Privacy Policy

Privacy Policy

Last updated: August 16, 2021

This Privacy Policy describes Our policies and procedures on the collection, use and  disclosure of Your information when You use the Service and tells You about Your  privacy rights and how the law protects You.

We use Your Personal data to provide and improve the Service. By using the  Service, You agree to the collection and use of information in accordance with this  Privacy Policy.

Interpretation and Definitions

Interpretation

The words of which the initial letter is capitalized have meanings defined under the  following conditions. The following definitions shall have the same meaning  regardless of whether they appear in singular or in plural.

Definitions

For the purposes of this Privacy Policy:

• Account means a unique account created for You to access our Service or  parts of our Service.

• Business, for the purpose of the CCPA (California Consumer Privacy Act),  refers to the Company as the legal entity that collects Consumers' personal  information and determines the purposes and means of the processing of  Consumers' personal information, or on behalf of which such information is  collected and that alone, or jointly with others, determines the purposes and  means of the processing of consumers' personal information, that does  business in the State of California.

• Company (referred to as either "the Company", "We", "Us" or "Our" in this  Agreement) refers to The Oklahoma City Sentinel.

For the purpose of the GDPR, the Company is the Data Controller.

• Consumer, for the purpose of the CCPA (California Consumer Privacy Act),  means a natural person who is a California resident. A resident, as defined in  the law, includes (1) every individual who is in the USA for other than a  temporary or transitory purpose, and (2) every individual who is domiciled in  the USA who is outside the USA for a temporary or transitory purpose.

• Cookies are small files that are placed on Your computer, mobile device or  any other device by a website, containing the details of Your browsing  history on that website among its many uses.

• Country refers to: Oklahoma, United States

• Data Controller, for the purposes of the GDPR (General Data Protection  Regulation), refers to the Company as the legal person which alone or jointly  with others determines the purposes and means of the processing of Personal  Data.

• Device means any device that can access the Service such as a computer, a  cellphone or a digital tablet.

• Do Not Track (DNT) is a concept that has been promoted by US regulatory  authorities, in particular the U.S. Federal Trade Commission (FTC), for the  Internet industry to develop and implement a mechanism for allowing  internet users to control the tracking of their online activities across websites.

• Facebook Fan Page is a public profile named The City Sentinel specifically  created by the Company on the Facebook social network, accessible  from www.facebook.com/TheCitySentinel

• Personal Data is any information that relates to an identified or identifiable  individual.

For the purposes for GDPR, Personal Data means any information relating to  You such as a name, an identification number, location data, online identifier  or to one or more factors specific to the physical, physiological, genetic,  mental, economic, cultural or social identity.

For the purposes of the CCPA, Personal Data means any information that identifies, relates to, describes or is capable of being associated with, or could  reasonably be linked, directly or indirectly, with You.

• Sale, for the purpose of the CCPA (California Consumer Privacy Act), means  selling, renting, releasing, disclosing, disseminating,making available,  transferring, or otherwise communicating orally, in writing, or by electronic  or other means, a Consumer's personal information to another business or a  third party for monetary or other valuable consideration.

• Service refers to the Website.

• Service Provider means any natural or legal person who processes the data  on behalf of the Company. It refers to third-party companies or individuals  employed by the Company to facilitate the Service, to provide the Service on  behalf of the Company, to perform services related to the Service or to assist  the Company in analyzing how the Service is used. For the purpose of the  GDPR, Service Providers are considered Data Processors.

• Third-party Social Media Service refers to any website or any social  network website through which a User can log in or create an account to use  the Service.

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

• Website refers to The Oklahoma City Sentinel, accessible from www.citysentinel.com

• You means the individual accessing or using the Service, or the company, or  other legal entity on behalf of which such individual is accessing or using the  Service, as applicable.

Under GDPR (General Data Protection Regulation), You can be referred to as the Data Subject or as the User as you are the individual using the Service.

Collecting and Using Your Personal Data

Types of Data Collected

Personal Data

While using Our Service, We may ask You to provide Us with certain personally  identifiable information that can be used to contact or identify You.Personally  identifiable information may include, but is not limited to:

• Email address

• First name and last name

• Phone number

• Address, State, Province, ZIP/Postal code, City

• Usage Data

Usage Data

Usage Data is collected automatically when using the Service.

Usage Data may include information such as Your Device's Internet Protocol  address (e.g. IP address), browser type, browser version, the pages of our Service  that You visit, the time and date of Your visit, the time spent on those pages, unique  device identifiers and other diagnostic data.

When You access the Service by or through a mobile device, We may collect  certain information automatically, including, but not limited to, the type of mobile  device You use, Your mobile device unique ID, the IP address of Your mobile  device, Your mobile operating system, the type of mobile Internet browser You use,  unique device identifiers and other diagnostic data.

We may also collect information that Your browser sends whenever You visit our  Service or when You access the Service by or through a mobile device.

Information from Third-Party Social Media Services

The Company allows You to create an account and log in to use the Service through  the following Third-party Social Media Services:

• Google

• Facebook

• Twitter

If You decide to register through or otherwise grant us access to a Third-Party  Social Media Service, We may collect Personal data that is already associated with  Your Third-Party Social Media Service's account, such as Your name, Your email  address, Your activities or Your contact list associated with that account.

You may also have the option of sharing additional information with the Company  through Your Third-Party Social Media Service's account. If You choose to provide  such information and Personal Data, during registration or otherwise, You are  giving the Company permission to use, share, and store itin a manner consistent  with this Privacy Policy.

Tracking Technologies and Cookies

We use Cookies and similar tracking technologies to track the activity on Our  Service and store certain information. Tracking technologies used are beacons, tags,  and scripts to collect and track information and to improve and analyze Our Service.  The technologies We use may include:

• Cookies or Browser Cookies. A cookie is a small file placed on Your  Device. You can instruct Your browser to refuse all Cookies or to indicate  when a Cookie is being sent. However, if You do not accept Cookies, You  may not be able to use some parts of our Service. Unless you have adjusted  Your browser setting so that it will refuse Cookies, our Service may use  Cookies.

• Flash Cookies. Certain features of our Service may use local stored objects  (or Flash Cookies) to collect and store information about Your preferences or  Your activity on our Service. Flash Cookies are not managed by the same  browser settings as those used for Browser Cookies. For more information on  how You can delete Flash Cookies, please read "Where can I change the  settings for disabling, or deleting local shared objects?" available  at https://helpx.adobe.com/flash-player/kb/disable-local-shared-objectsflash.html#main_Where_can_I_change_the_settings_for_disabling__or_deleting_local_shared_objects_

• Web Beacons. Certain sections of our Service and our emails may contain  small electronic files known as web beacons (also referred to as clear gifs,  pixel tags, and single-pixel gifs) that permit the Company, for example, to  count users who have visited those pages or opened an email and for other  related website statistics (for example, recording the popularity of a certain  section and verifying system and server integrity).Cookies can be "Persistent" or "Session" Cookies. Persistent Cookies remain on  Your personal computer or mobile device when You go offline, while Session  Cookies are deleted as soon as You close Your web browser. Learn more about  cookies: Cookies: What Do They Do?.

We use both Session and Persistent Cookies for the purposes set out below:

• Necessary / Essential Cookies

Type: Session Cookies

Administered by: Us

Purpose: These Cookies are essential to provide You with services available  through the Website and to enable You to use some of its features. They help  to authenticate users and prevent fraudulent use of user accounts. Without  these Cookies, the services that You have asked for cannot be provided, and  We only use these Cookies to provide You with those services.

• Cookies Policy / Notice Acceptance Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies identify if users have accepted the use of cookies on  the Website.

• Functionality Cookies

Type: Persistent Cookies

Administered by: Us

Purpose: These Cookies allow us to remember choices You make when You  use the Website, such as remembering your login details or language  preference. The purpose of these Cookies is to provide You with a more  personal experience and to avoid You having to re-enter your preferences  every time You use the Website.

• Tracking and Performance Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies are used to track information about traffic to the  Website and how users use the Website. The information gathered via these Cookies may directly or indirectly identify you as an individual visitor. This  is because the information collected is typically linked to a pseudonymous  identifier associated with the device you use to access the Website. We may  also use these Cookies to test new pages, features or new functionality of the  Website to see how our users react to them.

• Targeting and Advertising Cookies

Type: Persistent Cookies

Administered by: Third-Parties

Purpose: These Cookies track your browsing habits to enable Us to show advertising which is more likely to be of interest to You. These Cookies use information about your browsing history to group You with other users who have similar interests. Based on that information, and with Our permission,third party advertisers can place Cookies to enable them to show adverts which We think will be relevant to your interests while You are on third party  websites.

For more information about the cookies we use and your choices regarding cookies,  please visit our Cookies Policy or the Cookies section of our Privacy Policy.

Use of Your Personal Data

The Company may use Personal Data for the following purposes:

• To provide and maintain our Service, including to monitor the usage of our  Service.

• To manage Your Account: to manage Your registration as a user of the  Service. The Personal Data You provide can give You access to different  functionalities of the Service that are available to You as a registered user.

• For the performance of a contract: the development, compliance and  undertaking of the purchase contract for the products, items or services You  have purchased or of any other contract with Us through the Service.

• To contact You: To contact You by email, telephone calls, SMS, or other  equivalent forms of electronic communication, such as a mobile application's  push notifications regarding updates or informative communications related  to the functionalities, products or contracted services, including the security  updates, when necessary or reasonable for their implementation.

• To provide You with news, special offers and general information about  other goods, services and events which we offer that are similar to those that  you have already purchased or enquired about unless You have opted not to  receive such information.

• To manage Your requests: To attend and manage Your requests to Us.

• To deliver targeted advertising to You: We may use Your information to  develop and display content and advertising (and work with third-party  vendors who do so) tailored to Your interests and/or location and to measure  its effectiveness.

• For business transfers: We may use Your information to evaluate or conduct  a merger, divestiture, restructuring, reorganization, dissolution, or other sale  or transfer of some or all of Our assets, whether as a going concern or as part  of bankruptcy, liquidation, or similar proceeding, in which Personal Data  held by Us about our Service users is among the assets transferred.

• For other purposes: We may use Your information for other purposes, such  as data analysis, identifying usage trends, determining the effectiveness of  our promotional campaigns and to evaluate and improve our Service,  products, services, marketing and your experience.

We may share Your personal information in the following situations:

• With Service Providers: We may share Your personal information with  Service Providers to monitor and analyze the use of our Service, to show  advertisements to You to help support and maintain Our Service,to advertise  on third party websites to You after You visited our Service,for payment  processing, to contact You.

• For business transfers: We may share or transfer Your personal information  in connection with, or during negotiations of, any merger, sale of Company  assets, financing, or acquisition of all or a portion of Our business to another  company.

• With Affiliates: We may share Your information with Our affiliates, in  which case we will require those affiliates to honor this Privacy Policy.  Affiliates include Our parent company and any other subsidiaries, joint  venture partners or other companies that We control or that are under  common control with Us.

• With business partners: We may share Your information with Our business  partners to offer You certain products, services or promotions.

• With other users: when You share personal information or otherwise  interact in the public areas with other users, such information may be viewed  by all users and may be publicly distributed outside. If You interact with  other users or register through a Third-Party Social Media Service, Your  contacts on the Third-Party Social Media Service may see Your name, profile,  pictures and description of Your activity. Similarly, other users will be able to  view descriptions of Your activity, communicate with You and view Your  profile.

• With Your consent: We may disclose Your personal information for any  other purpose with Your consent.

Retention of Your Personal Data

The Company will retain Your Personal Data only for as long as is necessary for the  purposes set out in this Privacy Policy. We will retain and use Your Personal Data 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.

The Company 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 Service, or We are  legally obligated to retain this data for longer time periods.

Transfer of Your Personal Data

Your information, including Personal Data, is processed at the Company's operating  offices and in any other places where the parties involved in the processing are  located. It means that this information may be transferred to =E2=80=94 and  maintained on =E2=80=94 computers located outside of Your state, province,  country or other governmental jurisdiction where the data protection laws may differ  than those from Your jurisdiction.

Your consent to this Privacy Policy followed by Your submission of such information represents Your agreement to that transfer.

The Company will take all steps reasonably necessary to ensure that Your data is  treated securely and in accordance with this Privacy Policy and no transfer of Your  Personal Data 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.

Disclosure of Your Personal Data

Business Transactions

If the Company is involved in a merger, acquisition or asset sale, Your Personal  Data may be transferred. We will provide notice before Your Personal Data is  transferred and becomes subject to a different Privacy Policy.

Law enforcement

Under certain circumstances, the Company may be required to disclose Your  Personal Data if required to do so by law or in response to valid requests by public  authorities (e.g. a court or a government agency).

Other legal requirements

The Company may disclose Your Personal Data in the good faith belief that such  action is necessary to:

• Comply with a legal obligation

• Protect and defend the rights or property of the Company

• Prevent or investigate possible wrongdoing in connection with the Service

• Protect the personal safety of Users of the Service or the public

• Protect against legal liability

Security of Your Personal Data

The security of Your Personal Data is important to Us, but remember that no method  of transmission over the Internet, or method of electronic storage is 100% secure.  While We strive to use commercially acceptable means to protect Your Personal  Data, We cannot guarantee its absolute security.

Detailed Information on the Processing of  Your Personal Data

The Service Providers We use may have access to Your Personal Data. These third party vendors collect, store, use, process and transfer information about Your  activity on Our Service in accordance with their Privacy Policies.

Analytics

We may use third-party 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 our Service. 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 Service 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

Advertising

We may use Service Providers to show advertisements to You to help support and  maintain Our Service.

• Google AdSense & DoubleClick Cookie

Google, as a third party vendor, uses cookies to serve ads on our Service.  Google's use of the DoubleClick cookie enables it and its partners to serve  ads to our users based on their visit to our Service 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 web  page: http://www.google.com/ads/preferences/

• AdMob by Google

AdMob by Google is provided by Google Inc.

You can opt-out from the AdMob by Google service by following the instructions described by Google: https://support.google.com/ads/answer/2662922?hl=3Den

For more information on how Google uses the collected information, please  visit the "How Google uses data when you use our partners' sites or app" page: https://policies.google.com/technologies/partner-sites or visit the  Privacy Policy of Google: <a href=3D"https://policies.google.com/privacy"  rel=3D"external nofollow noopener"  target=3D"_blank">https://policies.google.com/privacy

• Bing Ads

Bing Ads is an advertising service provided by Microsoft Inc.

You can opt-out from Bing Ads by following the instructions on Bing Ads Opt-out page: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

For more information about Bing Ads, please visit their Privacy Policy:  https://privacy.microsoft.com/en-us/PrivacyStatement

Email Marketing

We may use Your Personal Data to contact You with newsletters, marketing or  promotional materials and other information that may be of interest to You. You  may opt-out of receiving any, or all, of these communications from Us by following  the unsubscribe link or instructions provided in any email We send or by contacting  Us.

We may use Email Marketing Service Providers to manage and send emails to You.

• Mailchimp

Mailchimp is an email marketing sending service provided by The Rocket Science Group LLC.

For more information on the privacy practices of Mailchimp, please visit their  Privacy policy: https://mailchimp.com/legal/privacy/

• AWeber

AWeber is an email marketing sending service provided by AWeber  Communications.

For more information on the privacy practices of AWeber, please visit their  Privacy policy: https://www.aweber.com/privacy.htm

• GetResponse

GetResponse is an email marketing sending service provided by GetResponse.

For more information on the privacy practices of GetResponse, please visit  their Privacy policy: https://www.getresponse.com/legal/privacy.html

Payments

We may provide paid products and/or services within the Service. In that case, we  may use third-party services 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.

• Apple Store In-App Payments

Their Privacy Policy can be viewed at https://www.apple.com/legal/privacy/en-ww/

• Google Play In-App Payments

Their Privacy Policy can be viewed at https://www.google.com/policies/privacy/

• WePay

Their Privacy Policy can be viewed at https://go.wepay.com/privacy-policy

• PayPal

Their Privacy Policy can be viewed  at https://www.paypal.com/webapps/mpp/ua/privacy-full

• Square

Their Privacy Policy can be viewed at https://squareup.com/legal/privacy-noaccount

Behavioral Remarketing

The Company uses remarketing services to advertise to You after You accessed or  visited our Service. We and Our third-party vendors use cookies and non-cookie  technologies to help Us recognize Your Device and understand how You use our  Service so that We can improve our Service to reflect Your interests and serve You  advertisements that are likely to be of more interest to You.

These third-party vendors collect, store, use, process and transfer information about  Your activity on Our Service in accordance with their Privacy Policies and to enable  Us to:

• Measure and analyze traffic and browsing activity on Our Service

• Show advertisements for our products and/or services to You on third-party  websites or apps

• Measure and analyze the performance of Our advertising campaigns

Some of these third-party vendors may use non-cookie technologies that may not be  impacted by browser settings that block cookies. Your browser maynot permit You  to block such technologies. You can use the following third-party tools to decline  the collection and use of information for the purpose of serving You interest-based  advertising:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=3D2&lang=3DEN

You may opt-out of all personalized advertising by enabling privacy features on  Your mobile device such as Limit Ad Tracking (iOS) and Opt Out of Ads Personalization (Android). See Your mobile device Help system for more information.

We may share information, such as hashed email addresses (if available) or other  online identifiers collected on Our Service with these third-party vendors. This  allows Our third-party vendors to recognize and deliver You ads across devices and  browsers. To read more about the technologies used by these third-party vendors  and their cross-device capabilities please refer to the Privacy Policy of each vendor  listed below.

The third-party vendors We use are:

• Google Ads (AdWords)

Google Ads (AdWords) remarketing service is provided by Google Inc.

You can opt-out of Google Analytics for Display Advertising and customise  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

• Bing Ads Remarketing

Bing Ads remarketing service is provided by Microsoft Inc.

You can opt-out of Bing Ads interest-based ads by following their instructions: https://advertise.bingads.microsoft.com/en-us/resources/policies/personalized-ads

You can learn more about the privacy practices and policies of Microsoft by  visiting their Privacy Policy page: https://privacy.microsoft.com/enus/PrivacyStatement

• 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/516147308587266

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 USA 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

• Pinterest

Pinterest remarketing service is provided by Pinterest Inc.

You can opt-out from Pinterest's interest-based ads by enabling the "Do Not  Track" functionality of your web browser or by following Pinterest instructions: http://help.pinterest.com/en/articles/personalization-and-data

You can learn more about the privacy practices and policies of Pinterest by  visiting their Privacy Policy page: https://about.pinterest.com/en/privacy-policy

Usage, Performance and Miscellaneous

We may use third-party Service Providers to provide better improvement of our  Service.

• Google Places

Google Places is a service that returns information about places using HTTP  requests. It is operated by Google

Google Places service may collect information from You and from Your Device for security purposes.

The information gathered by Google Places is held in accordance with the Privacy Policy of Google: https://www.google.com/intl/en/policies/privacy/

GDPR Privacy

Legal Basis for Processing Personal Data under GDPR

We may process Personal Data under the following conditions:

• Consent: You have given Your consent for processing Personal Data for one  or more specific purposes.

• Performance of a contract: Provision of Personal Data is necessary for the  performance of an agreement with You and/or for any pre-contractual  obligations thereof.

• Legal obligations: Processing Personal Data is necessary for compliance  with a legal obligation to which the Company is subject.</li>

• Vital interests: Processing Personal Data is necessary in order to protect  Your vital interests or of another natural person.

• Public interests: Processing Personal Data is related to a task that is carried  out in the public interest or in the exercise of official authority vested in the  Company.

• Legitimate interests: Processing Personal Data is necessary for the purposes  of the legitimate interests pursued by the Company.</li>

In any case, the Company will gladly help to clarify the specific legal basis that  applies to the processing, and in particular whether the provision of Personal Data is  a statutory or contractual requirement, or a requirement necessary to enter into a  contract.

Your Rights under the GDPR

The Company undertakes to respect the confidentiality of Your Personal Data and  to guarantee You can exercise Your rights.

You have the right under this Privacy Policy, and by law if You are within the EU,  to:

• Request access to Your Personal Data. The right to access, update or delete  the information We have on You. Whenever made possible, you can access,  update or request deletion of Your Personal Data directly within Your  account settings section. If you are unable to perform these actions yourself,  please contact Us to assist You. This also enables You to receive a copy of the  Personal Data We hold about You.

• Request correction of the Personal Data that We hold about You.You  have the right to have any incomplete or inaccurate information We hold  about You corrected.

• Object to processing of Your Personal Data. This right exists where We are  relying on a legitimate interest as the legal basis for Our processing and there  is something about Your particular situation, which makes You want to  object to our processing of Your Personal Data on this ground. You also have  the right to object where We are processing Your Personal Data for direct  marketing purposes.

• Request erasure of Your Personal Data. You have the right to ask Us to  delete or remove Personal Data when there is no good reason for Us to  continue processing it.

• Request the transfer of Your Personal Data. We will provide to You, or to  a third-party You have chosen, Your Personal Data in a structured,  commonly used, machine-readable format. Please note that this right only  applies to automated information which You initially provided consent for Us  to use or where We used the information to perform a contract with You.

• Withdraw Your consent. You have the right to withdraw Your consent on  using your Personal Data. If You withdraw Your consent, We may not be  able to provide You with access to certain specific functionalities of the  Service.

Exercising of Your GDPR Data Protection Rights

You may exercise Your rights of access, rectification, cancellation and opposition  by contacting Us. Please note that we may ask You to verify Your identity before  responding to such requests. If You make a request, We will try our best to respond  to You as soon as possible.

You have the right to complain to a Data Protection Authority about Our collection  and use of Your Personal Data. For more information, if You are in the European  Economic Area (EEA), please contact Your local data protection authority in the  EEA.

Facebook Fan Page

Data Controller for the Facebook Fan Page

The Company is the Data Controller of Your Personal Data collected while using the  Service. As operator of the Facebook Fan Page www.facebook.com/TheCitySentinel, the Company and the operator of the social network Facebook are Joint  Controllers.

The Company has entered into agreements with Facebook that define the terms for  use of the Facebook Fan Page, among other things. These terms are mostly based on  the Facebook Terms of Service: https://www.facebook.com/terms.php

Visit the Facebook Privacy Policy https://www.facebook.com/policy.php for more  information about how Facebook manages Personal data or contact Facebook online,  or by mail: Facebook, Inc. ATTN,Privacy Operations, 1601 Willow Road, Menlo  Park, CA 94025, United States.Facebook Insights

We use the Facebook Insights function in connection with the operation of the  Facebook Fan Page and on the basis of the GDPR, in order to obtain anonymized statistical data about Our users.

For this purpose, Facebook places a Cookie on the device of the user visiting Our  Facebook Fan Page. Each Cookie contains a unique identifier code and remains  active for a period of two years, except when it is deleted before the end of this  period.

Facebook receives, records and processes the information stored in the Cookie,  especially when the user visits the Facebook services, services that are provided by  other members of the Facebook Fan Page and services by other companies that use  Facebook services.

For more information on the privacy practices of Facebook, please visit Facebook  Privacy Policy here: https://www.facebook.com/privacy/explanation

CCPA Privacy

This privacy notice section for California residents supplements the information  contained in Our Privacy Policy and it applies solely to all visitors, users, and others  who reside in the State of California.

Categories of Personal Information Collected

We collect information that identifies, relates to, describes, references, is capable of  being associated with, or could reasonably be linked, directly or indirectly, with a  particular Consumer or Device. The following is a list of categories of personal  information which we may collect or may have been collected from California  residents within the last twelve (12) months.

Please note that the categories and examples provided in the list below are those  defined in the CCPA. This does not mean that all examples of that category of  personal information were in fact collected by Us, but reflects our good faith belief  to the best of our knowledge that some of that information from the applicable  category may be and may have been collected. For example, certain categories of  personal information would only be collected if You provided such personal  information directly to Us.

• Category A: Identifiers.

Examples: A real name, alias, postal address, unique personal identifier,  online identifier, Internet Protocol address, email address, account name,  driver's license number, passport number, or other similar identifiers.

Collected: Yes.

• Category B: Personal information categories listed in the California  Customer Records statute (Cal. Civ. Code =C2=A7 1798.80(e)).</p>

Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver's license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card  number, debit card number, or any other financial information, medical  information, or health insurance information. Some personal information  included in this category may overlap with other categories.

Collected: Yes.

• Category C: Protected classification characteristics under California or  federal law.

Examples: Age (40 years or older), race, color, ancestry, national origin,  citizenship, religion or creed, marital status, medical condition, physical or  mental disability, sex (including gender, gender identity, gender expression,  pregnancy or childbirth and related medical conditions), sexual orientation,  veteran or military status, genetic information (including familial genetic  information).

Collected: No.

• Category D: Commercial information.

Examples: Records and history of products or services purchased or considered.

Collected: Yes.

• Category E: Biometric information.

Examples: Genetic, physiological, behavioral, and biological characteristics,  or activity patterns used to extract a template or other identifier or identifying  information, such as, fingerprints, faceprints, and voiceprints, iris or retina  scans, keystroke, gait, or other physical patterns, and sleep, health, or  exercise data.

Collected: No.

• Category F: Internet or other similar network activity.Examples: Interaction with our Service or advertisement.

Collected: Yes.

• Category G: Geolocation data.

Examples: Approximate physical location.

Collected: No.

• Category H: Sensory data.

Examples: Audio, electronic, visual, thermal, olfactory, or similar information.

Collected: No.

• Category I: Professional or employment-related information.

Examples: Current or past job history or performance evaluations.

Collected: No.

• Category J: Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part  99)).

Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.

Collected: No.

• Category K: Inferences drawn from other personal information.

Examples: Profile reflecting a person's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.

Collected: No.

Under CCPA, personal information does not include:

• Publicly available information from government records

• Deidentified or aggregated consumer information

• Information excluded from the CCPA's scope, such as:

o Health or medical information covered by the Health Insurance  Portability and Accountability Act of 1996 (HIPAA) and the  California Confidentiality of Medical Information Act (CMIA) or  clinical trial data

o Personal Information covered by certain sector-specific privacy  laws, including the Fair Credit Reporting Act (FRCA), the  Gramm-Leach-Bliley Act (GLBA) or California Financial  Information Privacy Act (FIPA), and the Driver's Privacy  Protection Act of 1994

Sources of Personal Information

We obtain the categories of personal information listed above from the following categories of sources:

• Directly from You. For example, from the forms You complete on our  Service, preferences You express or provide through our Service, or  from Your purchases on our Service.

• Indirectly from You. For example, from observing Your activity on our  Service.

• Automatically from You. For example, through cookies We or our  Service Providers set on Your Device as You navigate through our Service.

• From Service Providers. For example, third-party vendors to monitor  and analyze the use of our Service, third-party vendors to provide  advertising on our Service, third-party vendors to deliver targeted advertising to You, third-party vendors for payment processing, or other  third-party vendors that We use to provide the Service to You.

Use of Personal Information for Business Purposes or  Commercial Purposes

We may use or disclose personal information We collect for "business purposes" or "commercial purposes" (as defined under the CCPA), which may include the following examples:

• To operate our Service and provide You with our Service.

• To provide You with support and to respond to Your inquiries, including to investigate and address Your concerns and monitor and improve our  Service.

• To fulfill or meet the reason You provided the information. For example,  if You share Your contact information to ask a question about our  Service, We will use that personal information to respond to Your  inquiry. If You provide Your personal information to purchase a  product or service, We will use that information to process Your  payment and facilitate delivery.

• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.

• As described to You when collecting Your personal information or as otherwise set forth in the CCPA.

• For internal administrative and auditing purposes.

• To detect security incidents and protect against malicious, deceptive, fraudulent or illegal activity, including, when necessary, to prosecute those responsible for such activities.

Please note that the examples provided above are illustrative and not intended  to be exhaustive. For more details on how we use this information, please refer  to the "Use of Your Personal Data" section.

If We decide to collect additional categories of personal information or use the  personal information We collected for materially different, unrelated, or  incompatible purposes We will update this Privacy Policy.

Disclosure of Personal Information for Business Purposes or  Commercial Purposes

We may use or disclose and may have used or disclosed in the last twelve(12)  months the following categories of personal information for business or  commercial purposes:

• Category A: Identifiers

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code =C2=A7 1798.80(e))

• Category D: Commercial information

• Category F: Internet or other similar network activity

Please note that the categories listed above are those defined in the CCPA. This  does not mean that all examples of that category of personal information were  in fact disclosed, but reflects our good faith belief to the best of our knowledge  that some of that information from the applicable category may be and may  have been disclosed.

When We disclose personal information for a business purpose or a commercial purpose, We enter a contract that describes the purpose and requires the  recipient to both keep that personal information confidential and not use it for  any purpose except performing the contract.

Sale of Personal Information

As defined in the CCPA, "sell" and "sale" mean selling, renting, releasing,  disclosing, disseminating, making available, transferring, or otherwise communicating orally, in writing, or by electronic or other means, a consumer's personal information by the business to a third party for valuable consideration. This means that We may have received some kind of benefit in return for sharing personal information, but not necessarily a monetary benefit.

Please note that the categories listed below are those defined in the CCPA. This  does not mean that all examples of that category of personal information were  in fact sold, but reflects our good faith belief to the best of our knowledge that  some of that information from the applicable category may be and may have  been shared for value in return.

We may sell and may have sold in the last twelve (12) months the following  categories of personal information:

• Category A: Identifiers

• Category B: Personal information categories listed in the California Customer Records statute (Cal. Civ. Code =C2=A7 1798.80(e))

• Category D: Commercial information

• Category F: Internet or other similar network activity

Share of Personal Information

We may share Your personal information identified in the above categories  with the following categories of third parties:

• Service Providers

• Payment processors

• Our affiliates

• Our business partners

• Third party vendors to whom You or Your agents authorize Us to  disclose Your personal information in connection with products or  services We provide to You

Sale of Personal Information of Minors Under 16 Years of  Age

We do not knowingly collect personal information from minors under the age  of 16 through our Service, although certain third party websites that we link to  may do so. These third-party websites have their own terms of use and privacy  policies and we encourage parents and legal guardians to monitor their  children's Internet usage and instruct their children to never provide  information on other websites without their permission.

We do not sell the personal information of Consumers We actually know are  less than 16 years of age, unless We receive affirmative authorization (the  "right to opt-in") from either the Consumer who is between 13 and 16 years of  age, or the parent or guardian of a Consumer less than 13 years of age.  Consumers who opt-in to the sale of personal information may opt-out of future sales at any time. To exercise the right to opt-out, You (or Your authorized representative) may submit a request to Us by contacting Us.

If You have reason to believe that a child under the age of 13 (or 16) has  provided Us with personal information, please contact Us with sufficient detail  to enable Us to delete that information.

Your Rights under the CCPA

The CCPA provides California residents with specific rights regarding their  personal information. If You are a resident of California, You have the following rights:

• The right to notice. You have the right to be notified which categories of  Personal Data are being collected and the purposes for which the  Personal Data is being used.

• The right to request. Under CCPA, You have the right to request that  We disclose information to You about Our collection, use, sale,  disclosure for business purposes and share of personal information. Once We receive and confirm Your request, We will disclose to You:

o The categories of personal information We collected about You

o The categories of sources for the personal information We collected about You

o Our business or commercial purpose for collecting or selling that personal information

o The categories of third parties with whom We share that personal  information

o The specific pieces of personal information We collected about You

o If we sold Your personal information or disclosed Your personal  information for a business purpose, We will disclose to You:

▪ The categories of personal information categories sold

▪ The categories of personal information categories disclosed

• The right to say no to the sale of Personal Data (opt-out). You have the  right to direct Us to not sell Your personal information. To submit an  opt-out request please contact Us.

• The right to delete Personal Data. You have the right to request the  deletion of Your Personal Data, subject to certain exceptions. Once We  receive and confirm Your request, We will delete (and direct Our Service Providers to delete) Your personal information from our records, unless  an exception applies. We may deny Your deletion request if retaining the  information is necessary for Us or Our Service Providers to:

o Complete the transaction for which We collected the personal  information, provide a good or service that You requested, take actions reasonably anticipated within the context of our ongoing  business relationship with You,or otherwise perform our contract  with You.

o Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for  such activities.

o Debug products to identify and repair errors that impair existing  intended functionality.

o Exercise free speech, ensure the right of another consumer to  exercise their free speech rights, or exercise another right  provided for by law.

o Comply with the California Electronic Communications Privacy Act  (Cal. Penal Code =C2=A7 1546 et. seq.).

o Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable  ethics and privacy laws, when the information's deletion may  likely render impossible or seriously impair the research's  achievement, if You previously provided informed consent.

o Enable solely internal uses that are reasonably aligned with  consumer expectations based on Your relationship with Us.

o Comply with a legal obligation.

o Make other internal and lawful uses of that information that are  compatible with the context in which You provided it.

• The right not to be discriminated against. You have the right not to be discriminated against for exercising any of Your consumer's rights,  including by:

o Denying goods or services to You

o Charging different prices or rates for goods or services, including the use of discounts or other benefits or imposing penalties

o Providing a different level or quality of goods or services to You

o Suggesting that You will receive a different price or rate for goods or services or a different level or quality of goods or services

Exercising Your CCPA Data Protection Rights

In order to exercise any of Your rights under the CCPA, and if You are a California resident, You can contact Us:

• By email: News@city-sentinel.com

Only You, or a person registered with the California Secretary of State that You authorize to act on Your behalf, may make a verifiable request related to Your personal information.

Your request to Us must:

• Provide sufficient information that allows Us to reasonably verify You are the person about whom We collected personal information or an  authorized representative

• Describe Your request with sufficient detail that allows Us to properly understand, evaluate, and respond to it

We cannot respond to Your request or provide You with the required information if we cannot:

• Verify Your identity or authority to make the request

• And confirm that the personal information relates to You

We will disclose and deliver the required information free of charge within 45 days of receiving Your verifiable request. The time period to provide the  required information may be extended once by an additional 45 days when  reasonable necessary and with prior notice.

Any disclosures We provide will only cover the 12-month period preceding the verifiable request's receipt.

For data portability requests, We will select a format to provide Your personal information that is readily useable and should allow You to transmit the information from one entity to another entity without hindrance.

Do Not Sell My Personal Information

You have the right to opt-out of the sale of Your personal information. Once  We receive and confirm a verifiable consumer request from You, we will stop selling Your personal information. To exercise Your right to opt-out,please  contact Us.

The Service Providers we partner with (for example, our analytics or advertising partners) may use technology on the Service that sells personal information as defined by the CCPA law. If you wish to opt out of the use of Your personal information for interest-based advertising purposes and these potential sales as defined under CCPA law, you may do so by following the instructions below.

Please note that any opt out is specific to the browser You use. You may need to  opt out on every browser that You use.

Website

You can opt out of receiving ads that are personalized as served by our Service  Providers by following our instructions presented on the Service:

• The NAI's opt-out platform: http://www.networkadvertising.org/choices/

• The EDAA's opt-out platform http://www.youronlinechoices.com/

• The DAA's opt-out platform: http://optout.aboutads.info/?c=3D2&lang=3DEN

The opt out will place a cookie on Your computer that is unique to the browser  You use to opt out. If you change browsers or delete the cookies saved by your  browser, You will need to opt out again.

Mobile Devices

Your mobile device may give You the ability to opt out of the use of information about the apps You use in order to serve You ads that are targeted to Your interests:

• "Opt out of Interest-Based Ads" or "Opt out of Ads Personalization" on Android devices

• "Limit Ad Tracking" on iOS devices

You can also stop the collection of location information from Your mobile  device by changing the preferences on Your mobile device.

"Do Not Track" Policy as Required by  California Online Privacy Protection Act  (CalOPPA)

Our Service does not respond to Do Not Track signals.

However, some third party websites do keep track of Your browsing activities.  If You are visiting such websites, You can set Your preferences in Your web  browser to inform websites that You do not want to be tracked. You can enable  or disable DNT by visiting the preferences or settings page of Your web  browser.

Children's Privacy

Our Service does not address anyone under the age of 13. We do not knowingly  collect personally identifiable information from anyone under the age of 13. If  You are a parent or guardian and You are aware that Your child has provided  Us with Personal Data, please contact Us. If We become aware that We have  collected Personal Data from anyone under the age of 13 without verification of  parental consent, We take steps to remove that information from Our servers.

If We need to rely on consent as a legal basis for processing Your information  and Your country requires consent from a parent, We may require Your parent's consent before We collect and use that information.

Your California Privacy Rights (California's  Shine the Light law)

Under California Civil Code Section 1798 (California's Shine the Light law),  California residents with an established business relationship with us can request information once a year about sharing their Personal Data with third parties for the third parties' direct marketing purposes.

If you'd like to request more information under the California Shine the Light  law, and if You are a California resident, You can contact Us using the contact  information provided below.

California Privacy Rights for Minor Users  (California Business and Professions Code Section 22581)

California Business and Professions Code section 22581 allow California residents under the age of 18 who are registered users of online sites, services  or applications to request and obtain removal of content or information they  

have publicly posted.

To request removal of such data, and if You are a California resident, You can contact Us using the contact information provided below, and include the email  address associated with Your account.

Be aware that Your request does not guarantee complete or comprehensive removal of content or information posted online and that the law may not permit or require removal in certain circumstances.

Links to Other Websites

Our Service may contain links to other websites that are not operated by Us. If  You click on a third party link, You will be directed to that third party's site.  We strongly advise You to review the Privacy Policy of every site You visit.

We have no control over and assume no responsibility for the content, privacy  policies or practices of any third party sites or services.

Changes to this Privacy Policy

We may update Our Privacy Policy from time to time. We will notify You of  any changes by posting the new Privacy Policy on this page.

We will let You know via email and/or a prominent notice on Our Service,prior  to the change becoming effective and update the "Last updated" date at the  top of this Privacy Policy.

You are advised to review this Privacy Policy periodically for any changes.  Changes to this Privacy Policy are effective when they are posted on this page.

Contact Us

If you have any questions about this Privacy Policy, You can contact us:

By email at news@city-sentinel

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