Privacy Policy

Privacy Policy and Cookie Statement

Introduction and Definitions

This Privacy Policy governs all websites, apps, and other Services that link to, or contain references to, this document and are published or made available by The Chicago Morning Star its parent, subsidiaries and affiliates (“we”, “us” or “our”). Please read this Privacy Policy carefully. It summarizes the various ways we acquire and treat your Data when you access, visit and/or use the Service. It also governs your Data that we may acquire offline. This Privacy Policy does not cover information collected on sites, applications, destinations, or services linked to from the Service that we do not own or control.

You can access this Privacy Policy any time in the footer of the Service’s home page, via the menu button/hamburger icon or on the Service description screen, or as otherwise indicated depending on the Service you are using. By purchasing a Product, registering for any aspect of the Service, or otherwise accessing, visiting or using the Service, you consent to this Privacy Policy. If you do not agree with the terms and conditions of this Privacy Policy, you should not access, visit and/or use the Service. We advise that you print or retain a digital copy of this Privacy Policy for future reference.

In addition to reviewing this Privacy Policy, please also review our User Agreement and any other terms and conditions that may be posted elsewhere in the Service or otherwise communicated to our users, because the User Agreement and all such terms and conditions are also part of the Agreement between you and us.

All capitalized terms used in this Privacy Policy that are not otherwise defined have the meanings set forth in the Glossary. “Personally Identifiable Information” that alone or in combination with other information or in certain contexts can be used to identify, distinguish or trace you or your Device(s) is referred to in this document as “PII.” PII, together with all other information about you and/or your Device(s) that we acquire is referred to collectively as your “Data”.

This Privacy Policy may be modified from time to time, so check back often. So that you are aware changes have been made, we will adjust the “Last Revised” date at the beginning of this document. If we make a significant change in the way we use or share your PII, we will also post on the Service a prominent notice that a change was made. Continued access of the Service by you will constitute your acceptance of any changes or revisions to the Privacy Policy.

The Types of Data Acquired About You

Personally Identifiable Information (PII). We acquire PII that may include, in certain contexts, your name, postal address, zip code, email address, and telephone number. We also acquire your IP address, User ID, and/or Device ID, which certain jurisdictions consider to be PII because it could be used to identify an individual or Device if it were combined with other identifying information.
Sensitive PII. In certain circumstances, such as when purchasing a Product, you may provide a credit, debit, or payment account number, or other payment information which we recognize as more sensitive than other PII. We generally do not request on or through the Service other Data that is often considered “highly sensitive,” such as other financial account information (e.g., credit report information, bank account numbers), personal health information, or government issued identification numbers (e.g., social security number, drivers’ license number, or passport number), although we reserve the right to do so when such Data is necessary to offer you certain services.
Anonymous Data. Some of the Data that we acquire cannot identify, distinguish or trace you or your Device, even if combined with other identifying information, and some Data that could be considered PII when combined with other identifying information is not used in a way that identifies, distinguishes or traces you or your Device, but is instead used in an anonymous way, often aggregated with other anonymous Data about other users.

How We Acquire Your Data

Data You Provide. We mostly receive PII because you provide it to us. For instance, when you enter a contest, complete a survey, purchase a Product, or register and/or set up an account/profile, you may be provided, or required to choose, a password and/or User ID, and you may provide a credit, debit, or payment account number, or other payment information, as well as your name, telephone number(s), email and/or street address. Other Data such as your age, gender, an avatar, and preferences may also be requested. In addition, we may acquire your Data when you contact us by telephone, postal mail, social media interaction or messaging (e.g., email, SMS, MMS, or similar technologies). We also may acquire information that you provide about other people, for example, when you use our “refer-a-friend” email feature or purchase one of our Products as a gift.
Data Automatically Collected. The Service may also automatically collect Data about you, your online behavior and your Device. The Data collected may include, without limitation, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of you and/or your Device, as well as date/time stamp, IP address, pages visited, time of visits, Content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The Service may collect your Data even if the Service is not open on your Device or you’re not logged in.
Data Acquired Elsewhere. We may also acquire your PII or other Data offline or otherwise outside of the Service. For example, we may purchase or otherwise acquire such Data from third party data suppliers. We reserve the right to merge or co-mingle this other Data with your PII and Data collected on or through the Service.
Social Network Integration. If you choose to access, visit and/or use any third party social networking service(s) that may be integrated with the Service, we may receive your Data that has been made available to those services, including information about your contacts on those services. For example, some social networking services allow you to push Content from our Service to your contacts or to pull information about your contacts so you can connect with them on or through our Service. Some social networking services also will facilitate your registration for our Service or enhance or personalize your experience on our Service. Your decision to use a social networking service in connection with our Service is voluntary. However, you should make sure you are comfortable with your Data the third party social networking services may make available us by visiting those services’ privacy policies and/or modifying your privacy settings directly with those services. We reserve the right to use, transfer, assign, sell, share, and provide access to all of your Data that we receive through third-party social networking services in the same ways as all of your Data we receive through our Service (as described in Section IV below).
Be Careful Publicly Posting PII. Please be aware that Content and PII that you disclose in publicly accessible portions of the Service may be available to other users, and may also be made available outside the Service by third parties, so you should be mindful of all PII, especially sensitive PII, that you may wish to post.

How We Use Your Data

Processing Your Requests for Products. We use your Data to process your request for Content and/or other Product(s). For example, if you subscribe to any of our Products we may use your e-mail address to send you a confirmation notice and your mailing address to send you the Product. Similarly, if you enter a contest, we will use your PII to notify you if you are a winner. If you enter a contest or submit Content to us (e.g., a “letter to our editors” or online review or comment), we may also publish your name, screen name, home town and other PII you have provided to us.
Administering the Service. We also use your Data for any lawful business purpose in connection with administering the Service, including without limitation for customer service, to help diagnose problems with servers, to improve Products that we offer by tailoring them to your needs, to gather broad demographic information, to analyze trends, to seek compatible advertisers, sponsors, clients and customers, and to track users’ movements around the Service and elsewhere on the web or across apps and/ devices. Your geographic location Data may specifically be used to show you Content (including advertising and sponsored messaging) based on geographic location.
Access by Third Party Providers. We may also allow access to your Data by Third Party Providers that provide us with services, such as technical maintenance, market research, community and forums management, auction services, e-commerce, personal/job search and other advertising functionality, but only for the purpose of and to the extent necessary to provide those services. And if you choose to purchase or subscribe to any Product(s), we may forward your Data to Third Party Providers for services such as credit/debit card or other payment processing, order fulfillment, credit pre-authorization, and address verification. There are also times when you provide Data to us in areas of the Service that may be managed or participated in by one or more Third Party Providers. In such cases, the Data may be used by us and by such Third Party Provider(s), each pursuant to its own policies. While we may seek to require Third Party Providers to follow appropriate privacy policies and will not authorize them to use your Data except for the express purpose for which it is provided, we do not bear any responsibility for any actions or policies of third parties.
Marketing Communications. We may also use your Data to communicate with you about new features, events or Products offered by us, Third Party Providers, our advertisers, and other companies and individuals with which we have a relationship.
Health, Safety, and Legal Requests. We reserve the right to access, use, and share with others your Data for purposes of health, safety and other matters in the public interest. We may also provide access to your Data in order to cooperate with official investigations or legal proceedings brought by or otherwise involving governmental and/or law enforcement officials, as well as private parties, including, for example, in response to subpoenas, search warrants, court orders, or other legal process. We may also provide access to protect our rights and property and those of our agents, customers, and others including to enforce our agreements, policies, and terms of use.
Employment Opportunities. If you provide your PII to us in connection with an employment inquiry, without limiting the applicability of the rest of this Privacy Policy, we will use your PII to evaluate your job application, and for related recruiting, reporting and recordkeeping purposes. We may maintain your PII on file, whether we hire you or not, to administer your relationship with us and/or for job applicant related reporting and recordkeeping for as long as required or permitted by law.
Transfer or Sale of Our Business. As our business changes, we may buy or sell various assets owned or controlled by us. In the event all or a portion of the assets are sold, assigned, transferred or acquired by another company due to merger, divestiture, restructuring, reorganization, dissolution, financing, acquisition, bankruptcy or otherwise, your Data may be among the transferred assets.
Combining Your Anonymous Data with PII. We reserve the right to merge or co-mingle anonymous, non-personally identifiable Data about you, your offline and online behavior, and/or your Device (including its geographic location), with your PII for any lawful business purpose.

Sharing Your Data for Marketing; Opt-Out; How to Update Your Data

Credit/Debit Card and Payment Account Data. We will not sell or rent your credit/debit card number or payment account Data. We may transfer such Data to Third Party Providers who need access to fulfill a transaction.
Sharing Your Data for Marketing. Unless otherwise specified on the Service, we may sell or share your Data among our parent, subsidiaries, and affiliates and with other third parties who we think may offer or enable you to become aware of Products that may be of interest to you.
How to Opt-Out of Sharing for Marketing. If you do not wish to have PII such as your name, email address, postal address or phone number shared with third parties for their marketing purposes, contact our Privacy Policy Coordinator as described at the end of this document. But note that, in order for us to properly administer the Service, we must continue to share your Data with Third Party Providers as described in Section 4(3) above (if you object to such sharing, you should not use the Service). Note also that this option to opt-out applies only to PII, and not Anonymous Data.
How to Opt-Out of Marketing Messages from Us. If you do not wish to receive future marketing or other commercial messages from us, simply follow the unsubscribe instructions contained within the message you receive. But note that you may continue to receive certain communications from us that are necessary for the Service, such as renewal notifications, invoices, technical notices, updates, security alerts, and support and administrative service bulletins.
How to Update Your PII. If you have registered on any part of the Service, please use the mechanism or contact information on the Service that allows you to change or update your member preferences, if available, to keep all such Data accurate and up-to-date. If no such mechanism or contact information is available on the Service, contact our Privacy Policy Coordinator as described below with your changes.

Cookies and Related Technologies; Do Not Track (DNT)

Cookies/Local Device Storage. The Service will at times place and/or store code or other types of information and/or software on your Device or within your browser, or in our emails/communications such as cookies (including flash cookies), locally shared objects, and HTML5 (collectively, “Local Device Storage”). We and Third Party Providers may use Local Device Storage in connection with the Service for any lawful business purpose, including without limitation to determine whether you have seen a particular advertisement before on the same or different Device and to otherwise control the display of ads, to track the movements of individual users through the Service and elsewhere on the web or across apps, devices, and geographic locations, to help diagnose problems with servers, to gather broad demographic information, to conduct research, to deliver editorial Content, to record registration and personalization information, and to otherwise administer the Service. For example, if you register on any part of the Service and are given the option to save your user name and password, we may provide this convenience to you via Local Device Storage. Local Device Storage may also collect and store your PII, which may be shared with our parent, subsidiaries, and affiliates and other third parties.
You May Disable Local Device Storage. If you do not want Local Device Storage, your Device or browser may include an option that allows you to not accept it. However, if you disable Local Device Storage, some portions of the Service may not function properly.
Tracking Technologies. In addition to Local Device Storage, we may use web beacons, web bugs, internet or pixel tags, clear gifs, digital fingerprinting (aka “Machine Identification”) and similar technologies (collectively, together with Local Device Storage, the “Tracking Technologies”) on the Service and in our communications with you, such as within e-mail and text messages and push notifications. We use Tracking Technologies to determine which of our messages have been opened by recipients, and for all or some of the same lawful business purposes we describe above for use of Local Device Storage.
Do Not Track (DNT). Your browser setting may allow you to automatically transmit a “Do Not Track” (DNT) signal to websites and online services that you visit. There is no consensus among industry participants as to what DNT means in this context, and some browsers automatically apply DNT signals by default and therefore do not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites and online services, we do not alter our practices when the Service receives a DNT signal from a visitor’s browser. As discussed below, you may opt out of the use of your Data for online behavioral advertising by third parties at any time. To find out more about DNT, please visit http://allaboutdnt.com.

Online Behavioral Advertising (OBA) and How to Opt-Out of OBA

How OBA Works. We and our Third Party Providers will at times also use Tracking Technologies for purposes of “online behavioral advertising” (OBA). OBA allows the serving of advertisements tailored to interests you have shown by browsing on the Service and on other sites, applications, destinations and services, using the same or a different device. To enable OBA, we and Third Party Providers use Tracking Technologies to collect data including, for example, the make, model, settings, specifications (e.g., CPU speed, connection speed, browser type, operating system, device identifier) and geographic location of your device, as well as date/time stamp, IP address, pages visited, time of visits, content viewed, ads viewed, the site(s), application(s), destination(s), and/or service(s) you arrived from, and other clickstream data. The use of Tracking Technologies by Third Party Providers is subject to their own privacy policies, not this Privacy Policy, and we have no responsibility or liability in connection therewith.
Opt-Out of OBA. If you do not want OBA, you may be able to opt-out by visiting http://www.aboutads.info, http://www.networkadvertising.org, http://www.youronlinechoices.com/uk/and/or by clicking the “Ad Choices” icon that appears in advertising served through OBA. Please note that the option to opt-out applies only to tracking by Third Party Providers across this Service and other sites, applications, destinations and services, and not tracking among pages within the Service itself. Residents of the European Economic Area (EEA) and Switzerland have additional options as described below in Section XII(B) to exercise choices with respect to OBA.

Transfer of Your Data Among Jurisdictions

Your Data may be processed, transferred to, and maintained on, servers and databases located within the U.S. and elsewhere where the privacy laws may not be as protective as your jurisdiction. We reserve the right to transfer your Data to and from any state, province, country or other governmental jurisdiction. Your consent to this Privacy Policy followed by your submission or our collection of such Data represents your agreement to any such transfer.

Data Security and Notification

Security Measures. We take commercially reasonable security measures to protect against unauthorized access to, or unauthorized alteration, disclosure or destruction of, PII that you share with us.
No Liability for Breach. Because no data transmission is completely secure, and no system of physical or electronic security is impenetrable, we cannot guarantee the security of the Data that you send to us or the security of servers, networks or databases, and by using the Service you agree to assume all risk in connection with your Data. We are not responsible for any loss of such Data or the consequences thereof.
Breach Notification. In the event that we believe the security of your Data in our possession or control may have been compromised, we may seek to notify you. If notification is appropriate, we may notify you by e-mail, push notification, or otherwise.

Notice to California Customers – Your Privacy Rights

Shine the Light. California’s “Shine the Light” law, Civil Code Section 1798.83, gives California customers the right to prevent our disclosure of their personal information to third parties for those third parties’ direct marketing purposes, and requires certain businesses to respond to requests from California customers asking about the business’ practices related to disclosing personal information to third parties for the third parties’ direct marketing purposes. Alternately, such businesses may have in place a policy not to disclose personal information of customers to third parties for the third parties’ direct marketing purposes if the customer has exercised an option to opt-out of such information-sharing. We have such a policy in place. As discussed above in Section 5(3), if you wish to opt-out of our sharing of your Data with third parties for the third parties’ direct marketing purposes or to find out more about your opt-out rights, please contact our Privacy Policy Coordinator as described below.
Online Erasure. California’s “Online Erasure” law, Business and Professions Code Sections 22580-22582, requires operators of certain websites and online services to allow registered users who are under the age of 18 and residents of California to request removal of Content they post. If you fit that description and posted Content on a section of our Service that is directed to minors, you may request removal of the Content by contacting our Privacy Policy Coordinator as described below. In response to your request, we may elect to make the Content invisible to other users and the public (rather than deleting it entirely), in which case the Content may remain on servers we control and/or may be publicly available elsewhere if a third party copied and reposted the Content.

Notice to Residents of the European Economic Area (EEA) and Switzerland

Purposes of Processing. As explained in Section IV above, we process your Data to process your requests for Products, administer the Service, facilitate access by Third Party Providers, make marketing communications, facilitate health, safety and legal requests, respond to your requests in connection with employment opportunities, transfer or sell our business, and to combine data sets. As explained in Sections V – VII, we may also use, transfer and otherwise process Data acquired from you directly or by use of Tracking Technologies, for marketing purposes, including to serve you with Online Behavioral Advertising (OBA).
Legal Basis for Processing. We serve you with OBA with your consent, and you have the right to withdraw consent at any time as described in Section VII above, by visiting our Consent Tool, or by contacting our Privacy Policy Coordinator described below. We rely on the legitimate interest basis of processing for the other activities described in subsection (A) above because processing Data is necessary to provide you with our Products and to respond to your requests, our activities are reasonably expected by our visitors, and those activities do not unduly and negatively affect the privacy rights of our visitors. When you make a purchase, enter a sweepstakes, or engage in another type of transaction with us, we may process your Data to fulfill that contract.
Transfers. As described in Section VIII above, your Data may be processed in or transferred to the U.S. or elsewhere in the world. We will ensure that transfers of personal data to a third country or an international organization are subject to appropriate safeguards.
Individual Rights. If you are a resident of the EEA or Switzerland, you are entitled to the following rights. Contact our Privacy Policy Coordinator as described below to exercise these rights. Please note: In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing Data.

Right to access and rectify your Data. You have the right to obtain information about our processing of Data and a copy of your Data that we store. You have the right to request that we update your Data if it is inaccurate or incomplete.
Right to request erasure of your Data. You have the right to have your Data erased from our systems if the Data is no longer necessary for the purpose for which it was collected or you withdraw consent and no other legal basis for processing exists.
Right to restrict our processing of your Data. You have the right to restrict our processing if you contest the accuracy of the Data we store about you, our processing is deemed unlawful and you oppose erasure of your Data, or we no longer need the Data for the purposes for which we collected it but we must store it to comply with our legal obligations.
Right to portability of your Data. You have the right to receive your Data and to transmit it to another controller where our processing is based on consent you gave us and was carried out by automated means.
Right to object to our processing of your Data. You have the right to object to our processing where we process Data based on legitimate interest.
Right to lodge a complaint.You have the right to lodge a complaint about our Data collection and processing actions to your data protection authority. Contact details for data protection authorities are available at http://ec.europa.eu/justice/article-29/structure/data-protection-authorities/index_en.htm.
EEA Representative. If you are a Data Protection Authority in the EEA with questions about this policy or the Service, please contact us directly to our Privacy Policy Coordinator as described in Section XII below. Alternatively, you can contact our EEA Representative at the following address, who will forward your correspondence to us:data@chicagomorningstar.com
Note: If you do not represent a Data Protection Authority in the EEA, please do not use the address above, but instead direct your question(s) to our Privacy Policy Coordinator as described immediately below.

Privacy Policy Coordinator

If you have any concerns or questions about any aspect of this policy, please feel free to contact our Privacy Policy Coordinator as follows:

privacy_administration@chicagomorningstar.com

As discussed above in Section V(B) and XI, you may opt-out of having PII such as your name, email address, postal address or phone number shared with third parties for their marketing purposes. If you wish to exercise this right, please contact our Privacy Policy Coordinator and state which of these items you wish to opt-out of sharing with third parties.

Also, as discussed above in Section V(D), if you have registered on any part of the Service and you wish to update or make changes to your PII on file with us, you may contact our Privacy Policy Coordinator.

Make sure to include enough information for us to help you, including for example your name, contact information, and the specific website, mobile site, application, and/or other service you’re contacting us about.

Note: Only inquiries about this policy or your PII should be sent to the Privacy Policy Coordinator. No other communications will be accepted or responded to.

For communications on other matters, please contact us through the means described on the Service, if available (for example, in the “Contact Us” section).

If you don’t agree to the terms contained in this Privacy Policy, you must immediately exit the Service.