Privacy Policy

Date published: April 05, 2019

Date modified: August 31, 2019

1. Who we are

U.Today (“us”, “we”, or “our”) operates the U.Today website (the “Website”).

2. About this privacy notice

We use your data to provide and improve the Website. By using the Website, you agree to the collection and use of information in accordance with this policy. Unless otherwise defined in this Privacy Policy, terms used in this Privacy Policy have the same meanings as in our Terms and Conditions accessible from U.Today

This Privacy Notice explains how Website collects, uses, and discloses data about you and processes information that identifies or can be used to identify you (sometimes referred to as “personal data” or “personal information” under applicable privacy and data security laws, and hereinafter “personal data”) when you use our website(s), mobile apps, and other online products or Website that link to this Privacy Policy (collectively, the “Website”) or when you otherwise interact with us. From time to time we partner with third parties to provide you with products, promotions or other experiences. We will show you the privacy policies belonging to those third parties when they will receive information in connection with those experiences. Their privacy policy will govern the collection of your personal data, in addition to this Privacy Policy.

3. Changes to this Privacy Policy

We may update our Privacy Policy from time to time. We will notify you of any changes by posting the new Privacy Policy on this page. We will let you know via email and/or a prominent notice on our Website, prior to the change becoming effective and update the “effective date” at the top of this Privacy Policy. You are advised to review this Privacy Policy periodically for any changes. Changes to this Privacy Policy are effective when they are posted on this page. Please come back and check from time to time for the latest information on our privacy practices.

4. What personal data we collect and how

4.1 Personal data you provide to us.

We collect data you provide directly to us. Account data. If you sign up for a U.Today account (“Account”), we will collect data you give us related to your Account, including your name, email address, username and password. Purchase data. If you make a purchase from a third party after clicking on an affiliate link through the U.Today, we will receive data about the purchase for the purpose of managing our business relationship. Other data you share through the Website. You may provide us with data when you fill in a form, conduct a search, update or add information to your Account, respond to surveys, post to community forums, provide us with feedback, participate in promotions, or use other features of the Website.

4.2 Data that indirectly identifies you and automatically collected data.

When you access or use the Website, we collect data that indirectly identifies you and we automatically collect other data about you, including:
Log Data. We automatically receive and record information from your device or web browser when you interact with the Website. For example, we collect your internet protocol (IP) address, mobile device ID, time zone setting, language preference, operating system, platform, internet Website provider (ISP), and links you have clicked on or shared with others, including through email and social media. If you sign up for an Account, we also create a user ID that indirectly identifies you. We use this information to collect data about your activities through the Website. We associate information that indirectly identifies you with your Account (if you have one) and other information we have collected about you. <
Cookies. When you visit the Website, we will set certain “cookies” and similar tracking technologies on your device, including cookies and web beacons. For more information about cookies and how to disable them, please see our “Cookie Policy” section.

4.3 Location data.

We use your IP address to infer your approximate location. We may also collect the language option or country you choose. When we provide certain Website, such as providing you with a version of our Website that is localized to your country, we link location data to other information we have collected about you in order to do so.

4.4 Special category data.

When we conduct research or carry out surveys and you participate in our research or surveys, we may collect sensitive personal data about you, for example, information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation. We will get your explicit consent for our collection, use, or sharing of this data as required by law.

5. Aggregated data

5.1 We analyze and aggregate personal data we collect, such as the number and frequency of your visits to the Website, to produce anonymized metrics and statistical information that does not identify you as an individual.

5.2 We combine information about you with information about other users to create audience segments of aggregated data, for example, statistical, demographic and usage data. If we combine or connect aggregated data with your personal data, we treat the combined data as personal data and deal with it in accordance with this Privacy Policy.

6. How we collect personal data

6.1 You may give us your personal data directly, for example when you create an Account, fund us by donation, subscribe to our newsletters, posts or comments, enter a competition, participate in a promotion or survey, ask for user support, or contact us for any reason.

6.2 We automatically collect personal data when you interact with our Website. We collect information about your devices and browsing actions and interests by using cookies and similar technologies. Our “Cookies policy” section provides more details on how this works.

6.3 Third parties who provide advertising and related Website (such as analytics providers and ad networks) may give us your personal data so that we can compare it to personal data we hold in order to determine if you are the same individual (this is sometimes called “cookie-matching”). We may collect data from unaffiliated third parties so we can better understand you and provide you with information and offers that may be of interest to you. For example, we may receive information about your interests or preferences as well as contact information, such as email address.

6.4 If you access our Website using your Facebook or Google credentials, we will automatically collect certain information, such as your Facebook or Google user ID. We will use any information collected from Facebook or Google, including the user ID Facebook or Google attribute to you, only in accordance with Facebook’s or Google’s policies and your preferences selected through Facebook or Google.

7. What we use your data for:

We use the data we collect to provide, maintain, and improve our Website. We also use the data we collect to:
Send you technical notices, updates, security alerts and support and administrative messages and to respond to your comments, questions and customer service requests;
Communicate with you about products, Website, offers, and events offered by U.Today and others, and provide news and information we think will be of interest to you;
Monitor and analyze trends, usage and activities in connection with our Website and personalize and improve the Website;
Detect, investigate and prevent fraudulent transactions and other illegal activities and protect the rights and property of U.Today and others.

8. Transfer Of Data

Your information, including Personal Data, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ than those from your jurisdiction.

Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

U.Today will take all steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Data will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

9. Third-Party Sites

9.1 Our sites and apps may include links to third-party sites, apps and social media platforms (“Third-Party Sites”). Clicking on those links may allow third parties to collect or share data about you. We do not endorse or control Third-Party Sites, each of which may be governed by its own terms of Website and privacy policy and we encourage you to read their privacy policies and terms so that you understand how they process information about you. You are solely responsible for all liability for any damages or other harm, whether to you or third-parties, resulting from your use of Third-Party Sites. Please take all protections necessary to protect yourself when accessing Third-Party Sites, particularly when downloading or purchasing anything therefrom.

9.2 The Website may offer social sharing features and other integrated tools, which let you share actions you take on our Website with other media, and vice versa. Your use of such features enables the sharing of information with your friends or the public, depending on the settings you establish with the entity that provides the social sharing feature. We also use the analytics tools provided by the social media platforms to help us to understand how people interact with our social media presence, to identify trends and to carry out joint promotional activities with those platforms. For example, sometimes we agree with a social media platform that we will jointly promote certain content.

We also use the analytics tools provided by the social media platforms to help us to understand how people interact with our social media presence, to identify trends and to carry out joint promotional activities with those platforms. For example, sometimes we agree with a social media platform that we will jointly promote certain content.

We receive aggregated statistical information from social media platforms about the performance of our posts and promoted content, such as numbers of views and kinds of viewers. This data is aggregated and anonymized by the social media platform prior to being made available to us.

We also use the paid advertising and paid content tools provided by the social media platforms to help us carry out advertising campaigns for our ad partners and to promote our content on the social media platforms. For example, we use the “Promoted Pins” tool on Pinterest to promote editorial or paid content to visitors to Pinterest. Again, we receive from the social media platforms only aggregated statistical information about interactions with our ads and paid content, such as number of views, number of times shared and so on.

We process information provided to us by the social media platforms on the basis of our legitimate interest in interacting with our audience on social media and using social media to promote our content.

For more information about the purpose and scope of data collection and processing in connection with social sharing features or your use of the social media platforms, please visit the privacy policies of the respective entities at the following links:

• Facebook and Instagram - https://en-gb.facebook.com/policy.php
• Twitter - https://twitter.com/en/privacy
• YouTube - https://policies.google.com/privacy?hl=en
• Snapchat - https://www.snap.com/en-US/privacy/privacy-center/
• Twitch - https://www.twitch.tv/p/legal/privacy-policy/
• TikTok - https://www.tiktok.com/en/privacy-policy
• Pinterest- https://policy.pinterest.com/en/privacy-policy
• Tumblr - https://www.tumblr.com/privacy
• LinkedIn - https://www.linkedin.com/legal/privacy-policy
• LINE - https://terms.line.me/line_rules

10. Cookie policy

10.1 What is “cookie”

Cookies are small data text files that are sent from a server during a browsing session. Cookies are typically stored on your computer’s hard drive and are used by web sites to simulate a continuous connection to that site. The use of cookies automatically identifies your browser whenever you interact with a site. When we talk about “cookies” in this Privacy Policy, we mean not just cookies, but all similar technologies.

Cookies and similar technologies allow us to collect the following types of personal data: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken through our Website; time and date of those actions; country and language selected.

Browsers and devices have tools that allow you to disable cookies on sites and apps. If you disable cookies you may not be able to access all the features of our Website. We suggest that you keep our essential cookies (described below) active for a better user experience and to help us keep improving and developing our products and Website.

Session cookies remember you during your session on our Website. They are deleted when you log out of the Website and when you close your web browser. Session cookies are used to ensure you are served content correctly, to balance and monitor load on our servers, and for other technical matters essential to the operation of our Website. You can configure your device to reject these cookies, but our Website will probably not work correctly, or at all, if you do.

Consent cookies are used by our consent management platform we employ to record your preferences about third party cookies described below, and to store and share your preference with those third parties. These cookies are essential for compliance with the legal obligations imposed on us and on third parties with whom we have a business relationship to ensure we request your consent, record your consent preferences, and act on such consent preferences.

Analytics cookies

Analytics cookies are used by us and by third parties who process data for us for data analytics purposes (for example Google Analytics) so that we can manage and improve the performance and design of our Website and for monitoring, auditing, research and reporting.
We have activated Google’s IP anonymisation function on our Sites. This will cause your IP address to be cut by Google within Member States of the European Union or in other countries party to the Agreement on the European Economic Area before being transmitted to the USA. Only in exceptional cases will the full IP address be transmitted to a Google server in the USA and shortened there. On our behalf, Google will use this information to evaluate your use of the Sites, to compile reports on Site activity and to provide us with other Website relating to website and internet use. The IP address transmitted by your browser in the context of Google Analytics is not merged with other Google data.
With respect to Google Analytics, you can read about how Google uses data gathered for that purpose here.

10.2 Third party cookies: advertising and affiliate links

Our ad partners and our affiliate links partners collect personal data from you for the purposes they disclose through our cookie consent management platform.

Ad partners include ad networks such as third party ad servers, ad agencies, ad technology vendors and research firms

Affiliate links partners pay us when you buy things from them or another third party after clicking on an affiliate link in our content.

Our ad partners use third party cookies to serve ads to you and to target you with tailored (or personalized) ads when you are using the Website and when you visit Third-Party Sites. They also use cookies to measure traffic on the Website (for example to track ad views).

Ad partners and affiliate links partners may view, edit or set their own cookies on your mobile device or web browser when you interact with our Website. They use cookies to track your use of our Website and your activities elsewhere online. We are not responsible for the privacy practices of these third parties and we encourage you to read their privacy policies so that you understand how they process information about you.

We provide links to their privacy policies in our consent management platform, which you can access by here.

You can decide who you will allow to set these third party cookies on your browser or device by going to our consent settings center. You can change your mind and revisit your consent choices at any time by returning there.

11. Privacy information for EEA and UK users

11.1 Information for UK/EU Users (including legal bases)

We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for another purpose, we will explain the legal basis we rely on.

The table below shows what we use your personal data for and the lawful basis for processing it in each case.

Purpose	Type of data
Recognize you and analyze how you, and other users, navigate the Website and apps and what type of content you’re interested in, and to manage and improve the Website by testing new features of our sites and apps. We do this by using cookies or similar technology as explained in our “Cookie Policy” section.	Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details.
Recognize you and analyze how you, and other users, interact with ads on our Website and what type of ads you’re interested in. We do this by using cookies or similar technology as explained in our “Cookie Policy” section.	Data that indirectly identifies you such as your IP address, mobile device ID and location data. This data does not include anything that allows us to identify you by name or contact details.
Communicate legal information to you.	Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information you include in your user profile).
Analyze comments and feedback you have given us including comments, feedback and reviews you have posted on our Website in order to use the information to carry out journalistic activities, to improve our Website and content offerings, and to enforce our Terms of Service.	Data that directly identifies you (such as your name, username, and email address) and data that indirectly identifies you (such as your IP address or mobile device ID and location data).
Provide you with communications and Website you’ve signed up, for such as our newsletters.	Data that directly identifies you such as your name, username, email address and location data.
Publish content on our Website including articles, feedback, reviews and user comments about our posts.	Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information included in your user profile).
Fulfill orders for subscriptions, products or Website placed through our Website.	Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.
Communicate our terms, notify you about changes to them and communicate with you about non-compliance.	Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username and email address).
Communicate our Privacy Policy and notify you of changes to them	Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username, and email address).
Conduct surveys or undertake similar types of research so that we can improve and develop our business, our Website.	Data that directly identifies you (such as your name, username, name, email address and location data)
Allow you to take part in a prize draw, sweepstake, or other competition or other promotional activity.	Data that directly identifies you such as your name, username, and email address.
Administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT Website, network security, fraud prevention, customer Website and business reorganization, including exchanging information with third parties for fraud protection and spam/malware prevention.	Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address).
Send marketing communications to you if you subscribe to our newsletters or other products and Website. Comply with applicable laws, regulations and legal and regulatory processes.	Data that directly identifies you such as your name and email address. Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and/or data that directly identifies you (such as your name, username, and email address).

11.2 Legal rights for EEA and UK users

If you are an EU or UK resident, you have certain rights in respect of the information that we hold about you. Below is a short overview of those rights:
Access. With some exceptions designed to protect the rights of others, you have the right to a copy of the personal data that we hold about you. Where the data is data that you have given to us, you have the right to receive your copy of it in a common electronic format, and to provide copies of it to other people if you wish.
Correction. You have the right to have the personal data we hold about you corrected if it is factually inaccurate. This right does not extend to matters of opinion, such as views expressed in editorial content.
Deletion. In some limited circumstances, you have the right to have personal data that we hold about you erased (the “right to be forgotten”). This right is not generally available where we still have a valid legal reason to keep the data (for example, because we are obliged to do so by law).
Objection. You have the right to object to our processing of your personal data where we rely on “legitimate interests” as our legal basis for processing, but we may be able to continue processing if our interest outweighs your objection.
Withdrawing consent. If we are processing your personal data on the basis of your consent, you have the right to withdraw that consent at any time, in which case we will stop that processing unless we have another legal basis on which to continue.

11.3 How to exercise your rights

To exercise your rights, email consent@u.today

In order to protect your privacy and that of others, we will ask you to prove your identity before we take any steps in response to a request you have made. If a third party is making a request on your behalf, we will ask them to prove that they have your permission to act for you.

We may contact you to ask you for further information to help you exercise your legal rights or to speed up our response. We will try to respond to requests within one month and we will let you know if we need to take longer, for example because your request is complicated. We may have an overriding lawful basis for processing your personal data, or certain exemptions may apply. If we refuse your request, we will explain why.

11.4 Complaints

You have the right to complain about data privacy matters to the Information Commissioner’s Office (www.ico.org.uk), or the relevant data protection regulator in your country of residence. You can contact the ICO on 0303 123 1113. We invite you to raise your concerns with us first, so that we can try to resolve them.

12. Privacy Information for California Residents

12.1 California Privacy Rights

This section provides you with our practices regarding the collection, use, and disclosure of your personal data in the 12 months prior to our last update to this Policy (see the date at the top). It also explains your rights regarding your personal data that we collect (as set forth in the California Consumer Privacy Protection Act or the “CCPA”).

Categories of Information We Collect:

• Online identifiers (e.g. IP address, ADID/IDFA, cookie IDs, internal identification numbers).
• Location data (e.g. your city, state or country information).

Categories of Sources:

• You
• Your device
• Data partners.

Purpose of Collection

• To communicate with you, including to process your requests for products/Website and/or information.
• To register your Account.
• To improve our Website, including to better understand our customer base, meet our diversity and inclusion goals; and to help our business partners do the same.
• To enforce our User Agreement, and for the administration and protection of our business.
• To comply with applicable law, regulations, and legal and regulatory processes.
• If you opt-in to do so, we may use your name and email address for our marketing purposes and to help our business partners with their marketing.

We may share your personal data with government entities when required to do by law. If you are a California resident, you have the right to know what personal data we collect, disclose, and “sell” about you (as that term is used in the CCPA).

Additionally, you have the right to access, delete and opt out from the “sale” of your personal data.

Specifically, California residents may request that we: Inform you about the categories of personal data we collect or disclose about you; the categories of sources of such data; the business or commercial purpose for collecting your personal data; and the categories of third parties with whom we share/disclose personal data. Such information is also set forth above in this Privacy Policy. Provide you access to and/or a copy of the specific pieces of personal data we collected about you (also called a data portability request) Delete certain personal data we have about you.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your rights.

Note for non-California residents: We will seek to honor requests to exercise the above rights made by non-California residents to the extent required by applicable law. Please note that certain data may be exempt from such access, data portability, and deletion requests under California law. For example, we need to retain certain data in order to provide the Website to you. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal data. You may also make a verifiable consumer request on behalf of your minor child. You may only make a verifiable consumer request for access or deletion twice within a 12-month period. You can submit your access or deletion request by signing into your account. You can find instructions on how to proceed at our consent settings center or contact us at consent@u.today

Please note that the verifiable consumer request must: Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal data or an authorized representative. Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. We cannot respond to your request or provide you with personal data if we cannot verify your identity or authority to make the request and confirm the personal data relates to you. Making a verifiable consumer request does not require you to create an Account with us. We will only use personal data provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

12.2 California Notice of Right to Opt-Out of “Sale”

California residents may opt out of the “sale” of their personal data. California law broadly defines “sale” in a way that may include allowing third parties to receive certain data, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on our Website or other sites and apps. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you content relevant to you. Depending on what Website you use, we may sell (as defined by California law) the following categories of data for such advertising purposes:

• Online Identifiers and internet activity information
• Contact details
• Demographic information
• Inferences about personal preferences and attributes drawn from profiling

If you would like to opt out of our use of your personal data for such purposes, you may do by contacting us at consent@u.today This will cause data to cease to be added to any cookies or other tracking technologies that have been set on our Website or block them entirely. Please note that you will need to opt out again if you visit one of our Website from a different device or browser or if you clear your cookies. Please note that we do not knowingly sell the personal data of minors under 16 years of age without legally-required affirmative authorization.

12.3 California Shine the Light Disclosure

Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask for a notice identifying the categories of personal customer data which we share with our affiliates and/or third parties for their own direct marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please submit a written request to the following address: 111 E. 18th Street, New York, NY 10003, Attn: Office of the General Counsel.