Updated July 21, 2020
Table of Contents
The California Consumer Privacy Act of 2018 (“CCPA”), as amended, requires certain disclosures and gives certain rights to California residents regarding their personal data. The CCPA applies only to California residents. Under CCPA, California residents have the right to know the categories of personal data and specific types of personal data we collect about you, the right to request deletion of your personal data, and the right to opt out of the sale of your personal data. More information on these rights and how California residents may exercise them is provided below under the headings “Additional California User Rights and Choices” and “Additional California User Contacts.” QMI provides notices to all users but applies the CCPA rights to know, to delete, and to opt out of sales to California residents only.
Data We Collect
We collect the following categories of personal data.
Categories of Personal Information
Identifiers, such as name, alias, billing and delivery addresses (current and past), unique personal identifier, online identifier, device identifiers, IP address, email address, phone number, account name, social media username, other circulation information (which includes some payment account, dwelling and service information), or other similar identifiers
We do not collect social security numbers via the Services, but we may be required to collect this identifier offline to award contest prizes valued at $600 or more, as required by tax regulations
Demographic data protected under state or federal law, such as age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex, sexual orientation, or veteran or military status
Commercial information, such as records of products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies
Internet or other electronic network activity, such as browsing history, search history, information on a consumer's interaction with an internet website, application, or advertisement
Geolocation data, such as physical location or movements
Professional or employment-related information, such as current or past job history
Inferences drawn from other information, such as any profile created about a consumer that reflects likely preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitude
With Whom We May Share or Sell Categories of Personal Information
For all the above categories, we may share with or sell to service providers, affiliates, business partners, marketing and advertising service providers or partners, government authorities or as required by law, merger or acquisition party, to parties as requested by you.
With respect to the identifier category: Social security number, when collected, is only shared with tax regulators.
Sources of Personal Data
QMI and certain third-party providers of tools utilized in the Services collect personal data from various sources, including:
- From Cookies, Web Beacons, and Tracking Technologies: When you use the Services, we or our third-party providers may automatically collect personal data from you through tracking and similar technologies that tells us which pages were visited and by how many users, the order in which pages were visited, and which hyperlinks were "clicked." Collecting this data may involve the collection of IP addresses, device IDs, and other online identifiers, operating system and browser software used by each user. Although such information is not personally identifiable, we or our third-party providers can identify the city and country in which a user is based, and we may be able to determine additional geographic location data.
The data we collect automatically from you helps us diagnose problems with our server, administer the Services, identify the most popular areas or features of the Services, identify where our users are coming from and determine the effectiveness of our promotional activities. In addition, QMI may disclose some of this information to advertisers to inform them of the number of people who have seen and/or clicked through their advertisements.
Web Beacons: The Services may also utilize web beacons (1x1 single-pixel graphics) that allow us to count the number of users who have visited or accessed the Services and to recognize users by accessing certain cookies. We and our third-party suppliers and/or the web sites and services of third-party advertisers and merchants with which we have a relationship may use web beacons to facilitate Services administration and navigation, to track the actions of users of the Services, to compile aggregate statistics about Services usage and response rates, for auditing purposes, and to provide an enhanced online experience for visitors to the Services. We may also include web beacons in HTML-formatted e-mail messages that we send to determine which e-mail messages were opened. You may choose to opt-out by contacting us at email@example.com.
Log Data: When you access the Services, our servers automatically record data that your browser or mobile device sends whenever you visit the Web site or our mobile applications. These server logs may include information such as your web request, IP address, device ID, geolocation, browser type, browser language, your computer operating system, email patterns, your mobile device and mobile operating system, the name of your internet service provider or your mobile carrier, the date and time of your request, and one or more cookies that may uniquely identify your browser.
Geolocation Data: QMI may collect data about your geolocation when you access any of our mobile applications. If you do not enable the service to use your geolocation data or if the app does not have that feature, we will not collect or store your geolocation data.
- Directly From You: QMI and certain third-party providers of tools utilized in the Services collect personally identifiable information through voluntary submissions you make via the Services.
- Certain features of the Services and third-party tools utilized in the Services, such as inquiries submitted through our “contact us” page, surveys and contests/sweepstakes, registration, offers, and subscription, advertising or other types of purchases, may require that you provide personally identifiable information (including, for example, mailing address, zip code, gender, age, date of birth, income, phone number and e-mail address, and when applicable for subscriptions and purchases, credit card, debit card or other payment or billing information). We and our third-party provider may have access to this data, with the exception of payment card data. QMI does not collect through the Services and does not have access to your credit card, debit card or other payment information.
- When registering to set up an account or to use certain aspects of the Services such as full access to the Services through a paid subscription, e-mail, chat or messenger features, and forums, or to receive certain alerts, newsletters or specifically targeted information, we or our third-party provider do require that you provide a valid e-mail address and zip code. Additional personally identifiable information may also be voluntarily provided by you. We and our third-party provider may have access to this data.
- In the event you enter a contest and win a prize valued at $600 or more, we may require your tax identification number to claim the prize. We will not ask you to submit this information through the Services. The reason we ask for this information is because we are required to report it to tax regulators.
- Our circulation system contains subscriber personal information related to your subscription to our publications. We collect this information when you subscribe, when you request changes to service, when you make or arrange for payment of your subscription via ACH transactions or when you communicate with us about your subscription. We use this data to provide our print and electronic newspaper service to you. Circulation data includes subscriber name, delivery address, billing address, phone, e-mail, service start and stop dates, vacation stops, dwelling type, dwelling status, do not call list status, bank account information for those that use direct debit from a bank account (ACH), web site logins, previous addresses, subscriptions to certain third party products that we print and distribute, delivery information for non-subscribers and complaint history.
- From Third Parties: We work with third-party service providers in connection with our Services. Such third-party services may include payment partners, website hosting, marketing, website usage analytics, advertising, and monitoring and maintaining the Services. In working with our service providers we may share your personal data with them and receive data back from them so that we may provide the Services to you.
How We Use Data
QMI uses the data we collect from you for the following business purposes:
- We use your name, address, billing information, and email address to fulfill your newspaper subscription, offer, advertising order, or other purchases you make and to deliver purchased products or services to you.
- In the event we offer account features, we may use data collected from you to identify you when you sign in to your account and to create and maintain your account and profile.
- To respond to your questions or inquiries.
- We may use your personal data for marketing purposes and to serve you tailored advertising.
- Aggregated cookie and web beacon data to build higher quality, more effective and more useful services by performing statistical analyses of the collective characteristics and behavior of the users of the Services, and by measuring demographics and interests regarding specific areas and features of the Services. This data may be combined with other data for retargeting advertising and other marketing purposes.
- E-mail address, social media username, or other contact information to deliver newsletters, alerts, subscription newspapers and other information requested by you. QMI limits our own e-mail contact and solicitations to those customers who have "opted in" to receiving such communications. The solicitations are limited in that they, among other things, will clearly indicate the originator of the e-mail and provide the customer with a method of "opting out" of receiving future communications of a similar nature.
- Demographic and/or geolocation data to decide which advertisements and sponsor messages to show to which users. As an example, if Sponsor XYZ wishes to display their advertising only to female users of the Services, we may use registration data to ensure that Sponsor XYZ's ads are displayed only to female users. Please also see the section on Internet based advertising and IP targeting below.
- To "pre-populate" forms, which are displayed for the purpose of collecting individual data by us and/or our sponsors.
- Geolocation data when you access our mobile applications to provide location aware products or services and for advertising purposes, and if you submit video or images for the news, for news reporting purposes.
- Personal information (for example, user name and login information) to monitor access to content offered through the Services and/or to make promotional offers to you. Paid subscribers may receive unlimited access to QMI content offered through the Services, while non-subscriber access may be limited.
How We Share and Disclose Personal Data
QMI may share or disclose your personal data to the following parties and under the following circumstances. Please also review the chart above related to categories of third parties.
- QMI may provide statistical information from cookies and beacons to advertisers, affiliates, and other current and potential business partners for advertising, promotional and other purposes. QMI also uses the aggregate data to inform these third parties as to the number of people who have seen and clicked on links to their web sites.
- During the registration process or during other interactions with the Services, you may choose to "opt in" to receiving promotional materials from us and/or our affiliates, advertisers, or other business partners and QMI. If you "opt in" to receiving such promotional materials, QMI reserves the right to release any personally identifiable registration information regarding you to third parties who provide goods or services that we believe may be of interest to you. If you decide that you would like to discontinue receiving promotional information from such third parties, please contact those third parties directly, or contact us at firstname.lastname@example.org.
- Third-party providers of financial transaction tools may collect your credit card, debit card, payment information and other personally identifiable information through the Services if voluntarily provided by you. QMI does not collect this information.
- Our third-party vendors may use your name, address, billing information, payment card information, and email address to fulfill your purchases and orders and to deliver purchased products or services to you.
- Your personal information provided through the Services may also be an asset of QMI’s business transferred to a third party in the event of a sale, merger or other business combination involving QMI.
- QMI may share your personal data with a third-party provider who may combine it with third-party data controlled by others for targeted marketing and advertising activity.
- We may provide your location data to third parties who provide goods or services that we believe may be of interest to you.
- We may also share your personal data (a) to comply with a law, regulation, or other governmental request, for example, to comply with subpoenas, court orders, legal process, or requests by law enforcement or governmental entities, (b) to investigate or defend against third-party claims against QMI, (c) to detect, prevent, or investigate fraud or other illegal activity or to enforce the Terms, (d) to respond to a request by you to disclose the information, (e) with your knowledge and consent, and (f) to address emergencies or acts of god.
- QMI may share your personal information with third parties that perform services on QMI’s behalf (including cloud, web and/or server hosting services and providers of third-party tools used in the Services); QMI does not authorize such third parties to use your personal information except as necessary to provide services to QMI or for purposes authorized by QMI.
- We and our Services are participants in behavioral advertising, adtech, and similar marketing and advertising activities. We have contractually agreed to restricted data processing with our adtech service providers. We disclose personal data to these service providers to facilitate such activities, but we do not view this disclosure to be a “sale” of personal data under CCPA.
- We share some subscriber circulation data with our business partners and marketing and advertising providers.
- Interest based advertising and IP targeting: QMI may work with data providers to serve advertising to you through display media or other methods. These providers may use personal information that we have collected or that you have provided to locate you online, such as when you visit or log in to websites or mobile applications. This information may be linked to online identifiers or IP addresses assigned to you, and to demographic or interest-based data, in order to target you with relevant advertising, including about our products or services. To learn more about or opt out of this and other interest-based advertising, please visit the industry opt-out pages operated by the DAA, at http://www.aboutads.info and by the NAI at http://networkadvertising.org.
- Third-party advertising networks: We may also use third-party advertising companies to collect data and/or serve ads when you visit our Website. These companies may use information (not including your name, address, email address or telephone number) about your visits to this and other Websites in order to provide advertisements about goods and services of interest to you. These companies may also use non-cookie technologies to recognize your computer or device and/or to collect and record information about your web surfing activity including your activities on or off this Website. Please keep in mind that your web browser may not permit you to block the use of these non-cookie technologies, and those browser settings that block cookies may have no effect on such techniques. If you would like more information about this practice and to know your choices about not having this information used by these companies, visit http://networkadvertising.org/ and youradchoices.com.
Your Rights and Choices
If you wish to correct, update, amend, or delete/remove personal information that is provided through the Services, you may contact us by email at email@example.com. QMI will use reasonable efforts to comply with your request. California residents should also review the additional rights and choices under “Additional California User Rights and Choices” section below.
In addition to the rights discussed above, there are various other ways you can choose to access, update, or limit the personal data you provide to us.
- Mobile Application Users. You may also choose to uninstall our Application from your mobile device regardless of whether you are an account holder or not.
- Unsubscribe from Emails.You may opt-out of receiving Emails from us by following the “unsubscribe” instructions included in certain emails we send you.
- Google Analytics. We use the Google Analytics service to gather and provide us with statistical data about how our Web site is used. This Google service uses a cookie that can be recognized by Google when you visit other websites. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google Analytics' collection and use of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
Additional California User Rights and Choices
California residents only have the following additional rights and choices under the CCPA:
Right to Know. You have the right to know the personal data we have about you. When you request that we provide you with the data we collect or disclose we will provide you with an individualized response about our collection and use of your personal data over the past 12 months. That response will include:
- Specific pieces of personal data we have collected about you
- The categories of personal data we have collected (see chart above)
- The sources from which we have collected your personal data
- Our business purpose for collecting or selling personal data
- The categories of third parties to whom we have disclosed or sold personal data
- Whether we have disclosed or sold your personal data for a business purpose.
You may only exercise this right twice within a 12-month period.
Right to Request Deletion. You have the right to request deletion of personal data we have about you. When you request that we delete your personal data, we will delete personal data we maintain about you from our records as of the date of your request subject to certain limitations. We will also request that any service providers that we know maintain your data on our behalf also delete your personal data. In some cases, deletion may be accomplished through de-identification of the information.
Please note that certain information may be excepted from your deletion request. For example, we may keep your information where necessary to detect and resolve issues related to system security and fraud detection.
Exercising Your Right to Know or Right to Request Deletion. To exercise the right to know and request deletion described above please initiate a verifiable consumer request through the web portal link provided below or by calling toll free 844-957-1731. You may also contact us via email at firstname.lastname@example.org.
If you have any questions about your right to know or deletion described above, you may contact us at email@example.com.
We cannot respond to your right to know or deletion if we cannot verify your identity or the authority of your agent to make the request and confirm that the personal data we maintain that relates to you. When you make a request, we will verify your identity by matching two or three data points that you provide with data points that we maintain and have determined to be reliable for the purposes of verification (e.g., telephone number and email address).
You must also describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it. If we have questions regarding your request you must make an effort to respond to our inquiries. If we do not understand your request we may not be able to comply.
Response Timing and Format. Where possible, we will respond to a verified right to know or delete request within 45 days of receipt. If we require more time, we will inform you of the reason and the need for an extension.
Any disclosures we provide will only cover the 12-month period preceding the verified consumer request's receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal data that is readily useable and should allow you to transmit the information to another entity.
We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.
Right to Opt-Out of Sale of Personal Information. Although we do not view our disclosure of your personal data to be classified as a “sale” under CCPA, we offer you the ability to opt out the disclosure. To tell us you want to opt-out of the disclosure of your personal data, you may click on the “Do Not Sell My Personal Information” link in the “Additional California User Contacts” section below or on the homepage of our Website or mobile app and fill out the form displayed. You may also email us at firstname.lastname@example.org opt-out.
Authorized Agents. You may designate an authorized agent to make requests on your behalf. We will require verification that you did in fact give that person your authorization. Unless the law requires otherwise, your authorized agent must provide contact details for you. We will contact you to confirm that you authorized the agent to act on your behalf. Once you confirm, we will promptly respond to the rights request.
Non-Discrimination.We will not discriminate against you for exercising any of the rights listed in this section. Specifically, we will not:
- Deny you Services, except to the extent that not having personal data prevents us from providing any aspect of the Services.
- Provide you a different level or quality of Services, except to the extent that not having personal data limits our ability to provide any aspect of the Services.
- Charge or suggest that we will charge you different prices or rates for the Services, including through granting discounts or other benefits, or imposing penalties.
Storage and Security
We use standard physical, technical and administrative measures designed to reduce the risk of loss, misuse, unauthorized access, disclosure or modification of your personal data. These security measures include Secure Socket Layer (SSL) technology data transmission. However, no method of transmitting or storing data is completely secure. As a result, although we strive to protect the personal data we collect about you, we cannot guarantee the security of any information we collect through the Services. If you have reason to believe that your personal data is no longer secure, please notify us immediately by contacting us at email@example.com.
QMI will retain your personal information collected through the Services for as long as QMI deems reasonably necessary or desirable, unless you make a verifiable request to delete your personal data or unless a different retention period is required by any applicable law, rule, or regulation. QMI reserves the right to delete or destroy data collected through the Services at any time.
No children under 13: The Services are not directed at or intended for use by children under 13 years old. You may be required to provide a date of birth to register for certain functionality of the Services (for example, contest/sweepstakes entries). You are not permitted to use the Services if you are under 13. Please review our Terms for additional information.
No Children Under 16: QMI has no actual knowledge that we collect or sell the personal data of minors under 16 years of age. If you have reason to believe that a child under 16 years old has provided personal data to us through the Services without the appropriate consent, please contact us as provided in the Contact Us section below with sufficient detail to enable us to delete that information from our records. We will act promptly on your request to delete such information.
Users outside the United States: The Services are not directed at or intended for users outside the U.S. Please be advised that if you are located in the European Union or another region with laws related to data collection, use and transfer that may differ from U.S. law, your personal information submitted through the Services and transferred to the U.S. may not have the same legal data protection as in your jurisdiction. Please review our Terms for additional information.
“Do Not Track” Signals:“Do Not Track” is a privacy preference that users can set in certain web browsers. Please note that our Services do not respond to Do Not Track signals or similar mechanisms transmitted by web browsers.
Changes to your personal data:If you wish to correct, update, or amend personal data that is provided through the Services, you may contact us by email at firstname.lastname@example.org. QMI will use reasonable efforts to comply with your request.
Third parties and links: QMI does not control the acts of users of the Services. All users should be aware that, when they disclose personally identifiable information in a bulletin board, chat or messenger feature, guestbook, or other forum, the information may be collected and used by others to send that person unsolicited e-mail from other parties outside of the Services or QMI. In the event that you encounter any user of the Services who is improperly collecting or using information about you or other users, please contact email@example.com.
The Services may contain links to other Internet web sites and services, including co-branded or other affiliated or unaffiliated sites that may or may not be owned or operated by QMI. Unless otherwise explicitly stated, QMI is not responsible for the privacy practices or the content of such web sites or services, including their use of any information collected when users or visitors to the Services click through links to those sites. Even though such information might not identify you personally, QMI strongly encourages you to become familiar with the privacy practices of those sites and services. QMI encourages users to be aware when they leave this Web site or our Services.
QMI cannot and does not assume any responsibility for any actions or omissions of third parties, including the manner in which they use information received either from us or independently. Nevertheless, in the event you encounter any third party associated with, or who claims association with, us who you feel is improperly collecting or using information about you, please contact firstname.lastname@example.org; QMI will make reasonable efforts to forward your message to the third party.
For general inquiries, concerns or questions, please email us at email@example.com.
Additional California User Contacts
California users only who want to exercise their rights under the CCPA may use these instructions and contacts:
To submit a request to know the personal data we have collected about you, click here, call us toll free at 844-957-1731, or write to us at:
Quincy Media, Inc.
Attn: Data Privacy
130 S 5th Street
Quincy, IL 62301
To submit a request to delete the personal data we have collected about you, click here, call us toll free at 844-957-1731, or write to us at:
Quincy Media, Inc.
Attn: Data Privacy
130 S 5th Street
Quincy, IL 62301