Updated February 2019.
I. IMPORTANT INFORMATION ABOUT WHO WE ARE AND THIS POLICY
Philadelphia Media Network
Information About this Policy
For purposes of this Policy, Personal Information is information about a specific individual including name, address, telephone number, and email address-- when used to identify that individual. Certain information that is not Personal Information (such as an address) can be Personal Information when it is linked to other information about you. For detailed information about the kinds of Personal Information that we gather about you through our Digital Properties, please refer to Section II, below. Certain third parties collect information about you on our site for the purpose of delivering to you, and helping us to deliver to you, advertising that reflects your interests. For information about the third parties that collect data on our site for purposes of Targeted Advertising, visit https://adssettings.google.com/authenticated.
Third party links and applications.
CHILDREN’S ONLINE PRIVACY PROTECTION NOTICE
Our Digital Properties and Services are not designed or intended for children under the age of 13. In accordance with the Children’s Online Privacy Protection Act, we do not knowingly collect or store any Personal Information for children under the age of 13. If you are under 13, please do not provide us any Personal Information
II. WHAT CATEGORIES OF PERSONAL INFORMATION DO WE GATHER ABOUT YOU?
When you use our Services, we may collect, use, store and transfer different kinds of Personal Information about you, including, but not limited to, the following types of Personal Information:
Personal Information you provide to us when you use our Services, such as:
- Identity Data - (for example, your first name, maiden name, last name, username or similar identifier, birth year, gender, marital status, title, or other basic demographic information);
- Contact Data - (for example, your billing address, delivery address, email address and telephone numbers);
- Financial Data - (for example your bank account and payment card details);
- Transaction Data - (for example, details about payments to and from you and other details of Services you have purchased from us);
- Mobile Device Location Data (for example, if you use our mobile applications and permit certain precise location settings and permissions, you consent to providing us with access to your precise geolocation information—such as information based on your GPS coordinates—so that we can deliver customized content or advertising to you based on your current location. You may withdraw this consent at any time by turning off those same settings and permissions in your app and mobile device, but such withdrawal will not affect the lawfulness of processing the previously collected information);
- Usage Data - (for example, information about how you use our Digital Properties and Services, including, for example, if you contact Philadelphia Media Network, we may log information about the means through which you contacted us and our interaction with you);
- Profile Data - (for example, your username and password, purchases or orders made by you, your interests, preferences, feedback and survey responses);
- Marketing and Communications Data - (for example, your preferences in receiving marketing from us and our third parties, if any, and your communication preferences);
- Technical Data (for example, your internet protocol (IP) address, internet service provider (ISP), your login data, browser type and version, browser language, referring/exit pages, operating system, date/time stamp, clickstream data, time zone setting and basic geolocation, device type, unique device identifiers, browser plug-in types and versions, operating system and platform and other technology on the devices you use to access our Services and Digital Properties).
We do not collect sensitive personal information, such as information about your political views, religious affiliation or gender orientation.
III. HOW IS YOUR PERSONAL INFORMATION RECEIVED, COLLECTED, AND USED?
We may collect, receive, and use your Personal Information in different situations and for different purposes, including:
To Provide Services. We may collect your Personal Information, third parties, online, offline or public resources in order to process your order and provide Services, including in order to maintain, support, personalize, and improve our Services (including our Services and Digital Properties), deliver and provide the requested Services, communicate with you about those Services (including to request feedback) or request your participation in surveys, discuss your account or renew your subscription, and comply with and enforce contractual obligations. In order to process your orders and payments and manage your payment methods, it may be necessary for us to share your Personal Information, including your Financial Information, with certain third-party service providers. We may also combine that Personal Information and/or allow our third-party service providers to combine that information with other information we have collected from you, third parties, or public sources for legitimate business purposes.
To Provide Relevant Information about our Services.
When you sign up to receive any of our Services, we may collect and use your Personal Information in order to provide you with information about our Services and your account with us. For example, we may use your Personal Information to provide you with information about:
- - our Services, individually or in combination;
- - changes to our Services, including but not limited to the addition of Services;
- - features, benefits and aspects of our Services that may be of interest to you;
- - news stories;
- - upcoming events;
- - your account with us;
- - content and publications that may be of interest to you;
- - information about enhancements to our Services;
- - information about our parent companies, including The Lenfest Institute, and promotions for its efforts;
- - your participation as a contributor to our Services, whether through comments, contributions or other means;
- - other information related to our Services, your account and/or your relationship with us; and
- - other similar information.
We may share your information between Philadelphia Media Network and affiliates for these purposes, we may also share your Personal Information with third party service providers to facilitate these communications on our behalf and at our direction. We may also obtain information about you from other companies that have your permission to share that information, as well as from other online and offline sources, which we may then combine with information that we collect directly and indirectly from you, for these purposes.
We share Financial Data only for purposes of processing payments from you, updating payment card information, having third parties process payments from you on our behalf, complying with government and legal requests, for the purposes of financial auditing, in response to certain emergencies, and in certain other business transactions and other matters in which Philadelphia Media Network has a legitimate interest in sharing that information.
To Deliver Targeted Marketing from The Philadelphia Inquirer, the Philadelphia Daily News and philly.com and our Partners.
When you sign up to use our Services, we may collect and use your Personal Information to communicate with you about products and services that may be of interest to you, and which may be provided by us, or by our advertisers, partners, third party marketing partners, or other third parties. Some of those messages are sent to directly market products or services to you. You can manage those communications by:
- - opting out of those communications when you subscribe;
- - using the unsubscribe link in the applicable e-mail;
- - emailing us at DigitalSupport@philly.com; or
- - calling us at: 215-854-4171
To Support our Relationship with You.
Subscribers to The Philadelphia Inquirer, the Philadelphia Daily News or philly.com receive certain newsletters and other communications as part of our product offerings and as part of the management of their subscriptions. Subscribers may opt out of specific categories of newsletters by using the unsubscribe link in the applicable e-mail. Please note that some of our advertising and third-party advertising is contained within newsletters that contain editorial content. If you would like to avoid this advertising, you must opt out of the newsletter.
If you opt out of direct marketing communications, please note that we will need to maintain in our records and process your Personal Information to the extent it is needed to maintain a suppression list. Also, if you are a subscriber to our products or services, you will continue to receive information and communications pertaining to your account with us and/or services we that we offer, even where you have opted out of direct marketing communications, so you can continue to receive newsletters and other communications that are part of our product offerings and so we can communicate with you about your account.
To Respond to Inquiries made by you.
We may collect your Personal Information when you contact us for information or support for our Digital Properties, Services, and/or other information, in order to respond and provide the appropriate assistance and response and use that information for the purpose of providing you with tailored customer service and to improve our customer service.
To Deliver Targeted Advertising. We may collect and use your Personal Information to delivering targeted advertising to you. We also allow third parties who deliver targeted advertising on our site to collect information about you through our Digital Properties. Cookies are used to help target advertising to you. You can learn more about certain types of targeted advertising by visiting the following websites Digital Advertising Alliance, Network Advertising Initiative or the Interactive Advertising Bureau (iab), and can disable cookies on AdChoices. In addition to disabling cookies and other tracking technologies, you may opt-out of receiving targeted advertising from participating ad networks, audience segment providers, ad serving vendors, and other service providers by visiting websites operated by the Digital Advertising Alliance. For more information about cookies, visit https://www.google.com/settings/ads/onweb.
The collection of data through interactive advertising on our site is subject to certain industry self-regulating guidelines. Philadelphia Media Network is a member of the Interactive Advertising Bureau (the “iab”) and conducts its online behavioral advertising (which is sometimes referred to as targeted advertising) in accordance with the industry self-regulating guidelines, including the iab Code of Conduct, Digital Advertising Alliance Self Regulatory Principles and the Code of the Network Advertising Initiative, to the extent the Code applies to online publishers.
To Provide You with Content that Reflects your Interests. We may collect and use your Personal Information to provide you with easier access to news and information that reflects your interests, and content in which you have previously viewed.
To Facilitate the processing of Classified Advertising Purchased by You. We may collect Personal Information from you, for example your Contact and Financial Data, when processing your purchase of a classified ad.
To Facilitate the processing of Contest Entries, the Award of Prizes, Tickets to Events and Similar Activities. We may need to collect Personal Information when you choose to participate in a promotion, sweepstakes, contest, prize draw, other competition or when you choose to attend, or purchase tickets for an event that we organize and/or sponsor. The information we collect will be needed to administer such promotions as well as communicate with you about the same. For example, we may need to collect your name, age, birth year, contact information, and other Personal Information to comply with the rules and legal requirements governing the promotion and to verify participants and the winner’s identity. We may also share this information with third parties who sponsor, organize or contribute products or services to those promotions, or from whom we purchase prizes for certain promotions (such as airline tickets, hotel accommodations, etc.) for fulfillment and promotional purposes, and with the Internal Revenue Service and other government agencies for tax reporting purposes, and for the other purposes described in this policy.
To Survey, Obtain Feedback, Seek Testimonials, and to Engage our Readers through Comments and Contributions. We may collect your Personal Information when you choose to engage with us in a consumer panel, survey, or otherwise give us feedback. Also, we may use reader testimonials, contributions and/or exemplars in or on our Digital Properties, publications, or other Philadelphia Media Network marketing materials, which may require the inclusion of Personal Information, such as your name, photograph, user name or other similar information. For more information about our commenting platform and contributions you submit for publication through our Digital Properties, click here:
To Monitor Digital Properties Usage, Trends, and Experience. As is true with most websites and digital properties, when you interact with our digital properties, or by email, we may automatically collect, or facilitate the collection of, Personal Information on your interactions with us and our Digital Properties and about your equipment. For example, we may collect Personal Information by using first and third-party cookies, Flash cookies, HTML5 local storage, server logs, web beacons, clear gifs, and other similar technologies. We use these automated technologies and the Personal Information collected through them for different purposes. For example, some of these technologies are strictly necessary for the core functionality of our Digital Properties and providing our Services, including performance analytics, personalization, and in order to provide secure Digital Properties and Services, and are automatically deployed. For certain Digital Properties, we may tailor your interactions with our Digital Properties when you are logged in using your user account by remembering information you entered on our websites or to provide information you requested on our Digital Properties, including subscriber content access. These cookies also help us know where you have indicated certain cookie and advertising preferences, including refusals, to ensure your preferences are honored.
We also use functional cookies and technologies to help us improve our Digital Properties and Services, as well as our relationships with our readers and their experiences on our Digital Properties. For example, we may use third party applications and automated technologies, like Google Analytics and Parse.ly, to determine how often our readers access or read our content, so we can enhance our Services, provide the most interesting content, and gain readership.
You can manage the use of certain cookies on our site at https://www.google.com/settings/ads/onweb. The data collected by that technology may be used to target ads at other websites and may be transferred to third parties.
We also obtain Personal Information about You from Third Parties.For example, we may obtain Personal Information about you from various third parties, and use it for various purposes related to our business and to improving the Products and Services that we provide to you, including:
Vendors, Consultants, and other Service Providers. We may receive your Personal Information from various third parties and public sources in connection with the operation of our business and the Services we provide you, including for the functionality and security of our Digital Properties and other products and services Philadelphia Media Network products and/or services, to satisfy legal obligations or enforce legal rights, to enhance and otherwise improve our Digital Properties, Services and content, and to provide you with enhanced experiences. These third parties and public sources could include: our business partners, subcontractors in technical, payment, and delivery services, advertising networks, analytics providers, marketing partners, search information providers, social media platforms, or credit reference agencies.
Marketing Research/Statistics. We may collect your Personal Information directly or through our third-party marketing partners (“Marketing Partners”) as necessary to help us and our Marketing Partners research and develop new products, services, updates, generate business or the like on our behalf. For example, we may analyze statistical, demographic, and marketing information for product development purposes and to understand usage and traffic trends to grow our readership and to improve our relationship with you. In some cases, those third parties are also granted the right to use that data on an anonymized and aggregated basis to help improve their products and services. We may also obtain certain data about you from third party sources including our Marketing Partners or other vendors, consultants and Service Providers to help us provide and improve our content, products, services, websites and digital properties, as well as for marketing and advertising. We may combine that data with information we obtain from our products, services and digital properties, other users, or third parties to enhance your experience and improve our content, products and services.
Marketing and Advertisers. We may collect your Personal Information and share that information with third party advertisers or sponsors in order to support and grow our business and journalism as well as bring you relevant content, information, and advertisements. For example, your Personal Information may be used to inform advertisers about the nature of our subscriber base and the number of unique visitors that have viewed a particular ad or visited a particular webpage. We may also use your Personal Information to publish summary information regarding, for example, our publications’ readers or online visitors for promotional purposes and as a representative audience for advertisers, sponsors, and affiliates.
User Experience and Advertisements. Your Personal Information may also be collected by us or by third parties with services or advertisements on our Digital Properties in order to customize your interactions and provide a more meaningful advertisement experience (for example, so you do not see the same advertisement repeatedly). Depending upon your settings, cookies may also allow third parties engaged in interest-based advertising on our site to recognize your browser software on other sites, as well. Your consent for this collection and use may be managed in a variety of ways at the operating system level of your device or equipment, through third-party platform extensions. If you do not accept cookies from these third parties, your access to our Products will not be affected, but your experience with our Products may be affected.
When we provide you geographically relevant Services, offers, or advertising. With your consent, which may be provided when you enable certain features on your mobile or electronic device, we may collect your Mobile Device Location Data, and use such data to provide you with content, Services, offers, or advertising through your app or device that are relevant to your precise location. We may also use such information to improve our Digital Properties, content, and Services. This precise location data will be stored on your mobile device. You may have the right to withdraw your consent at any time by changing the settings on your app but such withdrawal will have no impact on the lawfulness of the prior processing. Please note some features and functions may not work properly if location services is/are disabled.
Events. We may collect or receive your Personal Information when you register for or attend an event hosted or sponsored by us. If the event is in partnership with a third party, that information may be gathered by the third party, and shared with us. If we gather that information from you directly, we may share your Personal Information with that interested party, for example so they have an attendance list, or if they need to contact you with event details. We will not share your information with them for their marketing purposes without your consent, which may be obtained at the time of your registration or through a supplemental privacy notice, but will not be required in order to attend.
Creating a Public Profile. We may collect your Personal Information, such as content ID, and profile data, when you create a “Public Profile” or when you provide information in order to comment on any of our Digital Properties. If you create a public profile with us to comment on articles or share content on our forums or discussion groups, the information that you share becomes public.
Publicly available Sources. We may also obtain information about you from other companies that have your permission to share information about you, as well as from other online and offline sources. We may combine that information with information that we collect directly and indirectly from you.
We use the Personal Information for various purposes, including:
Government Reporting/Audit/Requests Requirements. We may use or share Personal Information in order to satisfy governmental reporting, tax, and other requirements (e.g., import/export), as required by law. This may include having to meet U.S. national security or law enforcement, regulatory, or self- regulatory requirements.
To verify and/or authenticate an identity, access rights, privileges, etc. For example, we may use Personal Information to authenticate and permit online access to subscriber and/or user account information. We may also obtain information about you from other companies that have your permission to share information about you, as well as from other online and offline sources. We may combine that information with information that we collect directly and indirectly from you.
At your Direction. In certain circumstances, we may collect and use your Personal Information at your direction or as otherwise needed to fulfill the purposes for which you provided the Personal Information or that were distributed when it was collected.
Other Business-Related Purposes. For other business-related purposes permitted or required under applicable local law and regulation or to enforce our agreements, policies, and terms of service.
As otherwise obligated by law. For example, subpoena or similar legal process compliance, if we have a good faith belief the disclosure is legally necessary for the protection of rights, safety, or fraud investigations, to protect Philadelphia Media Network, you, our readers and subscribers, or the public from harm or illegal activities.
Emergency. To respond to an emergency which we believe in good faith requires us to assist in preventing the death or serious bodily injury of any person.
Consent. If we otherwise notify you and you consent to the sharing.
Other Information about the Personal Information that You Share with Us and How We Use It.
Third Party Personal Information.
Change of purpose.
IV. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?
- Philadelphia Media Network Entities. Your Personal Information may be shared among Philadelphia Media Network entities to provide our Services and to better understand our business, analyze our operations, improve the Services, and to develop new Services to support our business and journalism goals. In addition, we share Personal Information to provide readers with information on the Services that we think are most relevant to them and to enable us to measure the success of our marketing activities.
- Service Providers and Vendors. We contract with service providers to help us with credit card and bill processing, shipping, email distribution, list processing, analytics and promotions management, and ad serving. We provide service providers only with the information they need to perform their services. We prohibit them from sharing, reselling, or using your Personal Information for their own direct marketing purposes. For example, if you subscribe to the print edition of The Philadelphia Inquirer or the Philadelphia Daily News or are a registered user of philly.com, we may share your email address with service providers necessary to send you emails (including newsletters) on our behalf. That service provider may not share your email address or Personal Information with any third parties, and may only send you emails on behalf of Philadelphia Media Network. Other service providers may help us with delivering or shipping to you our print newspapers and publications, or other products you may order, and to ensure fulfillment of your orders and purchases. Another we may share, or facilitate the sharing of, your Personal Information is with third party retail or payment processing platforms or vendors in order to process and confirm payment. Or, we may share your Personal Information with third party customer service providers and vendors that allow us to assist in answering consumer inquiries and complaints and address our readers’ technical issues, as well as to receive and collect reader feedback on our Services, etc. As described in Section III, we may also engage service providers to collect and analyze information about our readers’ use of our Digital Properties in order for us to improve our Services and grow our business.
- Social Media Platforms. We may use widgets and tools from third party social media platforms on our Digital Properties to enable sharing and other functions through social media platforms, which facilitates the collection and sharing of your Personal Information by these social media platforms.
- Promotions, Contests, Surveys, and Events. We may facilitate the collection of, or share your Personal Information with, third party service providers, vendors, co-hosts, co-sponsors, or the like when we conduct, administer, host, or co-sponsor promotions, contests, surveys, or events.
- Marketing and Advertising Partners. We share personal data with third parties for marketing and advertising, such as Google and Facebook, so they can assist us in promoting our Services on and off our Digital Properties to current and future readers and subscribers through targeted advertisements.
- Third Party Advertisers. We may share your Personal Information with third party advertisers. Generally, we will only share aggregated statistical, demographic and marketing analyses of readers and their browsing and purchasing patterns to inform advertisers about the nature of our reader base, which does not contain Personal Information.
- With other third parties, as required for legal compliance, law enforcement, public safety, or security purposes. For example, we may disclose your Personal Information if we have a good faith belief that disclosure is necessary to comply with the law or with legal process, such as to comply with a subpoena, protect and defend our rights and property, to protect against misuse or unauthorized use of our websites, or to protect the personal safety or property of our users or the public. For example, we may release Personal Information to comply with a court order or subpoena. Or, if you provide false information or attempt to pose as someone else, we may release Personal Information as part of any investigation into your actions.
We allow certain third parties to collect data from our site, including Personal Information, and to aggregate and to anonymize that data so it cannot identify you, and to use it for various purposes, including, but not limited to providing us with services and improving the services they provide to us and to third parties.
V. CALIFORNIA PRIVACY RIGHTS NOTICE
If you are a California resident, you have the right, under California Civil Code Section 1798.83, to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed Personal Information for their direct marketing purposes in the prior calendar year. Please email requests for such information to _Dataprivacy@inquirer.com_.
VI. Certain Understandings about the GDPR.
As a publisher of local news and information about Philadelphia, Pennsylvania, we do not target any of our Services to users in, or residents of the European Union, United Kingdom, Switzerland or other jurisdictions that have adopted the General Data Protection Regulation (collectively, “GDPR countries”). Similarly, we do not monitor the behavior of users of our Services, including our Digital Properties in any GDPR countries. Our Services are published in American English and can only be purchased in U.S. Dollars. In the event that any of our third-party service providers gather information such as IP address or location data on our behalf, that information is used only to make sure that we are not monitoring users in the GDPR Countries, or targeting any advertising or content to them. If you have any questions about how the GDPR relates to our business, please reach out to us by sending us an email at: DataPrivacy@inquirer.com
VII. DATA INTEGRITY AND SECURITY
VIII. MINIMIZATION, RETENTION, AND DELETION OF PERSONAL INFORMATION
We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including, for example, for so long as we provide you with Services, and for the purposes of satisfying any legal (including but not limited to enforcement of agreements or resolving disputes), accounting, or reporting requirements.
To determine the appropriate retention period for Personal Information, we consider the amount, nature, and sensitivity of the Personal Information, the potential risk of harm from unauthorized use or disclosure of your Personal Information, the purposes for which we process your Personal Information and whether we can achieve those purposes through other means, and the applicable legal requirements. If you wish to cancel your account or request that we no longer use your information to provide you with Services, contact DigitalSupport@philly.com.
In some circumstance. Even after we no longer retain your Personal Information, we may anonymize your Personal Information (so that it can no longer be associated with you) for research, statistical or other purposes in which case we may retain and use that information indefinitely without further notice to you.
IX. ACCEPTANCE AND CHANGES TO THIS POLICY
X. WHO SHOULD YOU CONTACT IF YOU HAVE QUESTIONS?
Philadelphia Media Network
801 Market Street
Philadelphia, PA 19107
Attn: Data Privacy Requests
Updates to Personal Information: If you would like to update the Personal Information that we have about you, or if you no longer desire our services, you can contact our privacy manager at the above contact information. If you are a subscriber, you can update your Personal Information by calling Customer Service at:1-800-222-2765 or by accessing your subscription account online at www.philly.com/myaccount.
Unsubscribe Requests: If you would like to contact us about unsubscribing from any of our email lists, you can do by clicking the link to “unsubscribe” at the bottom of any email from us or by emailing DigitalSupport@philly.com, and providing all of your email addresses that could appear on our email lists, as well as the name of the newsletter from which you would like to unsubscribe.
Thank you for your interest in Philadelphia Media Network.
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