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Privacy Policy

PRIVACY POLICY AND YOUR PRIVACY RIGHTS

Last updated on August 26, 2021.


Tribune Publishing Company and its Affiliates operate newspapers, and news, entertainment, and informational websites, and other digital and online services. In this Privacy Policy, Affiliates refers to subsidiaries and entities that Tribune Publishing Company or its subsidiaries operate or have an ownership interest in.


This Privacy Policy applies only to the information Tribune Publishing Company and its Affiliates (collectively, “Tribune Publishing,” “we,” “us,” or “our”) collect through the websites, mobile applications, electronic devices, kiosks, and all other services we provide, 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 and Affiliates may have a specific, separate Privacy Policy that will govern use of those Services. The Privacy Policy describes:


The information we collect and how we collect it;

What we do with the information we collect;

How we share and disclose user information with third parties;

Tribune Publishing’s use of online analytics and interest-based advertising;

How you can access and update your information;

How we protect information;

Linked sites and advertisements;

Collection of certain information by third parties through our Services;

Use of the Services by users from outside the United States;

Use of the Services by children;

No rights of third parties;

Changes to this Privacy Policy;

How to contact us;

California privacy rights; and

Choices for Nevada residents;

1. The information we collect and how we collect it.

How we collect and store information depends on the Services you use. You can use some of the Services without providing any information other than that automatically collected as described below.


1.1 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;

Sign up to receive desktop (browser-based) or mobile push 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; or

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 Tribune Publishing account or connect or use with the Services. When you sign in to your Tribune Publishing account or mobile application with your SNS account information or otherwise connect to your SNS account with the Services, you authorize Tribune Publishing to collect, store, and use in accordance with this Privacy Policy any and all information available to Tribune Publishing through the SNS interface, including without limitation any information that you have made public in connection with your SNS account, information that the SNS shares with us, or information that is disclosed as being shared 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 (a) 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; and (b) 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 data, 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, and 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 Tribune Publishing identifier for our internal use, in which case your Tribune Publishing identifier will be considered Tribune Publishing information and nothing in this Privacy Policy restricts how Tribune Publishing 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 Chicago, the Services may be customized with downtown Chicago-specific information and advertisements. In order to do this, your location information may be shared with 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: (a) store your username and password; (b) monitor and analyze the usage of our sites and Services by collecting the information discussed in section 1.2.1 above; (c) customize the Services to your explicit and inferred preferences; and (d) deliver interest-based 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 share information you have provided to us with 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. We may also use Flash cookies. Flash cookies operate differently than browser cookies, and cookie management tools available in a web browser will not remove Flash cookies. To learn more about how to manage Flash cookies, you can visit the

Adobe website and make changes at the Global Privacy Settings Panel. 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.


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.


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 deliver interest-based advertising across different devices and browsers that you use to access the Services (for instance, computers, tablets, mobile devices, applications and websites); and

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 share and 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 share your information with non-affiliated third parties: (a) in order to provide services or products that you have requested; (b) when we have your permission; or (c) as described in this Privacy Policy.


We may share your information with any agent or company that is part of Tribune Publishing Company in order to provide the Services or advertising or to communicate with you on our behalf.


We may provide access to or share your information with 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. When you sign up to participate in a contest or sweepstakes, your information may also be provided to our sweepstakes or contest advertisers, operators, or sponsors and the use of that information will be also governed by those advertisers’, operators’, or sponsors’ privacy policies or practices.


We may share your information with 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 Tribune Publishing 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 Tribune Publishing Terms of Service.

We may share your information in connection with any proposed or actual merger, reorganization, transfer of control, a sale of some or all Tribune Publishing 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.


4. Tribune Publishing’s use of online analytics and interest-based advertising.

4.1 Online analytics

We may use third-party web analytics services on our Services, such as those of Google Analytics, Adobe Omniture, and similar providers. These service providers use the sort of technology described in Section 1.2 to help us analyze how users use the Services, including by noting the third-party website from which you arrive. The information (including your IP address) collected by the technology will be disclosed to or collected directly by these service providers, who use the information to evaluate your use of the Services. We also use Google Analytics for certain purposes related to advertising, as described in the following section. To prevent Google Analytics from using your information for analytics, you may install the Google Analytics Opt-out Browser Add-on by clicking here. Click here to view Google’s Privacy Policy and Terms of Service.


4.2 Interest-based advertising

When you use the Services, Tribune Publishing may serve you with ads based on various factors such as the content of the page you are visiting, information you provide such as your age or gender, your searches, demographic and geographic data, user-generated content and other information that you provide to us. These ads may be based on your current activity or your activity over time and may be based on your interests.


Also, third parties, including without limitation those whose products or services are accessible or advertised via the Services, may place cookies or other tracking technologies (such as mobile ‘SDKs,’ which function like a mobile version of a browser cookie and are embedded in mobile applications) on your computer browser, mobile phone applications, or other device to collect information about your use of the Services in order to (i) inform, optimize, and serve ads based on past visits to our websites and other sites and mobile applications and (ii) report how our ad impressions, other uses of ad services, and interactions with these ad impressions and ad services are related to visits to our websites, mobile applications, and use of our Services. We also allow other third parties to serve interest-based ads to you on the Services, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services so that interest-based ads may be delivered to you when you are using other websites and mobile applications. We also may share with third-party advertisers a hashed version of your email address, which may be identified by a service provider for purposes of delivering interest-based advertising on the Services, other websites, and/or mobile applications. We likewise may work with platform providers who serve advertising across devices. For instance, we may want to reach our web-based customers when they are on their mobile devices. This is done, generally, by correlating common attributes (such as IP addresses, other browser or device information or hashed email addresses) across devices, to infer a common identity across multiple channels.


The third parties that use these technologies may offer you a way to opt-out of interest-based ad targeting as described below. We do not maintain or control these opt-opt mechanisms, which are provided by non-affiliated third parties. Further, we do not control which third parties choose to participate in these opt-out mechanisms. Please note that opting out of interest-based advertising does not mean that you will no longer see advertising on the Services, but these ads may be less relevant to your interests.


To maximize the effectiveness of your opt-out, you should register your choice through all of these mechanisms and on each web browser and/or mobile device that you use to access the Services:


General Browser-based Opt-outs: If you would like more information about interest-based browser advertising and how you can generally control cookies from being put on your computer to deliver such advertising, you may visit the Network Advertising Initiative’s Consumer Opt-Out link, the Digital Advertising Alliance’s (DAA’s) Consumer Opt-Out link or TrustArc’s Advertising Choices Page to opt-out of receiving interest-based advertising from companies that participate in those programs. You may also use the links available in advertisements that appear in the Services and learn more about our advertising practices through the About Our Ads link that may be available through the Services.

LiveRamp: To opt out of this data collection, sharing and use by our partner, LiveRamp, please click here.

Lotame: To opt out of this data collection, sharing and use by our partner, Lotame, please visit https://www.lotame.com/about-lotame/privacy/.

Google Analytics: If you have a Google account, we may use Google Analytics to display advertising to you. You can opt-out of Google Analytics for display advertising or customize Google display network ads by visiting the Google Ads Settings page. You will need to log in to Google via the Sign In link if you are not already logged in when you visit that page.

Mobile Device Settings: You can also opt-out of ‘cross-app’ advertising — interest-based advertising that is associated with your use of our or other mobile applications. To do so, please go to your device settings and opt-out through the controls provided through Google/Android or iOS, as applicable. Each operating system, iOS for Apple phones, Android for Android devices and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of interest-based in-application advertisements. (We cannot guarantee that these instructions will not change, or that they will continue to be available; they are controlled by each mobile platform, not us.). For any other devices and/or operating systems, please visit the privacy settings for the applicable device or contact the applicable platform operator.

Note that, after choosing to opt-out via any of the methods above, if you use a different device or a different browser, or if you delete browser cookies, you may need to repeat the opt-out steps for that particular device or browser. In addition, if you block cookies on your browser or if third-party cookies are blocked by default, the opt-out tools above may not function. If you opt- out of the use of your information for interest-based advertising, data may still be collected and used for other purposes including analytics and research.


5. How you can access and update your information.

To ensure that you have some control over the information we have 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 (may be available on some Services and not others) or by contacting us at privacy@tribpub.com.


6. How we protect information.

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


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


7. 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 provide 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 share any information you provide or that is collected during your use of those Services with those providers.


8. Collection of certain information by third parties through our Services.

For certain advertising and other features that appear in the Services, a third party, such as an advertiser, search engine or other partner may collect information such as your name, home address, email address, or device information, such as an IP address. These entities may use this information in any way they choose, including to market to you, or to share with others. The information may be covered by those entities’ separate privacy policy. In some cases, these entities may not have a separate online presence. You should therefore only submit your information in these cases when you are comfortable doing so given the above conditions. If you have any questions about the privacy practices of these other parties, you should contact them.


9. 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 certain interactive, personalized or enriched media features, products and services may not be available in every jurisdiction. Moreover, if and to the extent that the offerings available to you from outside of the United States collect and process personal information, 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. If you access the Services from an IP address associated with a location the European Economic Area, your behavior will not be monitored. 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 with whom we share it as described in our Privacy Policy and processed in those facilities.


10. Use of the Services by children.

The Services are not intended for persons under the age of 16. By using the Services, you hereby represent that you are at least 16 years old. Some third parties, such as platform providers like the iTunes Store or Google Play may provide age-based ratings on some of the Services. These ratings shall have no bearing on this limitation. Third parties may also provide content categories on some of the Services. These categories likewise shall have no bearing on this limitation.


11. No rights of third parties.

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


12. Changes to this Privacy Policy.

Tribune Publishing Company 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.


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@tribpub.com.


14. Your California privacy rights.

The California Consumer Privacy Act of 2018 (“CCPA”) and other California privacy laws provide California residents with specific privacy rights. This Section 14 and its subsections outline these additional rights and supplement this Tribune Publishing Company Privacy Policy.


14.1 California Collection Notice

This California Collection Notice (“Notice”) for California residents provides California residents the additional information about our information collection and use practices required by the CCPA.


This Notice provides information about the categories of personal information that we collect from California residents generally, the purposes for which we use the information, the sources of the information, and the categories of third parties to whom we disclose the information for business purposes.


Information you provide to us:

Categories of information collected Purposes of use (See “2. What we do with the information we collect” in this Privacy Policy for additional information) Sources of personal information Categories of third parties to whom we disclose the information for business and operational purposes (See “3. How we share and disclose user information with third parties” in this Privacy Policy for additional information)

Registration, subscription or contact information such as e-mail address, name, phone number, mobile phone number, shipping address, username, password, and billing information Provide the Services

Complete a purchase


Communicate with you and provide customer service


Personalize your experience


Editorial use


Improve the Services


Our marketing and third-party marketing and advertising purposes


Bug detection and error reporting


Auditing consumer interactions


Security, fraud, and legal compliance


You

Other users who provide information about you


Consumer data resellers


Public records databases


Conferences and other events


Our Affiliates


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Customer service information such as questions and other messages you address to us directly through online forms, by email, over the phone, or by post; and summaries or voice recordings of your interactions with customer care Provide the Services

Communicate with you and provide customer service


Bug detection and error reporting


Security, fraud, and legal compliance


You

Our Affiliates


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Entities for legal purposes


Entities that acquire our business or assets


Demographic, statistical and interest information such as your age, date of birth, gender, interests, lifestyle information, and hobbies Provide the Services Communicate with you and provide customer service

Bug detection and error reporting


Security, fraud, and legal compliance


Provide the Services


Communicate with you and provide customer service


Personalize your experience


Improve the Services


Our marketing and third-party marketing and advertising purposes


Security, fraud, and legal compliance


You

Other users who provide information about you


Consumer data resellers


Our Affiliates


Public records databases


Conferences and other events


Marketers


Social media networks, in accordance with your privacy preferences on such services


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list


brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Financial and transactional information such as credit or debit card number, verification number, and expiration date, to process payments and information bout your transactions and purchases with us Provide the Services

Communicate with you and provide customer service


Security, fraud, and legal compliance


You

Third-party payment processors who collect this information on our behalf and who also have an independent relationship with you


Third party partners or co-branded partners


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Entities for legal purposes


Entities that acquire our business or assets


User-generated content such as comments on articles, photos, videos, audio, any information you submit in public forums or message boards, reviews and feedback or testimonials you provide about our Services Provide the Services

Communicate with you and provide customer service


Personalize your experience


Editorial use


Improve the Services


Our marketing and third-party marketing and advertising purposes


Bug detection and error reporting


Security, fraud, and legal compliance


You

Other users who provide information about you in connection with their event or profile


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Research, survey, or sweepstakes information (including personal identifiers and user generated content) collected if you participate in a survey or sweepstakes; includes information needed for you to participate (such as contact information), and to fulfill your prize Provide the Services

Communicate with you and provide customer service


Personalize your experience


Improve the Services


Our marketing and third-party marketing and advertising purposes


Bug detection and error reporting


Auditing consumer interactions


Security, fraud, and legal compliance


You

Survey or sweepstakes partners


Researchers and analysts


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Contact information about others (including personal identifiers) such as name and mailing address to send a gift or use our send-to-a-friend functionality. If you use send-a-friend on our Services, your email address may be included in the communication sent to your friend. Provide the Services

Communicate with you and provide customer service


Improve the Services


Auditing consumer interactions


Security, fraud, and legal compliance


You

Other users (if you are the recipient of a communication)


Our Affiliates


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Social media information (which may include personal identifiers, photos, location, user generated content, demographic information) if you link your account or access the Services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings such as your name, email address, friend list, photo, gender, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, YouTube, and Twitter) Provide the Services

Communicate with you and provide customer service


Personalize your experience


Editorial use


Improve the Services


Our marketing and third-party marketing and advertising purposes


Bug detection and error reporting


Auditing consumer interactions


Security, fraud, and legal compliance


You

Social media networks, in accordance with your privacy preferences on such services


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Other information any other information you choose to directly provide to Tribune Publishing in connection with your use of the Services Provide the Services

Communicate with you and provide customer service


Personalize your experience


Editorial use


Improve the Services


Our marketing and third-party marketing and advertising purposes


Bug detection and error reporting


Auditing consumer interactions


Security, fraud, and legal compliance


You Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Information we collect automatically from you and/or your device:

Categories of information collected Purposes of use (See “2. What we do with the information we collect” in this Privacy Policy for additional information) Sources of personal information Categories of third parties to whom we disclose the information for business and operational purposes (See “3. How we share and disclose user information with third parties” in this Privacy Policy for additional information)

Device information and identifiers such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers Provide the Services

Personalize your experience


Improve the Services


Our marketing and third-party marketing and advertising purposes


Bug detection and error reporting


Auditing consumer interactions


Security, fraud, and legal compliance


You (through your device)

Advertising providers


Analytics providers


Cookies and tracking technologies


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Internet network and device activity data such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information.

See “1.2.3 Cookies and other electronic technologies” in this Privacy Policy for additional information.


Provide the Services

Personalize your experience


Improve the Services


Our marketing and third-party marketing and advertising purposes


Bug detection and error reporting


Auditing consumer interactions


Security, fraud, and legal compliance


You (through your device)

Advertising providers


Analytics providers


Cookies and tracking technologies


Marketers


Our Affiliates


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Geolocation information such as city, state and ZIP code associated with your IP address or derived through Wi-Fi triangulation; and precise geolocation information from GPS-based functionality on your mobile devices, with your permission in accordance with your mobile device settings, Provide the Services

Personalize your experience


Improve the Services


Our marketing and third-party marketing and advertising purposes


Bug detection and error reporting


Auditing consumer interactions


Security, fraud, and legal compliance


You

Advertising providers


Analytics providers


Marketers


Our Affiliates


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Information we infer or inference information we receive from third parties:

Categories of information collected Purposes of use (See “2. What we do with the information we collect” in this Privacy Policy for additional information) Sources of personal information Categories of third parties to whom we disclose the information for business and operational purposes (See “3. How we share and disclose user information with third parties” in this Privacy Policy for additional information)

Inference data such as information about your potential preferences that we infer from your activities on the Services, and information you provide or inference information we receive from other parties Provide the Services

Communicate with you and provide customer service


Personalize your experience


Improve the Services


Our marketing and third-party marketing and advertising purposes


You, if we infer it from your information and activities

Our Affiliates


Consumer data resellers


Analytics providers


Service providers

Our Affiliates


Other individuals, services, and partners at your request


Other third parties, such as third-party advertisers and advertising and list brokering networks


Entities for legal purposes


Entities that acquire our business or assets


Aggregate and/or De-Identified Information

We may aggregate or anonymize information and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use this Aggregate/De-Identified Information for any purpose permitted under the law, including without limitation for research and marketing purposes, and disclose such information to third parties, including advertisers, promotional partners, and sponsors in our sole discretion.


14.2 CCPA Privacy, Data Access & Deletion Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:


Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.

Provide access to and/or a copy of certain personal information we hold about you.

Delete certain personal information we have about you.

We need certain types of information so that we can provide the Services to you. If you ask us to delete it, you may no longer be able to access or use the Services.


14.3 CCPA Right to Opt Out of Sale of Personal Information

If you are a California resident, CCPA gives you the right to opt out of our “sale” of your personal information as follows:


We may sell certain of your information to third parties to provide you with offers and promotions and opportunities that may be of interest to you. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally required affirmative authorization. You can opt out of these sales by clicking here.

Under the CCPA, sale is broadly defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver interest-based advertising on the Services or other services. Advertising, including interest-based advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you, as further described in Section 4.2 above in this Privacy Policy. California residents can opt out of these sales by on each individual Tribune Publishing Company website by clicking the “Do Not Sell My Personal Information” link in the footer and setting their cookie preferences. This choice is specific to each website, so you must opt out on each Tribune Publishing Company website where you want your choice to apply.

Depending on what Services you use, we may provide the following categories of personal information to third parties for these purposes:


For online interest-based advertising purposes: demographic and statistical information, user-generated content, device information and identifiers, connection and usage data, geolocation, and social media information.

For sharing with third parties to send you relevant offers and promotions and opportunities: contact and registration information; demographic and statistical information, employment and education data, user-generated content, and geolocation.

14.4 Verification

We will take reasonable steps to verify your identity before responding to a request for access, deletion, or to opt-out, which may include, at a minimum, depending on the sensitivity of the information you are requesting and the type of request you are making, verifying your name, email address, and mailing address.


You also are permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.


14.5 How to Exercise Your CCPA Access, Deletion and Opt-out Rights

If you would like to exercise your legal rights to access, delete or opt-out of the sale of your personal information, you may click here. While using this webform will be the most efficient way to exercise your rights, you may also call us at 1-866-686-5356.


14.6 Non-Discrimination and Financial Incentives

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion or sale opt out rights. Certain information may be exempt from such requests under applicable law. You also have the right to receive information about the financial incentives that we offer to you (if any).


14.7 California Shine the Light

California law permits users who are California residents to request and obtain from us once a year, free of charge, a list of the third parties to whom we have disclosed their ‘personal information’ (if any, and as defined under applicable California law) for their direct marketing purposes in the prior calendar year, as well as the type of personal information disclosed to those parties. If you are a California resident and would like to request this information, please submit your request in an email to privacy@tribpub.com.


14.8 California Do-Not-Track Disclosure Requirements

We are committed to providing you with meaningful choices about the information collected on our Services for third-party purposes, and that 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 of this Privacy Policy. However, we do not recognize or respond to browser-initiated Do Not Track signals, as the Internet industry currently is still working on Do Not Track standards, implementations and solutions.


14.9 Additional California Rights for Minors

If you are a California resident under the age of 18 and are a registered User of our Services, you may request that we remove from our Services any content you post to our Services that can be accessed by any other User (whether registered or not). Please note that any content that is removed from our Services may still remain on our servers and in our systems. To request removal of content under this provision, please send an email to privacy@tribpub.com and provide us with a description of the content and the location of the content on our Services, and any other information we may require in order to consider your request. Please note that removal of content under this provision does not ensure complete or comprehensive removal of the content or information posted on the Services by you.


15. Choices for Nevada residents.

Under Nevada law, certain Nevada consumers may opt out of the sale of “personally identifiable information” for monetary consideration to a person for that person to license or sell such information to additional persons. “Personally identifiable information” includes first and last name, address, email address, phone number, Social Security Number, or an identifier that allows a specific person to be contacted either physically or online.


If you are a Nevada resident who has purchased or leased goods or services from us, you may submit a request to opt out of any potential future sales under Nevada law by clicking here. Please note we will take reasonable steps to verify your identity and the authenticity of the request. Once verified, we will maintain your request in the event our practices change.

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