Voice of San Diego Website Privacy Policy Effective as of: December 1, 2018

Voice of San Diego (the “VOSD”, “we”, “us”, or “our”) operates the VOSD website at https://www.voiceofsandiego.org/  (the “Site”).

We take your privacy concerns seriously and want to make every effort to address them as we strive to offer customers, visitors and other users of the Site a high quality, interactive and personalized experience. That is why we have adopted the following website privacy policy (“Privacy Policy”), which explains our position on information gathering and how we intend to use and share any information we collect. This Privacy Policy applies to all information collected through our website and is only applicable to the Site, and not to any other websites that you may be able to access from the Site, each of which may have data collection, storage, and use practices and policies that differ materially from this Privacy Policy.

We use your data to provide and improve the Site. By using the Site, you agree to the collection and use of information in accordance with this Privacy Policy.

Definitions

Contact Data includes contact information such as your name, mailing address, and e-mail address.

Cookies are small files stored on your device (computer or mobile device).

Demographic Data includes information such as your zip code, age, and income.

Financial Data includes payment information such as your account or credit card number.

Personal Information means data about a living individual who can be identified from those data (or from those and other information either in our possession or likely to come into our possession).

Privacy Policy is VOSD’s website privacy policy, which explains VOSD’s position on information gathering and how we intend to use and share any information we collect.

Service Provider means any natural or legal person who provides services on VOSD’s behalf.

Site is the voiceofsandiego.org website operated by VOSD.

Subscriber is a User who provides an email address and requests VOSD to send one or more newsletters to that email address.

Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site, including: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; and (4) types of web browsers used to access the Site.

Usage Data is data collected automatically either generated by the use of the Site or from the Site infrastructure itself (for example, the duration of a page visit).

User is any living individual who is using the Site or the Service.

Username is the screen identifier of a Registered User, Subscriber, or Member.

VOSD is Voice of San Diego, a member-based nonprofit investigative news organization based in San Diego, California.

1. WHAT ARE OUR INFORMATION COLLECTION PRACTICES?

What information we collect and store depends on the page you are visiting and the services you elect to participate in. We use this information to operate our services, provide you with the highest-quality services, offer opportunities we think will be of interest and better tailor the advertising you see from us to suit you. This information is not shared with anyone outside of VOSD except as provided for in this Privacy Policy. More specifics on the information we collect are outlined within this policy.

1.1 WHAT TYPES OF INFORMATON ARE COLLECTED?

  1. TRAFFIC DATA COLLECTED. We automatically track and collect the following categories of information when you visit our Site: (1) IP addresses; (2) domain servers; (3) types of computers accessing the Site; and (4) types of web browsers used to access the Site (collectively “Traffic Data”). Traffic Data is anonymous information that does not personally identify you but is helpful for marketing purposes or for improving your experience on the Site. We also use “cookies” as described in section 1.1(c) below.

  2. PERSONAL INFORMATION COLLECTED. In order for you to access certain premium services and to purchase products that we offer via the Site, we require you to provide us with certain information that personally identifies you (“Personal Information”). Personal Information includes the following categories of information:

    1. Contact Data (such as your name, mailing address, and e-mail address);
    2. Financial Data (such as your account or credit card number); and
    3. Demographic Data (such as your ZIP code, age and income).

    If you communicate with us by e-mail, post messages to any of our chat groups, bulletin boards, or forums, or otherwise complete online forms, surveys, or contest entries, any information provided in such communication may be collected as Personal Information. If you wish to forward an article to a friend, we will ask that you provide your friend’s name and e-mail address. While we may collect statistics on which articles are forwarded, we do not sell, rent, or market your friend’s personal information, and retain the information only as long as necessary to provide this service.

  3. USE OF COOKIES. Most standard Web browsers contain a feature called “cookies,” which allow a Web site to place information about a User’s visit to that Web site in a small data text file that is stored on the User’s computer. Our use of cookie technology is used to recognize you and hold information from one visit to the next in an effort to increase your ease of use of the Site and to allow us to better understand how people use our Site through click-stream analysis. For example, cookies are used to store your Username and password, sparing you from having to re-enter that information each time you visit. Another example is that we may use cookies to control the number of times you see a particular advertisement while visiting the Site. You can turn off the cookies feature by using your browser preference options, but doing so will limit your access to the Site and may prevent you from registering.

    We use software developed by another company to display advertising on the Site, and we may use cookies in conjunction with displaying those ads. In addition, advertisers may elect to use other advertising companies to serve their ads on the Site, and advertisers themselves may also place a cookie on your computer. We do not have access to the cookies or their contents that are placed by advertisers or by third-party advertising companies. Those cookies are controlled by the content provider, and users should refer to that provider’s privacy policy for further information regarding its use of cookies.

1.2 HOW DO WE USE THE INFORMATION COLLECTED?

We process your information for purposes based on legitimate business interests, the fulfillment of our contract with you, compliance with our legal obligations, and/or your consent.

  1. COMPANY USE OF INFORMATION. We use Contact Data to send you information about us or our products or services, or promotional material from some of our partners, or to contact you when necessary. We use your Financial Data to verify your qualifications for certain products or services and to bill you for products and services. We use your Demographic Data to customize and tailor your experience on the Site, displaying content that we think you might be interested in and according to your preferences. We do not rent, sell, barter or give away your name, e-mail addresses or mailing addresses for use by advertisers and other third parties for the purpose of solicitations, unless you have previously given your consent at the time of general registration or registration for a specific contest or service. Nothing in this Privacy Policy is intended to restrict our use or sharing of aggregated or de-identified information in any way.

  2. SHARING OF PERSONAL INFORMATION. We share certain categories of information we collect from you in the ways described in this Privacy Policy. We share Demographic Data with advertisers and other third parties only on an aggregate (i.e., non-personally-identifiable) basis. We share Contact Data and Financial Data with third parties who assist us by performing core services (such as hosting, billing, fulfillment, or data storage and security) related to our operation of the Site (collectively, “Service Providers”). Those Service Providers have all agreed to uphold the same standards of security and confidentiality that we have promised to you in this Privacy Policy, and they will only use your Contact Data and other Personal Information to carry out their specific business obligations to VOSD. You may opt out of providing Personal Information as described in paragraph 1.2(c) and 1.2(d), below. In addition, we maintain a procedure for you to review and request changes to your Personal Information; this procedure is described in Section 2.1, below.

    E-MAIL AND E-MAIL OFFERS. If you granted permission to receive solicitations (referred to as E-mail Offers) at the time of registration on the Site but subsequently wish to opt out from receiving such solicitations, you may send an email to VOSD at info@voiceofsandiego.org.

    Our HTML-encoded e-mail messages may include graphic files, which we use to gather information about e-mails sent to our Subscribers. When you open such a message in an HTML-capable e-mail program, your computer accesses our server to retrieve the graphic file and allows us to record and store the date and time, the recipient’s e-mail address, and other standard logging information. These HTML-encoded e-mail messages may also read cookies.

  3. USER CHOICE REGARDING COLLECTION, USE, AND DISTRIBUTION OF PERSONAL INFORMATION. You may choose not to provide us with any Personal Information. In such an event, you can still access and use much of the Site; however you will not be able to access and use those portions of the Site that require your Personal Information. If you do not wish to receive information and promotional material from us or from some of our partners, please send your request via email to info@voiceofsandiego.org.

2. CONFIDENTIALITY AND SECURITY OF PERSONAL INFORMATION

Except as otherwise provided in this Privacy Policy, we will keep your Personal Information private and will not share it with third parties, unless such disclosure is necessary to: (a) comply with a court order or other legal process; (b) protect our rights or property; or (c) enforce our Terms of Service. Your Personal Information is stored on secure servers that are not accessible by third parties. We provide you with the capability to transmit your Personal Information via secured and encrypted channels if you use a similarly equipped web browser.

2.1 HOW DO I ACCESS, UPDATE, AND CHANGE PERSONAL INFORMATION?

At any time, you may visit your personal profile, if you are a registered user, at https://www.voiceofsandiego.org/account/edit-your-profile/. Through your personal profile you may: review and update your Personal Information that we have already collected.

2.2 LOST OR STOLEN INFORMATION

You must promptly notify us if your Username or password is lost, stolen, or used without permission. In such an event, we will remove that Username or password from your account and update our records accordingly.

2.3 PUBLIC INFORMATION

The Site contains links to other websites. We are not responsible for the privacy practices or the content of such websites. We also make chat rooms, forums, message boards, and news groups available to you. Please understand that any information that is disclosed in these areas becomes public information. We have no control over its use and you should exercise caution when deciding to disclose your Personal Information. VOSD expects its partners, providers of content and services, and advertisers to respect the privacy of our Users. Be aware, however, that third parties, including our partners, providers of content and services, advertisers and others accessible through our site may have their own privacy and data collection policies and practices. You should check the applicable privacy policies of those third parties when providing information on a feature or page operated by a third party.

3. RETENTION OF DATA

We will retain your Personal Information only for as long as is necessary for the purposes set out in this Privacy Policy. We will retain and use your Personal Information to the extent necessary to comply with our legal obligations (for example, if we are required to retain your data to comply with applicable laws), resolve disputes, and enforce our legal agreements and policies. We will also retain Usage Data for internal analysis purposes. Usage Data is generally retained for a shorter period of time, except when this data is used to strengthen the security or to improve the functionality of our Site, or we are legally obligated to retain this data for longer periods.

4. TRANSFER OF DATA

Your information, including Personal Information, may be transferred to — and maintained on — computers located outside of your state, province, country or other governmental jurisdiction where the data protection laws may differ from those of your jurisdiction. If you are located outside United States and choose to provide information to us, please note that we transfer the data, including Personal Information, to the United States and process it there. Your consent to this Privacy Policy followed by your submission of such information represents your agreement to that transfer.

We will take all the steps reasonably necessary to ensure that your data is treated securely and in accordance with this Privacy Policy and no transfer of your Personal Information will take place to an organization or a country unless there are adequate controls in place including the security of your data and other personal information.

5. CHILDREN’S PRIVACY

VOSD is particularly concerned with providing a safe online environment for children. Children under the age 13 will not be allowed to register on the site. We do not knowingly allow children under the age of 13 to register on our Site. If we discover that we have collected information from anyone under the age of 13, we will take reasonable steps to promptly remove such information.

6. UPDATES AND CHANGES TO PRIVACY POLICY

We reserve the right, at any time and without notice, to add to, change, update, or modify this Privacy Policy, simply by posting such change, update, or modification on the Site and without any other notice to you. Any such change, update, or modification will be effective immediately upon posting on the Site. You may also receive an e-mail outlining the change. Non-registered users of VOSD may view the Privacy Policy, including any revisions, by clicking on the Privacy Policy link on the home page of VOSD. If the changes represent a material departure from our current policy or materially affect users’ rights and obligations, if feasible, the changes will be posted on this page 30 days in advance of their effective date.

7. INTERNET USE RISKS

You should know that when you voluntarily disclose Personal Information on the Site (for example, in the discussion forums), that information can be collected and used by others and may result in unsolicited messages from other people. While we do our best to protect your Personal Information, we cannot be responsible for information that you choose to publicly disclose. Further, you are solely responsible for maintaining the secrecy of any passwords or other account information. Although we make good faith efforts to store the information we collect in a secure operating environment that is not available to the public and to work with responsible third parties, we cannot guarantee complete security for your information.

In addition, our advertisers, content providers, partners and other Internet sites or services that may be accessible through the Site have separate data and privacy practices that are independent of us, and we disclaim any responsibility or liability for their policies or actions. Please contact those sites directly if you have questions about their privacy policies.

8. PLATFORM FOR PRIVACY PREFERENCES

The Site supports the Platform for Privacy Preferences, or P3P, which allows us to convey our privacy policies, to the extent possible, in standardized, machine-readable code. While our site supports P3P, the resulting code has inherent limitations, such that it does not fully and may not accurately express all our data practices.

Some P3P-enabled browsers may interpret the same P3P code in different ways, while others may interpret P3P code in a manner inconsistent with the original intention. Accordingly, your browser’s interpretation of the P3P code should only be considered as a short-hand expression of our privacy practices. This Privacy Policy remains our primary policy and takes precedence over the P3P code for all purposes.

9. THIRD-PARTY SERVICE PROVIDERS

We may employ third-party companies and individuals to provide services on our behalf (“Service Providers”). These services include, for example list processing and analytics, advertising, and credit card processing. These service providers have access to your personal information only to perform these tasks on our behalf and are obligated not to disclose or use it for any other purpose.

9.1 ANALYTICS

We may use service providers to monitor and analyze the use of our service.

Google Analytics

Google Analytics is a web analytics service offered by Google that tracks and reports website traffic. Google uses the data collected to track and monitor the use of the Site. This data is shared with other Google services. Google may use the collected data to contextualize and personalize the ads of its own advertising network.

You can opt-out of having made your activity on the Site available to Google Analytics by installing the Google Analytics opt-out browser add-on. The add-on prevents the Google Analytics JavaScript (ga.js, analytics.js and dc.js) from sharing information with Google Analytics about visits activity.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

9.2 ADVERTISING

We may use Service Providers to show advertisements to you to help support and maintain our Site.

Google AdSense DoubleClick Cookie

Google, as a third-party vendor, uses cookies to serve ads on our Site. Google’s use of the DoubleClick cookie enables it and its partners to serve ads to our users based on their visit to our Site or other websites on the Internet.

You may opt out of the use of the DoubleClick Cookie for interest-based advertising by visiting the Google Ads settings page: http://www.google.com/ads/preferences/

9.3 BEHAVIORAL REMARKETING

We use remarketing services to advertise on third-party websites to you after you visited our service. We and our Service Providers use cookies to inform, optimize and serve ads based on your past visits to our Site.

Google AdWords

Google AdWords remarketing service is provided by Google Inc.

You can opt out of Google Analytics for Display Advertising and customize the Google Display Network ads by visiting the Google Ads settings page: http://www.google.com/settings/ads

Google also recommends installing the Google Analytics Opt-out Browser Add-on – https://tools.google.com/dlpage/gaoptout – for your web browser. Google Analytics Opt-out Browser Add-on provides visitors with the ability to prevent their data from being collected and used by Google Analytics.

For more information on the privacy practices of Google, please visit the Google Privacy Terms web page: https://policies.google.com/privacy?hl=en

Twitter

Twitter remarketing service is provided by Twitter Inc.

You can opt out from Twitter’s interest-based ads by following their instructions: https://support.twitter.com/articles/20170405

You can learn more about the privacy practices and policies of Twitter by visiting their privacy policy page: https://twitter.com/privacy

Facebook

Facebook remarketing service is provided by Facebook Inc.

You can learn more about interest-based advertising from Facebook by visiting this page: https://www.facebook.com/help/164968693837950

To opt out from Facebook’s interest-based ads, follow these instructions from Facebook: https://www.facebook.com/help/568137493302217

Facebook adheres to the Self-Regulatory Principles for Online Behavioural Advertising established by the Digital Advertising Alliance. You can also opt out from Facebook and other participating companies through the Digital Advertising Alliance in the United States, http://www.aboutads.info/choices/, the Digital Advertising Alliance of Canada in Canada, http://youradchoices.ca/ or the European Interactive Digital Advertising Alliance in Europe http://www.youronlinechoices.eu/, or opt out using your mobile device settings.

For more information on the privacy practices of Facebook, please visit Facebook’s data policy: https://www.facebook.com/privacy/explanation

9.4 PAYMENTS

We may provide paid products and/or services within the Site. In that case, we use Service Providers for payment processing (e.g. payment processors).

We will not store or collect your payment card details. That information is provided directly to our third-party payment processors whose use of your personal information is governed by their privacy policy. These payment processors adhere to the standards set by PCI-DSS as managed by the PCI Security Standards Council, which is a joint effort of brands like Visa, MasterCard, American Express and Discover. PCI-DSS requirements help ensure the secure handling of payment information.

The payment processors we work with are:

Stripe

Its privacy policy can be viewed at https://stripe.com/us/privacy

10. GENERAL

In the event of the sale or merger of VOSD, ownership of the information described in this Privacy Policy will be transferred to the acquiring or successor company. VOSD endorses and abides by the privacy principles approved by the Interactive Services Association and the Direct Marketing Association. If you have any questions or comments about our policies, we may be reached at Voice of San Diego, 110 West A St. Suite 650, San Diego, CA 92101; (619) 325-0525.