The Atlanta Journal-Constitution California Privacy Notice

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” or “we” or “our” or “us”)). 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”). This California Privacy Notice (“AJCCA Notice”) applies to California residents that are “Consumers” as defined by the California Consumer Privacy Act (as amended and together with its regulations “CCPA”) and is a supplement to the AJC Network’s other privacy policies or notices, including our main Privacy Policy. There are Affiliates that may have their own California privacy notices and consumer rights programs. You will need to consult their policies and make requests to them separately.

This AJC CA Notice reflects our practices regarding the Collection, use, Sale, Sharing, and retention of your Personal Information (“Information Practices”), as a California Consumer when you use AJC Network Services and other various properties.   If you are a current employee or contractor (with CEI Systems access) of AJC Network, you may view our California Workforce Member Privacy Notice under “Policies and Guidelines” through InsideCox. If you are a job applicant, you may view our California Applicant Privacy Notice by visiting the CEI Careers page here. If you are a former employee, retiree, beneficiary, dependent, former contractor, or current contractor (without CEI system access) of AJC Network, you may view our California Former Workforce Member Notice by visiting our main page here. If you interact with us in your capacity of representing another business, you may view your notice here.

In the event of a conflict between this AJC CA Notice and our main Privacy Policy, or our other privacy policies, this AJC CA Notice shall govern as to our rights or obligations under the CCPA. Capitalized terms that are used herein shall have the meaning given to them in the CCPA unless otherwise noted. We may from time-to-time update information in this AJC CA Notice regarding our data practices and your rights, modify our methods for responding to your requests, or supplement our responses to your requests as required to reflect updates to the law. You can tell when this AJC CA Notice was last updated by looking at the Effective Date at the top of the AJC CA Notice. Any changes to this AJC CA Notice will become effective upon posting of the revised AJC CA Notice on our websites.

Unless otherwise noted, the disclosures contained within this AJC CA Notice cover our activities in the prior 12 months from the Effective Date as well as our current practices.

TABLE OF CONTENTS

You can click on the following links to navigate to the different sections in this AJC CA Notice

1. Collection, Use and Disclosure of Personal Information
   1. Categories of PI
   2. Sources of PI
2. Retention of PI
3. Selling and Sharing of PI
4. Your California Privacy Rights
   1. Right to Opt-Out of Share and Sale of Personal Information
      1. Exercising Opt-Out Rights
      2. Opt-Out Preference Signals

• Managing Cookie Preferences

1. California Minors

1. Right to Limit Use and Disclosure of Your Sensitive Personal Information
2. Right to Know, Delete, and Correct Your Personal Information
   1. Right to Know
   2. Right to Delete

• Right to Correct

1. Non-Discrimination

5. California Shine the Light Law
6. Contact Us

1. Collection, Use and Disclosure of Personal Information

Generally, we Collect, retain, use, and disclose your Personal Information (“PI”) to provide you the AJC Network Services, which may include but is not limited to https://www.ajc.com, and as otherwise related to the operation of our business. In addition, we may Collect, use and disclose your PI as required or permitted by applicable law, or as directed by you, in accordance with this AJC CA Notice. 

1. Information We Collect

The table below provides the categories of PI and Sensitive PI we Collect about California Consumers and examples of the PI we Collect. Note that the examples of PI we Collect about you may vary depending on the nature of your interactions with us, and may not include all of the examples listed below.  We Collect, retain, use, and disclose the PI we Collect for the CCPA-defined business purposes in the bulleted list below and for the purposes described in our Privacy Policy (collectively, our “Business Purposes”). We disclose the PI we Collect to the categories of recipients below for the same Business Purposes.

Categories of PI and Sensitive PI	Business Purposes for Collection and Disclosure	Categories of Recipients to  whom PI is Disclosed for a Business Purpose
Identifiers such as name, nicknames, aliases, contact information including email, phone, and address, User IDs, passwords, IP addresses, device IDs, and account names and numbers.	·   Providing the AJC Network Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; ·   Detecting security incidents and protecting against malicious, deceptive, or illegal activity; ·   Troubleshooting the AJC Network Services to identify and repair issues; ·   Internal research and development; ·   Quality and safety assurance, and improving, upgrading, and enhancing the AJC Network Services; ·   Processing and managing interactions and transactions for the AJC Network Services; ·   Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, vendors that assist us in providing the AJC Network Services and running our internal business operations (“Vendors”), analytics and advertising partners, business partners and social media platforms.
Personal records (any personal information described in subdivision (e) of Section 1798.80 of the California Civil Code) such as financial information.	·   Providing the AJC Network Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; ·   Troubleshooting the AJC Network Services to identify and repair issues; ·   Processing and managing interactions and transaction for Services.	Affiliates, Vendors, and business partners.
Characteristics of protected classifications under California or federal law such as age, gender, and household information.	·   Providing the AJC Network Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; ·   Internal research and development; ·   Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, analytics and advertising partners, joint marketing partners, business partners, and social media platforms.
Commercial information such as purchase or service history.	·   Providing the AJC Network Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; ·   Detecting security incidents and protecting against malicious, deceptive, or illegal activity; ·   Troubleshooting the AJC Network Services to identify and repair issues; ·   Internal research and development; ·   Quality and safety assurance, and improving, upgrading, and enhancing the AJC Network Services; ·   Processing and managing interactions and transactions for the AJC Network Services; ·   Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, and business partners.
Internet or other electronic network activity information such as browsing history, referring URLs, search history, interactions with advertising links, and mobile application usage.	·   Providing the AJC Network Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; ·   Detecting security incidents and protecting against malicious, deceptive, or illegal activity; ·   Troubleshooting the AJC Network Services to identify and repair issues; ·   Internal research and development; ·   Quality and safety assurance, and improving, upgrading, and enhancing the AJC Network Services; ·   Processing and managing interactions and transactions for the AJC Network Services; ·   Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, analytics and advertising partners, joint marketing partners, business partners, and social media platforms.
Geolocation data such as your location we infer based on your IP address.	·   Providing the AJC Network Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; ·   Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, analytics and advertising partners, joint marketing partners,  business partners, and social media platforms.
Sensory data (audio, electronic, visual) such as voice recordings from interviews or call centers or profile photos you place on your profile.	·   Providing the AJC Network Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; ·   Quality and safety assurance, and improving, upgrading, and enhancing the AJC Network Services; ·   Processing and managing interactions and transactions for the AJC Network Services.	Affiliates, Vendors, and business partners.
Inferences from PI Collected such as customer profiles including subscriber preferences, customer characteristics, and behaviors.	·   Providing the AJC Network Services, including maintaining and servicing your accounts, verifying your information, processing payments, advertising, marketing, or analytic services, and similar functions and services; ·   Internal research and development; ·   Quality and safety assurance, and improving, upgrading, and enhancing the AJC Network Services; ·   Processing and managing interactions and transactions for the AJC Network Services; ·   Personalizing your website experience and to deliver content and product and service offerings relevant to your interests.	Affiliates, Vendors, analytics and advertising partners, joint marketing partners, business partners, and social media platforms.

In addition, each of the above referenced categories of PI may be disclosed with the government, including law enforcement, or  other parties to comply with law or legal process, to the Consumer or other parties at the Consumer’s request, for the additional purposes explained in our Privacy Policy, and to assignees as part of a merger or asset sale.

Further, we may Deidentify or Aggregate your PI, and as permitted by applicable law, we do not treat Deidentified or Aggregate Consumer information as PI. Similarly, as permitted by the CCPA, we may not treat publicly available information as PI.

1. Sources of PI

We Collect the above categories of PI directly from you, your device or browser, Vendors, suppliers, public databases, social media platforms, data append services, and Affiliates.

2. Retention of PI

Except as otherwise permitted or required by applicable law or regulation, we will only retain your PI (which includes the categories of PI set forth in the charts above) for as long as necessary to fulfill the purposes we Collected it for, as required to satisfy any legal, obligations, or as necessary to resolve disputes. To determine the appropriate retention period for PI, we consider applicable legal requirements, the amount, nature, and sensitivity of the PI, the potential risk of harm from unauthorized use or disclosure of your PI, the purposes we Process your PI for, and whether we can achieve those purposes through other means. For certain types of PI, we will only maintain it for a limited duration.

3. Selling and Sharing of PI

The table below provides the categories of PI and Sensitive PI we Sold or Shared with Third Parties for Cross-Context Behavioral Advertising.

Category of PI and Sensitive PI	Sold?	Shared for Behavioral Advertising?	Purposes for Selling / Sharing	Categories of Third Parties to Whom Information Was Sold or Shared
Identifiers	Yes	Yes	Commercial purposes such as advertising	Analytics and advertising partners
Internet or other electronic network activity information	Yes	Yes	Commercial purposes such as advertising	Analytics and advertising partners
Geolocation data	Yes	Yes	Commercial purposes such as advertising	Analytics and advertising partners

4. California Privacy Rights 

If you are a resident of California, you have the right to submit certain requests relating to your PI as described below.

1. Right to Opt-Out of Share or Sale of Personal Information

1. Exercising Opt-Out Rights

You have the right to direct us to not Sell or Share your PI, as defined under the CCPA. Some of the ways we use cookies for advertising and marketing are considered a “Sale” or “Sharing” under the CCPA. We provide Californians who use AJC Network Services a way to manage their cookie preferences based on categories of cookies through our management tool available , or by clicking on the “Do Not Sell or Share My Personal Information” button in the footer of our website. You will need to do this on each browser and each device that you use to access AJC Network Services and clearing cookies on your browser(s) may disable your preference settings. More information on how to exercise choices regarding Third Party cookies and interest-based advertising is available .

1. Opt-Out Preference Signals

You may also opt out of the Sale or Sharing of your PI via cookies or tracking technologies through an opt-out preference signal. In order to process your request through an opt-out preference signal, you must use a browser supporting the preference signal. If you choose to use an opt-out preference signal, you will need to turn it on for each browser and each device you use.

• California Minors

We do not knowingly Share or Sell the PI of Consumers we know are under 16. Any California residents under the age of 18 who have registered to use AJC Network Services, and who posted content or information on our websites, can request removal by contacting us at [e-mail] detailing where the content or information is posted and attesting that you posted it. We will then make reasonably good faith efforts to remove the post from prospective public view or anonymize it, so the minor cannot be individually identified to the extent required by applicable law. This removal process cannot ensure complete or comprehensive removal. For instance, other parties may have republished or archived content by search engines and others that we do not control.

1. Right to Limit Use and Disclosure of Your Sensitive Personal Information

We do not use or disclose Sensitive PI for the purpose of inferring characteristics about you, or for any other reasons besides the permitted purposes including: to provide our goods and services, or as needed: to ensure security and integrity; to prevent fraud or illegal activity; for physical safety; for short-term, transient use, including for non-personalized advertising; to perform services on behalf of the business; and to verify or maintain the quality or safety of a service or device owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance such services or devices.  For this reason, we do not treat the Sensitive PI we Process as subject to a limit use and disclosure request and, therefore, we do not offer a way for you to submit such a request.

1. Right to Know, Delete, and Correct Your Personal Information

Any Request to Know, Request to Delete, and Request to Correct you submit to us is subject to an identification and residency verification process (“Verifiable Consumer Request”). We will not fulfill your CCPA request unless you have provided sufficient information for us to reasonably verify you are the Consumer about whom we Collected PI. 

If you are unable to provide us with certain information about yourself or, in some cases, about your transaction history with us, we will be unable to verify your identity to fulfill a request to know, delete, or correct. In some cases, we may verify identity by confirming that you are the owner of the email address we have on file. For your specific pieces of information, as required by the CCPA, we will apply heightened verification standards, and reserve the right to request further information from you, in addition to the information mentioned above. 

Some information we maintain about Consumers is not sufficiently associated with a Consumer for us to be able to verify that it is a particular Consumer’s Personal Information (e.g., clickstream data tied only to a pseudonymous browser ID). As required by the CCPA, we do not include that information in response to Verifiable Consumer Requests. Under the CCPA there are exceptions to your request rights. If we do not comply fully with a request, we will explain the reasons in our response. 

We will make commercially reasonable efforts to identify Consumer PI that we Collect, Process, store, disclose, and otherwise use, and to respond to your California Consumer privacy rights requests. We will typically not charge a fee to fully respond to your requests, but we may charge a reasonable fee, or refuse to act upon a request, if your request is excessive, repetitive, unfounded, or overly burdensome. 

You may use an Authorized Agent to submit a Consumer rights request. If you use an Authorized Agent to submit a request, we may require proof that the agent has been authorized by you to do so, and take other steps permissible under the CCPA, to ensure it is a proper request by an authorized agent. 

1. The Right to Know

You have the right to send us a request, no more than twice in a twelve-month period, for any of the following:

• The categories of PI we have Collected about you, including:

1. The categories of sources from which the PI was Collected
2. Our Business or Commercial Purposes for Collecting, Selling, or Sharing PI
3. The categories of Third Parties to which we disclose PI
4. The categories of PI that we Sold, and for each category identified, the categories of Third Parties to which we Sold that particular category of PI
5. The categories of PI that we disclosed for a Business Purpose, and for each category identified, the categories of Third Parties to which we disclosed that particular category of PI

• The specific pieces of PI we have Collected about you.

1. The Right to Deletion

You may request that we delete your PI that we have Collected directly from you and are maintaining. Exceptions do apply, including, without limitation, where we need to retain your PI as permitted by applicable law, such as for regulatory reasons, to complete a warranty or other contract with you, or other internal uses of the information that are compatible with the context in which you provided it. Note also that we are not required to delete your PI that we did not Collect directly from you.

• The Right to Correct

If you believe that any of your PI we maintain about you is inaccurate, you have the right to request that we correct that information. Note that we may deny your request if we determine that the contested PI is more likely than not accurate based on the totality of the circumstances, including the nature of the PI, how we obtained the contested PI, and documentation relating to the accuracy of the PI. We may also delete the contested PI as an alternative to correcting the information only if the deletion of PI does not negatively impact you, or you give us consent to delete the contested PI.

To exercise the right to know, right to delete, or right to correct, you may submit a request by clicking here or calling us at 1-800-933-9771 and including your name, address, email address, and phone number. Do not send other information via e-mail. We will contact you for further information if necessary. In order to complete your request, you will be required to respond to any follow up inquiries we may make, and we may deny your request if you do not do so.

1. Right to Non-Discrimination for the Exercise of Your Privacy Rights

We will not discriminate against any Consumer for exercising their rights under the CCPA.

5. California Shine the Light Law

Separate from your CCPA rights, California’s “Shine the Light” law permits California residents to request certain information regarding our disclosure of PI to third parties for their own direct marketing purposes. We do not share personal information with third parties for their own direct marketing purposes. If you are a California resident, you may request information about our compliance with Shine the Light by contacting us at [e-mail] or by sending a letter to:

ATTN: Chief Privacy Officer – Shine the Light Request

Cox Enterprises Inc. / Atlanta Journal-Constitution

6205-A Peachtree Dunwoody Road

Atlanta, GA 30328

Any such request must include “California Shine the Light Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code. Please note that we are only required to respond to one request per customer each year, and we are not required to respond to requests made by means other than through this email address or mail address.

As these rights and your CCPA rights are not the same and exist under different laws, you must exercise your rights under each law separately.

6. Contact the AJC Network.

If you have any questions about this AJC CA Notice, please contact the AJC Network at [e-mail].  Requests under Section 4 California Privacy Rights will not be accepted via email.