Effective December 13, 2023
- Scope of This Policy
- Agreement to Terms
- Information We Collect
- Children’s Privacy
- Our Use of Personal Information
- Our Disclosure of Personal Information
- Your Privacy Choices
- Additional Disclosures for Residents of the European Union (EU) and the United Kingdom (UK)
- Links to Other Websites
- How to Contact Us
1. Scope of This Policy
2. Agreement to Terms
3. Information We Collect
We may collect the following categories of personal information (a) directly from you (such as when you create an account, post comments and/or content on the Site, or contact us, (b) from third-parties such as data vendors and social media networks, (c) from the device and browser that you use to access the Service, and (d) from cookies and similar technologies.
We may collect your first name, last name, email address, postal address, and account username and password.
Financial and Transactional Information
We may collect payment details (such as credit or debit card information), billing address, and order history.
We collect the information and content of communications that you share through the Service. This may include your name, username, likes, status, profile information and/or picture.
Demographics and Characteristics
We may collect information regarding your email address, company name, job title, billing address and information, event attendance, newsletter engagement, survey data, political views and opinions. This information is used to better tailor the features, performance and support of the Site and Services for users.
We may collect your profile photo in the event that you choose to add a photo to your account.
Social Media Information
If you access or log-in to the Site through a social media or other service or connect the Site and/or Service to a social media or other service, we may collect your user ID and/or user name associated with that social media service, any information or content you have permitted the social media service to share with Punchbowl News, such as your profile picture, email address or friends lists, and any information you have made public in connection with that social media service.
We may collect device information when you visit our Site. Device information may include your device type, browser type, online and/or unique identifiers, IP address, and geolocation information.
We may collect information concerning your interaction with the Site, including when you access the Site and your browsing activity on the Site (such as which pages you visit, in what order, and for how long). This may also include “traffic data” or tracking information provided by the Site’s host or similar providers (e.g., Google Analytics) that may be helpful for marketing purposes or for improving the Site.
Other Identifying Information that You Voluntarily Choose to Provide
We may collect identifying information that you include in your responses to surveys or questionnaires or in emails, letters, texts, or other communications you send to us.
We store certain information that gets collected automatically at our end through cookies and other similar technologies. A cookie is a small string of information that a website that you visit transfers to your browser for identification purposes. Cookies can be used to follow your activity while using a website or across websites, and that information helps companies understand your preferences and tendencies, as well as improve and personalize your website experience. Some cookies are necessary to operate a website, while others can be functional, analytical, or used for marketing purposes, including targeted advertising (as discussed in more detail below). Cookies on the Site are generally divided into the following categories:
- Strictly Necessary Cookies. These are required for the operation of the Site. They include, for example, cookies that enable you to log into password-protected portions of the Site. These cookies are session cookies that are erased when you close your browser.
- Analytical/Performance Cookies. These allow us to recognize and count the number of visitors to the Site and understand how such users navigate through the Site (e.g., when and which pages are visited, in what order the pages are visited, and where a user is located).
We also use Google Analytics for part of this process. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. Google provides users with the ability to prevent their data from being used by Google Analytics—learn more by going to https://tools.google.com/dlpage/gaoptout.
- Functional Cookies. These improve the functional performance of the Site and make it easier for you to use. For example, cookies are used to remember that you have previously visited the Site and asked to remain logged into it (e.g., this saves your username). These cookies qualify as persistent cookies because they remain on your device for use during your next visit to the Site. You can delete these cookies as detailed below.
- Targeting Cookies. These record your visit to the Site and the pages you have visited and the links you have followed, to recognize you as a previous visitor, and to track your activity on the Site and other websites you visit. These cookies are used to display ads on other websites based on your visits to our Site and other online activity. These cookies qualify as persistent cookies because they remain on your device.
You can also prevent the use of certain cookies by modifying your Internet browser settings, typically under the sections “Help,” “Internet Options,” or “Settings.” If you disable or delete certain cookies in your Internet browser settings, you may still access our Site, however, you might not be able to access or use important functions or features of our Site, and you may, for example, be required to re-enter your log-in details.
We may serve advertisements, and also allow third-party ad networks, including third-party ad servers, ad agencies, ad technology vendors and research firms, to serve advertisements through the Service. These advertisements may be targeted to users who fit certain general profile categories or display certain preferences or behaviors (“Targeted Ads”). Information for Targeted Ads (including personal information) may be provided to us by you, or derived from the usage patterns of particular users on the Service and/or services of third parties. Such information may be gathered through tracking users’ activities across time and unaffiliated properties, including when you leave the Site. To accomplish this, we or our advertising partners may deliver cookies, including a file known as a “web beacon,” from an ad network to you through the Service. Web beacons allow ad networks to provide anonymized, aggregated auditing, research and reporting for us and for advertisers. Web beacons also enable ad networks to serve Targeted Ads to you when you visit other websites. Web beacons allow ad networks to view, edit or set their own cookies on your browser, just as if you had requested a web page from their site.
Punchbowl News complies with the Digital Advertising Alliance (“DAA”) Self-Regulatory Principles for Online Behavioral Advertising. Through the DAA and Network Advertising Initiative (“NAI”), several media and marketing associations have developed an industry self-regulatory program to give consumers a better understanding of, and greater control over, ads that are customized based on a consumer’s online behavior across different websites and properties. To make choices about Targeted Ads from participating third parties, including to opt-out of receiving Targeted Ads from participating organizations, please visit the DAA’s or NAI’s consumer opt-out pages, which are available at https://www.aboutads.info/choices or http://www.networkadvertising.org/choices/. Users in the European Union should visit the European Interactive Digital Advertising Alliance’s user information website at https://www.youronlinechoices.eu/.
At this time, we do not recognize automated “do-not-track” browser signals.
5. Children’s Privacy
The Service is not intended for users under the age of 16 and Punchbowl News does not knowingly collect personal information from individuals under the age of 16. If you are aware of, or suspect that, someone under the age of 16 is using the Service without permission, please notify us immediately by contacting us at email@example.com or as detailed in the How to Contact Us section below. If you have questions or concerns about the Internet and privacy for your child, we encourage you to check out the FTC Guidelines for protecting your child’s privacy online.
6. Our Use of Personal Information
We collect and use your personal information for the following purposes:
- Providing the Service to you and providing products or services requested by, or reasonably anticipated within the context of our relationship with, you;
- Managing our relationship with you, and responding to your inquires or requests, and requesting feedback;
- Analyzing use of the Site;
- Providing relevant promotional materials or other marketing;
- Administering promotions, events, contests, sweepstakes, or surveys;
- Keeping track of your shopping cart;
- Keeping track of login names and passwords;
- Keeping track of click stream data;
- Tailoring web content and advertisements to your interests;
- Personalizing the Site (e.g., name automatically appears on the Site);
- Detecting security incidents and protecting against malicious, deceptive, fraudulent, or illegal activity, or prosecuting those responsible; and
- Complying with legal and regulatory obligations.
7. Our Disclosure of Personal Information
We may share your personal information with the following third parties:
- Our group companies, including our parent companies, affiliates, and/or subsidiaries.
- Service providers, including hosting, technology, analytics and communications providers and security and fraud prevention consultants. In some instances, service providers will be directly responsible to you for their use of your personal information. They may be obliged by law to provide you with additional information regarding the personal information that they hold about you and how and why they process that information. Further information may be provided to you in a separate notice or may be obtained from such service providers directly, for example, via their websites.
- Other users, such as if you post comments or content to our message boards, chat rooms, blogs, product review forums, and other interactive forums that we may make available as part of the Service.
- Business and promotional partners, such as when you enter or participate in promotions, contests, polls, or sweepstakes (collectively, “Promotions). These business and promotional partners may use your personal information to administer the Promotion or for their marketing purposes, but only in conformance with their privacy policies as made available to you at the time of collection. Punchbowl News is not responsible for such business and promotional partners’ privacy policies or practices.
- Advertising networks to provide you with relevant marketing.
- Advisers and financial institutions, including auditors, notaries, business continuity support service providers, and legal, tax, and risk and compliance advisors.
- With third parties in connection with a change to the control or financial status of the company, including a corporate restructuring, sale, acquisition, financing, reorganization, bankruptcy, receivership, transfer, assignment of assets, or business merger or divestiture. Personal information and other information may be shared in the diligence process with counterparties and others assisting with the transaction and transferred to a successor or affiliate as part of that transaction.
- Government bodies, dispute resolution organizations, law enforcement agencies, or third parties in connection with (a) responding to a subpoena, search warrant, or other lawful request for information that we receive; (b) cooperating in a law enforcement or similar investigation; or (c) otherwise protecting our rights, as applicable.
8. Your Privacy Choices
If you no longer want to receive our newsletter, emails, or other marketing communications, you may unsubscribe at any time by following the “Unsubscribe” link in the relevant communication or by contacting us as described in the How to Contact Us section below.
To opt-out of text messages, you may text “STOP” in reply to any Punchbowl News marketing text message.
Please note that you cannot unsubscribe from certain correspondence from us, including messages relating directly to your account or purchases placed through the Site.
By logging into your account, you may view, update, and/or delete certain information associated with your account (e.g., name, email address) You may also view, update, and/or delete this information by contacting us at the contact information in the How to Contact Us section below. We may request that you verify your identify by providing us with your name and email address. You may also request that we delete your user account.
We maintain reasonable technical and organizational measures to protect personal information from loss, misuse, alteration, or unintentional destruction. We have implemented various security measures to protect both the personal information and the general information that we receive from you through the Service. Whenever you give out personal information online there is a risk that third parties may intercept and use that information. Although we seek to protect your personal information and privacy, we cannot guarantee the security of any information you disclose online. To the extent permitted under applicable law, we assume no liability or responsibility for disclosure of your information due to errors in transmission, unauthorized access by third parties, or other causes beyond our control.
You play an important role in keeping your information secure. You should not share your username or password with anyone. If you have reason to believe that your account is no longer secure, please contact us immediately at the contact information in the How to Contact Us section below.
10. Additional Disclosures for Residents of the European Union (EU) and the United Kingdom (UK)
This section provides additional information for residents of the EU and UK.
As a US company, most of our operations are conducted in the United States and in order to provide the Service, personal information will be processed in the United States, where laws regarding processing of personal information may be less stringent than the laws in your country. We provide appropriate protections for cross-border transfers as required by applicable law for international data transfers. With respect to transfers originating from the European Economic Area, we implement the standard contractual clauses approved by the European Commission.
Retention of Your Personal Information
We retain personal information for as long as necessary to fulfill the purposes for which the information was collected; as needed to address tax, corporate compliance, employment, litigation, and other legal rights and obligations; and as otherwise permitted by law.
Legal Basis for Processing Your Personal Information
Where required, we have several different legal grounds on which we collect and process your personal information for the purposes set out in the Our Use of Personal Information section above, including: (i) as may be necessary to perform a contract with you; (ii) as necessary to comply with a legal obligation; (iii) consent (where consent has been provided as appropriate under applicable law); and (iv) as necessary for our legitimate interests (such as when we act to maintain our business generally, including maintaining the safety and security of the Service).
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or that otherwise significantly affects you.
As available and except as limited under applicable law, individuals in the EU and UK have the rights described below:
- Access. You have the right to request a copy of the personal information we are processing about you, which we will provide to you in electronic form.
- Rectification. You have the right to require that any incomplete or inaccurate personal information that we process about you is amended.
- Deletion. You have the right to request that we delete personal information that we process about you, unless, for example, we are required to retain such information to comply with a legal obligation or to establish, exercise, or defend a legal claim.
- Restriction. You have the right to request that we restrict our processing of your personal information where: (i) you believe such data to be inaccurate; (ii) our processing is unlawful; or (iii) we no longer need to process such data for a particular purpose, but where we are not able to delete the data due to a legal or other obligation or because you do not want us to delete it.
- Portability. You have the right to request that we transmit the personal information we hold with respect to you to another data controller.
- Objection. Where the legal justification for our processing of your personal information is our legitimate interest, you have the right to object to such processing on grounds relating to your situation. We will abide by your request unless we have compelling legitimate grounds for the processing which override your interests and rights, or if we need to continue to process the data to establish, exercise, or defend a legal claim.
- Withdrawing Consent. If you have consented to our processing of your personal information, you have the right to withdraw your consent at any time, free of charge. Please note that if you withdraw your consent, this will not affect the lawfulness of our use and processing of your information based on your consent before the point in time when you withdraw your consent or processing of your information based on other legal bases.
Some rights may be limited, and we may need to retain certain personal information, as required or permitted by applicable law. To inquire about or exercise the rights listed above, at any time, contact us at firstname.lastname@example.org with the subject line “EU Privacy” so that we can get your email to the right team. We will respond to your request consistent with applicable law.
If you feel that your request or concern was not satisfactorily resolved by us, you have the right to lodge a complaint with your local data protection authority.
11. Links to Other Websites
For your convenience, we may link to third-party sites and services, or otherwise display third-party content through our Site to provide increased value to our visitors. We have no control over these linked sites, each of which has separate privacy and data collection policies and practices independent from us. As such we have no responsibility or liability for these independent policies or actions and are not responsible for the privacy practices or the content of any such websites. Please note that these other sites may send their own cookies to users, collect data, or solicit personal information, and we encourage you to review their policies before engaging with these third-party sites.
13. How to Contact Us