Effective Date: March, 2022
Welcome! Thank you for your interest in the Atlanta Journal-Constitution, a division of Cox Enterprises, Inc., and our “Affiliates” (other companies within the Cox Enterprises, Inc. corporate family) (collectively “AJC Network”). We respect your privacy when you use our websites, mobile applications and other online and offline products and services, including our podcasts and newspaper subscriptions, (collectively, the “AJC Network Services”).
Your California Privacy Rights
You can click on the following links to navigate to the different sections in this Notice.
INFORMATION WE COLLECT
When you use the AJC Network Services, we, or Service Providers acting on our behalf, may collect your Personally Identifiable Information (defined herein). This generally happens in one of three ways—you provide us with information, we collect information through automated methods, or we collect information from other sources. There are some situations in which it is necessary for us to collect your Personally Identifiable Information in order to provide a service to you or to meet legal requirements.
A. Information about You that You Provide. You may share certain information when you interact with the AJC Network and/or its Service Providers (defined below). For example, AJC Network collects information when you use or register for AJC Network Services, subscribe to notifications, post on an AJC Network Service, participate in promotional activities, purchase products or services, express your interests and/or preferences, participate in web forums or other interactive sessions, subscribe to our newsletters or provide feedback, request information, or communicate, use or transact through the AJC Network Services. We may also ask for your information for special reasons, such as for research or in surveys. In addition, when you interact with Third-Party Services (defined below), you may be able to provide information to those third parties. For more information on Third-Party Services’ data collection and practices see Section 6. For more information on Service Provider data collection and practices see Section 3.
B. Information Collected Automatically. When you use the AJC Network Services, our technology, or that of our Service Providers and/or Third-Party Services, has the ability to automatically collect certain types of information about you (“Usage Information”). Usage Information may include IP address, device identifier, browser type, operating system, information about your use of the AJC Network Services, and data regarding network connected hardware (e.g., computer or mobile device). For instance, when you use the AJC mobile app to receive weather alerts, depending on your device’s location settings, we may use your location to determine the weather forecast relevant to your location. Except to the extent required by applicable law, or to the extent Usage Information is combined by or on behalf of AJC Network with AJC Network-Collected PII, AJC Network does not consider Usage Information (including, without limitation, unique device identifiers) to be PII or AJC Network-Collected PII. For more information on Third-Party Services’ data collection and practices see Section 6. For more information on Service Provider data collection and practices see Section 3. For information on choices some of these third parties may offer you regarding automated data collection see Section 11.
The methods that may be used on the AJC Network Services to collect Usage Information include:
- Internet usage information: Internet usage information is data about your use of the AJC Network Services, such as IP address, browser type, Internet service provider, device identifiers, device advertising identifiers, mobile network, operating system details, date/time stamps, language preferences, referring URLs, length of visits, anonymous traffic data, pages viewed, browsing history, search history, information regarding interactions with our website or advertisements, and related data.
- Information Collected by Cookies and Other Tracking Technologies: Cookies , Web Beacons (also known as “tracking pixels”), Embedded Scripts , Location-Identifying Technologies, Device Recognition Technologies , In-app Tracking Methods , Recording and Tracking Interactions and Usage , and other tracking technologies currently in use or to be developed in the future (“Tracking Technologies”) may be used to collect information about interactions with the AJC Network Services or e-mails, including information about your browsing and purchasing behavior.
Cookies.A cookie is a small text file that is stored on a user’s device for record-keeping purposes. Cookie types that are used on the AJC Network Services include session ID cookies or tracking cookies. Session ID cookies make it easier for you to navigate the AJC Network Services and expire when you close your browser. Tracking cookies remain longer and help in understanding how you use the AJC Network Services and enhance your user experience. Cookies may remain on your hard drive for an extended period of time. If you use your browser’s method of blocking or removing cookies, some but not all types of cookies may be deleted and/or blocked and as a result some features, and functionalities of the AJC Network Services may not work. HTML5 cookies can be programmed through HTML5 local storage. HTML5 cookies are locally stored on your device other than in the browser and browser settings will not control them. The AJC Network Services may associate some or all of these types of cookies with your devices.
Web Beacons (“Tracking Pixels”).Web beacons are small graphic images, also known as “Internet tags” or “clear gifs,” embedded in web pages and e-mail messages. Web beacons may be used, without limitation, to count the number of visitors to the AJC Network Services, to monitor how users navigate the AJC Network Services, and to count content views.
Embedded Scripts.An embedded script is programming code designed to collect information about your interactions with the AJC Network Services. It is temporarily downloaded onto your computer from AJC Network’s web server, or from a third party with which AJC Network works and is active only while you are connected to the AJC Network Services and deleted or deactivated thereafter.
Location-identifying Technologies.GPS (global positioning systems) software, geo-filtering, geo-targeting, geo-fencing, and other location-aware technologies locate you (sometimes precisely), or make assumptions about your location, for purposes such as verifying your location and delivering or restricting content based on your location. If you have enabled GPS or use other location-based features on the AJC Network Services, your device location may be tracked by us and third parties. The localized weather and traffic feature offered within our mobile app, for example, may access and use information about your device location (such as based on IP address or GPS, as applicable). Additionally, some of the AJC Network Services use information you enter to offer location-based recommendations and the AJC Network Services’ content may be personalized based on various information we may have about you to try to provide you with more location-relevant content.
Device Recognition Technologies.Technologies, including application of statistical probability to data sets, as well as linking a common unique identifier to different device use (e.g., Facebook ID), which attempt to recognize or make assumptions about users and devices (e.g., that a user of multiple devices is the same user or household) (“Cross-device Data”).
In-App Tracking Methods.There are a variety of Tracking Technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifiers, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps and/or devices.
Recording and Tracking Interactions and Usage.Technologies that monitor, and may record, certain of your interactions with the AJC Network Services and/or collect and analyze information from your device, such as, without limitation, your operating system, plug-ins, system fonts, and other data, for purposes such as identification, security, fraud prevention, troubleshooting, tracking and/or improving the AJC Network Services and customizing or optimizing your experience on the AJC Network Services.
Some information about your use of the AJC Network Services and certain third-party services may be collected using Tracking Technologies across time and services and used by AJC Network and third parties for purposes such as to associate different devices you use and deliver relevant ads and/or other content to you on the AJC Network Services and certain third-party services. See Section 11 regarding certain choices regarding these activities. AJC Network is giving you notice of the Tracking Technologies and your choices regarding them explained in Section 11 so that your consent to encountering them is meaningfully informed.
HOW WE USE THE INFORMATION WE OBTAIN.
- Allow you to participate in the features we offer on the AJC Network Services;
- Contact you regarding your purchase;
- Facilitate, manage, personalize, and improve your online experience;
- Provide you with notices about your account and/or subscriptions, including expiration and renewal notices;
- Notify you about changes to the AJC Network Services or any products or services we offer;
- Enable you to interact with us and others through various means, such as through our message boards or discussion or comment areas;
- Transact with you, provide services or information you request, deliver content, respond to your comments, questions and requests, serve you content and/or advertising, and send you notices;
- AJC Network marketing and other purposes;
- Improve the AJC Network Services and for any other internal business purposes;
- Tailor our content, advertisements, and offers;
- Perform data analyses, including market and consumer research, trend analysis, demographic analysis and financial analysis;
- Fulfill other purposes disclosed at the time you provide PII or otherwise where we are legally permitted or are required to do so;
- Determine your location and manage digital content rights (e.g., territory restrictions);
- Prevent and address fraud, breach of policies or terms, and threats of harm;
- Diagnose and address technical and service problems;
- Comply with applicable legal requirements and our policies; and
- Contact you via telephone or text. We will obtain your consent to contact you when and, in the manner, required by law.
INFORMATION WE SHARE WITH THIRD PARTIES.
AJC Network may share non-PII, and PII that is not deemed AJC Network-Collected PII hereunder (provided that AJC Network is aware of no restrictions of AJC Network’s use, if any), with third parties for any purpose. Without limiting the generality of the foregoing, we and third parties may convert your PII, including AJC Network-Collected PII, to non-PII, including without limitation through hashing it or substituting a unique identifier for the PII and we and third parties may use and share that data as permitted by applicable law, including to match data attributes to and from other sources. Any such third-party activities are subject to their privacy policies and practices. AJC Network’s sharing of AJC Network-Collected PII is, however, subject to the following:
- Marketing: Subject to your communications choices explained in Section 11.D, we may use your PII to send you marketing communications. AJC Network will not share your AJC Network-Collected PII with third parties, other than Affiliates, for their own direct marketing purposes, except in connection with Corporate Transactions (defined below).
- Your Disclosure or Consent: As more fully described in Section 5 (Information You Disclose Publicly or to Others) and Section 6 (Third-Party Content, Third-Party Services, Social Features, Advertising and Analytics), your activities on the AJC Network Services may, by their nature, result in the sharing of your AJC Network-Collected PII (as well as your other PII and your non-PII) with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not AJC Network.
- AJC Network’s agents, vendors, consultants, and other Service Providers (collectively “Service Providers”) may receive, or be given access to, your information, including, without limitation, PII, Demographic Information, and Usage Information, in connection with their work on AJC Network’s behalf, provided however, AJC Network does not authorize its Service Providers to use AJC Network-Collected PII provided by AJC Network to the Service Providers to send you direct marketing messages other than related to AJC Network absent your consent. For more information on choices Service Providers may offer you, see Section 11;
- To comply with the law, law enforcement or other legal process, and, where permitted, in response to a government request; and
In addition, AJC Network may share your AJC Network-Collected PII (as well as your other PII and your non-PII), in connection with or during negotiations of any proposed or actual financing of our business, or merger, purchase, sale, joint venture, or any other type of acquisition or business combination of all or any portion of AJC Network assets, or transfer of all or a portion of AJC Network’s business to another company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding (“Corporate Transactions”).
SWEEPSTAKES, CONTESTS, AND PROMOTIONS.
INFORMATION YOU DISCLOSE PUBLICLY OR TO OTHERS.
THIRD-PARTY CONTENT, THIRD-PARTY SERVICES, SOCIAL FEATURES, ADVERTISING AND ANALYTICS.
The AJC Network Services may include hyperlinks to, or include on or in connection with the AJC Network Services (e.g., apps, plug-ins, application programming interfaces (“API”), and software development kits (“SDK”)), websites, locations, platforms, applications or services operated by third parties (“Third-Party Service(s)”). These Third-Party Services may use their own cookies, web beacons, and other Tracking Technology to independently collect information about you and may solicit PII from you.
Certain functionalities on the AJC Network Services permit interactions that you initiate between the AJC Network Services and certain Third-Party Services, such as third-party social networks (“Social Features”). If you post information on a third-party service that references the AJC Network Services (e.g., by using a hashtag associated with the AJC Network in a tweet or status update), your post may be used on or in connection with the AJC Network Services or otherwise by AJC Network. Also, both AJC Network and the third party may have access to certain information about you and your use of the AJC Network Services and any Third-Party Service.
AJC Network may engage and work with Service Providers and other third parties to serve advertisements on the AJC Network Services and/or on third-party services. Some of these ads may be tailored to your interests based on your browsing of the AJC Network Services and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” and “online behavioral advertising” (“Online Interest-based Advertising”), which may include sending you an ad on a third-party service after you have left the AJC Network Services (i.e., “retargeting”).
In addition, we may serve ads on third-party services that are targeted to reach people on those services that are also identified on one of more of our databases (“Matched List Ads”). This is done by using Tracking Technologies or by matching common factors between our databases and the databases of the third-party services. For instance, we may use such ad services offered by Facebook or Twitter and other Third-Party Services. We are not responsible for these Third-Party Services, including without limitation their security of the data. If we use Facebook to serve Matched List Ads on Facebook services, you should be able to hover over the box in the right corner of such a Facebook ad, or go to your account settings, and find out what options Facebook offers you to control such ads. If we use Twitter Matched List Ads, you should be able to review your ad options in account settings on Twitter.
We are not responsible for such third parties’ failure to comply with your or our opt-out instructions, they may not give us notice of opt-outs to our ads that you give to them, and they may change their options without notice to us or you.
DATA SECURITY AND MONITORING.
AJC Network takes reasonable measures to protect AJC Network-Collected PII (excluding public UGC) from loss, theft, misuse, unauthorized access, disclosure, alteration, and destruction. Nevertheless, transmission via the Internet and online digital storage are not completely secure and AJC Network does not guarantee the security of your information collected through the AJC Network Services.
The AJC Network Services are intended for a general audience and not directed to children less than 13 years of age. AJC Network does not intend to collect “personal information” as defined by the U.S. Children’s Online Privacy Protection Act (“COPPA”) (“Children’s Personally Identifiable Information”) in a manner that is not permitted by COPPA. If you are under 13, do not provide any Personally Identifiable Information to us. If we obtain actual knowledge that we have collected Children’s Personally Identifiable Information in a manner not permitted by COPPA, we will remove such data to the extent required by COPPA. If you believe your child may have provided us with their Personally Identifiable Information, you can contact us at firstname.lastname@example.org and we will delete their Personally Identifiable Information to the extent required by law. California minors have certain additional rights detailed in our California Privacy Notice .
ACCESSING AND CHANGING INFORMATION.
AJC Network may allow you to delete, correct, or update some AJC Network-Collected PII, and potentially certain other information about you (e.g., profile and account information) by contacting us or by signing into your AJC Network online account. AJC Network will make good faith efforts to make requested changes in AJC Network’s then-active databases as soon as practicable, but it is not always possible to completely change, remove or delete all of your information or public postings from AJC Network’s databases (California minors see Section 9) and residual and/or cached data may remain archived thereafter. Further, we reserve the right to retain data (a) as required by applicable law; and (b) for so long as reasonably necessary to fulfill the purposes for which the data is retained except to the extent prohibited by applicable law.
CHOICES: TRACKING AND COMMUNICATIONS OPTIONS.
A. Tracking Technologies Generally. Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to HTML 5 cookies or other Tracking Technologies. Please be aware that if you disable or remove these technologies, some parts of the AJC Network Services may not work and that when you revisit the AJC Network Services your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.
Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Like many online services, AJC Network currently does not alter AJC Network’s practices when AJC Network receives a “Do Not Track” signal from a visitor’s browser. To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but AJC Network is not responsible for the completeness or accuracy of this third party information.
Some third parties, however, may offer you choices regarding their Tracking Technologies. One way to potentially identify cookies on a website is to add the free Ghostery plug-in to your browser (www.ghostery.com), which according to Ghostery will display for you traditional, browser-based cookies associated with the websites (but not mobile apps) you visit and privacy and opt-out policies and options of the parties operating those cookies. AJC Network is not responsible for the completeness or accuracy of this tool or third-party choice notices or mechanisms. For specific information on some of the choice options offered by third-party analytics and advertising providers, see the next section. We may offer tools in connection with the AJC Network Services that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the AJC Network Services.
For the AJC Network Services, you may choose whether to receive some Online Interest-based Advertising by submitting opt-outs. Some of the advertisers and Service Providers that perform advertising-related services for us related to the AJC Network Services and third parties may participate in the Digital Advertising Alliance’s (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Online Interest-based Advertising, including use of Cross-device Data for serving ads, visit http://www.aboutads.info/choices/, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program specifically for mobile apps (including use of precise location for third party ads). Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options, see http://www.networkadvertising.org/choices/. Please be aware that, even if you are able to opt out of certain kinds of Online Interest-based Advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain Online Interest-based Advertising to you but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Also, if your browsers are configured to reject cookies when you visit these opt-out webpages, or you subsequently erase your cookies, use a different device or web browser or use a non-browser-based method of access (e.g., mobile app), your NAI / DAA browser-based opt-out may not, or may no longer, be effective. AJC Network supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expects that ad networks AJC Network directly engages to serve you Online Interest-based Advertising will do so as well, though AJC Network cannot guaranty their compliance. AJC Network is not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.
C. Mobile Apps. With respect to AJC Network’s mobile apps (the “AJC Apps”), you can stop all collection of data generated by use of the AJC App by uninstalling the AJC App. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain features (e.g., location-based services, push notifications, accessing calendar/contacts/photos, etc.), by adjusting the permissions in your mobile device and/or the app’s settings. Beware that if GPS precise location services are disabled, other means of establishing or estimating location (e.g., connecting to or proximity to wi-fi, Bluetooth, beacons, or our networks) may persist. To learn more about how you can control location permissions using your mobile device’s operating system settings, please visit the following links depending on which device you use:
Android 6.0 and above: https://support.google.com/googleplay/answer/6270602?hl=en
For earlier versions of Android: https://support.google.com/googleplay/answer/6014972
D. Communications. You can opt out of receiving certain promotional communications (emails or text messaging) from AJC Network at any time by, for promotional e-mails, following the instructions provided in emails to click on the unsubscribe link or by changing your marketing communication preferences by logging into your account and, for app push notifications, turn off push notifications on the settings of your device and/or the app, as applicable. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. If you opt-out of only certain communications, other subscription communications may continue. If you would like to completely deactivate your account, please contact us at email@example.com. Please note, however, that if you deactivate your account, you will not receive any newsletters from us, and you will not be able to participate in any of our contests, sweepstakes, or other promotions. Even if you opt out of receiving promotional communications, AJC Network may, subject to applicable law, continue to send you non-promotional communications, such as those about your account, transactions, servicing, AJC Network’s ongoing business relations, or communications related to administrative notices or any communications relevant to your use of the AJC Network Services, including communications in the event of a data security event.
E. Cross-Device Data.To learn more about how you can exercise certain choices regarding Cross-device data for Online Interest-based Advertising, see the prior section regarding the DAA’s Online Interest-based Advertising choices.
F. Nevada Residents.Although we do not “sell” “covered information” of Nevada “consumers” as those terms are defined by Chapter 603A of the Nevada Revised Statutes, you may contact us at firstname.lastname@example.org and register for us to provide you notice in the event we change our practices in the future. If we do, you will have an opportunity to be verified and exercise your opt-out rights. Changing your email elsewhere (e.g., informational requests, account information, etc.) will not update your Nevada contact information.
CONTACT AJC NETWORK.
ATTN: Chief Privacy Officer
Cox Enterprises Inc. / Atlanta Journal-Constitution
6205-A Peachtree Dunwoody Road
Atlanta, GA 30328
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