Privacy Policy - North Carolina Daily Times

**PRIVACY POLICY AND YOUR PRIVACY RIGHTS**
**CALIFORNIA NOTICE OF COLLECTION**

Last updated: February 26, 2024.

**Independent Online Media Group LLC** and its Affiliates (“North Carolina Daily Times,” “we,” “us,” or “our”) operate newspapers, news, entertainment, and informational websites, and other print and digital products and services. In this Privacy Policy, “Affiliates” refers to subsidiaries and entities in which North Carolina Daily Times or its subsidiaries operate or have an ownership interest.

This Privacy Policy applies only to the information North Carolina Daily Times and its Affiliates collect through the websites, mobile applications, electronic devices, kiosks, and all other print and digital products and services we provide, any other services that display this Privacy Policy, and all of the associated content, functionalities, and advertising (collectively, the “Services”). This Privacy Policy governs the Services regardless of how you access them. Some Services may have a specific, separate privacy policy that will govern the use of those Services. “Services” include, without limitation, all sites listed on our parent site, www.iolmg.com. This Privacy Policy describes:

1. **The information we collect and how we collect it**.
– **Information you provide**: We may collect information about you during your use of the Services, including but not limited to your name, username, password, email address, postal address, phone number, mobile phone number, payment information, gender, birth year, and information you provide or post on our Services or allow us to access, such as photos, video and/or audio, when you do certain things, such as:

– Enter registration information for one or more of our Services.
– Enter a sweepstakes or contest or register for a promotion.
– Participate in voting or polling activities, surveys, or similar activities where users are asked to respond to a variety of questions.
– Make a purchase.
– Request certain features (e.g., newsletters, updates, and other products).
– Sign up to receive SMS (text message) notifications.
– Download or use one of our mobile applications.
– Connect with the Services or otherwise allow us to access certain information about you via a social networking site (SNS).
– Post user-generated content, including comments, to or on any of our Services.
– Navigate our websites and mobile applications.
– Submit your information to us for any other reason.

– We may collect and store your user ID associated with an SNS account that you use to sign in to your North Carolina Daily Times account or connect or use with the Services. When you sign in to your North Carolina Daily Times account or mobile application with your SNS account information or otherwise connect to your SNS account with the Services, you authorize North Carolina Daily Times to collect, store, and use in accordance with this Privacy Policy any and all information available to North Carolina Daily Times through the SNS interface, including without limitation any information that you have made public in connection with your SNS account, information that the SNS provides to us, or information that is disclosed as being provided to us or others during the sign-in process. Please be careful and responsible whenever you are online. Should you choose to voluntarily disclose information through the Services, such as via an SNS, on message boards, in chat areas or in advertising or notices you post, that information can be viewed publicly and may be collected and used by third parties without our knowledge (or our consent) and may result in data collection by or unsolicited messages from other individuals or third parties.

1.2 Automatically-collected information

1.2.1 Device/usage information

We may automatically collect certain information about the computer or devices (including mobile devices) you use to access the Services. For example, we may collect and analyze information such as:

– IP addresses
– Geolocation information (as described in the next section below)
– Unique device identifiers including mobile advertising identifiers and other information about your mobile phone or other mobile device(s)
– Browser types
– Browser language
– Operating system
– The state or country from which you accessed the Services
– Information related to the ways in which you interact with the Services, such as:
– Referring and exit pages and URLs
– Platform type
– Clicked items
– Interaction with advertisements
– Domain names
– Landing pages
– Pages and content viewed and the order of those pages
– The amount of time spent on particular pages
– Mouse hover including location and time spent on each area of the page
– The date and time you used the Services
– The frequency of your use of the Services
– Error logs
– Other similar information

As described further below, we may use third-party analytics providers and technologies, including cookies and similar tools, to assist in collecting and analyzing this information.

We may also capture other data, such as search criteria and results. In some cases, we will associate this information with a unique North Carolina Daily Times identifier for our internal use, in which case your North Carolina Daily Times identifier will be considered North Carolina Daily Times information, and nothing in this Privacy Policy restricts how North Carolina Daily Times may use this information.

1.2.2 Location information

We may collect different types of information about your location, including general information (e.g., IP address, ZIP code) and more specific information (e.g., GPS-based functionality on mobile devices used to access the Services), and may use that information to customize the Services with location-based information, advertising, and features. For example, if your IP address indicates an origin in downtown Los Angeles, the Services may be customized with downtown Los Angeles-specific information and advertisements. To do this, your location information may be disclosed to our agents, vendors, or advertisers. If you access the Services through a mobile device and you do not want your device to provide us with location-tracking information, you can disable the GPS or other location-tracking functions on your device, provided your device allows you to do this. See your device manufacturer’s instructions for further details.

1.2.3 Cookies and other electronic technologies

When you use the Services, we use persistent and session cookies and other similar tracking technologies to:

– Store your username and password
– Monitor and analyze the usage of our sites and Services by collecting the information discussed in section 1.2.1 above
– Customize the Services to your explicit and inferred preferences
– Tailor advertising displayed by the Services, as well as advertisements that may be displayed on other websites or mobile applications

We, along with our vendors, may also use other Internet technologies, such as Flash technologies, Web beacons, or pixel tags, and other similar technologies, to deliver or communicate with cookies and track your use of the Services, as well as serve you ads and personalize/customize your experience when you are using our Services and/or when you are on other websites when those cookies can be accessed. We also may include Web beacons in email messages, newsletters, and other electronic communications to determine whether the message has been opened and for other analytics, personalization, and advertising. As we adopt additional technologies, we may also gather additional information through other methods.

We may sometimes target ads to you through ‘onboarded’ audiences: to do this, we may disclose information you have provided to us to service providers, who will de-identify the information and associate it with cookies that enable us to reach you with display media. We may also help these service providers place their own cookies, by deploying a cookie that is associated with a ‘hashed’ value associated with interest-based or demographic data, to permit advertising to be directed to you on other websites, applications, or services.

Most browsers automatically accept cookies, but you can modify your browser setting to decline cookies by visiting the Help portion of your browser’s toolbar. If you choose to decline cookies, please note that you may not be able to sign in, customize, or use some of the interactive features of the Services, and the advertisements you see may not be as relevant to you. Please note that limiting third-party cookies through your browser controls will not necessarily opt you out of first- or third-party interest-based advertising, as some technologies (including those we or our partners may use) may not respond to these browser controls.

To opt-out of interest-based advertising that is enabled by many industry platforms and providers (including much of the advertising described in this section), please see the choices we have described in Section 4.2, in particular the DAA’s opt-out page.

1.3 Information from third parties

We may obtain additional information about you from third parties such as marketers, partners, researchers, social networks, data services companies (e.g., for data enhancement), and others. We may combine information that we collect from you with information about you that we obtain from such third parties and information derived from any other subscription, product, or service we provide.

Our Services may allow you to disclose information with us that you have already provided to a third-party social networking platform. For example, you may be able to create an account for our Services or log in to our Services using your Facebook account or other third-party credentials. If you do so, information that you have provided to the third party may be made available to us by that third party subject to that third party’s own privacy policy, terms, and conditions, and you authorize us to collect, store, and use any information they may give us (e.g., your email address).

1.4 Collection of information across personal devices, and applications

Sometimes, we (or our service providers) may use the information we collect – for instance, log-in credentials, IP addresses, hashed email addresses, and unique mobile device identifiers – to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones, tablets, or computers), or work with providers that do this, in order to better tailor content, features, and advertising, and provide you with a seamless experience across the devices you use to access the Services.

2. What we do with the information we collect:

We use the information that we collect for the following purposes:

– For the purposes for which you provided it.
– To send you information about your relationship or transactions with us.
– To send you alerts or other communications via SMS messages or other media or networks.
– To notify you about new features of the Services, special events, or products, services, and special offers.
– To administer sweepstakes and contests.
– To process and respond to your inquiries.
– To contact you with information that we believe will be of interest to you.
– To attribute content that you make available through the Services.
– To generate and review reports and data about our user base and usage patterns of the Services.
– To perform analytics and research aimed at improving the accuracy, effectiveness, usability, or popularity of the Services.
– To offer, manage, monitor, and improve the content and features of the Services or develop new Services.
– To allow us to personalize or otherwise provide the content and advertising that you see on the Services and on other websites and mobile applications and to understand how users interact with and use our advertisements and Services.
– To enforce the legal terms that govern your use of the Services.
– To administer and troubleshoot the Services.
– To associate your activities, customize content or tailor advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications, and websites).
– To send you offers and advertisements through various channels (which may include, for instance, display, email, direct mail, and TV), whether on our behalf or on behalf of marketing partners with whom we may engage.

The Services are supported by advertising revenue. We may send you commercial emails on behalf of ourselves, our Affiliates, and advertisers. Each such email we send you will have an opt-out that you can use to stop receiving such communications.

3. How we disclose user information with third parties:

We may make your information available to other companies, websites, applications, or people in the circumstances described below:

– We may rent, sell, or disclose your information to non-affiliated third parties:
– To provide services or products that you have requested.
– When we have your permission.
– As described in this Privacy Policy.

– We may disclose your information to any agent or company that is part of North Carolina Daily Times to provide the Services or advertising or to communicate with you on our behalf.

– We may provide access to or disclose your information to select third parties who perform services on our behalf. These third parties provide a variety of services to us, including without limitation billing, sales, marketing, provision of content and features, advertising, analytics, research, customer service, shipping and fulfillment, data storage, security, fraud prevention, payment processing, and legal services.

– We may disclose your information to third parties for their own and sometimes our own advertising and marketing purposes, with whom we have a contractual relationship, including without limitation third-party advertisers and advertising and list brokering networks.

– We may access, disclose, transfer, and preserve your information when we have a good faith belief that doing so is necessary to:
– Protect our users and our legal rights, privacy, or safety, and that of our subsidiaries, Affiliates, employees, agents, contractors, or other individuals, including by enforcing this Privacy Policy or any applicable North Carolina Daily Times Terms of Service.
– Comply with the law including with subpoenas, search warrants, court orders, and other legal processes; and respond to inquiries or requests from government, regulatory bodies, law enforcement, public authorities, or content protection organizations.
– Permit us to pursue available remedies, commence, participate in, or defend litigation, or limit the damages that we may sustain.
– Enforce this Privacy Policy or any applicable North Carolina Daily Times Terms of Service.

– We may disclose your information in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all North Carolina Daily Times assets, or a financing or acquisition of all or a portion of our business by another company.

– We may aggregate and we may de-identify information collected by the Services or via other means so that the information is not intended to identify you. Our use and disclosure of aggregated and/or de-identified information is not subject to any restrictions under this Privacy Policy, and we may disclose it to others without limitation for any purpose.

5. Your Privacy Rights

If you are a California resident, you may possess certain rights. For more details, please refer to our Supplemental Privacy Notice for California Residents.

Furthermore, you have the right to request the deletion of specific information about you that we have acquired from Facebook (e.g., if you have utilized the Facebook Login feature on the North Carolina Daily Times website or mobile application). You can make this deletion request by: (i) contacting us at iolmg.com/about/fb-data-deletion-request; or (ii) emailing us at privacy@iolmg.com. We will take reasonable steps to verify your identity before responding to such requests. Certain information may be exempt from deletion requests under applicable law. We require certain types of information to provide the Services to you. If you request its deletion, you may no longer be able to access or use the Services.

6. California Do-Not-Track Disclosure Requirements

We are committed to offering you meaningful choices regarding the information collected on our Services for third-party purposes. This is why we provide the Network Advertising Initiative’s Consumer Opt-out link, Digital Advertising Alliance’s Consumer Opt-Out Link, TrustArc’s Advertising Choices page, and the Google opt-out link information in Sections 4.1 and 4.2. However, we do not acknowledge or respond to browser-initiated Do Not Track signals, as the Internet industry is currently still working on Do Not Track standards, implementations, and solutions.

7. How to Access and Update Your Information

To ensure that you have some control over the information we hold about you, you may review and update certain user profile information by logging in to the relevant portions of the Services where such information may be updated (available on some Services and not others) or by contacting us at privacy@iolmg.com.

8. How We Protect Information

We have implemented various administrative, technical, and physical security measures to safeguard against unauthorized access, destruction, or alteration of your information. These safeguards vary based on the sensitivity of the information we collect, process, and store and the current state of technology.

While we take appropriate measures to protect against unauthorized disclosures of information, we cannot guarantee that the information we collect will never be disclosed in a manner inconsistent with this Privacy Policy.

9. Linked Sites and Advertisements; Embedded Video Player

9.1 Linked Sites and Advertisements

The Services may contain links to third-party websites. We are not responsible for the privacy practices or the content of those third-party websites.

We have relationships with third-party providers to offer content, products, services, and functionality through the Services. When you visit sites or use any Services provided in conjunction with one or more of these third-party providers and the brands of those providers appear on the site or Services in connection with such content, products, services, or functionalities, we may disclose any information you provide or that is collected during your use of those Services with those providers.

9.2 Embedded Video Player

We use the unbranded version of the YouTube embedded video player (“YouTube Player”) to display some of our YouTube video content in our Services. YouTube may collect usage data when you use, interact or engage with the YouTube Player in our Services. You can read about Google’s Privacy Policy as it relates to the YouTube Player here: https://www.google.com/policies/privacy.

10. Collection of Certain Information by Third Parties through Our Services

For certain advertising that appears in the Services, an advertiser may request, and you may directly provide to that advertiser, information such as your name, home address, or email address. When you provide information in that way, the information you submit may be used by the advertiser in any way that it chooses, including to market to you, or to disclose to others. The information may be covered by the advertiser’s separate privacy policy, but in many cases, that will not be the case because the advertiser may have no separate online presence. You should therefore only submit your information in these cases when you are comfortable doing so given the above conditions, and if you have any questions about the privacy practices of an advertiser, you should contact the advertiser itself.

11. Use of the Services by Users from Outside the United States

The Services are hosted in the United States and locations outside the United States and are governed by United States law. If you are using the Services from outside the United States, please be aware that your information may be transferred to, stored and processed in the United States and other countries where our servers are located and our databases are operated. The data protection and other laws of the United States and other countries might not be as comprehensive or protective of certain rights as those in your country. Under United States law, your information may be subject to access requests from governments, courts, or law enforcement in the United States. By using the Services, you consent to your information being transferred to our facilities and to the facilities of those third parties to whom we disclose it as described in this Privacy Policy and processed in those facilities.

12. Use of the Services by Children

The Services are not intended for persons under the age of 13; however, we are providing some family content during this time of the COVID-19 crisis for parents or guardians who are home with their kids. We shall obtain the consent of a parent or guardian to the extent that the parent’s or guardian’s child under 13 submits personal information to us in connection with such family content. We will retain the information only so long as reasonably necessary to: (1) publish the family content with the consent of the parent(s) or guardian(s); (2) fulfill the request or allow the child to participate in the family content or activity; (3) ensure the security of our users and our online services; and/or (4) as required by law. On the specific pages that contain family content in our online Services, we may also offer family activities such as puzzles and games for children under the age of 13, which only collect persistent identifiers to support the services. Our other games offerings are not intended for use by children under the age of 13. If we learn we have collected personal information from a child in a manner inconsistent with legal requirements, we will either delete the personal information or seek consent from parents or guardians. A parent or guardian may contact privacy@iolmg.com to review personal information provided by the parent’s or guardian’s child, have such information deleted, and/or refuse to allow further collection or use of such information.

13. How to Contact Us

If you have any questions, comments, or concerns regarding our Privacy Policy or practices, please send an email to privacy@iolmg.com.

14. No Rights of Third Parties

This Privacy Policy does not create rights enforceable by third parties.

15. Changes to this Privacy Policy

North Carolina Daily Times reserves the right to change this Privacy Policy at any time to reflect changes in the law, our data collection and use practices, the features of our Services, or advances in technology. Please check this page periodically for changes. Your continued use of the Services following the posting of changes to this Privacy Policy will mean you accept those changes.

16. Supplemental Privacy Notice for California Residents

This Supplemental Privacy Notice supplements the information in our Privacy Policy above and applies solely to California residents. It applies to personal information we collect on or through the Services and through other means (such as information collected offline, in person, and over the telephone), including from our users, subscribers, advertisers and our other customers, as applicable. It does not apply to personal information we collect from our employees or job applicants

16.1 Summary of Information We Collect

California law, including the California Consumer Privacy Act of 2018, as amended and related regulations (the “CCPA”), requires us to disclose information regarding the categories of personal information and sensitive personal information that we have collected about California consumers, the categories of sources from which the information was collected, the business or commercial purposes (as that term is defined by applicable law) for which the information is disclosed, and the categories of parties to whom we disclose or sell/share (as those terms are defined by applicable law) the personal information.

16.2 California Notice of Collection

(a) We or our service providers may collect the below categories of information for the following business or commercial purposes (as those terms are defined in applicable law):

– Providing the Services (e.g., account servicing and maintenance, customer service, analytics, and communication about the Services).
– Our or our service provider’s operational purposes.
– Auditing consumer interactions on our site.
– Detecting, protecting against, and prosecuting security incidents and fraudulent or illegal activity.
– Bug detection and error reporting.
– Customizing content that we or our service providers display on the Services.
– Improving our existing Services and developing new services (e.g., by conducting research to develop new products or features).
– Other uses that advance our commercial or economic interests, such as communicating with you about relevant products and services available to you from third-party partners; or
– Other uses about which we notify you.

Examples of these types of uses are identified below and discussed more generally in our Privacy Policy above. We may also use the below categories of personal information for compliance with applicable laws and regulations, and we may combine the information we collect (“aggregate”) or remove pieces of information (“de-identify”) to limit or prevent identification of any particular user or device.

How We Utilize the Information We Gather About You:

We leverage each category of personal data mentioned above for the following business and commercial objectives. These activities may involve external entities, agents, or contractors (“service providers”) to whom we divulge your personal data for these aims (expounded further in Section 3 of this Privacy Policy).

(A) Providing the Times Services:

We employ your information to facilitate your utilization and navigation of Times Services, including:

– Enabling access to Times Services
– Managing access to your account
– Offering customer service
– Addressing your inquiries, requests, suggestions, or complaints
– Finalizing your payments and transactions
– Transmitting service-related transactional messages (e.g., updates to our terms and conditions)
– Preserving your reading list, recipes, or searches
– Exhibiting your Games statistics
– Enabling your participation in paid services, polls, promotions, surveys, panels, research, and comments.

(B) Personalizing Your Experience:

We track your interests and reading habits (e.g., articles you read) to tailor your experience using technology such as algorithmic recommendations and machine learning, potentially including third-party machine learning services. This enables us to highlight articles of potential interest while minimizing emphasis on articles you’ve already perused. Additionally, based on demographic and usage data, including location data like IP address and zip code, we present you with prices, promotions, products, or services we anticipate you’ll find engaging.

Any information you disclose in your content becomes public, along with your selected screen name and uploaded photo.

(D) Developing Products and Services, and Conducting Analysis:

We analyze data concerning our users’ subscriptions, purchases, registered account activity, and other usage behaviors to inform our business and marketing strategies. For instance, through analysis, which may involve proprietary or third-party machine learning technology, we predict preferences and price points for our offerings, assess the efficacy of our marketing efforts, and discern characteristics about our readers. We may also share aggregated characteristics with advertisers.

Google Analytics is one of the analytics providers we utilize on specific Times Services. For details on Google Analytics data usage and opting out, please refer to Google’s privacy policy.

(E) Administering Administrative Tasks:

– For auditing: Validating that our internal processes function as intended and adhere to legal, regulatory, and contractual requirements.
– For fraud and security monitoring: Detecting and preventing cyberattacks or unauthorized robotic activities.
– For customer satisfaction: Evaluating users’ satisfaction with Times Services and our customer care team.

(F) Offering Sweepstakes, Contests, and Other Promotions:

As previously mentioned, you can participate in our sweepstakes, contests, and other promotions, some of which may have additional rules governing the usage and disclosure of your personal information.

(G) Facilitating Personalized Advertising on Times Services and Generating Audiences for Third-Party Advertisers:

We gather data and collaborate with service providers and third parties to present and evaluate the performance of personalized ads on behalf of advertisers. This data comprises information obtained from ad tracking technologies set by us or third parties (e.g., cookies), data you provide (e.g., email address), your Times Services usage (e.g., reading and account activity history), information from advertisers or advertising vendors (e.g., demographic data), and insights inferred from this information.

For instance, we employ Google to serve ads on Times Services. Google utilizes cookies or unique device identifiers, alongside their own data, to display ads based on your visits to nytimes.com and other sites. Opt-out options for certain Google cookies are available through Google’s privacy policy.

Additionally, we categorize user groups for personalized ad targeting on behalf of advertisers. This involves combining data gathered through surveys or registration with automatically collected information using tracking technologies while browsing our sites and apps. These amalgamated insights are employed to construct models, which are then utilized to gauge users’ attributes, such as demographic information or interests. Collaborating with service providers, we utilize these measurements to segment users by shared attributes, each associated with a random ID transmitted to our ad server for ad campaign targeting on our sites and apps.

We may also deliver third-party advertising to users via matching services such as Unified ID 2.0 and LiveRamp’s Authenticated Traffic Solution. In such scenarios, we employ directly identifying information, like name, email address, or phone number, to execute targeted advertising, potentially converting email addresses/phone numbers into identifiers for advertising purposes. Additionally, we may collect such information from third parties. For information on your choices concerning such processing, please consult the “What Are Your Rights and Choices?” section below.

Another instance involves our affiliate link vendors utilized in our guides and product recommendations. Times Services like Wirecutter may contain links redirecting you to vendor URLs and other services not operated or controlled by us. These vendors leverage cookies and other technologies to gather information about your navigation from Times Services to the merchant you visit. If you make a purchase after following a link to a link vendor’s URL, we may earn a commission.

Additional Notes:

For further details on targeted advertising and opting out via your specific browser and device, visit the DAA Webchoices Browser Check and NAI Opt Out of Interest-Based Advertising. Download the AppChoices app for opting out in mobile apps. Instructions for opting out of these emails can be found in the “What Are Your Rights and Choices?” section below.

We endeavor to restrict how our third-party advertising technology vendors utilize the information they collect from you. Many of these providers mandate contractual agreements allowing them to optimize their services and products or create their own. Essentially, these providers combine information gathered about you through Times Services with data from their other clients, aiding them in targeting ads not only for us but also for other clients.

These third parties occasionally utilize additional services to serve ads; consult their privacy policies for further information. For additional information on tracking technologies and your rights and choices concerning them, refer to the relevant Cookie Policy. As outlined below in greater detail, California residents have the right to direct us not to “sell” or “share” their personal information. Residents of Colorado, Connecticut, Virginia, and Utah have the right to opt out of “targeted advertising” and “sales” (as defined by applicable law).

(H) Advertising or Marketing Times Services to You:

We promote our Times Services to you, sometimes leveraging marketing vendors for this purpose. For example, when you visit Times Services, the Google Dynamic Floodlight tag gathers data via redirect requests from your browser to entities other than Times Services, Google, and the owner or operator of other properties where The Times may serve marketing using Google.

We distribute ads through third-party-operated websites, locations, platforms, and services, often targeting individuals who have visited or registered for a Times Service but have not yet subscribed or made a purchase. These ads may also target individuals exhibiting traits or behaviors similar to our subscribers or customers.

We target our advertising to these users by uploading a customer list (email addresses) to a third party or incorporating a tracking technology from a third party into our Times Service. The third party then matches individuals present in both our data and theirs.

We undertake measures to opt you out of such matched ads if you reside in certain states where you have the right to opt out of such processing, as discussed further below. However, to opt out of receiving these matched ads, you should also reach out to the relevant third parties. For instance, when employing “Custom Audiences” to deliver

our ad through Facebook, you should be able to opt out by hovering over the box in the right corner of that Facebook ad. We are not liable for any failure by third parties to comply with opt-out requests. To opt out of Unified ID 2.0 (or UID 2), visit https://www.transparentadvertising.com/.

Periodically, we send targeted email newsletters or promotional emails. Instructions for opting out of these emails can be found in the “What Are Your Rights and Choices?” section below.

(I) Aggregating (or De-identifying) Personal Information into Larger Findings:

We sometimes aggregate or de-identify information to the extent it can no longer identify you, as defined by applicable laws. This enables us to gain a better understanding and representation of our users, such as when assessing ad performance, crafting advertising interest-based segments, or compiling survey results. We may utilize and disclose this aggregated or de-identified information for any purpose, unless prohibited by applicable law.

3. Disclosure or Sharing of Information:

(A) Within Our Company:

Our affiliates, including the companies listed here, may access your information for the purposes outlined in this section.

(B) With Service Providers:

We collaborate with service providers, as defined previously, to execute specific tasks, including:

– Processing payments
– Fulfilling orders
– Maintaining technology and related infrastructure
– Providing customer service
– Serving and targeting ads
– Evaluating ad performance
– Conducting surveys
– Shipping products and mailings
– Sending emails
– Processing lists and analytics
– Managing and analyzing research
– Overseeing promotions

During the execution of these tasks, service providers often have access to your personal information. At times, we may permit them to utilize aggregated or de-identified information for other purposes, as permitted by applicable laws.

There are instances where we disclose your information to third parties beyond our service providers. For example:

– We share your email address and other personal information with third parties for marketing Times Services across third-party sites and services, and for facilitating matching for third-party advertising on Times Services. These emails may or may not be hashed when shared with third parties.

– Certain vendors may use pseudonymized email addresses received from us to power products provided to us and other customers, potentially using your email address in pseudonymized form for services to other companies.

While we endeavor to influence the behavior of vendors identified as service providers, some may engage in activities beyond our control, potentially categorized by regulators as those of “third parties,” not service providers.

Further details on instances where we knowingly disclose personal information to third parties not classified as service providers:

i. If you’re a U.S. print subscriber, we may share your name and mailing address with other companies seeking to market to you via mail. This may constitute a “sale” of personal information under the laws of certain jurisdictions. Refer to the “What Are Your Rights and Choices?” section below if you prefer we do not share this information.

ii. We provide information to third-party advertisers and their agencies as outlined in Section 2(G) above.

iii. Information is provided to websites, locations, platforms, and services operated and owned by third parties in connection with marketing, as detailed in Section 2(H) above.

iv. Information about live event and conference attendees (e.g., name, company, job title) is shared with event sponsors, with notification provided when you provide us the information.

v. Information about participants in sweepstakes, contests, and similar promotions is shared with the promotions’ sponsors, with notification provided when you provide us the information.

vi. Payments made through Times Services may involve processing by external services, either with us collecting and providing your information to the third-party service (e.g., Worldpay), or the third-party service collecting your information directly for processing.

vii. In the event of reorganization, merger, sale, joint venture, assignment, transfer, or other disposition of all or any portion of our business, assets, or stock (including in bankruptcy or similar proceedings), we may disclose or transfer your information to a third party, such as an acquiring entity and its advisers.

viii. We may preserve or disclose personal information if required by law, legal process, to protect and defend our rights and property, to prevent misuse or unauthorized use of Times Services, to protect the safety or property of our personnel, users, or the public, or to cooperate with government authorities, which may be outside your country of residence.

ix. Public activities in our RSS feeds, APIs, and other distribution formats may be disclosed. Your public activities could consequently appear on other websites, blogs, or feeds.

4. Your Rights and Choices:

(A) General:

i. Communication Preferences:

You can manage your email preferences by unsubscribing from commercial emails and newsletters from The Times, including emails regarding The Athletic, through the instructions provided at the bottom of the email. Additionally, you can adjust your nytimes.com newsletter and marketing communication preferences or uninstall our app to opt out at any time.

For text messages, you can opt out of alerts by replying “STOP” or using any alternative keyword provided.

ii. Access, Correction, Change/Update, Deletion, or Restriction of Processing:

Depending on your jurisdiction, you may have the following choices:

– Access, modify, or delete your personal information.
– Receive an electronic copy of your personal information for data portability.
– Restrict or object to how we process your personal information.

To exercise any of these choices, contact us on privacy@iolmg.com. Please specify the changes you want, including suppression of your information from our database or limitations on its use. We’ll verify your identity via email and may request additional information.

iii. Managing Your Digital and Home Delivery Accounts:

You can update your account information and view your transaction history. If you need assistance, call our toll-free number. Managing accounts differs for subscribers via Apple’s App Store or Google Play.

iv. Browser and Platform Controls:

– Cookie Controls: Adjust your browser settings to delete or reject cookies, understanding that this may impact certain website features.
– Global Privacy Control: Some browsers support GPC to signal opt-out preferences for data processing.
– Do Not Track: Our websites do not respond to browser DNT signals, but you can use other tools to control data collection and use.
– Mobile Advertising ID Controls: iOS and Android systems offer options to limit tracking and reset advertising IDs.
– Email Web Beacons: Email client settings can prevent the automatic download of images, including web beacons.

v. Opt-Out of Targeted Advertising and “Sales or Sharing” of Personal Information:

Residents of specific jurisdictions can opt out of targeted advertising and “sales or sharing” of personal information. To exercise this right, use the “Your Privacy Choices” link on the webpage or access it through account settings.

vi. Delete My Account:

You can delete your registered user account on native apps and the web platform. If you’re a subscriber, cancel active subscriptions before deleting your account.

vii. Other Rights and Choices:

You won’t face discrimination for exercising privacy rights. Contact us with any accessibility issues or lodge a complaint with a data protection authority.

(B) California Privacy Rights:

i. Notice at Collection:

Receive notice of data practices, including categories of personal information collected, purposes, and retention periods, provided in this Privacy Policy.

ii. Rights to Know, Correction, and Deletion:

Request disclosure of collected personal information, corrections, and deletion under certain circumstances.

iii. “Do Not Sell or Share My Personal Information”:

Opt out of the “sale” or “sharing” of personal information with third parties not classified as service providers.

iv. Right to Limit Use and Disclosure of Sensitive Personal Information:

Limit the use of sensitive personal information for purposes other than requested services.

v. Authorized Agents:

Designate an authorized agent to exercise CCPA rights on your behalf.

vi. Non-Discrimination:

Exercise rights without facing discrimination.

vii. Record of Requests:

California residents’ requests are processed through our intake form, with verification required before fulfillment.

“Do Not Sell or Share My Personal Information”

California residents have the right to opt out of the “sale” or “sharing” of their personal information for cross-context behavioral advertising purposes, as defined by applicable law.

We may sell and share certain information with third parties to provide you with offers, promotions, and opportunities that align with your interests. This enables us to offer you free content and relevant offers.

If you wish to opt out of the use of your information for such purposes considered a “sale” or “sharing” under California law, you can do so through the following page: [Do Not Sell or Share My Personal Information]. You can also submit opt-out requests by email. Additionally, you can activate the Global Privacy Control to opt out of the “sale” or “sharing” of your personal information on participating browser systems. Please note that we do not knowingly sell or share the personal information of minors under 16 years of age without legally-required affirmative authorization.

Other Rights for California Consumers:

If you are a California resident, you may have additional rights, including the right to:

– Request information about the categories of personal information collected or disclosed about you, sources of such information, purposes for collecting or selling, and third parties to whom it’s disclosed.
– Access or obtain a copy of certain information we hold about you.
– Request deletion or correction of certain information we hold about you.

We will verify your identity before processing your request, which may include verifying your name, email address, and physical address.

You can also designate an authorized agent to submit requests on your behalf, provided they have signed, written permission or a power of attorney. For further information on your legal rights or to exercise them, contact us at or email us at privacy@iolmg.com.

You may also have the right to receive information about any financial incentives we offer and not be discriminated against for exercising your rights, as provided by applicable law. Certain information may be exempt from such requests.

Data Retention:

We retain your personal information for as long as necessary for the purposes outlined in this Privacy Policy, unless a longer retention period is required by law.

Factors determining retention periods include the duration of our business relationship with you, legal obligations, and relevance to enforcing agreements or resolving disputes.

If you opt out of email marketing, we keep your email on our suppression list for an extended period to comply with your request. We may delete or de-identify your information sooner upon receiving a verifiable deletion request, subject to exemptions under applicable law. Cached or archived copies may be retained.

“California Shine the Light”

Under California law, California residents have the right to request and receive from us, once a year and free of charge, a list of third parties to whom we have disclosed their ‘personal information’ (if any, as defined by applicable California law) for direct marketing purposes in the previous calendar year. This list includes the type of personal information disclosed to those parties. If you are a California resident and wish to request this information, please email your request to privacy@iolmg.com.

Additional California Rights:

If you are a California resident under the age of 18 and a registered user of our services, you may request the removal of content you have posted to our services that can be accessed by any other user, whether registered or not. Please note that content removed from our services may still be retained on our servers and systems. To request the removal of content under this provision, please email privacy@iolmg.com with a description of the content, its location on our services, and any other relevant information. Please be aware that removal of content under this provision does not guarantee complete removal of the content or information posted by you on our services.