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
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. <
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.
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.
9. Third-Party Sites
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
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|
|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).|
|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 email@example.com
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.
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:
- 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.
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 firstname.lastname@example.org
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 email@example.com 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.