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 * GANNETT PRIVACY POLICY
 * Introduction
 * Personal Information and Personal Data Definition
 * Personal Information We Collect
 * How We Use Personal Information
 * Do We Use "Cookies"?
 * Third Party Links
 * Security
 * Accessing, Correcting, Or Deleting Your Personal Information
 * Transfers
 * Aggregate And De-Identified Information
 * Privacy Policy For California Residents
 * Individuals In The European Economic Area (EEA), Or UK
 * Controller
 * Rights of Individuals Based in the EEA
 * Legitimate Interests
 * Data Transfers
 * Data Retention
 * Children’s On-Line Privacy Information
 * Accessibility
 * Changes To This Privacy Policy
 * Contact Us

GANNETT PRIVACY POLICY
 * GANNETT PRIVACY POLICY
 * Introduction
 * Personal Information and Personal Data Definition
 * Personal Information We Collect
 * How We Use Personal Information
 * Do We Use "Cookies"?
 * Third Party Links
 * Security
 * Accessing, Correcting, Or Deleting Your Personal Information
 * Transfers
 * Aggregate And De-Identified Information
 * Privacy Policy For California Residents
 * Individuals In The European Economic Area (EEA), Or UK
 * Controller
 * Rights of Individuals Based in the EEA
 * Legitimate Interests
 * Data Transfers
 * Data Retention
 * Children’s On-Line Privacy Information
 * Accessibility
 * Changes To This Privacy Policy
 * Contact Us


GANNETT PRIVACY POLICY

Last Updated:  11/23/2021


INTRODUCTION

This Privacy Policy describes the privacy practices for the websites and mobile
applications operated by Gannett Co., Inc. and its affiliates (“Gannett” “we”,
“our” “us”), and applies solely to the Personal Information (as defined below in
Section 1) that we collect and use relating to consumers and users residing
outside of the State of California. This Privacy Policy does not apply to
California residents. If you are a California resident, please click here  for
Your California Privacy Rights/Privacy Policy.

This Privacy Policy is applicable to the publications, businesses, websites and
mobile applications operated by Gannett/USA TODAY Network, including the Media
Property or application from which you accessed this Privacy Policy (our
websites and mobile applications are collectively referred to as "Media
Properties". It also applies to the related online services that we provide
through our Media Properties the "Services".

To the extent permitted by applicable law, by using the Media Properties and/or
the Services and providing us with Personal Information (defined below), you
agree to the practices described in this Privacy Policy and the Cookie Policy
referenced below and to the updates to these policies posted here from time to
time. If you are based in the European Economic Area (“EEA”) or the United
Kingdom (“UK”), this Privacy Policy serves as notice of how we process your
Personal Data (defined below) for which we are a controller. If we require your
consent, we will request it formally, in adherence to applicable data protection
laws.

To make sure you stay informed of all changes, you should check these policies
periodically. Updates will be referenced by the "Last Updated" date shown above.


PERSONAL INFORMATION AND PERSONAL DATA DEFINITION

For purposes of this Privacy Policy, unless a different definition is noted in a
particular instance, "Personal Information" (or "Personal Data" as used in
Section 9) means any information that identifies, relates to, describes,
references, or is reasonably capable of being associated with an identified or
identifiable natural person.

Personal Information for purposes of this Policy does not include your name,
photo and/or other information about you included in news or editorial content. 


PERSONAL INFORMATION WE COLLECT

We may collect the following types of Personal Information about you as
described below:

(A) Personal Information you provide to us,

(B) Personal Information we may automatically collect, and

(C) Personal Information we may receive from third parties.

A. Personal Information You Provide to Us

In using our Media Properties or Services, you may provide us with Personal
Information, which may include (the examples provided are illustrative and not
intended to be exhaustive):

 * Contact information such as name, email address, postal address and telephone
   number(s);
 * Demographic information such as birth date or gender; 
 * Account information and log in credentials, including unique identifiers such
   as username and password;
 * Payment and transaction information including credit or bank card
   information;
 * Preferences for communications;
 * Communications and opinions in chat rooms, message boards, forums, surveys,
   polls, and online forms;
 * Access to your geo-location (including through our mobile app) or to other
   data held on social media platforms and other software (for example, access
   to your contacts, calendar or photos);
 * Photos and/or videos; and
 * Any additional information that we describe to you, when we collect your data
   with your consent. 

B. Personal Information We May Automatically Collect About You

Our Media Properties and Services may automatically collect certain Personal
Information about you. This Personal Information may include (the examples
provided are illustrative and not intended to be exhaustive):

 * IP address, which is the number associated with the service through which you
   access the Internet, such as through your ISP (Internet service provider);
 * Date and time of your visit or use of our Media Properties or Services;
 * Domain server from which you are using our Media Properties or Services;
 * Type of computer, web browsers, search engine used, operating system, or
   platform you use;
 * Data identifying the web pages you visited prior to and after visiting our
   Media Properties or using our Services;
 * Your movement and activity within the website, which is aggregated with other
   Personal information;
 * Geo-location information through the use of any of our mobile applications;
 * Mobile device information, including the type of device you use, operating
   system version, and the device identifier (or “UDID”); and
 * Mobile application identification and behavior, use, and aggregated usage,
   performance data, and where the application was downloaded from.
 * If you sign up for text messaging, cookies or other tracking devices may be
   used to personalize your experience (for example, to send you personalized
   text message offers).

C. Personal Information We May Receive from Third Parties

We may collect additional Personal Information about you from third-party
websites, social media platforms, such as, but not limited, to Facebook,
Twitter, Instagram, SnapChat (“Social Media Platforms”), third party data
providers, and sources providing publicly-available Personal information (e.g.,
from the U.S. postal service) for the purposes described in Section 3 below.

Personal Information we may access from Social Media Platforms may include, but
is not limited to:

 * Your Social Media Platform login information
 * Your location data
 * Your profile information
 * Your list of contacts, friends or followers
 * Certain Personal Information about your activities on the Social Media
   Platform

Please keep in mind that when you provide Personal Information to us on a
third-party website or platform (for example, via our applications), the
Personal Information you provide may be separately collected by the third-party
website or the Social Media Platform. Please review the privacy policies of the
applicable third-party website or Social Media Platform for their privacy
practices.


HOW WE USE PERSONAL INFORMATION

A. Use and Purpose of Processing Your Personal Information 

We use and process your Personal Information for the following types of purposes
(the examples provided are illustrative and not intended to be exhaustive).

 * To provide you with the Media Properties and Services, and related
   promotions, newsletters and information you request
 * To respond to your inquiries and provide you with requested information and
   other communications, including by email, chat or text messages, and
   including alerts, notification of promotions, contests, and events
 * For marketing and advertising purposes, including sending you promotional
   material or special offers on our behalf or on behalf of our marketing
   partners and/or their respective affiliates and other third parties, provided
   that you have not already opted-out of receiving such communications
 * For billing and payment processing
 * To deliver personalized advertising and content
 * To fulfill contracts we have with you
 * To manage, improve and foster relationships with third-party service
   providers, including vendors, suppliers, and parents, affiliates,
   subsidiaries, and business partners
 * To maintain, improve, customize, or administer the Media Properties and
   Services, perform business analyses, or other internal purposes to improve
   the quality of our business, the Media Properties and the Services, resolve
   technical problems, or improve security or develop other products and
   services
 * To comply with our Terms of Service
 * To perform analytics for business purposes and business intelligence, such as
   monitoring traffic to our Media Properties, counting ad impressions, and
   auditing legal and regulatory compliance
 * To maintain the safety, security, and integrity of our Media Properties,
   products and Services, databases and other technology assets and our
   business, including preventing fraud, detecting security breaches and
   prosecuting violators
 * To identify and repair errors in our Media Properties' functionality
 * To evaluate or conduct a merger, divestiture, restructuring, reorganization,
   dissolution, or other sale or transfer of some or all of our assets, in which
   Personal Information we hold is among the assets transferred
 * To comply with any applicable laws and regulations and respond to lawful
   requests; and/or
 * For any other purposes disclosed to you at the time we collect your Personal
   Information and/or pursuant to your consent 

If we decide to use the Personal Information for materially different purposes,
we will update this Privacy Policy.

B. Disclosing Your Personal Information to Other Parties

We may disclose your Personal Information to other parties, including:

 * Our affiliates
 * Service providers
 * Advertisers, advertising technology companies, analytics companies and other
   third parties with whom we have business relationships
 * Government regulators
 * Our legal advisors and parties involved in a legal process
 * To an entity involved in the sale of our business
 * Third parties to whom you or your agents authorize us to disclose your
   Personal Information in connection with products or Services we provide to
   you

In order to provide advertisements and content that are more relevant to you, we
and our advertising and content providers may collect certain types of Personal
Information when you use our Media Properties (such as, by way of example, your
email, the IP address of your device, the identifier on your mobile device, or
cookies stored on your device). We or our advertising and content providers may
combine this information with other information we have, or that we collect
through other sources, and may share the information we collect with third
parties to provide interest based or targeted advertising. If you would like to
opt out from this use, or for more information, please see our Cookie Policy for
more information.

If we decide to disclose Personal Information to additional categories of
parties, we will update this Privacy Policy.


DO WE USE "COOKIES"?

Yes. Cookies, SDKs, tracking pixels and similar technologies are small files
that a website or mobile application stores on your device that recognizes the
user’s browser or device and captures and remembers certain information.

In general, we and our third-party providers and advertisers, use these
technologies to optimize the functionality of the Media Properties, to help us
understand how the Media Properties are used and to provide users with
interest-based content or advertising based upon their browsing activities and
interests.

If you sign up for text messaging, cookies or other tracking devices may be used
to personalize your experience (for example, to send you personalized text
message offers). 

For more information about the cookies and other technologies that we, our
affiliates and third party providers and advertisers use on our Media
Properties, please read our Cookie Policy.

In addition, you may opt out of certain interest-based advertising by using the
following resources:

(a) You may opt-out of tracking and receiving tailored advertisements on your
mobile device by some mobile advertising companies and other similar entities by
downloading the App Choices app at www.aboutads.info/appchoices.

(b) You may opt-out of receiving permissible targeted advertisements by using
the NAI Opt-out tool available at http://optout.networkadvertising.org/?c=1 or
visiting About Ads at http://optout.aboutads.info.

(c) You may opt-out of having your activity on our Media Properties and Services
made available to Google Analytics by installing the Google Analytics opt-out
add-on for your web browser by visiting:
https://tools.google.com/dlpage/gaoptout for your web browser.

(d) One of our providers, LiveRamp, Inc. collects certain Personal Information
from you on our Media Properties, such as your email (in hashed form), IP
address or information about your browser or operating system. LiveRamp then
returns to us an online identification code that is associated with your
Personal Information, and that we may store in our first-party cookie for our
own use in online and cross-channel advertising across our Media Properties. It
may also be shared with advertising companies to enable interest-based and
targeted advertising. To opt out of this use by LiveRamp, please click here:
https://optout.liveramp.com/opt_out.

(e) We also transfer certain Personal Information collected from you on our
Media Properties, such as your email (in hashed form), IP address, or
information about your browser or operating system to one of our service
providers, Neustar Information Services, Inc. (“Neustar”).  Neustar then returns
to us an online identification code that is associated with your Personal
Information, and that we may store in our first-party cookie for our own use in
online and cross-channel advertising across our Media Properties. It may also be
shared with advertising companies to enable interest-based and targeted
advertising. To opt out of this processing by Neustar, please click here:
https://www.home.neustar/privacy/opt-out.  You may also opt-out of this
processing by Neustar via the Network Advertising Initiative’s opt-out
mechanism, described above in subparagraph (b). 


THIRD PARTY LINKS

Our Media Properties or Services may contain links to other websites,
applications or services that are not owned or controlled by us, including links
to social media platforms, or may redirect you off our Media Property or away
from our Services to other locations for information or other services. This
Privacy Policy only applies to information collected by our Media Properties and
Services. We are not responsible for the privacy and security practices of other
websites, applications or social media platforms or the information they may
collect (which may include IP address or device identifiers). You should refer
to such third parties' privacy policies on their sites to determine their
respective privacy practices. Links to any other websites, applications, social
media platform or content do not constitute or imply an endorsement or
recommendation by us of the linked website, application, social media platform,
and/or content.


SECURITY

We use commercially reasonable procedures and various technical, administrative
and physical safeguards to help protect the confidentiality of your Personal
Information. However, you should assume that no data transmitted over the
Internet or stored or maintained by us or our third-party service providers can
be 100% secure. Therefore, although we believe the measures implemented by us
reduce the likelihood of security problems to a level appropriate to the type of
data involved, we do not promise or guarantee, and you should not expect, that
your Personal Information or private communications will always remain private
or secure. We do not guarantee that your Personal Information will not be
misused by third parties. We are not responsible for the circumvention of any
privacy settings or security features.

If you believe that your Personal Information has been accessed or acquired by
an unauthorized person, please promptly Contact Us so that necessary measures
can quickly be taken.


ACCESSING, CORRECTING, OR DELETING YOUR PERSONAL INFORMATION

As required by applicable laws, and subject to any permitted exceptions and
limitations, we will comply with any verified consumer request you submit with
respect to your Personal Information. Please submit a verifiable consumer
request to us through the web form link provided below in Contact Us.


TRANSFERS

Your Personal Information may be stored, transferred to, and processed in any
country where we have facilities or in which we engage service providers. These
countries may be outside the United States, and may have different data
protection laws than in the United States.


AGGREGATE AND DE-IDENTIFIED INFORMATION

We may aggregate and/or de-identify any information collected through the Media
Properties and Services so that such information can no longer be linked to you
or your device (“Aggregate/De-Identified Information”). We may use
Aggregate/De-Identified Information for any purpose, including without
limitation for research and marketing purposes, and may also share such data
with any third parties, including advertisers, promotional partners, and
sponsors, in our discretion.


PRIVACY POLICY FOR CALIFORNIA RESIDENTS

This Privacy Policy does not apply to California residents. If you are a
California resident, please go to Your California Privacy Rights/Privacy Policy
to learn about your California privacy rights.


INDIVIDUALS IN THE EUROPEAN ECONOMIC AREA (EEA), OR UK

This Section is included in this Privacy Policy to comply with the requirements
of the General Data Protection Regulation ("GDPR"). It applies only to
individuals coming to our Media Properties from within the EEA, Switzerland or
the UK and applies only (1) if we collect through the Media Property any
Personal Data of those individuals or (2) if we track individuals in the EEA,
Switzerland or the UK who access our Media Properties.


CONTROLLER

Gannett is the controller (as defined under the GDPR) for processing and using
the Personal Data of individuals within the EEA, Switzerland or the UK that is
collected through our Site. Please see the “Contact Us” section below to find
out how to contact us.


RIGHTS OF INDIVIDUALS BASED IN THE EEA

Subject to applicable law, you may be able to exercise any of the following
rights in relation to your Personal Data:

 * Right to know what information we have about you: This is known as the "right
   of access" and gives you the right to find out what, if any, Personal Data we
   have about you, how we process it, and to request a copy of the Personal
   Data.
 * Right to correct your information: This is known as the "right of
   rectification" and gives you the right to ask that we correct or complete any
   Personal Data we have about you.
 * Right to delete your information: This is known as the "right to erasure" or
   "right to be forgotten" and gives you the right to ask us to delete your
   Personal Data.
 * Right to change how we use your information: This is known as the "right to
   restrict processing" and gives you the right to ask us to change how we use
   your Personal Data in certain circumstances, such as where you contest the
   accuracy of the data or object to us using it in a certain way.
 * Right to move your information: This is known as the "right to data
   portability" and gives you the right to ask to receive your Personal Data
   from us in a structured, commonly used and machine-readable format or to have
   it transmitted to another controller.
 * Right to stop us from using your information: This is known as the "right to
   object" and gives you the right to ask us to stop using your Personal Data
   when applicable.
 * Rights relating to how we use your information to categorize you or make
   decisions about you: This is known as the "right in relation to automated
   decision-making and profiling": You have the right to be free from decisions
   we may make that are based solely on automated processing of your Personal
   Data, including profiling, if they produce a significant legal effect on you,
   unless such decision-making or profiling is necessary for entering into or
   performing a contract between you and us, or is made with your explicit
   consent.
 * Right to withdraw consent: If we rely on your consent to use your Personal
   Data, you have the right to withdraw that consent at any time. This will not
   affect our use of your data before we received notice that you wished to
   withdraw your consent.
 * Right to file a complaint with the supervisory authority: If you have a
   concern about our privacy practices, including the way we handled your
   Personal Data, you can report it to the supervisory authority that is
   authorized to hear those concerns in your jurisdiction, although we invite
   you to Contact Us with any concern as we would be happy to try and resolve it
   directly.

You may exercise your rights by contacting us as indicated under the “Contact
Us” section below. To change your consent settings for our use of cookies and
other technologies, please see our Cookie Policy. 

The requests above will be considered and responded to in the time period stated
by applicable law. Certain information may be exempt from such requests. We may
require additional information from you to confirm your identity in responding
to such requests. 


LEGITIMATE INTERESTS

"Legitimate interests" means the interests of our company in conducting and
managing our organization. For example, and without limitation, we have a
legitimate interest in processing your Personal Data to analyze how the Media
Property and our products and Services are being used, to administer our
contractual relationships, fulfil legal obligations, process employee data,
prevent fraud or criminal activity or misuse of our products or services, ensure
the security of our IT systems, architecture and networks, and meet our
corporate and social responsibility objectives, and/or effectively and
efficiently operate our business and provide you with the services offered
through our Services, as described in this Privacy Policy. When we process your
Personal Data for our legitimate interests, we make sure to consider and balance
any potential impact on you, and your rights under data protection laws. Our
legitimate interests do not automatically override your interests. We will not
use your Personal Data for activities where our interests are overridden by the
impact on you, unless we have your consent or those activities are otherwise
required or permitted to by law. You have the right to object to processing that
is based on our legitimate interests. For more information on your rights,
please see "Your Rights" section above.


DATA TRANSFERS

Gannett is based in the United States, and we use service providers (described
above) based in the United States to operate our business and our relationship
with you. When you use our Site and the Services, you acknowledge that your
Personal Data may be transmitted, stored, processed by us and our service
providers’ servers in the United States to provide you with the services that
you requested, administer our contract with you or to respond to your requests
as described in this Privacy Policy. The United States may have data protection
laws less stringent than or otherwise different from the laws in effect in the
country in which you are located. Where we transfer your Personal Data out of
the EEA we will take steps to ensure that your rights continue to be protected.
We endeavor to apply suitable safeguards to protect the privacy and security of
your Personal Data and to use it only consistent with your relationship with us
and the practices described in this Privacy Policy. We also enter into data
processing agreements and model clauses with vendors as appropriate.


DATA RETENTION

We will keep your Personal Data only for as long as is reasonably necessary for
the purposes outlined in this Privacy Policy based on the context in which you
provided it, or for the duration required by law, whichever is the longer.


CHILDREN’S ON-LINE PRIVACY INFORMATION

In general, the Media Properties and Services are not intended for use by
children under the age of 13, or 16 where applicable. In cases where certain
Media Properties or Services are intended for use by children under the age of
13 (or 16 where applicable), we will post appropriate notices and take steps as
required by applicable law to safeguard children’s data. In addition, we do not
knowingly collect Personal Information from children under the age of 13 (or 16
where applicable) through form submissions on our Media Properties or Services,
although certain third party sites that we link to may do so. These third-party
sites have their own terms of use and privacy policies and we encourage parents
and legal guardians to monitor their children’s Internet usage and to help
enforce our Privacy Policy by instructing their children to never provide
information on our Media Properties without their permission.

 

Involvement of parents: In accordance with the provisions of the Children’s
Online Privacy Act, in the event that we do begin collecting any Personal
Information or data from children under the age of 13 (or 16 where applicable),
we will notify parents first, and will seek parental or guardian consent to
collect, use and/or disclose certain Personal Information from children under
the age of 13, or 16 where applicable. A parent may review and have deleted
their child’s Personal Information, and may refuse to permit further collection
or use of their child’s information by contacting us as noted at the end of this
Privacy Policy. Parents may consent to our collection and use of their child’s
Personal Information without consenting to the disclosure of that information to
others.

If you have reason to believe that a child under the age of 13 (or 16) has
provided Personal Information "Contact Us" below with sufficient detail to
enable us to delete that information from our databases.


ACCESSIBILITY

Please see our Accessibility Support page at
https://static.usatoday.com/accessibility/ if you experience any difficulty in
accessing any part of this Website or this Policy. You may also contact us at
accessibility@usatoday.com.


CHANGES TO THIS PRIVACY POLICY

We may amend this Privacy Policy at our discretion and at any time. When we make
changes to this Privacy Policy, we will post the updated notice on our Media
Properties and update the notice's "Last Updated" date. Where permitted by
applicable law, your continued use of our Website and/or Services following the
posting of changes constitutes your acceptance of such changes.


CONTACT US

If you have any questions or comments about this Privacy Policy, the ways in
which we collect and use your Personal Information described here, your choices
and rights regarding such use, or you wish to exercise your rights, please
contact us as provided below.

PLEASE NOTE: YOU SHOULD ONLY CONTACT US AT THIS EMAIL FORM OR ADDRESS FOR
PRIVACY RELATED CONCERNS, AND NOT FOR EDITORIAL, SUBSCRIPTION OR CONTENT-BASED
ISSUES INCLUDING TAKE-DOWN REQUESTS RELATING TO YOUR NAME OR IMAGE APPEARING IN
NEWS STORIES. PLEASE SEE OUR CORPORATE "Contact Us" PAGE INSTEAD FOR THOSE
MATTERS.

 * Email us through our Online Request Form
 * Write us at: Gannett Media Corp., 175 Sully's Trail, Pittsford, NY 14534
   Attn: Privacy Officer

General Data Protection Regulation (GDPR) - European Representative

Pursuant to Article 27 of the GDPR, Gannett has appointed a company called
European Data Protection Office (EDPO) as its GDPR representative in the EEA. If
you are an individual based in the EEA, Switzerland and/or UK, in addition to or
alternatively to contacting us, you can also contact EDPO regarding matters
pertaining to the processing of your Personal Data under GDPR as follows.  

PLEASE NOTE: YOU SHOULD NOT CONTACT EDPO IF YOU ARE AN INDIVIDUAL WHO IS A
CITIZEN OF SWITZERLAND, THE UK OR ANY EEA COUNTRY, BUT YOU ARE RESIDING IN,
VISITING OR OTHERWISE LOCATED IN THE US AND YOU ARE ACCESSING OUR WEBSITES OR
SERVICES FROM THE US. IN THAT CASE, PLEASE CONTACT GANNETT DIRECTLY AS PROVIDED
ABOVE.

 * By EDPO’s Online Request Form
 * By post:  
   * EU Representative: EDPO (European Data Protection Office) • Avenue Huart
     Hamoir 71, 1030 Brussels • Belgium
   * UK Representative: EDPO UK Ltd • 8 Northumberland Avenue, London W2CN 5 BY
     • United Kingdom


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