Effective Date: 8-18-2020
Information We Collect
Our website collects information that identifies, relates to, describes, references, is capable ofbeing associated with, or could reasonably be linked, directly or indirectly, with a particularconsumer or device (“personal information”). In particular, our website has collected thefollowing categories of personal information from its users within the last twelve (12) months:
B. Personal information categories listed in the California Customer Records statute (Cal. Civ.Code § 1798.80(e)).YES
C. Protected classification characteristics under California or federal law.YES
D. Commercial information.YES
E. Biometric information.NO
F. Internet or other similar network activity.YES
G. Geolocation data.YES
H. Sensory data.NO
I. Professional or employment-related information.NO
J. Non-public education information (per the Family Educational Rights and Privacy Act (20U.S.C. Section 1232g, 34 C.F.R. Part 99)).NO
K. Inferences drawn from other personal information.YES
Personal information does not include:
* Publicly available information from government records.
* Deidentified or aggregated consumer information.
* Information excluded from the CCPA’s and the Nevada Act’s scope, like:
* health or medical information covered by the Health Insurance Portability and AccountabilityAct of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or
clinical trial data
* personal information covered by certain sector-specific privacy laws, including the Fair CreditReporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California FinancialInformation Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.We obtain the categories of personal information listed above from the following categories ofsources:
* Directly from you. For example, from forms you complete when you register on our website.
* Indirectly from you. For example, from observing your actions on our website and the linksthat you click on emails that we send you.
* From third-party business partners including [partners with websites on which we have placedweb beacons, which allow us to determine that you have visited a particular website or haveclicked on a particular link], and from other partners such as data brokers, social media sites, adnetworks, and analytics providers.
Use of Personal Information
We may use or disclose the personal information we collect for one or more of the followingbusiness purposes:
* To fulfill or meet the reason you provided the information. For example, if you provide yourpersonal information to utilize our services, we will use that information to deliver the serviceand refine our processes to more effectively provide services to you in the future.
* To recognize you when you return to our website.
* To process your requests, and to speed up your searches.
* To store information about your preferences, allowing us to customize our website accordingto your individual interests.
* To provide, develop, and support our website and our services.
* To create, maintain, customize, and secure your account with us.
* To personalize your experience on our website and to deliver content and product and serviceofferings relevant to your interests.
* To help maintain the safety, security, and integrity of our website, products and services,databases and other technology assets, and business.
* For testing, research, analysis, and product development, including to develop and improve ourwebsite and our services.
* To estimate our audience size and usage patterns.
* To respond to law enforcement requests and as required by applicable law, court order, orgovernmental regulations.
* As described to you when collecting your personal information or as otherwise set forth in theCCPA and/or the Nevada Act.
* In the event that we need to evaluate or conduct a merger, divestiture, restructuring,reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as agoing concern or as part of bankruptcy, liquidation, or similar proceeding, in which personalinformation held about our website users is among the assets transferred.
We will not collect additional categories of personal information or use the personal informationwe collected for materially different, unrelated, or incompatible purposes without providing younotice.
Sharing Personal Information
We may disclose your personal information to third parties for a business purpose. When wedisclose personal information for a business purpose, we enter a contract that describes thepurpose and requires the recipient to both keep that personal information confidential and not useit for any purpose except performing the contract.
We share your personal information with the following categories of third parties:
* Service providers who are contractually bound to only use your information to help provideour services.
* Data aggregators (collecting data from both online and offline sources).
* Social Media Companies.
* Internet cookie information recipients (like Google).
Disclosures of Personal Information for a Business Purpose
In the preceding twelve (12) months, we have disclosed the following categories of personalinformation for a business purpose:
Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category F: Internet or other similar network activity.
Sales of Personal Information
In the preceding twelve (12) months, we have sold the following categories of personalinformation:
Category A: Identifiers.
Category F: Internet or other similar network activity.
However, we no longer sell your personal information to third parties for marketing purposes orfor any other purpose beyond providing you our services.
Your Rights and Choices
The CCPA provides California residents with specific rights regarding their personalinformation, and the Nevada Act provides Nevada consumers with specific rights regarding theirpersonal information. If you fall within either of these groups, this section describes your rightsand explains how to exercise those rights.
Access to Specific Information and Data Portability Rights
You have the right to learn certain information to you about our collection and use of yourpersonal information over the past 12 months. You may view, collect, and/or change anypersonal information we have about you through your reader account settings.
Deletion Request Rights
You have the right to request that we delete any of your personal information that we collectedfrom you and retained, subject to certain exceptions. Once we receive your verifiable consumerrequest, we will delete (and direct our service providers to delete) your personal informationfrom our records, unless an exception applies.
We may deny your deletion request if retaining the information is necessary for us or our serviceprovider(s) to:
1. Complete the transaction for which we collected the personal information, provide a good orservice that you requested, take actions reasonably anticipated within the context of our ongoingbusiness relationship with you, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, orprosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights,or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code §1546 seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the publicinterest that adheres to all other applicable ethics and privacy laws, when the information’sdeletion may likely render impossible or seriously impair the research’s achievement, if youpreviously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based onyour relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context inwhich you provided it.
If you elect to delete your personal information, we cannot continue to provide you services asthat information is required to do so. You may opt to delete your account (and its associatedpersonal data) through this form. We may keep your email address,personal information, or other information as is relevant to documenting our compliance withyour deletion request, though we will not use any of this retained information for any otherpurpose.
We will not discriminate against you for exercising any of your rights. Unless permitted by theCCPA or the Nevada Act, as applicable, we will not:
* Deny you goods or services.
* Charge you different prices or rates for goods or services, including through granting discountsor other benefits, or imposing penalties.
* Provide you a different level or quality of goods or services.
* Suggest that you may receive a different price or rate for goods or services or a different levelor quality of goods or services.
Other California Privacy Rights
California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our websitethat are California residents to request certain information regarding our disclosure of personalinformation to third parties for their direct marketing purposes. Nevada consumers have the sameright under the Nevada Act. To make such a request, please notify us through our reader servicescontact form.
Changes to Our Privacy Notice
We reserve the right to amend this privacy Notice at our discretion and at any time. When wemake changes to this privacy Notice, we will post the updated Notice on the website and updatethe Notice’s effective date. Your continued use of our website following the posting of changesconstitutes your acceptance of such changes.
If you have any questions or comments about this Notice, the ways in which we collect and useyour information described above, your choices and rights regarding such use, or wish toexercise your rights, please do not hesitate to contact us through our reader services contactform, or at:
Postal Address: 3 Park Avenue, 33rd Floor, New York, NY 10016