A. PERSONAL DATA
B. COLLECTION OF INFORMATION
1. 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, make a forum submission, email us, send us a text message, purchase something through the Services, or at other times in which we alert you that you must submit personal data.
2. Information from Devices
3. Social Media Login
4. Public Information and Posts
Any personal data that you post or submit to our Site or Services, such as when posting comments in response to stories, submitting photos or videos, or engaging in forums or chat rooms, 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.
5. 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.
6. Advertisers and Other Third Parties
Our Company has a number of vendors. A list of them can be found at this link: https://www.adn.com/privacy_policy#vendors. Our vendors may sometimes share the personal data that they acquire with us when they have consent or there is a legitimate interest in doing so.
8. Other Sources
C. HOW WE USE YOUR PERSONAL DATA
1. 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, either directly or through one of our affiliates or service providers (which is required in order to view some content offered through the Services or to make certain submissions), or use Facebook Connect in conjunction with the Services, 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 online games and 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.
2. Personalize Content and Offers.
3. Send You Direct Marketing.
4. 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.
5. 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 the features and content of the Services. 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/.
6. 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 is aggregated and does not identify individual people. 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.
7. 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.
8. Third-Party Advertising.
9. Provide Co-Branded Services and Features.
10. 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.
11. Ensure Services Are Being Used Appropriately.
12. Sale of Our Business or Bankruptcy.
In conjunction with the sale or offering for sale of some or all of the Company or in the event of the Company's bankruptcy, assignment for the benefit of creditors, or similar financial circumstances, your personal data may be part of the assets disclosed.
13. Sale or License of Personal Data for Targeting Marketing.
14. 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.
15. 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.
16. Share Between Our Vendors for Analytics, Analysis, Audience Insights, Business Efficiencies, Content Personalization, and Delivery of Relevant Advertising.
The Company may rely on our legitimate interests as an advertising-funded organization to share your information with our vendors 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 content. To opt-out of sharing your information with such vendors, please email email@example.com. Please bear in mind that opting-out will relate to any future sharing and not to information already shared. A list of our vendors can be found here: https://www.adn.com/privacy_policy#vendors.
17. Disclosure to Our Processors.
E. OUR LEGAL BASES FOR USING YOUR PERSONAL DATA
1. Legal Bases
There are a number of legal grounds that enable us to collect and use your personal data. Below are the most relevant:
i. 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.
ii. To Fulfill a Contract ("Contract")
We may process your personal data in order to fulfil 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).
iii. 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.
iv. 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.
2. 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.
Purpose of Processing
Provide products and services that are relevant to you, improve your experience, and manage our relationship with you
Share between our affiliates for analytics, analysis, audience insights, business efficiencies, content personalization, and delivery of relevant advertising
Consent, Legitimate Interest
Ensure our products and services conform with industry standards
F. ACCESS AND CONTROL YOUR INFORMATION
1. 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 firstname.lastname@example.org. Please note that we may seek confirmation of your identity before making any changes to your account.
2. Managing Your Accounts with the Site.
You may have several accounts for Services available through this Site. To access or modify your subscription account with the Site, log in at https://subscribe.adn.com/portal/#/activation?returnurl=http%3a%2f%2fwww.adn.com and follow the instructions to change your account settings. For other accounts, such as a newsletter account or classifieds advertisement account, you can manage your account through the account management methodology prescribed by the vendor for that Service or contact us at email@example.com.
3. Opting Out / Withdrawing Consent for Processing.
7. 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.
G. EMBEDDED CONTENT AND LINKS TO THIRD-PARTY SITES AND SERVICES
H. OUR COMMITMENT TO SECURITY
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 guarantee the security of our databases, Site or Services; nor can we guarantee that information will not be intercepted while being transmitted over the Internet. In order to use some of the features of the Services, you may be required to create an account with us. For your protection, this account may 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 for your subscription account with this Site, follow the instructions on the login page at https://subscribe.adn.com/portal/#/activation?returnurl=http%3a%2f%2fwww.adn.com.
1. Collection of Information.
Company does not knowingly collect personal data from children under the age of 13 through the Services unless such collection is done in accordance with the law. If you are a child under the age of 13 that intends to submit information to the Company through the Services, you must obtain your parent's consent prior to making such a submission. In the event that the Company obtains actual knowledge that you are a child under the age of 13, the Company may require that you (and/or your parent) prove to us your prior parental consent. Even if you are 13 or over, we recommend that all children under the age of 18 obtain parental consent prior to the submission or purchase of anything through the Services. To obtain a parental consent form, please contact firstname.lastname@example.org.
2. Parental Options and Review.
J. GDPR COMPLIANCE
K. 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 Site 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.
L. COOKIES AND ONLINE TRACKING
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. For example:
Cookies can remember your sign-in credentials so you do not have to enter those credentials each time you visit a Service
Cookies can help us and third parties understand which parts of our Services 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 Services 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 a Service.
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 Services.
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 Services and (in conjunction with cookies) to provide content and ads that are more relevant to you.
3. 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 here.
4. 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.
N. CONTACT US
For privacy concerns, you may contact our Privacy Operator / Data Protection Officer as follows: