support for the right to receive information;
- Development, delivery, and maintenance of relevant and engaging products, services, and advertising;
- Understanding how and when our audience engages and interacts with us and other organizations;
- Improvement of our ability to serve our audience;
- Conducting commercial business; and
- Compliance with industry standards.
- To Comply with Legal Obligations (“Legal Obligation”)
Under certain circumstances, we may process your personal data to ensure compliance with legal and regulatory obligations or to prosecute or defend claims.
- Purpose of Processing
The specific legal basis for our use will depend on the purpose the information is used for. Please note that we may rely on more than one legal basis for our use.
For the purpose of providing products and services that are relevant to you, improving your experience, and managing our relationship with you, our legal bases for our use are Consent, Contract, Legitimate Interest, and Legal Obligation.
For the purpose of personalizing content and offers, our legal bases for our use are Consent, Contract, and Legitimate Interest.
For the purpose of sending you direct marketing, our legal bases for our use are Consent and Legitimate Interest.
For the purpose of sending you product-related and similar product and services communications, our legal bases for our use are Consent, Contract, and Legitimate Interest.
For the purpose of conducting market research and performing analytics, our legal bases for our use are Consent and Legitimate Interest.
For the purpose of gaining audience insights, our legal bases for our use are Consent and Legitimate Interest.
For the purpose of detecting ad blockers, our legal bases for our use are Contract, Legitimate Interest, and Legal Obligation.
For the purpose of allowing third-party advertising, our legal bases for our use are Consent, Contract, and Legitimate Interest.
For the purpose of providing co-branded services and features, our legal bases for our use are Consent, Contract, and Legitimate Interest.
For the purpose of disclosing information as permitted or required by law, our legal bases for our use are Consent, Contract, and Legitimate Interest.
For the purpose of ensuring services are being used appropriately, our legal bases for our use are Legitimate Interest and Legal Obligation.
For the purpose of selling of our business, our legal bases for our use are Legitimate Interest and Legal Obligation.
For the purpose of selling or licensing to third parties for direct marketing, our legal bases for our use are Consent and Legitimate Interest.
For the purpose of processing payments and checking your identity, our legal bases for our use are Consent, Contract, Legitimate Interest, and Legal Obligation.
For the purpose of disclosing to processors, our legal bases for our use are Consent, Contract, Legitimate Interest, and Legal Obligation.
For the purpose of sharing between our affiliates for analytics, analysis, audience insights, business efficiencies, content personalization, and delivery of relevant advertising, our legal bases for our use are Consent and Legitimate Interest.
For the purpose of ensuring our products and services conform with industry standards, our legal basis for our use is Legitimate Interest.
E. ACCESS AND CONTROL YOUR INFORMATION
- Updating Your Information. Please ensure your personal information is current or tell us of any changes or inaccuracies. You may update this information in your account settings or email us at email@example.com. Please note that we may seek confirmation of your identity before making any changes to your account.
- Managing Your Account with the Site. You may change your online account information with CPP at any time by accessing your account through the Login link on the Site. To change the information that you submitted to third party service providers, such as in conjunction with personal ads, classified ads or blogs, please contact the service provider. Their policies will dictate the extent to which you can access or change the information that they have collected about you.
- Email Promotions. For email promotions, in addition to changing your account settings, you may opt out of receiving commercial email messages from us by following the instructions contained in those email messages.
- Confirmation of Your Identity. Please note that we may seek confirmation of your identity before releasing any personal data to you or making changes to your account.
F. OUR COMMITMENT TO SECURITYUp
We have put in place physical, electronic, and managerial procedures that we believe are appropriate to safeguard and help prevent unauthorized access, maintain data security, and correctly use the information we collect online. Please note that we cannot guaranty the security of our databases or Site; nor can we guaranty that information will not be intercepted while being transmitted over the Internet. In order to use some of the features of this Site, you may be required to create an account with us. For your protection, this account will only be accessible by means of a password or similar security measure. If you believe that your password or email address has been compromised, you should change your account with us immediately. If you forget your password, follow the instructions on the login page.
G. EMBEDDED CONTENT AND LINKS TO THIRD-PARTY SITES AND SERVICES
- Collection of Information. This Site is not intended for the use of children under the age of 13, and CPP does not solicit or anticipate correspondence or Site visits from such children. In addition, CPP does not knowingly collect personal data from children under the age of 13. If you are a child under the age of 13 that intends to submit information to CPP through this Site, you must obtain your parent’s consent prior to making such submission. In the event that CPP obtains actual knowledge that you are a child under the age of 13, CPP may require that you (and/or your parent) prove to us your prior parental consent.
I. GDPR COMPLIANCE
- Additional Rights of Users in the EU. If you are an individual in the European Union, you may request a copy of your personal data from CPP and you may have the right to not be profiled. You can also ask us to correct any inaccuracies in your personal data. In some circumstances you may be able to ask us to transfer information you have provided to us to another organization. Similarly, you may be able to transfer your information from another organization to us, but you should check with us first to confirm this is possible. You may also have the right to object, erase, or restrict our processing of your information – for example, where we process personal data because this is in our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data. To exercise any of these rights, please contact us at firstname.lastname@example.org. These rights may be restricted by law, for example we may not be able to provide a copy of your data where the data we hold is also the data of a third party and it is not reasonable to disclose this information. Please note that we may seek confirmation of your identity before releasing any personal data to you or making changes to your account.
J. CALIFORNIA PRIVACY RIGHTS
California residents are entitled once a year, free of charge, to request and obtain certain information regarding our disclosure, if any, of certain categories of personal data to third parties for their direct marketing purposes in the preceding calendar year. California residents who are registered users of the Services and are under the age of 18 are entitled, in accordance with California law, to request and obtain removal of content and information that they themselves post on the Services. You may request such removal by emailing us at email@example.com. In your request, please provide a description of the material that you want removed and information reasonably sufficient to permit us to locate the material, and include your name, email address and/or Services user name, year of birth, mailing address (including city, state, and zip code), and the subject line “California Removal Request” so that we can process your request. Please note that your request does not ensure complete or comprehensive removal of the material. For example, some information that you have posted may be republished or reposted by another user or third party or may be retained for legal reasons.
K. COOKIES AND ONLINE TRACKING
- Cookies. Cookies are small files that are placed on your computer when you visit a website. Cookies may be used to store a unique identification number tied to your computer or device so that you can be recognized as the same user across one or more browsing sessions, and across one or more sites. Cookies serve many useful purposes.
- Cookies can remember your sign-in credentials so you do not have to enter those credentials each time you visit a website.
- Cookies can help us and third parties understand which parts of our Site are the most popular because they help us see which pages and features visitors access and how much time they spend on the pages. By studying this kind of information, we are better able to adapt our Site and provide you with a better experience.
- Cookies help us and third parties understand which ads you have seen so that you don’t receive the same ad each time you access the Site.
Most browsers accept cookies automatically, but can be configured not to do so or to notify the user when a cookie is being sent. If you wish to disable cookies, refer to your browser help menu to learn how to disable cookies. If you disable browser cookies or flash cookies, it may interfere with the proper functioning of the Site.
- Beacons. We, along with third parties, also may use technologies called beacons (or “pixels”) that communicate information from your device to a server. Beacons can be embedded in online content, videos, and emails, and can allow a server to read certain types of information from your device, know when you have viewed particular content or a particular email message, determine the time and date on which you viewed the beacon, and the IP address of your device. We and third parties use beacons for a variety of purposes, including to analyze the use of our Site and (in conjunction with cookies) to provide content and ads that are more relevant to you.
- Local Storage and Other Tracking Technologies. We, along with third parties, may use other kinds of technologies, such as Local Shared Objects (also referred to as “Flash cookies”) and HTML5 local storage, in connection with our Services. We also may use unique identifiers associated with your device, such as mobile ad identifiers. These technologies are similar to the cookies discussed above in that they are stored on your device and can be used to store certain information about your activities and preferences. However, these technologies may make use of different parts of your device from standard cookies, and so you might not be able to control them using standard browser tools and settings. For HTML5 local storage, the method for disabling HTML5 will vary depending on your browser. For Flash cookies, information about disabling or deleting information contained in Flash cookies can be found at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objects-flash.html.
- How to Disable Tracking Technologies. If you wish to disable cookies and other tracking technologies, please refer to your browser’s help menu to learn how to disable them. Information about how to disable Flash cookies is set forth above. Some web browsers may transmit “do-not-track” signals to the websites with which the user communicates. The Services currently do not take action in response to these signals. Please note that disabling cookies and other tracking technologies may interfere with the proper functioning of the Services.
M. TO CONTACT US
To contact us, please see the information set forth on the “Contact Us” page in our website.
For privacy concerns, you may contact our Privacy Operator / Data Protection Officer as follows:
By email: firstname.lastname@example.org
By postal mail: Website Privacy Issues
c/o Privacy Officer
The Charleston City Paper
P.O. Box 21942
Charleston, S.C. 29413
By phone: (843) 577-5304
Copyright © 2021, City Paper Publishing LLC. All rights reserved.