Effective May 14, 2024

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Welcome!

We take your privacy seriously and know you do too. This Privacy Policy is here to help you understand how we collect, process, and share your Personal Data (defined below). We also describe your Rights & Choices with respect to how we process your Personal Data. Please read this Privacy Policy carefully.

Who We Are

This is the Privacy Policy of Colorado Springs Gazette. LLC and its subsidiaries (“Gazette,” “us,” “our,” or “we”). You can contact us here.

Scope of This Privacy Policy

This Privacy Policy applies to our "Services" which include our:

• "Digital Services" including all websites (“Sites”) and mobile applications ("Mobile App(s)") owned by Colorado Springs Gazette, LLC that link to/post this Privacy Policy, including any subdomains or mobile versions.

•  "Offline Services" including:
• print publications ("Publications") and data you may provide in connection with your subscription to and receipt of our Publications.
• offline events we may host or in which we may participate ("Events"); and
• customer service telephone lines, and other offline means of providing Personal Data to us.

This Privacy Policy does not apply to information collected by third parties, for example, when you visit a third-party website or interact with online advertisements, unless and until we receive your information from those parties. Please review those third parties’ privacy policies before disclosing information to them.

Contact Us/Controller

The controller of your Personal Data under this Policy is Colorado Springs Gazette. LLC. You may contact our Data Privacy Team as follows:

The following describes how we process data relating to identified or identifiable individuals and households (“Personal Data”).

Categories of Personal Data We Process

The categories of Personal Data we process may include:

Limit the Use of My Sensitive Personal Data

Sources of Personal Data We Process

We collect Personal Data from various sources, which include:

Note:  please click the following links to view information on Data Retention or Regional Data Rights for any of the processing contexts listed below.

Account Registration

We process Identity Data, Preference Data, and Contact Data when you register and create an account for our Services. We process Payment Data if you associate payment information with that account.

We use this Personal Data to create and maintain your account, to provide the products and services you request, and for our Business Purposes. We may process Identity Data, Preference Data, and Contact Data for Commercial Purposes (which may include data sales/sharing).

Purchases and Transactions

We process Identity Data, Payment Data, Transaction Data, and Contact Data you complete a purchase or sale transaction through our Services. We do not permanently store your Payment Data, except at your request.

We process this Personal Data as necessary to perform or initiate a transaction with you, process your order, payment, or refund, carry out fulfillment and delivery, document transactions, and for our Business Purposes. We may process Identity Data, Transaction Data, Contact Data, and Device/Network Data for Commercial Purposes (which may include data sales/sharing). We do not sell or “share” Payment Data or use it for Business Purposes not permitted under applicable law.

Marketing Communications

We process Device/Network Data, Contact Data, Identity Data, and Inference Data in connection with marketing emails, SMS, push notifications, telemarketing, or similar communications, and when you open or interact with those communications. You may receive marketing communications if you consent and, in some jurisdictions, as a result of account registration or a purchase.

We process this Personal Data to contact you about relevant products or Services and for our Business Purposes. We may use this data for our Commercial Purposes (which may include data sales/sharing). Marketing communications may also be personalized as permitted by applicable law, but will not involve Targeted Advertising or the processing of Sensitive Personal Data where users have opted out or not provided necessary consents. See your Rights & Choices to limit or opt out of this processing.  We may use various third party tools to analyze our user behavior on our Services, user engagement with our communications, and user purchase behavior on our Digital Services, in order to tailor marketing and content recommendations accordingly. 

Digital Services

Generally

We process Device/Network Data, Contact Data, Identity Data, General Location Data, and Preference Data when you use our Services. You may also be able to complete purchases, register for an account, or enroll in marketing communications through our Digital Services.

We use this Personal Data as necessary to operate our Digital Services, such as keeping you logged in, delivering pages, etc., for our Business Purposes, and our other legitimate interests, such as:

• ensuring the security of our websites, Mobile Apps and other technology systems; and
• analyzing the use of our Services, including navigation patterns, clicks, etc., including by using session recording technology, to help us understand how users are interacting with our Services, and to help us improve the Services.

We may also process this Personal Data for our Commercial Purposes (which may include data sales/sharing). Commercial Purposes may include, for example:

• analyzing user behavior and analytics to create content or marketing recommendations
• analyzing user engagement with our communications including push notifications and email
• analyzing user purchase behavior on Digital Services

Mobile Apps

If you use our Mobile Apps, we may process Identity Data, Device/Network Data, Inference Data, and General Location Data.

We process this Personal Data to provide our App, for our Business Purposes, and our other legitimate interests, such as:

• to optimize the display and functionality of the App on your device.
• provide contextual information to you.
• deliver features that require the use of Location Data.
• creating aggregate information about users’ location and patterns, which we use to help improve our Services.

We may process this Personal Data for our Commercial Purposes (which may include data sales/sharing).

Cookies and other tracking technologies

We process Identity Data, Device/Network Data, Contact Data, Preference Data, and General Location Data, in connection with our use of cookies and similar technologies on our Digital Services. We may collect this data automatically.

We and authorized third parties may use cookies and similar technologies for the following purposes:

• for “essential” purposes necessary for our Digital Services to operate (such as maintaining user sessions, content delivery networks, and the like);
• for “functional” purposes, such as to enable certain features of our Digital Services (for example, to allow a customer to maintain an online shopping cart);
• for “analytics” purposes and to improve our Digital Services, such as to analyze the traffic to and on our Digital Services (for example, we can count how many people have looked at a specific page, or see how visitors move around the website when they use it (including by using session recording technology), to distinguish unique visits/visitors to our Digital Services, and what website they visited prior to visiting our website, and use this information to understand user behaviors and improve the design and functionality of the website);
• for “retargeting,” Targeted Advertising, or other advertising and marketing purposes, including technologies that process Preference Data or other data so that we can deliver, buy, or target advertisements which are more likely to be of interest to you; and
• for “social media” e.g. via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter.

We may also process this Personal Data for our Business Purposes and Commercial Purposes (which may include data sales/sharing). See your Rights & Choices for information regarding opt-out rights for cookies and similar technologies.

Third parties may view, edit, or set their own cookies or place web beacons on our websites. We, or third-party providers, may be able to use these technologies to identify you across platforms, devices, sites, and services. Third parties may engage in Targeted Advertising using this data. Third parties have their own privacy policies, and their processing is not subject to this Policy.

Contests and Promotions

We may collect and process Identity Data, Preference Data, certain Contact Data, and User Content when you enter a contest/sweepstakes or take part in a promotion.

We process this Personal Data as necessary to provide the contest/promotion, notify you if you have won, or to process delivery of a prize, for our Business Purposes, and other legitimate interests, such as:

• verifying your identity for authentication, anti-fraud, and security purposes (in which case we may process Government ID Data to complete verification);
• to improve our Services and to create a personalized user experience; and
• to contact you about relevant products or services, and in connection with marketing communications and Targeted Advertising.

We may process Identity Data, Contact Data, and User Content information for our Commercial Purposes (which may include data sales/sharing).

Some programs and offers are operated/controlled by our third-party partners or their affiliates or partners. We may receive this data from third parties to the extent allowed by the applicable partner; otherwise, this Privacy Policy will not apply to data processed by third parties.

Your Personal Data may be public. If you win a contest/sweepstakes, we may publicly post some of your data. We do not post Personal Information without consent where required by law. See any program agreement(s) for additional details and terms.

Contact Us, Support

We collect and process Identity Data, Contact Data, and User Content when you contact us, e.g., through a contact us form, or for support. If you call us via phone, we may collect Audio/Visual data from the call recording.

We process this Personal Data to respond to your request, and communicate with you, as appropriate, and for our Business Purposes. If you consent or if otherwise permitted by law, we may use Identity Data and Contact Data to send you marketing communications and for our Commercial Purposes (which may include data sales/sharing). We may also share Personal Data collected in connection with a support request with our Service Providers.

Feedback and Surveys

We process Identity Data, Contact Data, Inference Data, Preference Data, and User Content collected in connection with feedback you provide to us, surveys or questionnaires.

We process this Personal Data as necessary to respond to your requests/concerns, for our Business Purposes, and other legitimate interests, such as analyzing customer satisfaction.  We may process this Personal Data for our Commercial Purposes (which may include data sales/sharing). We may share Feedback/Survey data relating to third party partners with those partners, who may use it for their own purposes.

Business Purposes

We and our Service Providers process Personal Data we hold for numerous business purposes, depending on the context of collection, your Rights & Choices, and our legitimate interests. We generally process Personal Data for the following “Business Purposes.”

Service Delivery

We process Personal Data as is necessary to develop and provide our Services, and the products and services you purchase or request, including to authenticate users and their rights to access the Services, or various data, features, or functionality, and as otherwise necessary to fulfill our contractual obligations to you, to provide you with the information, features, and Services you request, and for editorial purposes, including creating content for our Services. Additionally, we use information to authenticate your right to access our Services, deliver products and Services, and for other related matters. Similarly, we may use Personal Data as necessary to audit compliance, and log or measure aspects of service delivery (e.g. to document ad impressions).

Internal Processing and Service Improvement

We may use any Personal Data we process through our Services as necessary in connection with our legitimate interests in improving the design of our Services, understanding how our Services are used or function, for customer service purposes, in connection with logs and metadata relating to service use, and for debugging and similar purposes relating our identification of errors and improving the stability of the Services. Additionally, we may use Personal Data to understand what parts of our Services are most relevant to users, how users interact with various aspects of our Services, how our Services perform, etc., or we may analyze use of the Services to determine if there are specific activities that might indicate an information security risk to the Services or our users.

Security and Incident Detection

We may process Personal Data in connection with our legitimate interest in ensuring that our Services are secure, and identify and prevent fraud, detect security incidents, protect against, and respond to malicious, deceptive, fraudulent, or illegal activity. We may analyze network traffic, device patterns and characteristics, maintain and analyze logs and process similar Personal Data in connection with our information security activities.

Compliance, safety, public interest

We may also process any Personal Data as necessary to comply with our legal obligations, such as where you exercise your rights under data protection law and make requests, for the establishment and defense of legal claims, or where we must comply with our legal obligations, lawful requests from government or law enforcement officials, and as may be required to meet national security or law enforcement requirements or prevent illegal activity. We may also process Personal Data to protect the vital interests of individuals, or on certain public interest grounds, each to the extent allowed under applicable law. Please see the data sharing section for more information about how we disclose Personal Data in extraordinary circumstances.

Aggregated Data

We process Personal Data in order to identify trends (to create aggregated and anonymized data, use of our Services, and other similar information (“Aggregated Data”). We may pass Aggregated Data to the third parties referred to in the section below to give them a better understanding of our business and to bring you a better service. Aggregated Data will not contain information from which you may be personally identified.

 Personalization

We process certain Personal Data as necessary in connection with our legitimate business interest in personalizing our Digital Services. For example, aspects of the Digital Services may be customized to you, to display content that you have interacted with in the past, or to display content that we think may be of interest to you based on your interactions with our Digital Services and other content. This processing may involve the creation and use of Inference Data relating to your preferences. In some cases, these inferences may be created as a result of using third party technology to engage in analysis of your activities and preferences when using our Services.

Commercial Purposes

We and certain third parties process Personal Data we hold for certain purposes, depending on the context of collection and your Rights & Choices, including:

Profiles

In order to understand our customers’ preferences, and better recommend content and Services that are personalized to our customers, we may create a “Profile” by linking together and analyzing Personal Data collected in the following contexts:

• Account Registration
• Purchases and Transactions
• Using our Digital Services
• Contest and promotions
• Contact Us; Support
• Feedback and Surveys

We may also augment Profiles with Personal Data that we create (such as Inference Data) or that we receive from our affiliated companies or third parties and may include Personal Data such as information about Services you have used or purchased previously, and demographic data.

We use Profiles for our legitimate interests in market research and statistical analysis in connection with the improvement of our Services. For example, we may analyze the Personal Data of customers who have subscribed to our Services in the past and compare them with other people in our database. If we identify customers in the database who have similar Personal Data to the subscribers, we may then target marketing to the new customers we have identified in our database, for example by sending marketing emails. We may conduct the profiling and send the direct marketing emails automatically. We may also use this information for other Commercial Purposes.

Personalized Marketing Communications

We may personalize Marketing Communications based on your Profile. If consent to Consumer Profiling or Targeted Advertising is required by law, we will seek your consent.

Targeted Advertising

We, and certain third parties operating on or through our Services, may engage in in display advertising or place third party advertisements for third parties’ products and services on our Services. Such advertising may involve the processing of Personal Data in order to build a profile about you and tailor the advertisements you see based on your interests, whether on our Services or across other sites (“Targeted Advertising”). The profiles and interests used for Targeted Advertising may be inferred or derived from Personal Data that we or those third parties obtain or infer from your activities across non-affiliated websites, applications, or services This form of advertising includes various parties and services providers, including third party data controllers, engaged in the processing of Personal Data in connection with Targeted Advertising. These parties may be able to identify you across sites, devices, and over time.

The parties that control the processing of Personal Data for Targeted Advertising purposes may create or leverage information derived from Personalization, Profiles, and Marketing Communications. In some cases, these parties may also develop and assess aspects of a Profile about you to determine whether you are a type of person a company wants to advertise to, and determine whether and how ads you see are effective. These third parties may augment your profile with demographic and other Preference Data, and may track whether you view, interact with, or how often you have seen an ad, or whether you purchased advertised goods or services.

We generally use Targeted Advertising for the purpose of marketing our Services and third-party goods and services, and to send marketing communications, including by creating custom marketing audiences on third-party websites or social media platforms.

Data Sales and “Sharing” (for behavioral advertising purposes)

We may engage in “sales” or “sharing” for behavioral advertising purposes (also referred to as Targeted Advertising by certain state laws) of data as defined by applicable law. For example, we may “sell” certain Personal Data when we engage in marketing campaigns with or on behalf of sponsors, conduct Targeted Advertising, or we may sell, “share” for behavioral advertising purposes, or grant access to Personal Data to our marketing partners, and other advertisers in relation to Targeted Advertising as described below, joint promotions, and other marketing initiatives. See the  US States/California, Colorado, Others section for a list of categories of Personal Data sold or shared.

We may disclose Personal Data to the following categories of third-party recipients and/or for the following reasons:

You may have certain rights and choices regarding the Personal Data we process. Please note, these rights may vary based on the state where you reside, and our obligations under applicable law. See the following sections for more information regarding your rights/choices in specific regions:

• US States/California, Colorado, Others

Your Rights

You may have certain rights and choices regarding the Personal Data we process. See the “Regional Supplement” section below for rights available to you in your jurisdiction. To submit a request, contact our Data Privacy Team. We verify your identity in connection with most requests, as described below.

Verification of Rights Requests

If you submit a request, we typically must verify your identity to ensure that you have the right to make that request, reduce fraud, and to ensure the security of Personal Data. If an agent is submitting the request on your behalf, we reserve the right to validate the agent’s authority to act on your behalf.

We may require that you match personal information we have on file in order to adequately verify your identity. If you have an account, we may require that you log into the account to submit the request as part of the verification process. We may not grant access to certain Personal Data to you if prohibited by law.

Your Choices

Marketing Communications

You can withdraw your consent to receive marketing communications by clicking on the unsubscribe link in an email. You can also withdraw your consent to receive marketing communications or any other consent you have previously provided to us by contacting us. To opt-out of the collection of information relating to email opens, configure your email so that it does not load images in our emails.

Withdrawing Your Consent/Opt-Out

Where we are processing your Personal Data based on your consent, you may change your mind and withdraw your consent at any time. The consequence of you withdrawing consent might be that we cannot perform certain services for you, such as location-based services, personalization or providing certain types of advertising, or other services conditioned on your consent or choice not to opt-out.

Location Data

You may control or limit Location Data that we collect through our Services by changing your preferences in your device’s location services preferences menu, or through your choices regarding the use of Bluetooth, WiFi, and other network interfaces you may use to interact with our Services.

Cookies, Similar Technologies, and Targeted Advertising

General

- If you do not want information collected through the use of cookies and similar technologies, you can manage/deny cookies (and certain technologies) using your browser’s settings menu or our Manage Cookies page. You may need to opt out of third-party services directly via the third party. For example, to opt-out of Google’s analytic and marketing services, visit Google Analytics Terms of Use, the Google Policy, or Google Analytics Opt-out.

Targeted Advertising

- You may opt out or withdraw your consent to Targeted Advertising (including “sharing” for cross-context behavioral advertising) by visiting our Privacy Rights Portal. In some cases, you may be able to opt-out by submitting requests to third party partners, including for the vendors listed below:

• Google Ads
• Facebook Custom Audience Pixel/Ad Preferences
• Twitter Audience Pixel
• Digital Advertising Alliance’s opt-out

• Network Advertising Initiative opt-out

Global Privacy Control (GPC)

- Our Digital Services may support certain automated opt-out controls, such as the Global Privacy Control (“GPC”). GPC is a specification designed to allow Internet users to notify businesses of their privacy preferences, such as opting-out of the sale/sharing of Personal Data. To activate GPC, users must enable a setting or use an extension in the user’s browser or mobile device. Please review your browser or device settings for more information regarding how to enable GPC.

Please note: We may not be able to link GPC requests to your Personal Data in our systems, and as a result, some sales/sharing of your Personal Data may occur even if GPC is active. See the “Regional Supplements” section below for more information regarding other opt-out rights.

Do-Not-Track

- Our Services do not respond to your browser’s do-not-track request.

We implement and maintain commercially reasonable security measures to secure your Personal Data from unauthorized processing. While we endeavor to protect our Services and your Personal Data unauthorized access, use, modification and disclosure, we cannot guarantee that any information, during transmission or while stored on our systems, will be absolutely safe from intrusion by others.

We retain Personal Data for so long as it is reasonably necessary to achieve the relevant processing purposes described in this Privacy Policy, or for so long as is required by law. What is necessary may vary depending on the context and purpose of processing. We generally consider the following factors when we determine how long to retain data (without limitation):

• Retention periods established under applicable law;
• Industry best practices;
• Whether the purpose of processing is reasonably likely to justify further processing;
• Risks to individual privacy in continued processing;
• Applicable data protection impact assessments;
• IT systems design considerations/limitations; and
• The costs associated with continued processing, retention, and deletion.

We will review retention periods periodically and may pseudonymize or anonymize data held for longer periods.

Our Services are neither directed at nor intended for use by persons under the age of 13 in the US, or under the age of 13 to 16 in the EEA, UK, Switzerland, Cayman Islands, or 15/16 in Australia. If we learn that we have inadvertently done so, we will promptly delete such Personal Data if required by law. Do not access or use the Services if you are not of the age of majority in your jurisdiction unless you have the consent of your parent or guardian.

We may change this Privacy Policy from time to time. Changes will be posted on this page with the effective date. Please visit this page regularly so that you are aware of our latest updates. Your use of our Digital Services following notice of any changes indicates acceptance of any changes.

US States/California, Colorado, Others

US States: California, Colorado and Certain Other States - Privacy Rights & Choices

Under the California Consumer Privacy Act (“CCPA”), the Colorado Privacy Act, and other state privacy laws, residents of certain US states may have the following rights, subject to regional requirements, exceptions, and limitations.

Confirm

- Right to confirm whether we process your Personal Data.

Access/Know

- Right to request any of following: (1) the categories of Personal Data we have collected, sold/shared, or disclosed for a commercial purpose; (2) the categories of sources from which your Personal Data was collected; (3) the purposes for which we collected or sold/shared your Personal Data; (4) the categories of third parties to whom we have sold/shared your Personal Data, or disclosed it for a business purpose; and (5) the specific pieces of Personal Data we have collected about you.

Portability

- Right to request that we provide certain Personal Data in a common, portable format.

Deletion

- Right to delete certain Personal Data that we hold about you.

Correction

- Right to correct certain Personal Data that we hold about you.

Opt-Out (Sales, Sharing, Targeted Advertising, Profiling)

- Right to opt-out of the following:

• If we engage in sales of data (as defined by applicable law), you may direct us to stop selling Personal Data.
• If we engage in Targeted Advertising (aka “sharing” of personal data or cross-context behavioral advertising,) you may opt-out of such processing.
• If we engage in certain forms of “profiling” or “automated decision-making” (e.g. potentially resulting in legal or similarly significant effects), you may opt-out of such processing.

Opt-out or Limit Use and Disclosure of Sensitive Personal Data

- right to opt-out of the processing of certain Sensitive Data, or request that we limit certain uses of Sensitive Personal Data. To the extent permitted by applicable law, this right may not apply in cases where we only use Sensitive Personal Data where necessary, or for certain business purposes authorized by applicable law.

Opt-in/Opt-out of Sale/Sharing of Minors’ Personal Data

- To the extent we have actual knowledge that we collect or maintain personal information of a minor under age 16 in California, those minors must opt in to any sales/sharing of personal information (as defined applicable state laws), and minors under the age of 13 must have a parent consent to sales/sharing of personal information. All minors have the right to opt-out later at any time.

Non-Discrimination

- California residents and others may have the right to not to receive discriminatory treatment as a result of your exercise of rights conferred by applicable state laws.

List of Direct Marketers

- California residents may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year.

Remove Minors’ User Content

- Residents of California under the age of 18 can delete or remove posts using the same deletion or removal procedures described above, or otherwise made available through the Services. If you have questions about how to remove your posts or if you would like additional assistance with deletion, contact us using the information below. We will work to delete your information, but we cannot guarantee comprehensive removal of that content or information posted through the Services.

Submission of Requests

You may submit requests as follows (please our review Verification of Rights Requests section). If you have any questions or wish to appeal any refusal to take action in response to a rights request, contact us at privacy@gazette.com. We will respond to any request to appeal within the period required by law.

Categories of Personal Data Disclosed for Business Purposes

For purposes of the CCPA, we have disclosed to Service Providers for “business purposes” in the preceding 12 months the following categories of Personal Data, to the following categories of recipients:

Categories of Personal Data Sold, Shared, or Disclosed for Commercial Purposes

For purposes of the CCPA, we have “sold” or “shared” in the preceding 12 months the following categories of Personal Data in the, to the following categories of recipients:

Categories of Sensitive Personal Data Used or Disclosed

For purposes of CCPA, we may use or disclose the following categories of Sensitive Personal Data: Government ID Data; Payment Data; Precise Location Data. However, we do not sell or share Sensitive Personal Data, or use it for purposes other than those listed in CCPA section 7027(m).