Privacy Policy
Effective March 1, 2020

PRIVACY POLICY

TABLE OF CONTENTS

1. Introduction
2. The Information We Collect
3. How We Use the Information We Collect
4. How We Share the Information Collected
5. Legal Grounds for Using (Processing) Your Information
6. Online Analytics and Advertising
7. Your Rights & Your Choices
8. Retention of Your Information
9. Cookies and Other Tracking Technologies
10. Links to Third Party Sites
11. Security
12. Special Note For Parents
13. Transfer Information to the United States
14. Changes to This Privacy Policy
15. Disputes; No Rights of Third Parties
16. Contact Us: Data Privacy Officer

• Appendix A: California Privacy Notice

1. Introduction
This privacy policy (“Privacy Policy” or “Policy“) explains the data protection practices of News Company Media and its subsidiaries and affiliates (collectively, “NCM“, “we” and “us“) when you visit or use the websites, mobile-optimized version of our websites, and our digital applications to which this policy is linked, as well as when you visit or use third-party subscription pages and or submit offline subscription forms and requests, for print and digital magazines, websites and other editorial properties published by NCM (the “Publications“) that are linked to or contain the URL for this Privacy Policy collectively, “Services“). Third-party subscription pages for Publications and other interactive web and digital pages where we collect information about you are considered “Services” when linked to this Privacy Policy and this Policy applies to information collected through such pages, but this Policy does not apply to other information collected through the third party website(s). Notwithstanding anything herein to the contrary, this Policy does not extend to information submitted on the NCM Careers page.

For the avoidance of doubt, this Policy also does not pertain to the editorial activities of our Publications, journalists, editors, photographers and other editorial staff who may collect, publish and distribute information about you from sources unrelated to your use of the Services (collectively, “Editorial Activities“). Without limiting the foregoing, this Policy does not apply to any Editorial Activities concerning information that you may share at any of our conferences, summits, panels or other events.

For the purposes of data protection laws, NCM is the data controller.

2. The Information We Collect

We obtain information about you through the means discussed below when you use our Services. The information we collect and the purposes for which we use it will depend to some extent on the specific Services you use and how you interact with NCM. For example, we collect the information you provide when you enter a sweepstakes or contest, complete a survey, participate in a reader panel, register for a part of our Services, register for a summit or event, make a purchase, participate in our social networking features, request back issues of our Publications, subscribe to our Publications, subscribe to newsletters, promotional correspondence, or other electronic services, or send us an email or feedback. If you elect to post material to any blogs or forums, or participate in our social networking features or other community boards that may be offered on our Services, then such materials will be collected and some information, including your posted pseudonym, may be publicly available for others to view.We, or our service providers on our behalf, may collect the following information about you or your use of the Services:

Information You Provide to Us

• • Registration, Subscription or Contact Information such as e-mail address, name, phone number, shipping address, and billing information
  • Customer service information such as questions and other messages you address to us directly through online forms, by email, over the phone, or by post; and summaries or voice recordings of your interactions with customer care
  • Demographic, statistical and interest information such as your age, date of birth, gender, interests, lifestyle information, and hobbies
  • Financial and transactional information such as credit or debit card number, verification number, and expiration date, to process payments and information about your transactions and purchases with us
  • Employment or Education Information when you register for events or for networking insights services such as education history, employment experience, business contact information
  • User-generated content such as comments on articles, photos, videos, audio, any information you submit in public forums or message boards, reviews and feedback or testimonials you provide about our Services
  • Research, survey, or sweepstakes information (including contact information and user generated content) collected if you participate in a survey or sweepstakes; includes information needed for you to participate (such as contact information), and to fulfill your prize
  • Contact Information about others, (including personal identifiers) such as name and mailing address to send a gift or use our send-to-a-friend functionality. If you use send-a-friend on our Services, your email address may be included in the communication sent to your friend.
  • Social media information (which may include contact information, photos, location, user generated content, demographic information) if you link your account or access the Services through a third-party connection or log-in, we may have access to any information you provide to that social network depending on your privacy settings such as your name, email address, friend list, photo, gender, location, and current city; and information you provide to us directly through our pages on social networking and blogging platforms (e.g., Facebook, Instagram, Snapchat, WordPress, and Twitter)
  • Other information any other information you choose to directly provide to NCM in connection with your use of the Services

Information we collect automatically:

Device information and identifiers such as IP address; browser type and language; operating system; platform type; device type; software and hardware attributes; and unique device, advertising, and app identifiers

Internet network and device activity data such as information about files you download, domain names, landing pages, browsing activity, content or ads viewed and clicked, dates and times of access, pages viewed, forms you complete or partially complete, search terms, uploads or downloads, the URL that referred you to our Services, the web sites you visit after this web site; if you share our content to social media platforms; and other web usage activity and data logged by our web servers, whether you open an email and your interaction with email content, access times, error logs, and other similar information.

Geolocation information such as city, state and ZIP code - Postcode associated with your IP address or derived through Wi-Fi triangulation; and precise geolocation information from GPS-based functionality on your mobile devices, with your permission in accordance with your mobile device settings

3. How We Use the Information We Collect
Depending on the Services you use and how you use them, we, or our service providers, may use your information to:

• • • Provide the Services you request, including to maintain and service your account, for example to:
      • Process and fulfill your transactions, including subscriptions
      • Maintain and servicing your account
      • Payment processing
      • Send communications that you have requested on your behalf
      • Administer your entries into sweepstakes, contests, promotions, or surveys
      • Provide community features and post your content
    • Communicate with You & Provide Customer Service to Provide the Services, for example to:
      • Provide transactional or service communications, such as to notify you when you have won one of our contests or sweepstakes or other promotions, when we make changes to subscriber agreements, send you an email newsletter, or to contact you about your account
      • Respond to your requests for information
      • Provide you with customer service and technical support
    • Personalize your experience to Provide the Services, for example to:
      • Customize certain features of the Services,
      • Deliver relevant content and to provide you with an enhanced experience based on your activities and interests
      • Send you personalized newsletters, surveys, and information about products, services and promotions offered by us, our partners, and other organizations with which we work
      • Customize the advertising on the Services based on your activities and interests
      • Create and update inferences about you and audience segments that can be used for targeted advertising and marketing on the Services, third party services and platforms, and mobile apps
      • Create profiles about you, including adding and combining information we obtain from third parties, which may be used for analytics, marketing, and advertising
      • Conduct cross-device tracking by using information such as IP addresses and unique mobile device identifiers to identify the same unique users across multiple browsers or devices (such as smartphones or tablets, in order to save your preferences across devices and analyze usage of the Service.
      • using inferences about your preferences and interests for any and all of the above purposes
    • Republish Information You Provide on the Services, for example to:
      • pursuant to our Terms, use and edit information submitted by you in response to opportunities provided on the Services, which you provide to us through emails, blogs, forums, in response to polls, or through any other user generated submission, for editorial purposes, including your name, likeness, photograph, and biographical information you provide, with or without attribution, including publication in the Publications, and in trade media, and advertising.
    • Improve the Services and develop new services, for example to:
      • Engage in analysis, research, and reports to better understand how you use the Services, so we can improve them and develop new services
    • Our Marketing and Third-Party Marketing and Advertising Purposes, for example to:
      • send you newsletters, promotional emails, surveys and information about products, services and promotions offered by us, our partners, and other organizations with which we work
      • Customize content that our third-party partners deliver on the Services (e.g., personalized third-party advertising)
      • Create and update inferences about you and audience segments that can be used for targeted advertising and marketing on the Services, third party services and platforms, and mobile apps
      • Create profiles about you, including adding and combining information we obtain from third parties, which may be used for analytics, marketing, and advertising

We may combine the information we collect about you, including from third parties, and conduct cross-device tracking for the marketing and advertising purposes above.

• • • Bug detection and error reporting, including to understand and resolve technical issues, app crashes and other issues being reported
    • Audit consumer interactions on the Services including to measure the placement, frequency, efficacy and compliance of advertising and ad impressions
    • Security, Fraud, and Legal Compliance, including by detecting, protecting against, and prosecuting security incidents, fraud, and illegal activity for example to:
      • Monitor prevent, and detect fraud, such as through verifying your identity
      • Combat spam or other malware or security risks
      • Monitor, enforce, and improve the security of our Services
      • Comply with any applicable procedures, laws, and regulations, subpoenas, governmental requests or legal process, or in connection with a legal investigation, if in our good faith opinion such is required or permitted by law;
      • Establish, exercise, or defend our legal rights (e.g., to enforce compliance with our Terms of Use, Privacy Policies, or other contracts or legal rights)
      • Protect or defend our Services, users, or others
    • Aggregate and/or De-Identified Information. We may aggregate or anonymized information and/or de-identify any information collected through the Services so that such information can no longer be linked to you or your device (“Aggregate/De-Identified Information”). We may use this Aggregate/De-Identified Information for any purpose permitted under the law, including without limitation for research and marketing purposes, and disclose such information to third parties, including advertisers, promotional partners, and sponsors in our sole discretion.

4. How We Share the Information Collected

NCM may (and you authorize us to) share or disclose information collected from and about you on the Services to other companies or individuals as set forth below.

• • • Service Providers: We may provide access to information to vendors that are performing services on our behalf, including fulfilling subscriptions to our Publications, managing our email lists and sending email messages on our behalf, processing payments, providing customer support, analytics providers, and performing other administrative services, in order to carry out such services.
    • Our Affiliates: We may share information we collect within the NCM family of companies to deliver products and services to you, ensure a consistent level of service across our Services, internal management and administrative purposes on our behalf and enhance our products, services, and your customer experience.
    • Information You Disclose Publicly. You may submit photographs, user profiles, written material, music, video, photos, comments and other content, which may include information relating to individual users (collectively, “UGC“) on the Services. We do not control who will have access to the UGC you choose to make public or how they will use it and take no responsibility for ensuring such UGC remains private or is secure. The UGC is not subject to this Privacy Policy. We are also not responsible for the accuracy, use or misuse of any UGC that you disclose or receive through the Services. Please see our Terms of Use for further information about the terms that govern the UGC you post.
    • Other Individuals, Services, and Partners at Your Request. We will share your information with other individuals and services at your request.
      • For example, if you choose to interact with such co-branded products or services using your account information with us, we may share your account information with third parties as required to provide the co-branded product or service that you request, including any information required for contest prize fulfillment.
    • Third Party Contests and Promotions Providers. In some cases, you may have entered a contest or sweepstakes sponsored by a third party, in which case the information you provide via the contest or sweepstakes may be shared by us with that third party for their use in their discretion, including direct marketing. Some of our contests and sweepstakes will ask you at the time of entry whether you would like to have your personal information shared with the sponsor, in which case we will honor your selection. Other contests will not give you that option and in that event, if you do not want your information to be shared, you should not enter the contest. The privacy policies of such third party companies apply to their use and disclosure of your information that we collect and disclose to such third party companies.
    • Third Party Partners to Provide Co-Branded Products and Services. Some of our Services may from time to time partner with a retailer or other third party to offer online shopping opportunities, games, services, subscriptions, registration opportunities for our events and summits and other applications on a co-branded or cross-promotional basis (“Co-Branded Areas“). The information you provide in connection with the transaction may be collected directly by, or shared by NCM with, the third party, as well as with any participating sponsors or advertisers of such Co-Branded Areas. Some of our Services may offer you the ability to access a third-party site with whom we have a relationship to access both sites through a co-branded registration or password; in that event, your applicable registration information may be collected directly by, or shared by NCM with, the third-party partner. For example, if you choose to interact with such co-branded products or services using your account information with us, we may share your account information with third parties as required to provide the co-branded product or service that you request, including any information required for contest prize fulfillment. These third parties will use your information in accordance with their own privacy policy.
    • Third Parties for Marketing Purposes. We may share your information with partners whose offerings may interest you such as other marketers, magazine publishers, retailers, participatory databases and non-profit organizations. This includes licensing information about your interests and activities, and marketing segments created with such data, which we may share with third parties for their marketing purposes.
    • Third-Party Online Advertisers, Ad Networks and Advertising Partners. As discussed in the “Online Advertising” Section above, the Services may integrate third-party advertising technologies that allow for the delivery of relevant content and advertising on the Services, as well as on other websites you visit and other applications you use, and these technologies will collect certain information from your use of the Services to assist in delivering such ads. These third parties include advertising networks, data exchanges, ad servers, certain analytics providers and others. The list of third party providers is found in the Section below entitled “Third Party Cookies“. This list may be updated from time to time.
    • Third Parties for Legal Purposes. By using the Services, you acknowledge and agree that we may access, retain, and disclose the information we collect and maintain about you if required to do so by law or in a good faith belief that such access, retention or disclosure is reasonably necessary to: (a) comply with legal process or a regulatory investigation (e.g. a subpoena or court order); (b) enforce our Terms of Service, this Privacy Policy, or other contracts with you, including investigation of potential violations thereof; (c) respond to claims that any content violates the rights of third parties; and/or (d) protect the rights, property or personal safety of NCM, its agents and affiliates, its users and/or the public. This includes exchanging information with other companies and organizations for fraud protection, and spam/malware prevention, and similar purposes.
    • Social Networks. As noted above, if you use your login credentials from a social media networking service on a Website, we may receive information from such service in accordance with its terms and privacy policy and your settings. If you elect to share your information with these social networking sites, we will share information with them in accordance with your election. The terms and conditions of these social networking sites will apply to the information we disclose to them.
    • Sales or Transfer of Business or Assets. In connection with a sale, merger, transfer, exchange, or other disposition (whether of assets, stock, or otherwise, including via bankruptcy) of all or a portion of the business conducted by the Website to which this policy applies, in which case the company will possess the information collected by us and will assume the rights and obligations regarding your information as described in this Privacy Policy (the “Acquisition Use“).

5. Legal Grounds for Using (Processing) Your Information

If you are a visitor from the European Economic Area, our legal basis for collecting and using the information described above will depend on the information concerned and the context in which we collect it. We collect information from you:

• • where we need it to perform our contract with you (i.e. our Terms of Service),
  • where the processing is in our legitimate interests (provided that these aren’t overridden by your interests or rights) (such as personalizing our services and marketing for example), or
  • if we otherwise have your consent.

If you have questions about or need further information concerning the legal basis on which we collect and use your information, please contact us using the contact details provided under the “Contact Us” section below.

6. Online Analytics and AdvertisingDelivery of Advertising and Other Content.

In addition to ads and content that we serve you directly, NCM may use third party advertising companies and marketing services to serve ads and other content when you visit the Services, as well as on other websites you visit and other applications you use. The ads may be based on various factors such as the content of the page you are visiting, your searches, demographic data, user-generated content, and other information we collect from you. These ads may be based on your current activity or your activity over time and across other websites and online services and may be tailored to your interests. Third parties, whose products or services are accessible or advertised via the Services, may also place cookies or other tracking technologies on your computer, mobile phone, or other device to collect information about you as discussed above. We also allow other third parties (e.g., ad networks and ad servers such as Google and others) to serve tailored ads to you on the Services, other sites, and in other applications, and to access their own cookies or other tracking technologies on your computer, mobile phone, or other device you use to access the Services. We sometimes provide our customer information (such as email addresses) to service providers, who may “match” this information in de-identified form to cookies (or mobile ad identifiers) and other proprietary IDs, in order to provide you with more relevant ads when you visit other websites and mobile applications.

We neither have access to, nor does this Privacy Policy govern, the use of cookies or other tracking technologies that may be placed on the device you use to access the Services by such non-affiliated third parties.

If you are interested in more information about tailored browser advertising and how you can generally control cookies from being put on your computer to deliver tailored advertising, you may visit the Network Advertising Initiative Opt Out Page, the Digital Advertising Alliance’s Consumer Opt-Out link, or Your Online Choices to opt-out of receiving tailored advertising from companies that participate in those programs.

To learn more about how to manage your preferences regarding our cookie-based advertising, please see the “Cookie Management” section in our Cookie Notice below.

To opt out of Google Analytics for display advertising or customize Google display network ads, visit the Google Ads Settings page. We do not control these opt-out links or whether any particular company chooses to participate in these opt-out programs. We are not responsible for any choices you make using these mechanisms or the continued availability or accuracy of these mechanisms.

Please note that if you exercise the opt out choices above, you will still see advertising when you use the Services, but it will not be tailored to you based on your online behavior over time.

Mobile Advertising. When using mobile applications from NCM or others, you may also receive tailored in-application advertisements. We may use third-party service providers to deliver advertisements on mobile applications or for mobile application analytics. Each operating system, iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices provides its own instructions on how to prevent the delivery of tailored in-application advertisements. We do not control how the applicable platform operator allows you to control receiving personalized in-application advertisements; thus, you should contact the platform provider for further details on opting out of tailored in-application advertisements. Often, you may opt-out by adjusting the ad tracking settings on your mobile device or resetting the “Advertising Identifier” (like an IDFA) from your mobile device’s settings page, which will prevent continued use of existing behavioral data tied to the previous “Advertising Identifier.” You may review the support materials and/or the device settings for the respective operating systems to opt-out of tailored in-app advertisements.

Do Not Track.
NCM does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on our Services.

7. Your Rights & Your ChoicesMarketing Emails.

If you want to stop receiving promotional e-mails from us, click on the “unsubscribe” link in any promotional email from us. Please note that once we receive your request, it may take an additional period of time for your opt-out to become effective. We may still communicate with you from time to time if we need to provide you with transaction information about the Services you are using, if we need to request information from you with respect to a transaction initiated by you, or for other legitimate non-marketing reasons, for example, if we update this Privacy Policy or our Terms of Service.

SMS Text Communications. You may opt-out of SMS messages from us by following the instructions provided in the message or by texting back STOP to the number we send the text from for that particular SMS message. When we receive an opt-out message from you for SMS messages, we may send a message confirming our receipt of your opt-out.

Privacy Information for California Residents. If you are a California resident, California law requires us to provide you with some additional information regarding your rights with respect to your “personal information” (as defined in the California Consumer Privacy Act (“CCPA”)). We describe the categories of personal information we collect, the sources and uses of such information and the entities to which we share such information in our California Privacy Notice.

A. California Data Access & Deletion Rights

If you are a California resident, the CCPA allows you to make certain requests about your personal information. Specifically, the CCPA allows you to request us to:

• • Inform you about the categories of personal information we collect or disclose about you; the categories of sources of such information; the business or commercial purpose for collecting your personal information; and the categories of third parties with whom we share/disclose personal information.
  • Provide access to and/or a copy of certain personal information we hold about you.
  • Delete certain personal information we have about you.
  • Provide you with information about the financial incentives that we offer to you, if any.

Please note that certain information may be exempt from such requests under California law. For example, we need certain information in order to provide the Services to you.

Verification: We will take reasonable steps to verify your identity before responding to a request, which may include, depending on your request and relationship with you verifying your name, email address, address, and/or having you respond to an email from us.

You are also permitted to designate an authorized agent to submit certain requests on your behalf. In order for an authorized agent to be verified, you must provide the authorized agent with signed, written permission to make such requests or a power of attorney. We may also follow up with you to verify your identity before processing the authorized agent’s request.

If you would like further information regarding your legal rights under California law or would like to exercise any of them, please contact us.

Please note that NCM employees who are seeking further information about their legal rights under California law should instead contact their NCM HR representative. Applicants submitting information on the NCM Careers pages should instead consult the News Company Media Human Resources Privacy Notice referenced therein.

B. Notice of Right to Opt Out of Sale of Personal Information

California residents may opt out of the “sale” of their personal information. We sell certain of your information to third parties to provide you with offers and promotions and opportunities that may be of interest to you.

Under the CCPA, sale is also broadly defined such that it may include allowing third parties to receive certain information, such as cookies, IP address, and/or browsing behavior, to deliver targeted advertising on the Services or other services. Advertising, including targeted advertising, enables us to provide you certain content for free and allows us to provide you offers relevant to you.

Depending on what Services you use, we may provide the following categories of personal information to third parties for these purposes:

• • For online targeted advertising purposes: demographic and statistical information, user-generated content, device information and identifiers, connection and usage data, geolocation, and social media information.
  • For sharing with third parties to send you relevant offers and promotions and opportunities: contact information (e.g., name and physical address) and publication subscription information.

If you would like to opt out of NCM’s use of your information for such purposes that are considered a “sale” under California law, you may do so as outlined. You can also submit a sale opt-out request by emailing us at PrivacyDirector@NCM.com or calling us at (877)365-3500. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.

Please note that NCM employees who are seeking further information about their legal rights under California law should instead contact their NCM HR representative. Applicants submitting information on the NCM Careers pages should instead consult the News Company Media Human Resources Privacy Notice referenced therein.

The CCPA further provides you with the right to not be discriminated against (as provided for in applicable law) for exercising your access, deletion or sale opt out rights.

C. California “Shine the Light” Disclosure

The California “Shine the Light” law gives residents of California the right under certain circumstances to opt out of the sharing of certain categories of personal information (as defined in the Shine the Light law) with third parties for their direct marketing purposes. If you would like to opt out of such sharing, please use the sale opt out form noted above. If you are a California resident and would like a copy of this notice, please submit a written request. In your request, please specify that you want a “NCM California Privacy Rights Notice.” Please allow at least 30 days for a response.

D. International Users. Some international users of our Services have certain legal rights to access certain information we hold about them and to request its deletion. For example, your local laws may permit you to request that we:

a.i. provide access to and/or a copy of certain information we have about you;
a.ii. prevent the processing of your information for direct-marketing purposes;
a.iii. update information which is out of date or incorrect;
a.iv. delete certain information which we have about you;
a.v. restrict the way that we process and disclose certain of your information;
a.vi. transfer your information to a third party provider of services; and
a.vii. revoke your consent for the processing of your information.

We will consider all requests and provide our response within the time period stated by applicable law. Certain information may be exempt from such requests in some circumstances, which may include if we need to keep processing your information for our legitimate interests or to comply with a legal obligation. We may request you provide us with information necessary to confirm your identity before responding to your request.
If you would like further information in relation to your legal rights under applicable law or would like to exercise any of them, please contact us using the information in the “Contact Us” section below at any time.

E. Privacy Information for Nevada Residents. Under Nevada law, Nevada residents who have purchased goods or services from us may opt out of the “sale” of “covered information” (as such terms are defined under Nevada law). “Covered information” includes, among other things, first and last name, address, email address, and phone number. As discussed above, we share your information with third parties (e.g. magazine publishers, retailers, participatory databases) that want to market products or services to you. In some circumstances, this sharing may qualify as a sale under Nevada law. If you are a Nevada resident who has purchased goods or services from us, you may submit a request to opt out of such activity by emailing nevadaoptout@NCM.com. Please note we may take reasonable steps to verify your identity and the authenticity of the request.

F. Subscriber Preferences. Subscribers to our Publications may change their subscription-related mail and email preferences. Despite your indicated preferences, we may send you service related communications, including notices about your subscription, and we may continue disclosing your information to third parties under the Service Provider Use, the Legal Use and the Acquisition Use described above.

8. Retention of Your Information

We keep your information for no longer than necessary for the purposes for which it is processed. The length of time for which we retain information depends on the purposes for which we collected and use it and/or as required to comply with applicable laws.

9. Cookies and Other Tracking Technologies

We use and allow certain other companies to use certain tracking technologies, including cookies, web beacons, and other similar technologies (collectively, “Cookies“) on the Services. This section (“Cookie Notice“) explains what these technologies are and why we use them, as well as your rights to control our use of them. We endeavor to adhere to the Digital Advertising Alliance’s (DAA) self-regulatory principles governing interest-based advertising.

What are Cookies?
Cookies are text files that contain a certain amount of information and are downloaded to your computer or mobile device when you visit a website. They are useful because they allow websites to recognize a user’s device. They are then returned to the original website on each subsequent visit or to any other website that recognizes them. For more information on cookies, go to our privacy page. The term “Cookie” is used in this Notice in the broad sense to include all similar techniques and technology, including web beacons and log files. For more information on these additional tools, see our glossary below.

Types of Information We Collect
Cookies help us to understand Website usage and to improve the content and offerings on our Services and in other media. Examples of the types of information that we collect through Cookies include: The number of users visiting Services, the number of times a Website was viewed, the pages viewed, the clicks made on the Services and the total duration of navigation on the Services; The name of the page that referred you to the Website; Whether this is your first time visiting the Website; Your viewing preferences (e.g. layout, sizing preferences, language etc.)
Your user name, your password, the type of browser used and your IP address, so that we can identify you during your next visits.

How We Use Cookies
Examples of ways that we use Cookies include:

a.i. To control the display of ads;
a.ii. To track usage patterns on the Services;
a.iii. To deliver editorial content;
a.iv. To record requests for subscriptions;
a.v. To implement our affiliate marketing program; and
a.vi. To personalize information.

NCM (or third party service providers on our behalf) may also use cookies to collect aggregate information about Website users on an anonymous basis (“Anonymous Information“). We may share demographic and usage information with our prospective and actual business partners, advertisers and other third parties for any business purpose.

Types of Cookies We Use on Our Services
We use first party and third party Cookies for several reasons. Some Cookies are required for technical reasons in order for our Site to operate, and we refer to these as “essential” or “strictly necessary” Cookies. Other Cookies also enable us to track and target the interests of our users and to enhance the experience on our Services. Third parties also serve Cookies through our Services for advertising, analytics and other purposes. The specific types of first and third party Cookies served through our Services and the functions they perform are described in more detail below.

First-party Cookies
These cookies are created by NCM. They allow you to browse our Services and use their features.
Essential Cookies: These cookies are strictly necessary to allow you to move around the Services and use their features, such as accessing your subscriptions. Without these cookies, we cannot enable appropriate content based on the type of device you are using. Therefore, these cookies cannot be disabled.
Functional Cookies: These cookies allow us to remember choices you make on our websites (such as your preferred language or the region you are in). To refuse these Cookies, please follow the instructions below under the section Cookie Management. Note that by disabling functional cookies, you may not be able to use some of our features or those features may not function properly.
Embedded Scripts: An embedded script is programming code that is designed to collect information about your interactions with the Services, such as the links you click on. The code is temporarily downloaded onto your computer or other device, is active only while you are connected to the Services, and is deactivated or deleted thereafter.
Analytics Cookies: We use Cookies and other identifiers (such as web beacons) to see how you use our Services in order to enhance their performance and develop them according to the preferences of our customers and visitors. For example, cookies and web beacons may be used to maintain a consistent look and feel across our Services, track and provide trend analysis on how our users interact with our Services, track errors, and measure the effectiveness of our promotional campaigns. To refuse these Cookies, please follow the instructions below under the section Cookie Management.
Cross-Device Cookies: NCM may use cookies in combination with the information we collect — for instance, IP addresses and unique mobile device identifiers — to locate or try to locate the same unique users across multiple browsers or devices (such as smartphones or tablets), or work with service providers that do this, in order to save your preferences across devices and analyze usage of the Services. To refuse these Cookies, you may install the Google Analytics Opt-out Browser Add-on.

Third-Party Cookies
Some of our third party partners (including advertisers and marketing services companies) may set and access Cookies on your computer as well, or we may do so on their behalf. We do not have control over how these third parties use such cookies and similar technologies or the information derived therefrom, and this Privacy Policy does not cover any use of information that such third parties may have collected from you or the methods used by the third-parties to collect that information. These types of cookies include:

Advertising Cookies: These Cookies, defined exclusively by third parties, collect several types of data about your browsing habits, as well as your preferences for products and services. This information allows NCM to serve you relevant advertisements on our Services. To refuse these cookies, please follow the instructions below under the section Cookie Management.
Some advertisements may also contain an icon that you may click on to find out more about how to manage your advertising preferences.
Third-Party Functional Cookies: These Cookies are defined by third parties who support our Services and allow you to use useful services and features. To refuse these cookies, please follow the instructions below under the section Cookie Management.

As of the Effective Date above, the third party partners may include the following. This list may be updated from time to time:

Web Beacons
Small graphic images or other web programming code called web beacons (also known as “clear GIFs” or “pixel tags”) or similar technologies may be included in our web pages and messages. Web beacons or similar technologies may be used for a number of purposes, including, without limitation, to count visitors to the Services, to monitor how users navigate the Services, to count how many e-mails that were sent were actually opened or to count how many particular articles or links were actually viewed. A clear gif may enable us to relate your viewing or receipt of a web page or message to other information about you, including your Personally Identifiable Information. To refuse Web Beacons, please follow the instructions below under the section Cookie Management.

HTML
HTML, the language some websites are coded in, may be used to store information on your computer or device about your interaction with and use of the Services. This information may be retrieved by us to help us manage our Services, such as by giving us information about how our Services are being used by our visitors, how they can be improved, and to customize them for our users.

Types of Cookies We Serve on Third-Party Services

Duration of storage of cookies on your device
We use both “session cookies” (which expire once you close your web browser) and “persistent cookies” (which stay on your computer until you delete them).

Cookie Management
Analytics
To learn about Google Analytics’ currently available opt-outs for the Web, please visit https://support.google.com/analytics/answer/181881?hl=en.
Disabling Advertising Cookies
Some of the advertising service providers may be members of the Network Advertising Initiative, which offers a single location to opt out of ad targeting from member companies. If you opt-out of receiving targeted ads in this manner, you will continue to receive advertising messages after you opt-out, but they will not be customized to you based on your use of the Services and/or third party websites. If you would like more information about advertisers’ use of tracking technologies and about your option not to accept these cookies, you can go to http://www.networkadvertising.org. If you would like to learn more about how interest-based information is collected, whether the companies we use are part of an industry network regarding behavioral advertising and to know your choices about not having information used in this manner, you can go to http://www.aboutads.info. The collection of information via certain ads served to users in Canada may be managed by visiting youradchoices.ca.
Please note that the-opt out is cookie-based and will only affect the specific computer and browser on which the opt-out is applied.

Using Browser Settings
You can disable and/or delete most types of cookies by using your browser settings. Please note that if you use your browser settings to block all cookies you may not be able to access parts of our or others’ Services. The following links provide information on how to modify the cookies settings on some popular browsers:

• Apple Safari http://support.apple.com/kb/PH5042
• Google Chrome https://support.google.com/chrome/bin/answer.py?hl=en&answer=95647&p=cpn_cookies
• Microsoft Internet Explorer http://windows.microsoft.com/en-US/windows7/How-to-manage-cookies-in-Internet-Explorer-9
• Mozilla Firefox http://support.mozilla.org/en-US/kb/Cookies

Do Not Track Signals
NCM does not act on “do not track” requests from your browser because, this way, we are able to personalize your experiences on our Services. For more information, go to http://www.networkadvertising.org or http://www.aboutads.info.
If you have questions about the use of Cookies on our Services, please contact us as described in Contact Us below.

Managing Cookie Preferences on Our Services
To manage your cookie preferences for our websites, including advertising cookies served by advertisers that participate in the IAB Europe GDPR Transparency & Consent Framework Global Vendor List, please click on the “Privacy Preferences” link in the footer of the relevant Website.

10. Links to Third Party Sites

When you are on the Services, you may be directed to other websites that are operated and controlled by third parties that we do not control. We are not responsible for the privacy practices employed by any of these third parties. If you access a third-party website from the Services, you do so at your own risk, and you understand that this Privacy Policy does not apply to your use of such websites.

11. Security

We implement appropriate administrative, technical and security safeguards to help prevent unauthorized access, use, or disclosure of the information we collect. However, no systems can be completely secure. Therefore, while NCM uses reasonable efforts to protect your information, NCM cannot guarantee its absolute security, and your use of the Services indicates your agreement to assume this risk.

12. Special Note For Parents

The Services are for a general audience and are not designed or intended for use by children, especially those under age thirteen (13) or sixteen (16) in the EU.

13. Transfer Information to the United States

The Services are operated in the United States of America (USA) and are intended for users located in the USA. If you are located outside of the USA, please note that the information you provide to us will be transferred to and processed in the USA, where laws regarding processing of personal data may be less stringent than the laws in your country.

14. Changes to This Privacy Policy

We reserve the right to change this Privacy Policy at any time without prior notice. Any changes will be effective immediately upon the posting of the revised Privacy Policy.

15. Disputes; No Rights of Third Parties

If you choose to access the Services, subscribe to our Publications or use any of our Services, any dispute over privacy is subject to our Terms of Use, including limitations on damages, resolution of disputes by binding arbitration, and application of the laws of the United States, and the State of New York. This Privacy Policy does not create rights enforceable by third parties.

16. Contact Us: Data Privacy Officer

If you have any questions or concerns about any aspect of this Privacy Policy, please contact our Data Privacy Officer at the address set forth below.

Data Privacy Officer
News Company Media
10/130 Jonson Street
Byron Bay Australia

Appendix A: California Privacy Notice

This Privacy Notice for California residents supplements the NCM Privacy Policy.

This Notice applies to website visitors, app users, event attendees and other customers in California. This Notice does not apply to employees, former employees, candidates, contractors, service providers, or business contacts of NCM. This supplemental privacy notice gives California residents additional information about our information collection and use practices required by the California Consumer Privacy Act of 2018 (“CCPA”). The CCPA also provides California residents with specific privacy rights, which are outlined in our Privacy Policy here.

This notice provides information about the categories of personal information that we collect from California residents generally, the purposes for which we use the information, the sources of the information, and the categories of third parties to whom we disclose the information for business purposes. More detailed information is available in our Privacy Policy.

If you would like to opt out of NCM’s use of your information for such purposes that are considered a “sale” under California law, you may do so. You can also submit a sale opt-out request by emailing us at office@newscompany.com.au. Please note that we do not knowingly sell the personal information of minors under 16 years of age without legally-required affirmative authorization.
Please note that NCM employees who are seeking further information about their legal rights under California law should instead contact their NCM HR representative.