Last Updated: May 23, 2018
Transparency/Notice – Types of Personal Information We Collect. The types of Personal Information we may collect (directly from you or from Third-Party sources) and our privacy practices depend on the nature of the relationship you have with us and the requirements of applicable law. Some of the ways that we may collect Personal Information include:
You may provide Personal Information directly to News Deeply through interacting with the Services, participating in surveys, during events such as sweepstakes, and requesting Services, or information.
As you navigate the Services, certain passive information may also be collected about your visit, including through Cookies and similar technologies as described below.
We endeavor to collect only that information which is relevant for the purposes of Processing. Below are the ways we collect Personal Information and how we use it.
Information Collected or Received from You. Our primary goals in collecting information are to provide and improve our Services, to administer your use of the Services (including your Account, if you are an Account holder), and to enable you to enjoy and easily navigate our Services.
News Deeply collects Personal Information regarding its current, prospective, and former customers, Users (defined in subsection (b) below), visitors, guests, and Employees (collectively “Individuals”).
(a) Account Information. If you create an Account, we’ll collect certain Personal Information that can be used to identify you, such as your name, email address, postal address, phone number and a profile picture. If you create an Account using your login credentials from one of your social networking services accounts (“SNS Accounts”), we’ll be able to access and collect your name and email address and other Personal Information that your privacy settings on the SNS Account permit us to access. If you create an Account through the Site or one of your SNS Accounts, we may also collect your gender, job title, date of birth and other information that may not be Personal Information. Additionally, you may have the option of providing certain other information such as links to content you have created, outside websites, and your own publications.
(b) Information Collected Using Cookies and other Web Technologies. Like many website owners and operators, we use automated data collection tools such as Cookies, Web Beacons, Log Data, and Social Media Widgets (collectively “Web Technologies”) to collect certain information.
“Web Beacons” (also known as web bugs, pixel tags or clear GIFs) are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, to monitor how many visitors view our Services, and to monitor the effectiveness of our advertising. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages (or in an e-mail).
“Log Data” means certain information about how a person uses our Services, including both Account holders and non-Account holders (either, a “User”). Log Data may include information such as a User’s Internet Protocol (IP) address, browser type, operating system, MAC address, IMEI, other device identifiers the web page that a User was visiting before accessing our Services, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a User clicked on and other statistics. We use Log Data to administer the Services and we analyze (and may engage Third-Parties to analyze) Log Data to improve, customize and enhance our Services by expanding their features and functionality and tailoring them to our Users’ needs and preferences. We may use a person’s IP address to generate aggregate, non-identifying information about how our Services are used.
We use Web Technologies generally for the following purposes:
- Performance Related We may use Web Technologies to assess the performance of our Sites, applications, Services, and tools, including as part of our analytic practices to help us understand how our visitors use our Sites, determine if you have interacted with our messaging, determine whether you have viewed an item or link, or to improve our Site content, applications, Services, or tools;
- Functionality Related. We may use Web Technologies that allow us to offer you enhanced functionality when accessing or using our Sites, Services, applications, or tools. This may include identifying you when you sign into our Sites or keeping track of your specified preferences, interests, or past items viewed so that we may enhance the presentation of content on our Sites;
- Advertising or Targeting Related. We may use first-party or Third-Party Cookies and Web Beacons to deliver content, including ads relevant to your interests, on our sites or on Third-Party sites and to track incoming traffic from paid external campaigns. This includes using technologies to understand the usefulness to you of the advertisements and content that has been delivered to you, such as whether you have clicked on an advertisement.
(c) Information Sent by Your Mobile Device. We collect certain information that your mobile device sends when you use our Services, like a device identifier, MAC address, IMEI, user settings and the operating system of your device, as well as information about your use of our Services.
(d) Location Information. We may collect and store information about your location by converting your IP address into a rough geo-location. We may use location information to improve and personalize our Services for you.
(e) Information Submitted Via Services. You agree that News Deeply is free to use the content of any communications submitted by you via the Services, including any ideas, inventions, concepts, techniques, or know-how disclosed therein, for any purpose including developing, manufacturing, and/or marketing goods or Services. News Deeply will not release your name or otherwise publicize the fact that you submitted materials or other information to us unless: (a) you grant us permission to do so; (b) we first send notice to you that the materials or other information you submit to a particular part of a Service will be published or otherwise used with your name on it; or (c) we are required to do so by law.
(f) Information From Other Sources. We may receive information about you from other sources, including through Third-Party services and organizations to supplement information provided by you. For example, if you access our Services through a Third-Party application, such as an App Store or SNS, we may collect information about you from that Third-Party application that you have made public via your privacy settings. Information we collect through App Stores or SNS accounts may include your name, your SNS user identification number, your SNS user name, location, sex, birth date, email, profile picture, and your contacts on the SNS. This supplemental information allows us to verify information that you have provided to News Deeply and to enhance our ability to provide you with information about our business, products, and Services.
Human Resources Data. News Deeply collects Personal Information from current, prospective, and former Employees, their contact points in case of a medical emergency, and beneficiaries under any insurance policy (“Human Resources Data”). The Human Resources Data we collect may include title, name, address, phone number, email address, date of birth, passport number, driver’s license number, Social Security number or other government-issued identification number, financial information related to credit checks, bank details for payroll, information that may be recorded on a CV or application form, language abilities, contact information of third parties in case of an emergency and beneficiaries under any insurance policy. We may also collect Sensitive Human Resources Data such as details of health and disability, including mental health, medical leave, and maternity leave; information about national origin or immigration status; and optional demographic information such as race, which helps us achieve our diversity goals.
We acquire, hold, use and Process Human Resources Data for a variety of business purposes including:
- Workflow management, including assigning, managing and administering projects;
- Human Resources administration and communication;
- Payroll and the provision of benefits;
- Compensation, including bonuses and long-term incentive administration, stock plan administration, compensation analysis, including monitoring overtime and compliance with labor laws, and company recognition programs;
- Job grading activities;
- Performance and employee development management;
- Organizational development and succession planning;
- Benefits and personnel administration;
- Absence management;
- Helpdesk and IT support services;
- Regulatory compliance;
- Internal and/or external or governmental compliance investigations;
- Internal or external audits;
- Litigation evaluation, prosecution, and defense;
- Diversity and inclusion initiatives;
- Restructuring and relocation;
- Emergency contacts and services;
- Employee safety;
- Compliance with statutory requirements;
- Processing of Employee expenses and travel charges; and
- Acquisitions, divestitures, and integrations.
Reasons We Use Your Data. We acquire, hold, use and process your Personal Information for a variety of business purposes, including:
(a) To Provide products, Services, or Information Requested. This includes:
- Generally managing your information and Account
- Responding to questions, comments, and other requests
- Providing access to certain areas, functionalities, and features of the Services
- Contacting you to answer customer support or technical questions
- Allowing you to register for events and participate in certain event-specific conversations made available through the Services.
- Allowing you to opt in to receive updates and messages from News Deeply staff and other news deeply Account holders
- Allowing you to display information about your professional background on News Deeply sites
- Following the activity of certain authors or members of the News Deeply community, and opting-in to allow members of the News Deeply community to follow your activity
- Allowing you to recommend articles to other News Deeply community members
- Allowing us to personalize your experience of the News Deeply platform.
(b) Administrative Purposes. We may use Personal Information for administrative purposes, including to:
- Measure interest in our Services
- Develop new products and services
- Ensure internal quality control
- Verify individual identity
- Communicate any changes to our policies
- Send you emails to help verify your Account and for other maintenance and customer service reasons
- Process payments for our Services (as applicable)
- Prevent potentially prohibited or illegal activities
- Enforce our Terms.
(c) Marketing. We may use Personal Information to provide you with materials about offers, products, and Services that may be of interest, including new content or Services (via email). Such uses include:
- To tailor content, advertisements, and offers;
- To notify you about offers, products, and services that may be of interest to you;
- To provide Services to you and our sponsors;
- For other purposes disclosed at the time that Individuals provide Personal Information; or
- Otherwise with your consent.
(d) Research and Development. News Deeply may use Personal Information to create non-identifiable information that we may use alone or in the aggregate with information obtained from other sources, in order to help us to optimally deliver our existing products and Services or develop new products and Services. From time to time, we may perform research (online and offline) via surveys. We may engage Third-Party service providers to conduct such surveys on our behalf. All survey responses are voluntary, and the information collected will be used for research and reporting purposes to help us better serve Individuals by learning more about their needs and the quality of the products and services we provide. The survey responses may be utilized to determine the effectiveness of our Services, various types of communications, advertising campaigns, and/or promotional activities. If an Individual participates in a survey, the information given will be used along with that of other study participants. We may share anonymous Individual and aggregate data for research and analysis purposes.
(e) Other Uses. News Deeply may use Personal Information for which we have a legitimate interest, such as direct marketing, individual or market research, anti-fraud protection, or any other purpose disclosed to you at the time you provide Personal Information or with your consent.
(f) Direct Mail, Email and Outbound Telemarketing. Individuals who provide us with Personal Information, or whose Personal Information we obtain from Third Parties, may receive periodic emails, newsletters, mailings, or phone calls from us with information on our or our business partners’ products and services or upcoming special offers/events we believe may be of interest. We offer the option to decline these communications at no cost to the Individual by following the instructions in Section 7 below.
(g) Anonymized and Aggregated Information Use. News Deeply may use Personal Information and other information about you to create anonymized and aggregated information, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access our Services, or other analyses we create. Anonymized and aggregated information is used for a variety of functions, including the measurement of visitors’ interest in and use of various portions or features of the Services. Anonymized or aggregated information is not Personal Information, and we may use such information in a number of ways, including research, internal analysis, analytics, and any other legally permissible purposes. We may share this information within News Deeply and with Third Parties for our or their purposes in an anonymized or aggregated form that is designed to prevent anyone from identifying you.
Information that We Share with Third Parties. We will not share any Personal Information that we have collected from or regarding you except as described below:
(a) Information Shared with Other Users for Certain Events. We may create event-specific forums for, for example, those that attended to continue communicating with each other after the event has ended or for posting certain questions in advance of a conference call. When you opt in to such forums, your full name and profile picture will be visible to others in that particular forum to enable users to recognize each other from the event.
(b) Information Shared with Our Services Providers. We may engage Third-Party services providers to work with us to administer and provide the Services. These Third-Party services providers have access to your Personal Information only for the purpose of performing services on our behalf and, in the case of payment processors, human resources software providers, email subscription services, messaging services, feedback and survey services, data analysis services, and publishing software providers, are expressly obligated not to disclose or use your Personal Information for any other purpose. We may share your Personal Information and any necessary payment information, such as credit card number, expiration date and billing address, with our payment processing services providers in order to complete transactions that are initiated through the Services.
(c) Information Shared with other Third Parties. We may share anonymized or aggregated data we collect from the use of the Services, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, market trends and other analysis that we create based on the information we receive from you and other Users.
(d) Information Shared with Web Analytics Services Providers. We use a number of web analytics service providers to gather information about how our Users interact with our Services.
Google. We use Google Analytics, a service provided by Google, Inc. (“Google”), to gather information about how users engage with our Site and Services. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google’s collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Intercom. We use Intercom (www.intercom.com) to facilitate communications with, maintain information about, and collect publicly available information about, our customers and users. For more information on Intercom’s services, please visit www.intercom.com.
(e) Information Disclosed in Connection with Business Transactions. Information that we collect from our Users, including Personal Information, is considered to be a business asset. Thus, if we are acquired by a Third-Party as a result of a transaction such as a merger, acquisition or asset sale or if our assets are acquired by a Third-Party in the event we go out of business or enter bankruptcy, some or all of our assets, including your Personal Information, may be disclosed or transferred to a Third-Party acquirer in connection with the transaction.
(f) Information Disclosed for Our Protection and the Protection of Others. We cooperate with government and law enforcement officials or private parties to enforce and comply with the law. We may disclose any information about you to government or law enforcement officials or private parties as we, in our sole discretion, believe necessary or appropriate: (i) to respond to claims, legal process (including subpoenas); (ii) to protect our property, rights and safety and the property, rights and safety of a Third-Party or the public in general; and (iii) to stop any activity that we consider illegal, unethical or legally actionable activity.
Your Choices. We offer you choices regarding the collection, use and sharing of your Personal Information and we’ll respect the choices you make. Please note that if you decide not to provide us with the Personal Information that we request, you may not be able to access all of the features of the Services.
(b) Modifying Your Information. You can access and modify the Personal Information associated with your Account by editing such information in the profile page. If you want us to delete your Personal Information and your Account, please contact us at email@example.com with your request. We’ll take steps to delete your information, but some information may remain in archived/backup copies for our records or as otherwise required by law.
(c) Human Resources Data. With regard to Personal Information that News Deeply receives in connection with the employment relationship, we will use such Personal Information only for employment-related purposes as more fully described above. If News Deeply intends to use this Personal Information for any other purpose, we will notify the Individual and provide an opportunity to opt-out of such uses.
(d) Cookies and Interest-Based Advertising. As noted above, you may stop or restrict the placement of Cookies on your computer or remove them from your browser by adjusting your web browser preferences. Please note that Cookie-based opt-outs are not effective on mobile applications. However, on many mobile devices, application users may opt out of certain mobile ads via their device settings.
The online advertising industry also provides websites from which you may opt-out of receiving targeted ads from our data partners and our other advertising partners that participate in self-regulatory programs. You can access these, and also learn more about targeted advertising and consumer choice and privacy, at www.networkadvertising.org/managing/opt_out.asp, or http://www.youronlinechoices.eu/ and www.aboutads.info/choices/. You can also choose not to be included in Google Analytics here.
(e) Limitations Although we make good faith efforts to provide you with access to your Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to your privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Although News Deeply makes good faith efforts to provide Individuals with access to their Personal Information, there may be circumstances in which we are unable to provide access, including but not limited to: where the information contains legal privilege, would compromise others’ privacy or other legitimate rights, where the burden or expense of providing access would be disproportionate to the risks to the Individual’s privacy in the case in question or where it is commercially proprietary. If we determine that access should be restricted in any particular instance, we will provide you with an explanation of why that determination has been made and a contact point for any further inquiries. To protect your privacy, we will take commercially reasonable steps to verify your identity before granting access to or making any changes to your Personal Information.
Responding to Do Not Track Signals. Our Site does not have the capability to respond to “Do Not Track” signals received from various web browsers.
The Security of Your Information. We take reasonable administrative, physical and electronic measures designed to protect the information that we collect from or about you (including your Personal Information) from unauthorized access, use or disclosure. When you enter sensitive information on our forms, we encrypt this data using SSL or other technologies. Please be aware, however, that no method of transmitting information over the Internet or storing information is completely secure. Accordingly, we cannot guarantee the absolute security of any information. We may contact you via email or through the functionality of the Services regarding security, privacy, and administrative issues relating to your use of the Services. If we learn of a security system’s breach, we may attempt to notify you electronically by posting a notice on the Site or sending an e-mail to you. You may have a legal right to receive this notice in writing.
International Transfer Your Personal Information may be transferred to, and maintained on, computers located outside of your state, province, country or other governmental jurisdiction where the privacy laws may not be as protective as those in your jurisdiction. If you’re located outside the United States and choose to provide your Personal Information to us, we may transfer your Personal Information to the United States and process it there.
Our Policy Toward Children. Our Services are not directed to children under 13. In addition, you are not permitted to use our Services if you do not meet the minimum age requirement applicable to our Services in your jurisdiction. We do not knowingly collect Personal Information from children under 13. If you learn that your child has provided us with Personal Information without your consent, you may alert us at firstname.lastname@example.org. If we learn that we have collected Personal Information of a child under 13 (or under 16 in certain jurisdictions, such as EU member countries) we will take steps to delete such information from our files as soon as possible and terminate the child’s account unless we receive verifiable parental consent.
Definitions. The following capitalized terms shall have the meanings herein as set forth below.
- “Agent” means any Third-Party that Processes Personal Information pursuant to the instructions of, and solely for, News Deeply or to which News Deeply discloses Personal Information for use on its behalf.
- “Employee” refers to any current, temporary, permanent, prospective or former employee, director, contractor, worker, or retiree of News Deeply or its subsidiaries worldwide.
- “Personal Information” is any information relating to an identified or identifiable natural person (“Individual”).
- “Process” or “Processing” means any operation which is performed upon Personal Information, whether or not by automatic means, such as collection, recording, organization, structuring, storage, adaptation or alteration, retrieval, consultation, use, disclosure by transmission, dissemination or otherwise making available, alignment or combination, restriction, erasure, or destruction.
- “Sensitive Data” or “Sensitive Personal Information” is a subset of Personal Information which, due to its nature, has been classified by law or by policy as deserving additional privacy and security protections. Sensitive Personal Information includes Personal Information regarding EU residents that is classified as a “Special Category of Personal Data” under EU law, which consists of the following data elements: (1) race or ethnic origin; (2) political opinions; (3) religious or philosophical beliefs; (4) trade union membership; (5) genetic data; (6) biometric data where Processed to uniquely identify a person; (6) health information; (7) sexual orientation or information about the Individual’s sex life; or (8) information relating to the commission of a criminal offense.
“Third-Party” is any company, natural or legal person, public authority, agency, or body other than the Individual, News Deeply or News Deeply’s Agents.
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