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1. What Personal Information Do We Gather About You?
When you use the NGNY Services by, among other actions, ordering a subscription or other product, providing registration details, setting newsletter preferences, browsing our sites, completing a survey, entering a contest or otherwise interacting with our NGNY Services, we gather personal information. Personal information is information that identifies you as an individual or relates to an identifiable individual. Several different types of personal information can be gathered when you interact with the NGNY Services, depending on the type of product or service being used. Collection of personal information is necessary to delivering you the NGNY Services or to enhance your customer experience.
We and our service providers collect personal information in a variety of ways, including:
A) Through the NGNY Services.
i. Registration: When you register for a NGNY Service, we collect personal information. For example, registration on NGNYimes.com can be done by supplying a unique email address and password, or by linking your Facebook or Google accounts. See below under “From Other Sources” for more information about linking your Facebook or Google Accounts. Registration to an event or conference requires that you complete a form that will include, at a minimum, your name and email address.
ii. User-Generated Content and Public Activities (Including Comments and Reader Reviews): We offer you opportunities to engage in public activities on newsgateny.com and other NGNY Services. “Public activities” are any actions you take on NGNY Services that are designed to be visible to other users, including comments, recommendations, reader reviews, ratings or any other items that you submit. If you choose to engage in public activities, you should be aware that any personal information you submit can be read, collected and used by other users of these services. We are not responsible for the personal information you choose to submit in the course of your public activities and we have no responsibility to publish, take down, remove or edit any of your public activities or submissions (except as required by applicable laws).
iii. Reader Surveys, Reader Panels and Market Research: We and our service providers collect personal information from you through voluntary surveys or feedback programs conducted via the NGNY Services, through our service providers’ platforms, by phone, by mail or during in-person interviews or focus groups. We will ask you for your consent to the processing of information at the point of collection. We also conduct similar research for advertisers.
iv. Reader Experience Programs: When you interact with our interactive programs and answer questionnaires, we collect personal information about you.
B) From Other Sources.
i. Publicly available databases, including privately-held marketing and data analytics resources. For example, we may receive demographic information (age, sex, household income, job industry and job title) from these sources.
ii. Joint marketing third party, when they share the information with us.
2. What Do We Do With The Personal Information We Collect About You?
We collect, use or otherwise process personal information as allowed under applicable law, including where based on one or more of the following:
– The consent you provide to us at the point of collection of your personal information;
– The performance of the contract, if any, we have with you;
– The compliance of a legal obligation to which we are subject; or
– The legitimate interests of the Newsgate New York, LLC, a third party or yourself. “Legitimate interest” is a technical term under the regulation. It means that there are good reasons for the processing of your personal information and measures are taken to minimize the impact on your privacy rights and interests. “Legitimate interest” also references our use of your data in ways you would reasonably expect and that have a minimal privacy impact. We have a legitimate interest in collecting and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within the Newsgate New York, LLC; and (3) to prevent fraud.
A) Provide the NGNY Services You Request. We use the information we gather about you to enable your use of the NGNY Services and fulfill your requests for certain products and services, such as providing the NGNY Services’ functionality to you, providing you with customer service, responding to your inquiries, requests, questions, suggestions, compliments or complaints, completing your transactions, sending you administrative information (such as change of our terms, conditions, or policies) enabling you to participate in and renew paid services, polls, promotions, surveys, panels or research, and message boards. We will engage in these activities to manage our contractual relationship with you or comply with a legal obligation.
B) Analysis and Development of New Products and Services. We perform statistical, demographic and marketing analyses of users of the NGNY Services, and their subscribing and purchasing patterns, so we can analyze or predict our users’ preferences for product and services development purposes, to determine our promotional campaign effectiveness so we can adapt our campaign to the needs and interests of our users, and to generally inform advertisers about the nature of our subscriber base. We use this information for analytical purposes, including analysis to improve customer relationships, to support strategic business decisions and our marketing tactics and to measure and track our brand health. We will engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest in doing so.
C) Customizing Your Experience. We use the information that we have to better understand you and customize certain features of the NGNY Services to provide you with an enhanced experience including to show you offerings, promotions or products that may be of interest to you, based on the demographic information, type of device you are using to access the NGNY Services, your usage of the NGNY Services and your reading history. We will provide personalized services because we have a legitimate interest.
D) Administrative Purposes. We and our service providers use the information we have about you for the following legitimate business purposes:
● For auditing purposes, to verify that our internal processes function as intended and comply with legal, regulatory and contractual requirements;
● For fraud and security monitoring purposes, including, for example, to detect and prevent cyberattacks; and
● To understand and assess satisfaction with our NGNY Services or our customer care team.
We engage in these activities to manage our contractual relationship with you, to comply with a legal obligation, or because we have a legitimate interest.
E) Aggregating and/or Anonymising Personal Information. We aggregate and/or anonymize personal information so that it will no longer be considered personally identifying. We do so to generate other data for our use, which we may use and disclose for any purpose.
3. With Whom Do We Share The Personal Information We Gather?
We may access, preserve and disclose personal information if we are required to do so by law or we have a good faith belief that such action is necessary to (1) comply with the law or with legal process; (2) protect and defend our rights and property; (3) protect against misuse or unauthorized use of the NGNY Services; (4) protect the personal safety or property of our users or the public (among other things, this means that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions); and (5) cooperate with public and government authorities (which may be outside your country of residence).