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PRIVACY POLICY

Last Updated: Oct. 11, 2024

Table of Contents

 1.  Overview
 2.  How Do We Collect Personal Information
 3.  The Types of Personal Information We May Collect From You
 4.  How We Use Your Personal Information
 5.  How We Disclose Personal Information
 6.  Children’s Privacy
 7.  Links to Third Party Websites
 8.  CCTV
 9.  Your Advertising Choices
 10. Information Security
 11. Cookies and Similar Technology
 12. Your Marketing Preferences

 13. Additional Information for Residents of California, Virginia, Colorado,
     Connecticut, Utah, Texas, Oregon, Montana, and Other U.S. States with
     Similar Privacy Laws
     
     1. Information for POLITICO Users
     2. Information for POLITICO Pro and E&E Users
     3. Information for AgencyIQ Users
     4. Notice of Financial Incentive
 14. International Data Transfers
 15. Shine the Light Disclosure
 16. Updates to the Policy
 17. Contact Us




OVERVIEW

This Privacy Policy explains how POLITICO, POLITICO Pro, E&E News, AgencyIQ, our
subsidiaries and affiliates, and any other digital properties that display
authorized links to this policy (“us”, “our”, or “we”) process personal
information when you interact with us online, via our websites and apps, and
offline, in person (collectively, “Services”).




HOW DO WE COLLECT PERSONAL INFORMATION

From you. We may collect personal information and other information that you
voluntarily provide when you take certain actions, such as when you register for
one of our Services (such as when you become a POLITICO Pro subscriber), request
information about available subscription options, order a subscription to our
Services, pay your bill online, sign up for our newsletters, sign up for our
author alerts, respond to our surveys, or otherwise use our Services.

From devices you use when you interact with us online. This includes information
collected through our Services and automatically from devices you use to connect
to our Services. For more information about this, please see our “Cookies and
similar technologies” section below.

From third parties and publicly available sources. This includes personal
information we collect from other public sources, including, but not limited to,
websites that enable social sharing, social media sites, and websites from our
service providers, vendors, our affiliates, or other individuals and businesses.

From you in person.




THE TYPES OF PERSONAL INFORMATION WE MAY COLLECT FROM YOU

Depending on how you interact with us, we may collect the following information:

 * Contact Information, such as your name, company, title, zip code, country,
   work address, email address, telephone number, or other similar identifiers.
 * Subscription-related Information, such as type of employment, organization
   name, organization type, field of interest, and locations of interest.
 * Biographic and Demographic Information, such as age and gender.
 * Financial and Payment Information, such as credit card details, bank account
   number, financial information, and payment preferences.
 * Account Information, such as a user name and password, profile details you
   choose to provide, and feedback and reviews you may provide on our Services.
 * Activity Information, such as information we collect when you access and
   interact with our Services, including browser or device model and settings,
   operating system, and unique identifiers, clickstream data, cookies and
   localStorage, browsing history, search history, web-based location, IP
   address, geolocation, and any other Internet usage information our Services
   may automatically record when you visit. For more information about cookies
   and similar technologies, please refer to the section “Cookies and Similar
   Technologies” below.
 * Inferences, such as inferences drawn from any of the personal information
   identified and discussed in this Privacy Policy.
 * Other Personal Information you provide, such as the content provided either
   in your job application or in your communications with us, including
   interactions with us online, in-person, or on the phone.




HOW WE USE YOUR PERSONAL INFORMATION

We may use your information for the following reasons, depending on your
relationship with us:

 * To provide you the products and services requested.
 * To communicate with you, such as when we send a welcome email and to verify
   email ownership, respond to your inquiries and send you communications,
   including our newsletter and subscriptions, and any other communications
   regarding our products and services. This may also include when we send you
   administrative e-mail notifications, such as security, or support and
   maintenance advisories.
 * To serve you targeted advertising or content.
 * To provide, market, and develop our products and services, including to
   maintain our websites and mobile applications, troubleshoot, provide customer
   and technical support, conduct data analysis, test and research, and better
   understand the interests of our users, readers, and subscribers who use our
   services and products.
 * To conduct marketing research.
 * To understand how you interact with our Services and personalize the product
   experience and content (including advertising and messaging campaigns).
 * To maintain the safety, security, and integrity of our Services, for example,
   by authenticating users and providing account security and fraud detection.
   We may also use your information to monitor, detect, and prevent fraud and
   improper or illegal activity.
 * To debug our systems, to secure our online services, including our network
   and websites, and to debug our online services.
 * To send you surveys, news and/or marketing communications (by email, phone,
   or text) subject to your marketing preferences and choices, including
   information about us or third party offerings we think may be of interest to
   you.
 * To conduct market research and develop quality assurance, including to study,
   develop, and improve our products and services. This may include measuring
   and analyzing audience traffic, including tracking user interests, trends,
   and patterns. We may also aggregate, anonymize, and/or de-identify personal
   information we collect and use it for any purpose, including product
   development and improvement activities.
 * To comply with legal requirements and/or to investigate or address claims or
   disputes relating to your use of our Services. This would include the use of
   your information to comply with our legal and regulatory obligations, to
   defend ourselves in litigation and investigations, and to prosecute
   litigations.
 * To facilitate the creation and maintenance of, as well as to secure, your
   membership and/or subscription account.
 * To help recognize you as a previous visitor and save and remember your
   preferences and settings and deliver to you appropriate interest-based
   content.
 * To deliver video content to you in the ordinary course of our business.
 * To conduct internal business purposes, including for data analysis, audits,
   and enhancing our services. We may also use inferences drawn from personal
   information to create a profile reflecting your preferences, so we can tailor
   our services to you.
 * To collect analytics in order to understand how our Services are used and to
   improve them over time.
 * To process and complete transactions, including collecting payment and
   contact information to process your transactions and deliver our Services to
   you.




HOW WE DISCLOSE PERSONAL INFORMATION

We may disclose some or all of the personal information collected from or about
you with any of the following entities and for any of the following purposes:

 * Advertising Partners. We may provide personal information to third parties,
   such as advertising partners or other marketing partners who provide services
   to us.  
 * Service Providers and Company Affiliates. We may provide personal information
   to vendors, payment processors, contractors, and business and service
   partners who provide services to us, including analysis firms and others. We
   may also disclose some or all of your information to our parent company,
   subsidiaries, joint ventures, or other companies under a common control
   (“Company Affiliates”), in which case we will require our Company Affiliates
   to honor this Privacy Policy. We may disclose some of the information that we
   collect from or about you with other parties in order to process and fulfill
   your requests for video content offered through the our Services, including
   to provide you with access to localized content and video content
   recommendations.
 * Social Networks. Some features of our Services may enable you to post content
   to social networking services (“SNSs”). If you choose to do this, we will
   provide information to such SNSs in accordance with your elections. You
   acknowledge and agree that you are solely responsible for your use of those
   websites and that it is your responsibility to review the terms of use and
   privacy policy of the third party provider of such SNSs. We will not be
   responsible or liable for: (i) the availability or accuracy of such SNSs;
   (ii) the content, products or services on or availability of such SNSs; or
   (iii) your use of any such SNSs.
 * Government, regulatory, or law enforcement agencies. We reserve the right to
   disclose your information to respond to valid information requests from
   government authorities and judicial requests, to investigate potential fraud,
   or where otherwise required by law. We may disclose your personal information
   where we believe the disclosure is necessary or appropriate to comply with
   regulatory or legal requirements, or to protect the safety, rights, or
   property of ourselves and others and to exercise, establish, or defend our
   legal rights.
 * In connection with a merger, acquisition, or business transfer. If we sell
   all or a part of our company, are part of a merger, consolidation,
   restructuring, and/or sale of assets or other corporate change, your
   information may be transferred as part of that transaction.
 * At your direction. We may disclose your personal information at your
   direction or with your consent.
 * Collaborators. We may disclose personal information with collaborators with
   whom we jointly develop or promote our services, including sponsorships and
   co-branded opportunities and promotions.
 * The General Public. We may disclose personal information with the general
   public if you choose to disclose personal information when contributing
   content to our Services through forums, blogs, social features, or the like.
 * Aggregate Data. We may disclose your personal information in an aggregated or
   non-identifying form or otherwise in a form that cannot reasonably be used to
   identify you.




CHILDREN'S PRIVACY

You must be 18 years or older to use our Services. Our Services are for a
general audience, are not targeted to children, and do not knowingly collect
personal information from children under 18 years of age.




LINKS TO THIRD PARTY WEBSITES

We may provide links to websites and other third party content (e.g., social
media platforms) that are not owned or operated by us. The websites and third
party content to which we link may have separate privacy notices or policies. We
are not responsible for the privacy practices of these websites.

If you provide any personal information through a third party site, your
interaction and your personal information will be collected by and controlled by
the privacy policy of that third party site. We recommend that you familiarize
yourself with the privacy policies and practices of any such third parties,
which are not governed by this Privacy Policy.




CCTV

We use CCTV video recording to protect the physical security of our property and
Services in line with applicable laws. We do this to comply with our contractual
obligations (e.g., with customers and insurers) and our internal physical
security policies to safeguard our properties, workplaces, people, and data.




YOUR ADVERTISING CHOICES


When you use our Services, our third party advertising partners, social media
providers, and analytics providers may collect personal information about your
online activity on our Services and on third party websites.


These providers may set web tracking tools (e.g., cookies and web beacons, as
discussed further below) to collect information regarding your online activity.
In addition, our advertising partners may use this information to deliver
advertisements to you when you visit third party websites within their networks.
If you would like more information about this practice, and to know your choices
with respect to it, please either visit the Digital Advertising Alliance’s opt
out page (currently available at http://www.aboutads.info/choices/) or the
Network Advertising Initiative’s opt out page (currently available at
http://www.networkadvertising.org/choices/). Please note that you may continue
to receive generic ads that are not based on your preferences.


Additionally, we may collaborate with our service providers and identity
partners ("Identity Resolution Partners") to deliver targeted advertising and
identify the different devices and browsers you may use to access our Services.
We and our Identity Resolution Partners may facilitate identity resolution by
creating probabilistic and deterministic identifiers. These identifiers may use
personal information, including your name, email address, phone number, and
Activity Information to generate an online identifier reasonably linkable to you
and/or your device or browser. For example, we may disclose hashed email
address, phone number, or other information about your device to our Identity
Resolution Partners, whom may, in turn, return an online identifier that we may
store in a first party cookie or similar technology and disclose to our
advertising partners to provide you a more personalized advertising experience.
These identifiers also help us with fraud detection and security, enforce our
Terms of Service, among other things. We are not responsible for the privacy
practices of our Identity Resolution Partners, which are separate from our own
and not covered by this Privacy Policy.

You may have additional rights related to these technologies depending on your
state of residency, as outlined in Section 13 below.





INFORMATION SECURITY

We use commercially reasonable administrative, technical, personnel, and
physical measures designed to safeguard information in its possession against
loss, theft, unauthorized use, disclosure, or modification. However, the
confidentiality of information transmitted over the Internet cannot be
guaranteed. We urge you to exercise caution when transmitting personal
information over the internet. We cannot guarantee that unauthorized third
parties will not gain access to your information; therefore, when submitting
personal information to us, you do so at your own risk.




COOKIES AND SIMILAR TECHNOLOGY

We and our partners use various tools to collect data when you visit our sites
and apps, including cookies, pixels, localStorage, and other similar
technologies. Some of these technologies store data in the browser or on your
device. Other technologies may use network-related or other information to
recognize your device (e.g., IP address). Our Services use these technologies,
for example, when you first request a web page and data is then stored on your
computer or other device so the website or mobile application can access
personal information when you make subsequent requests for pages from that
Service. These technologies may also be used to collect and store information
about your usage of the Services, such as pages you have visited, other content
you viewed, and search history. Additionally, we may these technologies to
collect analytics and measure the use of our Services.

We and our partners may also use these technologies to gather personal
information about how you view and use our Services and content and to connect
your activity with other data we store about you. We and our partners may
collect your personally identifiable information about your online activities
over time and across different websites when you use the Services. The use of
these technologies helps us serve you better by understanding what you are
interested in, tracking trends, measuring the effectiveness of ads, saving your
preferences, and storing information you may want to retrieve on a regular
basis. We also allow specific, approved partners to collect data from your
browser or device for advertising and measurement purposes using their own
similar tools.

Your web browser can be set to allow you to control these technologies, such as
whether you will accept cookies, reject cookies, or to notify you each time a
cookie is sent to your browser. If your browser is set to reject cookies,
websites that are cookie-enabled will not recognize you when you return to the
website, and some website functionality may be lost. The Help section of your
browser may tell you how to prevent your browser from accepting these
technologies, such as cookies. To find out more about cookies, visit
https://www.aboutcookies.org. Depending on the make and model of your phone, you
may be able to use device settings to opt out of the use of certain device IDs
for targeted advertising. For more information about Google Analytics, please
review the site “How Google uses data when you use our partners’ sites or apps,”
located at https://www.google.com/policies/privacy/partners/. To opt out of
Google Analytics specifically, please go to
https://tools.google.com/dlpage/gaoptout.

Some browsers permit the user to send a “Do Not Track” (“DNT”) preference to
websites that the user visits indicating that the user does not wish to be
tracked over time and across websites. Because there is not yet a common
understanding of how to interpret DNT, we do not currently respond to the DNT
signal on our websites. We do, however, respond to global privacy preferences
when required by law.




YOUR MARKETING PREFERENCES

We may periodically send promotional materials or notifications related to our
Services. If you no longer wish to receive promotional marketing materials from
us, you may opt out of receiving such materials. You may unsubscribe from
receiving marketing or other commercial emails from us by following the
instructions included in the email.

There are certain service notifications and other non-promotional emails that
you may not opt out of, such as notifications of changes to our Services or
policies.




ADDITIONAL INFORMATION FOR RESIDENTS OF CALIFORNIA, VIRGINIA, COLORADO,
CONNECTICUT, UTAH, TEXAS, OREGON, MONTANA, AND OTHER U.S. STATES WITH SIMILAR
PRIVACY LAWS

Depending on where you live, you may have certain additional rights regarding
your personal information. This section provides information for consumers
residing in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon,
and Montana in connection with the laws in those states, and other states with
similar privacy laws (“Applicable Laws”). Under these Applicable Laws, and for
purposes of this Section, “Personal Data” and/or “Personal Information”
generally mean information that identifies, relates to, or describes a resident
or household in one of the Applicable States, and, for Oregon residents, may
also include information that is linkable or linked to a device. Personal
Information and/or Personal Data does not include publicly available
information; lawfully obtained, truthful information that is a matter of public
concern; information that has been deidentified or aggregated; or other
information covered by certain sector-specific privacy laws, as consistent with
state law. We do not reidentify Personal Data and/or Personal Information that
has been deidentified. We and our advertising partners use certain Personal Data
and/or Personal Information to deliver online advertisements to you on your
devices tailored to your interests. This may be considered “sharing” or
“selling” under California law, "selling" under Colorado, Connecticut, Texas,
Oregon, and Montana law, and "targeted advertising" under Virginia, Colorado,
Connecticut, Utah, Texas, Oregon, and Montana law. This Section provides details
about the categories of Personal Data and/or Personal Information of consumers
in California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana,
and other U.S. states with similar privacy laws that we have collected,
disclosed, processed for purposes of targeted advertising, “shared”, or “sold”
during the last 12 months, as well as rights consumers have under Applicable
Laws.

Categories of Personal Data and/or Personal Information Collected, Disclosed,
“Shared”, “Sold”, or Processed for Targeted Advertising: 

The categories of Personal Data and/or Personal Information that we collected,
disclosed, “shared” (under the California law), processed for purposes of
targeted advertising (under the Virginia and Utah laws) or “sold” (under the
California, Colorado, Connecticut, Texas, Oregon, and Montana laws) are below,
along with the purposes for processing, and categories of third parties to whom
each category of Personal Data and/or Personal Information was disclosed,
“shared”, “sold”, or processed for the purpose of targeted advertising. Please
note that we process some categories of Personal Data and/or Personal
Information in connection with targeted advertising, which could be considered
“sharing” under the California law or “selling” under the California, Colorado,
Connecticut, Texas, Oregon, or Montana laws. Depending on how you interact with
us, we may not have processed Personal Information about you for each (or any)
of these purposes. Additionally, we do not knowingly sell, share, or process
Personal Data and/or Personal Information of children under 13 years of age.


We have provided detailed descriptions below on the data collection, use, and
disclosure practices of our companies depending on which service you use.



POLITICO Users

The below chart applies to POLITICO.com and the POLITICO mobile app.

Category of Personal Information Collected
Categories of Parties to Whom Personal Information Is Disclosed
Categories of Third Parties to Whom Personal Information is “Sold” or “Shared”
“Sold” or Processed for Targeted Advertising
Identifiers, such as name, IP address, email address, and online and device
identifiers
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising



 


Virginia and Utah: Processed for targeted advertising





Colorado and Connecticut: “Sold” for purposes of targeted advertising


Personal information, as defined in the California Customer Records law, such as
contact and financial information
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
N/A
Characteristics of protected classifications under California law, such as age
and gender
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Virginia and Utah: Processed for targeted advertising





Colorado and Connecticut: “Sold” for purposes of targeted advertising


Commercial information, such as transaction information and purchase history
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Virginia and Utah: Processed for targeted advertising





Colorado and Connecticut: “Sold” for purposes of targeted advertising


Internet or network activity information, such as browsing history and
interactions with our websites or apps
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Virginia: Processed for targeted advertising





Colorado and Connecticut: “Sold” for purposes of targeted advertising


Geolocation data, such as device location
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
N/A
Audio, electronic, visual and other similar information, such as call recordings
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
N/A
Professional or employment-related information, such as work history and prior
employer
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Virginia and Utah: Processed for targeted advertising





Colorado and Connecticut: “Sold” for purposes of targeted advertising


Inferences drawn from any of the Personal Information listed above to create a
profile or summary about, for example, an individual’s preferences and
characteristics
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Virginia and Utah: Processed for targeted advertising





Colorado and Connecticut: “Sold” for purposes of targeted advertising


Please note that we may process Personal Data and/or Personal Information in
each of the above categories in order to protect ours and others’ rights, and/or
to complete a merger or sale of assets or other corporate transaction. Please
note that we do not sell Personal Data and/or Personal Information for monetary
consideration.

Under California, Colorado, Virginia, Connecticut, Utah, Texas, Oregon, and
Montana laws, “sale” (and “share” in California) does not include, for example,
the transfer of Personal Data and/or Personal Information as an asset that is
part of a merger, bankruptcy, or other similar transaction involving all or any
portion of our business.

Sensitive Personal Information.  We do not process “sensitive” Personal
Information for purposes other than those permitted by applicable law (such as,
in California, to provide the services and for security purposes). Additionally,
we may process “sensitive” Personal Data for approved purposes under Applicable
Laws, such as to provide you with the product or services you requested or
prevent, detect, and respond to security incidents.

Data Retention.  We will retain Personal Data and/or Personal Information from
or about you as reasonably necessary and proportionate to achieve the purpose(s)
for which the Personal Information was collected or processed as outlined in
this Section unless a longer retention period is required or allowed by law.

Purposes


We may use this personal information for the following purposes, including
commercial purposes:

 * to operate, manage, and maintain our business;
 * to provide our Services;
 * to accomplish our business purposes and objectives;
 * to develop, improve, repair, and maintain our Services;
 * to engage in marketing and targeted advertising;
 * to conduct research and analytics;
 * to take quality assurance and safety assurance measures;
 * to conduct risk assessments and effectuate security controls;
 * to detect and prevent fraud;
 * to verify your identity;
 * to conduct audits and other internal functions;
 * to comply with the law, legal process, and internal policies;
 * to maintain records; and
 * to exercise and defend legal claims.

Depending on your interactions with us, we may not have used Personal Data
and/or Personal Information collected about that resident for each (or any) of
these purposes.


Sources of Personal Information

In general, we only collect Personal Data and/or Personal Information that is
reasonably necessary for and proportional to the purposes for which we process
it. We collect this Personal Data and/or Personal Information directly from
California, Virginia, Colorado, Utah, Connecticut, Texas, Oregon, and Montana
residents themselves, as well as from social media platforms (e.g., if the
individual has connected a social media account to our website); referrals;
joint marketing, co-branding, co-promotional, or advertising partners; and
sources of demographic and other information, including through devices you used
to interact with us through our Services. All sources of personal information
collected are noted in the “How Do We Collect Personal Information” and “The
Types of Personal Information We May Collect From You” sections above.


Your Privacy Rights Under Applicable State Law 


If you are a resident of California, Virginia, Connecticut, Utah, Colorado,
Texas, Oregon, or Montana you may have the following rights with respect to any
information about you that constitutes “Personal Information” under California
law and “Personal Data” under other state laws, as described below.

We are required by law to verify your identity in connection with any request in
order to prevent unauthorized access of your data. Failure to verify your
identity may result in your request not being processed. Where required by
applicable law, we will notify you if we deny your request and notify you of the
reasons we are unable to honor your request.


Right to Know and Access: You may request to access the following information we
have collected and maintain about you:

 * The specific pieces of Personal Data and/or Personal Information we collected
   about you;
 * The categories of Personal Data and/or Personal Information we collected
   about you and the categories of sources;
 * The business or commercial purpose for collecting, disclosing, or selling
   Personal Data and/or Personal Information about you; and,
 * The categories of Personal Data and/or Personal Information about you that we
   sold, shared, or otherwise disclosed and the categories of third parties to
   whom we sold, shared, or otherwise disclosed that Personal Data and/or
   Personal Information.

Please note that, in some instances, we may decline to honor your request or
only honor your request in part, where, for example, we are unable to verify
your identity or an exception to this right applies.


Right to Delete: You may request that we delete the Personal Data and/or
Personal Information we have collected from you. Please note that, in some
instances, we may decline to honor your request or only honor your request in
part, where, for example, we are unable to verify your identity or an exception
to this right applies.

Opt Out of “Sale”, “Shares”, and Targeted Advertising: Depending on the state
you reside in, you have the right to opt out of the “sale” of your data, the
disclosure of your data for cross-context behavioral advertising/targeted
advertising (known as a “share” in California), and profiling in furtherance of
solely automatized decisions that produce legal or similarly significant
effects. We also honor alternative opt-out signals, such as the GPC. We process
opt-out preference signals in a frictionless manner. Please note that we do not
sell Personal Information for monetary consideration.

Right to Correction: You have a right to request the correction of inaccurate
Personal Data and/or Personal Information that we may have on file about you.
Please note that, in some instances, we may decline to honor your request or
only honor your request in part, where, for example, we are unable to verify
your identity or an exception to this right applies.

Right to Non-Discrimination: You have the right to be free from unlawful
discrimination for exercising your above-listed rights under the CCPA.

Right to Appeal: Depending on your state of residence, you may have the right to
request an appeal our action in response to a consumer request.

CCPA Request Metrics for 2022:

 * Number of requests to delete that were received, complied with in whole or in
   part, and denied; 2
 * Number of requests to correct that were received, complied with in whole or
   in part, and denied; 0
 * Number of requests to opt-out of sale/sharing that were received, complied
   with in whole or in part, and denied; 1,032,403
 * The median or mean number of days it took to substantively respond (i.e not
   the 10 day “confirmation of receipt” window); 32.67

To Exercise Rights:


In order to exercise your Right to Opt Out of “Sales”, “Shares”, and Targeted
Advertising, please visit our "Do Not Sell or Share My Personal Information and
Opt Out of Targeted Advertising" page.


Depending on your state of residence, in order to exercise your Right to Appeal
our action in response to your request, please email us using the email address
in the “Contact Us” section below. In order to exercise your other rights
described above, please call us at (571) 489-5203 or submit a request through
the linked form at https://go.politico.com/your-privacy-rights.html.
Additionally, we may need to obtain information about you or your specific
request in order to verify your identity and respond.

Authorized Agent

Depending on your state of residence, you have the right to submit a request
through an authorized agent. If you are an authorized agent acting on behalf of
a resident to communicate with us or to exercise a privacy right discussed
above, you must be able to demonstrate that you have the requisite authorization
to act on behalf of the resident and have sufficient access to their laptop,
desktop, or mobile device to exercise these rights digitally. If you are an
authorized agent trying to exercise rights on behalf of a consumer, please
contact us at the contact information below with supporting verification
information, which includes proof that you have access to the consumer’s
interface and proof of your own identity.



POLITICO Pro and E&E Users:

The below chart applies to the POLITICO Pro and E&E News websites and associated
mobile apps.

POLITICO Pro and E&E News provide business-to-business services. This means that
Personal Data and/or Personal Information we collect, other than from California
residents, is excluded from certain U.S. state privacy laws. While we are not
required by Applicable Laws to respond to consumer requests from residents of
those applicable states, we will, as a courtesy, endeavor to reply to consumer
requests from residents of Virginia with business-to-business data so long as
doing so does not conflict with applicable law or a legitimate purpose allowing
or requiring us to protect the Personal Information from disclosure. We also
reserve the right to verify your identity in conjunction with any such Virginia
resident courtesy request.

The below applies to California residents and their Personal Information for the
above services:

Category of Personal Information Collected
Categories of Parties to Whom Personal Information Is Disclosed
Categories of Third Parties to Whom Personal Information is “Sold” or “Shared”
Identifiers, such as name, IP address, email address, and online and device
identifiers
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising



 


Personal information, as defined in the California Customer Records law, such as
contact and financial information
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
Characteristics of protected classifications under California law, such as age
or gender
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Commercial information, such as transaction information and purchase history
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Biometric information
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
Internet or network activity information, such as browsing history and
interactions with our websites or apps
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Geolocation data, such as device location
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
Audio, electronic, visual and other similar information, such as call recordings
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
Professional or employment-related information, such as work history and prior
employer
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Inferences drawn from any of the Personal Information listed above to create a
profile or summary about, for example, an individual’s preferences and
characteristics
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Please note that we may process Personal Information in each of the above
categories in order to protect ours and others’ rights, and/or to complete a
merger or sale of assets or other corporate transaction.

Under California, “sale” and “share” do not include, for example, the transfer
of Personal Information as an asset that is part of a merger, bankruptcy, or
other similar transaction involving all or any portion of our business.

Sensitive Personal Information.  We do not process “sensitive” Personal
Information for purposes other than those permitted by applicable law (such as,
in California, to provide the services and for security purposes).

Data Retention.  We will retain Personal Information from or about you as
reasonably necessary and proportionate to achieve the purpose(s) for which the
Personal Information was collected or processed as outlined in this Section
unless a longer retention period is required or allowed by law.

Purposes

We may use this personal information for the following purposes, including
commercial purposes:

 * to operate, manage, and maintain our business;
 * to provide our Services;
 * to accomplish our business purposes and objectives;
 * to develop, improve, repair, and maintain our Services;
 * to engage in marketing and targeted advertising;
 * to conduct research and analytics;
 * to take quality assurance and safety assurance measures;
 * to conduct risk assessments and effectuate security controls;
 * to detect and prevent fraud;
 * to verify your identity;
 * to conduct audits and other internal functions;
 * to comply with the law, legal process, and internal policies;
 * to maintain records; and
 * to exercise and defend legal claims.

Depending on your interactions with us, we may not have used Personal
Information collected about that resident for each (or any) of these purposes.


Sources of Personal Information

We collect this Personal Information directly from California residents
themselves, as well as from social media platforms (e.g., if the individual has
connected a social media account to our website); referrals; joint marketing,
co-branding, co-promotional, or advertising partners; and sources of demographic
and other information, including through devices you used to interact with us
through our Services. All sources of personal information collected are noted in
the “How Do We Collect Personal Information” and “The Types of Personal
Information We May Collect From You” sections above.

Your Privacy Rights Under Applicable State Law

California residents have certain rights with respect to their Personal
Information, as described below. As described above, we will, as a courtesy,
endeavor to reply to consumer requests from residents of Virginia with
business-to-business data so long as doing so does not conflict with applicable
law or a legitimate purpose allowing or requiring us to protect the Personal
Information from disclosure.

We are required by law to verify your identity in connection with any request in
order to prevent unauthorized access of your data. Failure to verify your
identity may result in your request not being processed. Where required by
applicable law, we will notify you if we deny your request and notify you of the
reasons we are unable to honor your request.

Right to Know and Access Personal Information: You may request to access the
following information we have collected and maintain about you:

 * The specific pieces of Personal Information we collected about you;
 * The categories of Personal Information we collected about you and the
   categories of sources;
 * The business or commercial purpose for collecting, disclosing, or selling
   Personal Information about you; and,
 * The categories of Personal Information about you that we sold, shared, or
   otherwise disclosed and the categories of third parties to whom we sold,
   shared, or otherwise disclosed that Personal Information.

Please note that, in some instances, we may decline to honor your request or
only honor your request in part, where, for example, we are unable to verify
your identity or an exception to this right applies.


Deletion of Personal Information: You may request that we delete the Personal
Information we have collected from you. Please note that, in some instances, we
may decline to honor your request or only honor your request in part, where, for
example, we are unable to verify your identity or an exception to this right
applies.

“Do Not Sell or Share” Personal Information: As noted above in this section, we
disclose some categories of Personal Information in connection with certain
types of advertisements that may be considered a “share” or “sale” under the
CCPA. We also honor alternative opt-out signals, such as the GPC. We process
opt-out preference signals in a frictionless manner. Please note that we do not
sell Personal Information for monetary consideration.

Correction of Inaccurate Personal Information: You have a right to request the
correction of inaccurate Personal Information that we may have on file about
you. Please note that, in some instances, we may decline to honor your request
or only honor your request in part, where, for example, we are unable to verify
your identity or an exception to this right applies.

Non-Discrimination: You have the right to be free from unlawful discrimination
for exercising your above-listed rights under the CCPA.

To Exercise Rights:

If you are a California resident, please visit our "Do Not Sell or Share My
Personal Information and Opt Out of Targeted Advertising" page in order to
exercise your Right to Opt Out of the Sale or Sharing of your Personal
Information.

In order to exercise your other rights described above, please call us at (571)
489-5203 or submit a request through the linked form at
https://go.politico.com/your-privacy-rights.html. Additionally, we may need to
obtain information about you or your specific request in order to verify your
identity and respond.

Authorized Agent

California residents may use an authorized agent on their behalf to exercise a
privacy right discussed above. If you are an authorized agent acting on behalf
of a California resident acting in their business capacity to communicate with
us or to exercise a privacy right discussed above, you must be able to
demonstrate that you have the requisite authorization to act on behalf of the
resident and have sufficient access to their laptop, desktop, or mobile device
to exercise these rights digitally. If you are an authorized agent trying to
exercise rights on behalf of a California resident acting in a business
capacity, please contact us at the contact information below with supporting
verification information, which includes proof that you have access to the
consumer’s interface and proof of your own identify.



AgencyIQ Users

The below chart applies to the AgencyIQ website.

AgencyIQ provides a business-to-business services. This means that Personal
Information we collect, other than from California residents, is excluded from
certain U.S. state privacy laws.

The below applies to California residents and their Personal Information:

Category of Personal Information Collected
Categories of Parties to Whom Personal Information Is Disclosed
Categories of Third Parties to Whom Personal Information is “Sold” or “Shared”
Identifiers, such as name, IP address, email address, and online and device
identifiers
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising



 


Personal information, as defined in the California Customer Records law, such as
contact and financial information
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
Characteristics of protected classifications under California law, such as age
or gender
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Commercial information, such as transaction information and purchase history
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Biometric information,
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
Internet or network activity information, such as browsing history and
interactions with our websites or apps
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Geolocation data, such as device location
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
Audio, electronic, visual and other similar information, such as call recordings
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes
N/A
Professional or employment-related information, such as work history and prior
employer
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Inferences drawn from any of the Personal Information listed above to create a
profile or summary about, for example, an individual’s preferences and
characteristics
Service providers, Company Affiliates, and other providers or partners that
support our operational business purposes


AdTech partners; Company Affiliates; advertisers



For the purpose of targeted advertising


Please note that we may process Personal Information in each of the above
categories in order to protect ours and others’ rights, and/or to complete a
merger or sale of assets or other corporate transaction.

Under California law, “sale” and “share” do not include, for example, the
transfer of Personal Information as an asset that is part of a merger,
bankruptcy, or other similar transaction involving all or any portion of our
business.

Sensitive Personal Information.  We do not process “sensitive” Personal
Information for purposes other than those permitted by applicable law (such as,
in California, to provide the services and for security purposes).

Data Retention.  We will retain Personal Information from or about you as
reasonably necessary and proportionate to achieve the purpose(s) for which the
Personal Information was collected or processed as outlined in this Section
unless a longer retention period is required or allowed by law.

Purposes

We may use this Personal Information for the following purposes, including
commercial purposes:

 * to operate, manage, and maintain our business;
 * to provide our Services;
 * to accomplish our business purposes and objectives;
 * to develop, improve, repair, and maintain our Services;
 * to engage in marketing and targeted advertising;
 * to conduct research and analytics;
 * to take quality assurance and safety assurance measures;
 * to conduct risk assessments and effectuate security controls;
 * to detect and prevent fraud;
 * to verify your identity;
 * to conduct audits and other internal functions;
 * to comply with the law, legal process, and internal policies;
 * to maintain records; and
 * to exercise and defend legal claims.

Depending on your interactions with us, we may not have used Personal
Information collected about that resident for each of these purposes.


Sources of Personal Information

We collect this Personal Information directly from California residents
themselves, as well as from social media platforms (e.g., if the individual has
connected a social media account to our website); referrals; joint marketing,
co-branding, co-promotional, or advertising partners; and sources of demographic
and other information, including through devices you used to interact with us
through our Services. All sources of personal information collected are noted in
the “How Do We Collect Personal Information” and “The Types of Personal
Information We May Collect From You” sections above.

Your Privacy Rights Under Applicable State Law 

California residents have certain rights with respect to their Personal
Information, as described below.

We are required by law to verify your identity in connection with any request in
order to prevent unauthorized access of your data. Failure to verify your
identity may result in your request not being processed. Where required by
applicable law, we will notify you if we deny your request and notify you of the
reasons we are unable to honor your request.

Right to Know and Access Personal Information: You may request to access the
following information we have collected and maintain about you:

 * The specific pieces of Personal Information we collected about you;
 * The categories of Personal Information we collected about you and the
   categories of sources;
 * The business or commercial purpose for collecting, disclosing, or selling
   Personal Information about you; and,
 * The categories of Personal Information about you that we sold, shared, or
   otherwise disclosed and the categories of third parties to whom we sold,
   shared, or otherwise disclosed that Personal Information.

Please note that, in some instances, we may decline to honor your request or
only honor your request in part, where, for example, we are unable to verify
your identity or an exception to this right applies.


Deletion of Personal Information: You may request that we delete the Personal
Information we have collected from you. Please note that, in some instances, we
may decline to honor your request or only honor your request in part, where, for
example, we are unable to verify your identity or an exception to this right
applies.

“Do Not Sell or Share” Personal Information: As noted above in this section, we
disclose some categories of Personal Information in connection with certain
types of advertisements that may be considered a “share” or “sale” under the
CCPA. We also honor alternative opt-out signals, such as the GPC. We process
opt-out preference signals in a frictionless manner. Please note that we do not
sell Personal Information for monetary consideration.

Correction of Inaccurate Personal Information: You have a right to request the
correction of inaccurate Personal Information that we may have on file about
you. Please note that, in some instances, we may decline to honor your request
or only honor your request in part, where, for example, we are unable to verify
your identity or an exception to this right applies.

Non-Discrimination: You have the right to be free from unlawful discrimination
for exercising your above-listed rights under the CCPA.

To Exercise Rights:

If you are a California resident, please visit our "Do Not Sell or Share My
Personal Information and Opt Out of Targeted Advertising" page in order to
exercise your Right to Opt Out of the Sale or Sharing of your Personal
Information.

In order to exercise your other rights described above, please call us at (571)
489-5203 or submit a request through the linked form at
https://go.politico.com/your-privacy-rights.html. Additionally, we may need to
obtain information about you or your specific request in order to verify your
identity and respond.

Authorized Agent

California residents may use an authorized agent on their behalf to exercise a
privacy right discussed above. If you are an authorized agent acting on behalf
of a California resident to communicate with us or to exercise a privacy right
discussed above, you must be able to demonstrate that you have the requisite
authorization to act on behalf of the resident and have sufficient access to
their laptop, desktop, or mobile device to exercise these rights digitally. If
you are an authorized agent trying to exercise rights on behalf of an AgencyIQ
consumer, please contact us at the contact information below with supporting
verification information, which includes proof that you have access to the
consumer’s interface and proof of your own identify.




NOTICE OF FINANCIAL INCENTIVE

We offer customers the ability to participate in a registration program
("Program"). Depending on your state of residence, the Program may be considered
a financial incentive or loyalty program. Participation in the Program is
entirely voluntary. If you would like to participate in the Program, please
opt-in by signing up. If you sign up, you will receive:

 * Access to article and newsletter content on POLITICO.com and the POLITICO
   mobile application (collectively, “POLITICO Content”). You will also receive
   an exclusive email newsletter offered only to registered users.

When you decide to participate in the Program, we will collect your email
address, job title, and employer (depending on which you voluntarily provide to
us) (collectively, "Registration Information"). Registration Information may
also be disclosed to service providers or other providers or partners that
support our operational business purposes. By voluntarily opting in to this
Program, you will receive free access to POLITICO Content and an exclusive email
newsletter, and you may also receive content from us through emails.
Depending on your state of residence, if you decide you no longer wish to
participate in the Program, you may withdraw at any time. You may exercise this
right to withdraw using the following method, depending on the information you
have provided to us:

 * Email webin@politico.com to request withdrawal from the Program, using the
   same email address you used for registration. To process your withdrawal
   request, we will need to delete your account. Before deleting your account to
   honor your withdrawal request, we will send you an email requesting that you
   explicitly acknowledge and confirm your decision to delete your account. This
   step is essential to ensure that the account deletion aligns with your
   intentions and helps mitigate unauthorized actions. Once we receive your
   confirmation, your account will be deleted, and you will be withdrawn from
   the Program. You may also unsubscribe from our newsletters at any time by
   visiting our Preferences page or by clicking “unsubscribe” at the bottom of
   the email. Visit the FAQ page for more information.

We estimate that the value of your data is equal to the value of the
subscription to our services. Registration Information enables us to deliver
personalized content, offers, subscription services, and value to you, which
enables us to establish a relationship with you, and is valued by us in order to
facilitate a positive customer experience. In determining the value of the
Registration Information, we consider the profit generated from our advertising
partners that includes personal information, which is reasonably correlated to
the value provided to you through personalized content, discounts, or offers.




INTERNATIONAL DATA TRANSFERS

We are based in the United States. Any information you provide to us through use
of the Services may be stored and processed, transferred between, and accessed
from the United States and other countries which may not guarantee the same
level of protection of personal information as the one in which you reside. We
may need to send your personal information overseas as part of our normal
business operations. Provided the data protection laws of these other countries
differ from those in the United States, please be assured that we take
reasonable steps to ensure that your privacy is protected.




SHINE THE LIGHT DISCLOSURE

We do not disclose personal information as defined by California Civil Code §
1798.83 (the “Shine the Light Law”) with third parties, other than our
affiliates, for their direct marketing purposes absent your consent. If you are
a California resident, you may request information about our compliance with the
Shine the Light Law by sending an email to privacy@politico.com or by sending a
letter to 1000 Wilson Blvd, 8th Floor, Arlington, VA 22209. Any such request
must include “Request for California Privacy Information” in the subject line
and include your name, street address, city, state, and ZIP code. Please note
that we are only required to respond to one request per customer each year, and
we are not required to respond to requests made by means other than through the
email address or mailing address referenced above.




UPDATES TO THE POLICY

We may update this policy from time to time. To the extent permitted by law, any
changes to our Privacy Policy will be posted to the websites and will become
effective upon posting. Any changes will be effective only after the effective
date of the change and will not affect any dispute arising prior to the
effective date of the change.




CONTACT US

We welcome all requests, suggestions and questions concerning our use of your
personal Information. All such communication should be directed to
privacy@politico.com or call us at (571) 489-5203.



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