Salt Lake Tribune Privacy Notice

Effective Date: January 1, 2020

Updated: January 1, 2020

This is the Notice of the Privacy Policy (“Notice” or “Policy”) for the Salt Lake Tribune (“Tribune,” “SL Trib,” “we,” “us,” or “our”). It describes the types and uses of personal information that we may collect readers or users of our online platform (www.sltrib.com) and mobile apps (collectively, the “Services”).

1. Our Contact Details

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 600

Salt Lake City, UT 84101

[email protected]

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.

2. The Salt Lake Tribune and Scope of this Privacy Notice

The Salt Lake Tribune is Utah’s largest newspaper. It makes its Pulitzer Prize-winning journalism available at sltrib.com. The Salt Lake Tribune respects that part of being a socially responsible outlet for top journalism means being transparent about our use of the personal information of our subscribers, website visitors, social media outlets, and mobile apps.

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.

This Notice is part of, and is governed by, our Terms of Service.

3. Summary of Our Collection, Use, and Sharing of Personal information

Our collection and uses of personal information are summarized as follows:

Personal Information: Collection and Uses

Category:

Subscriber/purchaser information (contact information, payment information, topics of interest, votes, and non-public feedback on projects and features)

Uses:

(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

Sharing

(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

Category:

Contributions intended for publication (such as comments and letters to the editor)

Uses:

(1) to consider it for publication

(2) to share it with our users and subscribers

Sharing:

(a) with our service providers

(b) users of our Services (our readership)

Category:

Usage information (such as URLs requested, IP addresses, device identifiers, session cookies, device identifiers, and browser type)

Uses:

(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

Sharing:

(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

4. Details of the Information We Collect and Our Collection Methods

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:

• User Information. “User Information” means information collected about readers or users of sltrib.com and may include the following categories: name, email address, telephone number, physical address, payment card account number(s) and related information, and online identifiers, such as a social media identifier, an avatar name, or “handle.” We collect User Information through interactive webforms when you sign in, register, or purchase a subscription to use our Services. We use a third-party payment processor to handle payment transactions. To the extent you deal directly with any payment processor or any other party, you will be subject their privacy policies and should familiarize yourself with such policies.

• User-Generated Content. “User-Generated Content” refers to information that you provide when you interact with our Services that may be associated with your profile, such as comments on articles, voting preferences for projects and features, or other types of voluntarily submitted information. You can provide User-Generated Content through posting comments on interactive webforms or through communications with Tribune staff (e.g., a letter to the editor, or an email to a reporter regarding an article).

• Usage Information. “Usage Information” means information that tells about your interactions with and use of our website. We automatically collect this information from you whenever you use the Services. Usage Information includes your IP address, which may indicate the location from which you are accessing our website. Usage Information also might include information about the device(s) you use to access our website. One of the primary reasons we collect Usage Information is implement our limited free article access program and paywall requirements. Users who do not subscribe to the Tribune may view a limited number of full articles each month. After they view the maximum number of free articles allowed, a subscription is required to gain full access to additional articles. Maintaining the ability to encourage subscription through limited access is absolutely critical to remain viable. Usage Information also enables us to, among other things, improve our Services and your experience, see which areas and features of our Services are popular and count visits, administer our website, track how you engage with our websites and other Services, learn about the systems, browsers, and apps you use to interact with our Services, and gather demographic information about our user base as a whole. This includes how often the Services are used, the events that occur within the application, aggregated usage, performance data, any exceptions that occur within the software and the source from which the application was downloaded.

• Cookies and Other Tracking Technologies. Usage Information is gathered primarily through the use of cookies similar technologies, such as web beacons. Cookies are pieces of information or data sent to your browser from a web server and stored on your computer’s hard drive for record-keeping purposes. Cookies tell our computer that you’ve visited before and can help to make your visit more personal so you don’t have to re-enter information on a return visit. Certain cookies – known as “session cookies” – keep track of your activities during a particular visit so that your experience with our websites can be enhanced and unified, rather than disjointed. “Persistent cookies” track a user over time and allow us to implement our limited free article program. Cookies also allow us to count the number of unique and return visitors who use our website. Web beacons are web page elements that can recognize certain types of information on your computer or mobile device, such as the time and date you viewed a page, which emails are opened, which links are clicked, and similar information.

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.

The information collected through cookies includes standard information from your browser, your IP address, and the actions you take including the pages you view and the links you click. These cookies do not necessarily personally identify you and can be controlled in your Internet browser including the “Do Not Track” option. Most browsers are initially set up to accept cookies. If you prefer, you can reset your browser to notify you when you’ve received a cookie or, alternatively, to refuse to accept cookies. It is important to note that you may not be able to use certain features like checking out (and participate in certain offerings) on our website if you choose not to accept cookies. You can read more about this type of data-driven marketing and your options for opting-out of such marketing on the Network Advertising Initiative website at https://www.networkadvertising.org.

We also use the services of Piano, which allows us to provide non-subscribers with a limited amount of content. Piano’s use of information capable of identifying you that it collects through supporting our Services is limited to providing its services to us. Piano’s privacy notice, available at https://piano.io/privacy-policy/, provides further information about how Piano uses information.

5. How We Use The Information We Collect

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.

SL Trib also uses your Personal Data for interest-based advertising, retargeting, and contextual advertising. Interest-based advertising involves the collection of data across different web domains so we can deliver ads that are tailored to your interests. Our retargeting practices allow SL Trib to show you products we think you would be interested in based on your activity on the Services. Contextual ads are customized based on the content you are viewing at any particular time. Again, you can read more about this type of data-driven marketing or to opt-out on the Network Advertising Initiative website, http://www.networkadvertising.org/managing/opt_out.asp. For additional information about disabling cookies, visit: www.aboutads.info/choices.

This Site is affiliated with Publisher First, Inc. dba Freestar (“Freestar”) for the purposes of placing advertising on the Site, and Freestar will collect and use certain data for advertising purposes. To learn more about Freestar’s data usage, click here.

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.

6. How We May Share Your Information with Other Parties

We may share the Personal Information collected through your use of the Services with service providers and other parties, as described below:

• Our Service Providers. As noted above, we rely on service providers to run our organization, including the operation of our website and limited free article access program. We may share your Personal Data with our third-party distributors, vendors, suppliers and others who provide services to us or on our behalf, such as operating and supporting the Services, hosting the Services, providing payment processing services, performing marketing or consulting services, and with processing and fulfillment functions. Usage Information is automatically provided to the services providers that power our website and help us administer the limited free article access program, and they are restricted from using information that could identify a particular user or household outside of the provision of services to us. Similarly, we may share your Personal Data with project creators, who may use the information to fulfill product orders, develop and improve their products, and contact you about product orders, future products, or their company in general.

• Public Content. If you post comments, images, and other content to a project page, that information (associated with your user name) will be publicly viewable.

• Third-Party Analytics Provers. We may share your information and Personal Data with our advertising and analytics partners, such as Google Analytics. The privacy policy of these providers applies to their collection, use and disclosure of your information. These third parties may combine your information with the information of other consumers for purposes of conducting these studies and/or analytics. You can learn more about Google Analytics’ processing of your personal information at https://policies.google.com/technologies/partner-sites.

• Our Affiliates. We may share some or all of your information with our subsidiaries and corporate affiliates, joint venturers, 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.

• Transfer or Assignment in Connection with Business Transfers or Bankruptcy. In the event of a merger, acquisition, reorganization, bankruptcy or other sale of all or a portion of our assets, we may transfer the personal information we hold to a successor business. Except as otherwise ordered by a court or required by law, the use and disclosure of all transferred user information will be subject to this notice. However, any information you submit or that is collected after this type of transfer may be subject to a new privacy policy adopted by the successor entity.

• Response to Subpoenas, Court Orders, Third Party Requests or Protection of Our Rights. We may disclose your information to government authorities or third parties if:

• 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.

7. Your Choices

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.

8. California Privacy Rights

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.

B. California Residents’ Rights of Access to Specific Information

California residents have the right to request that we disclose certain information to them about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Consumer Rights, below), 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.

C. Deletion Request Rights

California residents have the right to request that we delete any of your personal information that we collect from them, subject to certain exceptions. Once we receive and confirm your verifiable consumer request (see Exercising Consumer Rights, below), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

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.

D. The Right to Opt-Out – The Right to Stop the Sale of Personal Information

California residents have the right to opt out of any sale of your information to a third party, i.e., to prevent a transfer of information to a third party that is not restricted in certain ways from making use of the information. But as we explained above, we do not sell your information.

E. Exercising Consumer Rights

To exercise the rights described above, please submit a verifiable consumer request to us by one of the following methods:

• Emailing us at [email protected];

• 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 600, Salt Lake City, UT 84101

You may also use this webform to submit a request.

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.

F. Response Timing and Format

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.

G. Non-Discrimination

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.

H. Shine the Light Disclosure

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.

9. How We Protect Your Information

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.

10. How You Can Protect Yourself

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.

11. No Use by Children

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.

12. Changes to This Privacy Notice

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.

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I. Contact Us