1. Data We Collect
When you use the Site, we collect and process the following types of information:
We collect information about your use of our Services, including, but not limited to, your Internet connections, computer equipment, web browsers, sites visited before using or accessing our Site, sites visited after leaving our Site, and other similar information about traffic and usage, as you navigate to, through, and away from our Site. This is called “Non-Personal Data” because it does not identify you, but provides insights to us regarding your use of the Services.
Web Beacons are tiny graphics with a unique identifier that may be included on our Services for several purposes, including to deliver or communicate with Cookies, to track and measure the performance of our Services, and to monitor how many visitors view our Services. Unlike Cookies, which are stored on the device, Web Beacons are typically embedded invisibly on web pages or in an e-mail.
Log Data refers to certain information about how a user (including both account holders and non-Account holders) uses our Services. Log Data may include information such as a user’s Internet Protocol address, browser type, operating system, the pages or features of our Services to which a User browsed and the time spent on those pages or features, search terms, the links on our Services that a user clicked on, and other statistics.
You may be given the option to receive push notifications while using our Services. In order to serve push notifications, we may need to collect your IP address and a persistent identifier from your device. You can turn off push notifications in your device settings.
When you sign up for our e-mail newsletter, respond to communications from us (e.g., surveys, requests for feedback), contact us via phone, e-mail, or postal mail, and so on, we will collect certain types of Personal Data that you provide to us. “Personal Data” is information that can be used to identify you, either alone or in combination with other information. You may be asked to provide, and we will collect, certain types of Personal Data, which may include your first and last names, e-mail address, and zip code.
You may choose to allow us to access your location by granting the Site access to your location when prompted or through your device’s location services settings. You may change these settings on your device.
When you connect to the Services, we are able to recognize the Internet protocol (IP) address of the computer providing you with Internet access. We may use this IP address to help diagnose problems with our server or otherwise administer our Services. This IP address may also be used to gather broad demographic information. Your IP address is never associated with you as an individual and never provided to another company or organization.
Additionally, if you choose to access, visit, and/or use any third-party social networking service(s) that may be integrated with our Service, we may receive your Personal Data and other information about you and your computer, mobile, or other device that you have made available to those social networking services, including information about your contacts on those services. For example, some social networking services allow you to push content from our Service to your contacts or to pull information about your contacts so you can connect with them on or through our Service. Some social networking services also will facilitate your registration for our Service or enhance or personalize your experience on our Service. Your decision to use a social networking service in connection with our Service is voluntary. However, you should make sure you are comfortable with the information your third-party social networking services may make available to our Service by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services.
2. Use of Data
For Legitimate Interests. We use information collected by clickstream data collection, web pixels, and cookies to store your preferences, improve website navigation, make personalized features and other services available to you, to generate statistical information, monitor and analyze user traffic and usage patterns, monitor and prevent fraud, investigate complaints and potential violations of our policies, to improve the our content and the products, services, materials, and other content that we describe or make available through the Site, and otherwise help administer and improve the Services.
We may identify you from your Personal Data and merge or co-mingle Personal Data and Non-Personal Data, for any lawful business purpose. Where you provide registration information, cookies can also be used to identify you when you log onto the Services or portions of the Services. Except as otherwise stated, we may use information we collect from you for the legitimate business purpose of providing our Services to you, including, but not limited to: 1
- to respond to your requests and provide user support;
- to evaluate and improve the content of our Services;
- to customize the Services to your preferences;
- to establish accounts to use the Services;
- to communicate information and promotional materials to you (where you have not expressed a preference otherwise);
- to notify you of any changes to relevant agreements or policies;
- to enforce our agreements, terms, conditions, and policies;
- to prevent or investigate fraud (or for risk management purposes), or to comply with a legal obligation, court order, or in order to exercise our legal claims or to defend against legal claims;
- to conduct aggregate analysis and develop business intelligence that helps us to enhance, operate, protect, make informed decisions and report on the performances of our Services;
- to describe our Services to current and prospective business partners and to other third parties for other lawful purposes; and
- for other purposes identified to you and as requested by you (please note that if you live in certain jurisdictions, you have the right to withdraw your consent to such use at any time by contacting us via the contact information in Section 13, below).
With the Consent of a Data Subject within the EEA; or without consent, if a citizen of any other jurisdiction. If you are a Data Subject within the EEA and we have obtained your consent, we may also use your information in the following ways; and, if you are a citizen of any other jurisdiction, you acknowledge that we may use your information in the following ways:
- to send e-mail and postal mail to provide you with updates and news;
- to process any request you make;
- to process any commercial transaction, including, but not limited to, fulfilling an order request; and
- to process your Personal Data as described throughout this Policy.
- to respond to your requests;
- to provide you with products you have requested;
- to fulfill your purchase order(s);
- to send you e-mail and postal mail supplying you with the most recent service information or to send you information about your order (e.g., order confirmations, shipment notifications, etc.);
- to notify you of any changes to relevant agreements or policies; and
We may use third‐party e‐mail providers to deliver these communications to you. If you no longer want to receive these e-mail communications, you may opt-out of receiving e-mail communications, as further discussed below.
We may, from time to time, invite you to participate in online surveys. The information requested in these surveys may include, but is not limited to, your opinions, beliefs, insights, ideas, activities, experience, purchase history, and purchase intent regarding products, events, and our Services. The information collected by these surveys is used to research market trends, company growth, etc. Your input will help us to improve customer experience and shape development of our products and Services.
We may anonymize or aggregate Data that we collect from the use of the Services, such as de-identified demographic information, de-identified location information, information about the computer or device from which you access the Services, market trends, and other analysis that we create based on the information we receive from you and other users. If you provide Personal Data through our Services, we may aggregate that Data with other active Data, unless we specify otherwise at the point of collection. 2
3. How We Share Data
We do have relationships with trusted third parties, but we will not share any Personal Data that we have collected from or regarding you except as described below:
- Service providers that help us administer and provide the Services (for example, a web hosting company whose services we use to host our platform). These third-party services providers have access to your Personal Data only for the purpose of performing services on our behalf. We have entered into contractual relationships with these service providers and require them to comply with all applicable data privacy laws and regulations and to use the Data only for the purposes for which it was disclosed.
- As we believe necessary: (i) under applicable law; (ii) to enforce applicable terms and conditions; (iii) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; (iv) to detect, prevent, or otherwise address fraud, security or technical issues; (v) to respond to claims that contact information (e.g. name, e-mail address, etc.) of a third-party has been posted or transmitted without their consent or as a form of harassment; and (vi) to respond to requests from courts, law enforcement agencies, regulatory agencies, and other public and government authorities, which may include authorities outside your country of residence;
- Pursuant to your explicit approval prior to the disclosure; and
- We may share aggregated, de-identified Data with our sponsors and business partners to let them know how many users viewed and interacted with their materials. This information does not identify any individual or corporate entity.
4. Third-Party Service Providers
We use third-party service providers to help us operate our Services, who may collect, store, and/or process the information detailed herein. We allow access to our database by third parties that provide us with services, such as technical maintenance, market research, customer relations management, and purchase functionality, but only for the purpose of and to the extent necessary to provide those services.
There are also times when you provide information about yourself to us in areas of the Services that may be managed or participated in by third parties. In such cases, the information may be used by us and by such third party(ies), each pursuant to its own policies.
Google Analytics. We have enabled Google Analytics to collect data about our traffic through the use of Google advertisements and other anonymous identifiers. We use Google Analytics cookies and other cookies to compile data to better understand users and provide users with a more tailored experience. You can opt out of Google Analytics by visiting Google’s Opt-Out Browser Add-on website here.
MailChimp. We use MailChimp e-mail marketing services to send blast e-mails to Users. We track how Users open these e-mails and what links they click so that we can better serve customers with services and information that they find relevant. When you “subscribe” to our mailing list, You agree to receive e-mail advertisements and other information from us. You can learn more about MailChimp’s privacy policies at its website here.
Upon receiving an e-mail from us, you may choose to opt-out of future e-mail messages, in accordance with the CAN-SPAM Act of 2003, by clicking “unsubscribe” option at the bottom of our e-mails and following MailChimp’s simple opt-out procedure.
WordPress. Our Site is a WordPress website. WordPress is an open-source content management system that we have used to build and support our Site. You can learn more about WordPress software, here.
For more information about third-party advertisers and how to prevent them from using your information, visit the NAI’s consumer website here or here. If you do want to opt out using these tools, you need to opt out separately for each of your devices and for each web browser (such as Internet Explorer, Firefox, or Safari) that you use on each device.
5. Data Security
We take reasonable steps online and offline to safeguard the Personal Data that you provide to us. Nonetheless, it is common knowledge that transmission of information via the Internet is not wholly secure, and we cannot guarantee the security of your Personal Data, or any other information, transmitted to or through any of our Services. Any transmission of Personal Data, or other information, is at your own risk. By using our Services, you acknowledge and accept these risks. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us or that are otherwise provided to us and we cannot be responsible for the theft, destruction, or inadvertent disclosure of information. It is your responsibility to safeguard any passwords, ID numbers, or other special access features associated with your use of the Services. Any transmission of information is at your own risk. By using our Services, you acknowledge and accept these risks.
If you have any questions about security on our Services, if you become aware of any unauthorized use of an account, loss of your account credentials, or if you suspect a security breach, notify us immediately via e-mail at email@example.com. If our security system is breached, we will notify you of the breach only if and to the extent required under applicable law.
6. Your Choices, Access, and Rights to Your Personal Data
You may also request the deletion of this information by sending an e-mail to firstname.lastname@example.org.
If you reside in certain jurisdictions, such as the EEA, you may also have the following rights and options with regard to accessing, reviewing, correcting, and updating your Personal Data, as well as how we use and disclose your Personal Data:
Right to Access. We respect your right to access and control your information and we will respond to requests for information and, where applicable, will correct, amend, or delete your Personal Data.
- How to Access Your Personally Identifiable Information. You may choose to access or update your Personal Data as it exists in our records by logging into the account you have created.
- Access to Personal Data. You may choose to access your Personal Data by contacting us and requesting access, a process which shall include our identity verification procedures. Before providing data to you, we will ask for proof of identity and sufficient information about your interaction with us so that we can locate any relevant data. We may also charge you a fee for providing you with a copy of your data (except where this is not permissible under local law).
Updating Communications Preferences (Opt-Out Policy). We do send e-mails to users with information about our Services that we believe may be of interest. Users may opt out of receiving e-mail messages by contacting us via e-mail at email@example.com or by clicking on the “unsubscribe” link found at the bottom of every e-mail that we send. Please note that if you opt-out of receiving marketing-related e-mails from us, we may still send you important administrative messages that are required to provide you with our Services, as applicable. If you do not opt-out using the link at the bottom of an e-mail, you will continue to receive electronic communications until you choose to click on the link that will be provided in each e-mail you receive from us.
Right to Rectify — Correction and Deletion. Citizens of some jurisdictions, including the EEA, have the right to correct or amend their Personal Data if it is inaccurate or requires updating. You may also have the right to request deletion of your Personal Data; however, this is not always possible due to legal requirements and other obligations and factors. Remember that you can update your account information by contacting us at firstname.lastname@example.org.
Right to Erasure / Be Forgotten. Data Subjects of the EEA may have the right to request that we delete your Personal Data in certain circumstances, such as if holding the Personal Data is no longer necessary or as part of your Right to Object (below).
Right to Object. Data Subjects of the EEA may have the right to object to the use of Personal Data for direct marketing uses, scientific uses, or historical research. If you do not wish to have your Personal Data shared with third parties, contact our Data Protection Officer as described at the end of this document. If you do not wish to receive future commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. (But note that you may continue to receive certain communications from us, such as transactional or relationship messages, and/or messages about your account/profile).
Right to Data Portability. Data Subjects of the EEA have the right to request that we provide your Personal Data for the purpose of sharing it with another service provider (through a secure process).
Filing a Complaint. If you are not satisfied with how we manage your Personal Data, you have the right to make a complaint to a data protection regulator. A list of National Data Protection Authorities can be found here.
7. Data Retention
At any time, users may request deletion of their accounts by e-mailing email@example.com. When you delete your account, it cannot be recovered.
Please note that we do retain Non-Personal Data, including aggregated, de-identified data for the purposes described in the section above titled “How We Use Data.”
8. Data Protection Officer
Our appointed Data Protection Officer is Christina Botteri If you have an inquiry regarding your Personal Data, pursuant to the rights listed above, please send your message to the following:
Data Protection Officer
Star News Digital Media
95 White Bridge Road, Suite 207
Nashville, TN 37205
9. Links to Third Party Sites
10. Children’s Privacy
We do not sell products or services for purchase by anyone under the age of thirteen (13). In accordance with the Children’s Online Privacy Protection Act (“COPPA”), we will never knowingly request or solicit Personal Data from anyone under the age of thirteen (13) without verifiable parental consent.
In the event that we receive actual knowledge that we have inadvertently collected such Personal Data without the requisite and verifiable parental consent, we will delete that information from our database as quickly as is practical. We reserve the right to request proof of age at any stage so that we can verify that minors are not using the Service(s).
11. Your California Privacy Rights
California Civil Code Section 1798.83 permits California residents to request and obtain a list of what Personal Data (if any) we disclosed to third parties for direct marketing purposes in the preceding calendar year and the names and addresses of those third parties. Requests may be made only once a year and are free of charge. Under Section 1798.83, California residents are entitled to request and obtain such information, by e-mailing a request to firstname.lastname@example.org.
13. How to Contact Us
By e-mail: email@example.com
By regular mail:
Attn: Website Inquiry
Star News Digital Media
950 White Bridge Road, Suite 207
Nashville, TN 37205
1 These are suggested ways in which you may be using Personal Data. Please add to / subtract from this list, as appropriate and applicable.
2 When you do this, you must disclose it and its purpose to the user. For those subject to GDPR, you must obtain express consent and maintain records of consent.
3 Is this applicable?