Salt Lake Tribune Privacy Notice
If you have any questions, comments, or concerns about this Notice or about the Tribune’s use of your personal information, you may contact us at:
Salt Lake Tribune
Attn: Privacy Office
90 S. 400 W., Suite 700
Salt Lake City, UT 84101
801-257-8742
We may share some or all of your information with our subsidiaries and corporate affiliates, business partners, or other companies that are or may become under common control with us. We will require these entities to comply with the terms of this notice with regard to their use of your information.
This Notice does not apply to information collected about you by third parties (such as the operators of social media outlets or search engines that lead users to our content) or to information we collect about employment applicants, employees, and other business partners.
This Notice describes the personal information we collect, how we use it, with whom we share it, and your rights relating to your personal information. It also describes the security procedures we use to protect your personal information.
By accessing or using the Services, or by clicking the “accept” button when you register to use a Service, you consent to our use of your Personal Data as described in this Notice. This Notice may change from time to time. Your continued use of a Service after we make changes is deemed to be acceptance of those changes, so please check the Notice periodically for updates.
Our collection and uses of personal information are summarized as follows:
Subscriber/purchaser information (contact information, payment information, topics of interest, votes, and non-public feedback on projects and features)
(1) to provide and deliver our products and Services that you have requested
(2) to communicate with you about our products and Services
(3) to authenticate you and tailor content
(4) to improve our products and create new products
(5) for our internal accounting, security, record-keeping, and operational purposes
(6) to respond to correspondence from purchasers or subscribers
(7) for purposes required by law
(a) with our service providers, including shipping/delivery service providers, information system service providers, data network service providers, and analytics providers, to help us deliver and improve the Services
Contributions intended for publication (such as comments and letters to the editor)
(1) to consider it for publication
(2) to share it with our users and subscribers
(a) with our service providers
(b) users of our Services (our readership)
Usage information (such as URLs requested, IP addresses, device identifiers, session cookies, device identifiers, and browser type)
(1) to improve our products and create new products
(2) to provide targeted advertising to persons outside the EU and EEA
(3) to better understand how our customers use our Services
(4) for our internal accounting, security, and operational purposes
(5) for purposes required by law
(a) with our service providers
(b) with our advertising partners as described in Section 4, below.
A more detailed description of these practices is presented in the following sections
We collect information from you in two ways. First, you provide us with certain information when you register for and use our Services. Second, we collect certain information automatically as you interact with our Services. The “Personal Information” or “Personal Data” that we collect from you – that is, the information that identifies you as an individual or relates to an identifiable person – and our collection methods fall into multiple categories:
Information that may be collected by cookies and web beacons when you use the Services may include, without limitation:
• web pages you visit;
• date and time of your visit to or use of the Services;
• usage and activity data related to the Services;
• websites you visit before or after visiting the Services;
• browser type;
• Internet Protocol (IP) address used to connect your computer or mobile device to the Internet;
• your computer or mobile device and connection information, such as your browser type and version, operating system, and platform; and
• your device identifier.
Some components of our Services – including cookies or other tracking technologies – are delivered through service providers. These include content providers, application providers, and platforms that help us provide limited free use of our Services and administer our paywall program. These may also include advertisers, ad networks, and ad servers. This practice allows us and other websites to show you products that might be of interest to you. Although we do not receive information from these sources about you, these sources may use cookies or other tracking technologies to develop a profile of you that includes data about your behaviors and activities from our Services and others to provide interest-based (behavioral) advertising or other targeted content. Such advertising and content are clearly marked so that if you have any questions about an advertisement or other targeted content, you can contact the responsible provider directly.
We may use information collected from or about you for any of the following purposes:
• developing, providing and improving the SL Trib products and Services;
• assisting with fulfillment of product orders;
• managing and verifying your account and the identity of users of the Services;
• contacting you when necessary about your account or your use of the Services;
• sending you information and promotional materials about our products and Services as well as our company in general;
• responding to support requests;
• maintaining records;
• conducting internal reviews of our Services to help us better understand visitors’ and customers’ uses of our Services;
• protecting the security and integrity of our Services;
• complying with court orders, legal process and third-party requests, and to enforce our Terms of Service and this Notice; and
• any other legal, business or marketing purposes that are not inconsistent with the terms of this Notice.
We may combine information we collect about you through the Services with other information about you that we receive from third-party sources. By way of example and not limitation, we may use a change of address or other list service to ensure that our records for your account are accurate.
We may share the Personal Information collected through your use of the Services with service providers and other parties, as described below:
• you have given us permission to share your information;
• we are required to do so by law, or in response to a subpoena or court order;
• we believe in our sole discretion that disclosure is reasonably necessary to protect against fraud, or to protect our property or other rights, or those of other users of our Services, third parties, or the public at large, or to resolve or avoid disputes; or
• we believe that you have abused our Services through conduct that violates applicable laws or our Terms of Service.
We provide the opportunity to opt out of receiving communications from us and our partners when we request information about you. In addition, you may unsubscribe or opt out of receiving communications from us by clicking the unsubscribe link on marketing communications you receive. You may not opt out of email that we need to send to you regarding your account and use of our Services.
You may also change certain details in your profile by logging in and revising or deleting your account information.
You may have the right to access the personal information we collect about you or to request the correction of any errors in that information. For details, please contact us at the address above.
We provide personal information collected from customers under strict restrictions to our service providers. Our service providers are restricted from making use of customer information outside of providing services to us.
• The categories of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business or commercial purpose for collecting or selling that personal information.
• The categories of third parties with whom we share that personal information.
• The specific pieces of personal information we collected about you.
We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:
• Complete the transaction for which we collected the personal information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.
• Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
• Debug products to identify and repair errors that impair existing intended functionality.
• Exercise of free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
• Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
• Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
• Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
• Comply with a legal obligation.
• Make other internal and lawful uses of that information that are compatible with the context in which you provided it.
To exercise the rights described above, please submit a verifiable consumer request to us by one of the following methods:
• Calling us at toll-free at 1-866-758-8742; or
• Writing to us at Salt Lake Tribune, Attn: Privacy Office, 90 S. 400 W., Suite 700, Salt Lake City, UT 84101
We are also in the process of securing a toll-free number to handle privacy-related inquiries. When we have this capability, we will update this Policy.
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 information. 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 data portability twice within a 12-month period.
To verify the identity of an individual making a request, a two-step process will need to be completed. A verifiable consumer request must:
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
• Separately provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.
We will endeavor to respond to a verifiable consumer request within 45 days of its receipt. If we require more time, we will inform you of the reason and extension period in writing.
If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.
Any disclosures we provide will cover only the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
We will not discriminate against you for exercising your CCPA rights. Unless permitted by the CCPA, we will not:
• Deny you goods or services.
• Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
• Provide you a different level or quality of goods or services.
• Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.
However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to your personal information’s value and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time. However, we do not currently provide any financial incentives.
Under California Civil Code sections 1798.83-1798.84, California residents are entitled to ask us for a notice that identifies the categories of Personal Data we share with affiliates and/or third parties for marketing purposes, and provides contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please write to us at the address at the top of this privacy notice.
We have implemented commercially reasonable measures designed to secure personal information from unauthorized access, use, alteration, and disclosure. However, the transmission of information via the Internet is not completely secure and we cannot guarantee the security, integrity, or privacy of information exchanged between us. As we state in our terms of service, we do not assume any responsibility or liability beyond what is imposed on us by law for the security of personal information transmitted via the Internet.
Even the best policy can’t protect your online privacy and security in all circumstances. Unscrupulous advertisers, hackers, and scam artists are constantly searching the Internet looking for new targets. Your best protection is to understand the limits to privacy on the internet and use common sense in all of your on-line activities.
Be aware that email is an inherently insecure form of communication. Remember that third parties are sometimes able to illegally intercept your unencrypted messages, including online greetings.
Anytime you visit a chat room or post a message to an online bulletin board, your email address can be accessed by advertisers looking to compile lists for unsolicited commercial email (also known as spam). Be sure that you only disclose your email address in circumstances in which it is safe to do so. Beware of scams in which persons unknown to you request your screen name, password, or credit card information. Make sure you verify the identity of anyone asking for personal information. Always monitor your children’s online activities and educate them as to the rules for safe Internet use.
We do not knowingly collect contact information from children under the age of 13 without verifiable parental consent. If we become aware that a visitor under the age of 13 has submitted personal information without verifiable parental consent, we will promptly delete the information.
We may change this notice from time to time. If we decide to make a material change in this notice, we will post it on this page. Your continued use of our Services after the posting of changes to this notice will mean you accept these changes. In some cases, we may attempt to contact you through an email or other address you have provided, so we can give you choices about our using your information in a manner different from that stated at the time of collection. If we make any material changes in our privacy practices that affect personal information already in our systems, we will apply those changes to that older information only with your consent or as otherwise allowed by law.
104810924.1 0058578-00008
Telephone is (801) 257-8742.
Address:
The Salt Lake Tribune
90 South 400 West, Suite 700
Salt Lake City, Utah
84101