California Consumer Privacy Act

Notice to California Residents – Your California Privacy Rights:

This section of the Privacy Policy is FOR CALIFORNIA RESIDENTS and supplements the information contained in the McClatchy Privacy Policy and Privacy Policies of its subsidiaries (collectively, “we,” “us,” or “our”) and applies solely to visitors, users, and others who reside in the State of California (“consumers” or “you”). We adopt this notice to comply with California privacy laws, including the California Consumer Privacy Act of 2018 (“CCPA”) and to provide you with information concerning our business’s practices, both online and offline, regarding the collection, use, disclosure, and sale (if applicable) of Personal Information (as defined below) and of the rights of California consumers regarding their own Personal Information.

By accessing the Services, you expressly consent to the collection, use, disclosure and storage of your Personal Information and other information received by us as a result of such use in accordance with this Privacy Policy and the Terms of Service or your consent, and as permitted or required by applicable law. In order to provide our Services (as defined in the McClatchy Privacy Policy), we may use third-party service providers in the United States to store and process data, including your Personal Information, on our behalf. When acting on our behalf, such service providers are only authorized to collect, use, disclose or store Personal Information as described in this Privacy Policy. However, the government, courts, law enforcement, security, or regulatory agencies may be able to obtain access to or disclosure of Personal Information as required by law.

Information We Collect

At various times, we may collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“Personal Information”). We may have collected the following categories of Personal Information from consumers (when applicable) within the last twelve (12) months:

This Policy does not address the following categories of Personal Information which are not covered by CCPA:

• Publicly available information from government records.
• De-identified or aggregated consumer information.
• Information protected under other laws, such as health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA) or clinical trial data; or
• Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver's Privacy Protection Act of 1994.

Sources of Personal Information We Collect

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you or your agent. For example, during account registration, we may ask for Personal Information such as your name, e-mail address, year of birth, gender, street address, job title and industry and related information.
• Directly and indirectly from activity on our website. For example, we may collect Personal Information that you provide us when you comment on articles, participate in message boards, and submit images, photos, videos, or other content to the Services.
• From third-parties that interact with us in connection with the Services we perform. We may receive Personal Information about you from third parties, including third party social networking services and advertising partners. We, our service providers, and other third parties with whom we do business may collect information about you from publicly available sources (e.g., social media platforms) and commercially available resources. We may combine that Personal Information with the Personal Information described above and will handle the combined Personal Information as described in this Privacy Policy. You should always review, and if necessary, adjust your privacy settings on third-party websites and services before linking or connecting them to the Services. You may also unlink your third-party account from the Services by adjusting your settings on the third-party service. We also may collect Personal Information about you from third-party business partners, publicly available sources, and our subsidiaries and affiliates.

Use of Personal Information

We may use or disclose the Personal Information we collect for one or more of the following business purposes and commercial purposes:

• To provide you with products and services, respond to your requests, manage contests, and to personalize the content on our services;
• Internal auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance with this specification and other standards;
• Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity;
• Debugging to identify and repair errors that impair existing intended functionality;
• Short-term, transient use, provided the Personal Information that is not disclosed to another third party and is not used to build a profile about a consumer or otherwise alter an individual consumer's experience outside the current interaction, including, but not limited to, the contextual customization of ads shown as part of the same interaction;
• Performing services on behalf of the business or service provider, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing financing, providing advertising or marketing services, providing analytic services, or providing similar services on behalf of the business or service provider;
• Undertaking internal research for technological development and demonstration;
• Undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us;
• To provide you with email alerts, event registrations and other notices concerning our products or services, or events or news, that may be of interest to you;
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collections;
• To improve our website and present its contents to you;
• To communicate with you about your account; learn about you; send you or provide you with ads, such as tailored ads, offers, or other content based on your interests;
• To resolve disputes;
• Collect payment information, such as your credit card number and expiration date, where appropriate to process a financial transaction you have requested;
• To improve, maintain, and troubleshoot our services; and
• To comply with regulatory or legal processes.

Sharing Personal Information

We may disclose or sell your Personal Information to a third party for a business or commercial purpose.  In the preceding twelve (12) months, we may have disclosed or sold the following categories of Personal Information for a business purpose or a commercial purpose:

• Identifiers
• California Customer Records Personal Information categories.
• Protected classification characteristics under California or federal law.
• Internet or other similar network activity
• Geolocation data
• Inferences drawn from other Personal Information

We share Personal Information with the following categories of third parties:

• Our affiliates;
• Service providers;
• Government regulators;
• Parties involved in a legal process; 
• To an entity involved in the sale of our business; and 
• Third parties to whom you or your agents authorize us to disclose your Personal Information in connection with products or services we provide to you.

As disclosed above, we and our advertising partners may collect Personal Information (such as the cookies stored on your browser, the advertising identifier on your mobile device, or the IP address of your device) when you visit our site (or use our app). We, and our partners, use this Personal Information to tailor and deliver ads to you on our site (or app), or to help tailor ads to you when you visit others' sites (or use others' apps). To tailor ads that may be more relevant to you, we and/or our partners may share the information we collect with third parties.

CCPA Consumer Privacy Rights

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes those CCPA rights and explains how to exercise those CCPA rights.
 
Right to Know About Personal Information Collected, Disclosed, or Sold

You have the right to request that we disclose certain information to you about our collection, use, and disclosure of your Personal Information over the past 12 months. Once we receive and confirm your verifiable consumer request, we will disclose to you:

• 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.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
  • sales, identifying the Personal Information categories that each category of recipient purchased; and
  • disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.

Right to Request Deletion of Personal Information

Subject to certain exceptions, you have the right to request that we delete the Personal Information that we collected about you. Once we receive and confirm your verifiable consumer request, we will delete your Personal Information from our records subject to certain exceptions. In the event that we are unable to honor a request, we will inform you of the reasons behind the decision.

Right to Opt-Out of the Sale of Personal Information

In the event that we sell your Personal Information, you have the right to submit a request to opt-out of the sale of your Personal Information. You may also choose to opt-out of the sales of certain categories of Personal Information, should you choose. You may later choose to permit us to sell your Personal Information. 

In the event that we sell your Personal Information and if you do not wish for us to sell your Personal Information to third parties for advertising purposes (if we sell your Personal Information), select the applicable control from the “Do Not Sell My Personal Information” link provided. After opting out, we may continue to share some Personal Information with our partners (who will function as our service providers in such instance) to help us perform advertising-related functions such as, but not limited to, measuring the effectiveness of our ads, managing how many times you may see an ad, reporting on the performance of our ads, ensuring services are working correctly and securely, providing aggregate statistics and analytics, improving when and where you may see ads and/or reducing ad fraud. If you access this site (or app) from other devices or browsers, visit the link below from those devices or browsers to ensure your choice applies to the Personal Information collected when you use those devices or browsers.

Additionally, although clicking the “Do Not Sell My Personal Information” link will opt you out of the sale of your Personal Information for advertising purposes, it will not opt you out of the use of previously collected and sold Personal Information (except for Personal Information sold within 90 days prior to your exercising your right to opt out) or all interest-based advertising. If you would like more information about how to opt out of interest-based advertising in desktop and mobile browsers on a particular device, please visit http://optout.aboutads.info/#/ and http://optout.networkadvertising.org/#. You may download the AppChoices app at http://www.aboutads.info/appchoices to opt out in connection with mobile apps, or use the platform controls on your mobile device to opt out.

Right to Non-Discrimination for the Exercise of a Consumer’s Privacy Rights

You have a right to not receive discriminatory treatment for exercising your CCPA rights. We respect your rights and we will not discriminate against you in violation of the CCPA for exercising any of your CCPA rights. 

Notice of Financial Incentive

We do not offer any financial incentive, benefit, or price differences in return for the disclosure, deletion, or sale of Personal Information. 

Procedures for Exercising Your CCPA Consumer Rights

To exercise the CCPA consumer rights described above, please submit a verifiable consumer request to us by either:

• Calling us at:  +1 (888) 914-9661 PIN: 590 963
• Visit these sites:  
  • Request Information/Request Deletion
  • Do Not Sell My Personal Information 

 
In order to protect your Personal Information, please note that:

• Only you or an authorized agent 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 only make a verifiable consumer request for access or data portability twice within a 12-month period;
• The request must provide sufficient information that allows us to reasonably verify you are the person about whom we collected Personal Information or an authorized representative; and
• The description of the request must provide sufficient detail that allows us to properly understand, evaluate, and respond to it.

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.  Although you may use an authorized agent to submit a request to opt-out on your behalf, we may deny a request from an authorized agent that does not submit proof with the request that they have been authorized by you to act on the consumer’s behalf.

It is important to know that you are not required to create an account with us to make a verifiable request. We will only use Personal Information provided in a verifiable consumer request to verify the requestor's identity or authority to make the request.

Response Timing and Format

If you have an account with us, we may deliver our written response to that account. If you do not have an account with us, we will deliver our written response through our web portal. Any disclosures we provide will only cover the 12-month period preceding your verifiable request's receipt.  For data portability requests, we will select an industry-acceptable format to provide your Personal Information.

Unless a request is manifestly unfounded or excessive, we will not charge a fee to process or respond to your verifiable consumer request. If we determine that a request is manifestly unfounded or excessive, we will tell you why we made that decision and reserve the right to either refuse to act on your request or charge you a reasonable fee to complete your request. 

Changes to Our Privacy Policy

We reserve the right to amend section of the Privacy Policy at our discretion and at any time. When we make changes to the Privacy Policy, we will notify you by email or through a notice on our website homepage.

Contact Information

If you have any questions or comments about this notice, our Privacy Policy, the ways in which we collect and use your Personal Information, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: +1 (888) 914-9661 PIN: 590 963

Website: mcclatchy.com

Email: [email protected]

Postal Address:

McClatchy Privacy Office

2100 Q Street

Sacramento, CA 95816-6899

Last Updated: December 2019