1. Purpose of this Policy. We understand that privacy is very important to our visitors. We want to make sure that you understand why we collect certain information, how we use it, and how we protect it. We want our guests to feel confident that their information is handled with care, and in compliance with applicable laws.
a) Personal Information is information, such as your name, address, telephone number, or email address, which identifies or is reasonably capable of being linked with a particular individual or household. Personal Information can also include Internet activity information, such as your browsing history, search history, and information about your interactions with a website or application.
b) Information provided by you, or collected by The Buffalo News from its website visitors, includes the following categories of Personal Information:
- Identifiers such as your name, alias, postal address, unique personal identifier, IP address, email address, social security number, driver's license number, passport number, or other similar identifiers
- Bank account number, credit or debit card number or similar customer records
- Commercial information, including records of products or services purchased, obtained or considered, or other purchasing or consuming histories or tendencies
- Biometric information (such as fingerprints or DNA information)
- Internet usage information, including browsing history, search history, and information regarding a consumer's interaction with our website, an application, or an advertisement
- Geolocation data
- Professional or employment-related information
- Inferences drawn from any of the information identified in the previous bullets to create a profile reflecting the consumer's preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes
You have certain legal rights with respect to your Personal Information, including the right to know what categories of your Personal Information (listed above) have been collected or transferred. Please see Section VI, later in this Policy.
Finally, you are solely responsible for maintaining the secrecy of your passwords and/or any account information. Please be careful and responsible whenever you are online.
II. What Information Does The Buffalo News Collect?
1. When you register on a Buffalo News website, we collect the following information from you:
- Email address
- Name, address and telephone number
2. In addition to information obtained through registration, The Buffalo News may also obtain information from you when you purchase advertising, start a newspaper subscription, or sign up for contests, notices, email alerts or promotional offers. This information may include, but is not limited to, your name, address, telephone number, and email address.
3. We may also use industry standard technologies like pixel tags and web beacons to track use of our website pages and promotions, or we may allow our third party service providers to use these devices on our behalf. Pixel tags and web beacons are tiny graphic images placed on certain pages on our website, or in our emails, that allow us to determine whether a specific action has been performed. When these web pages are accessed or an email is opened or clicked on, pixel tags and web beacons generate a non-personally identifiable notice of that action. Pixel tags allow us to measure and improve our understanding of visitor traffic and behavior on our website, as well as give us a way to measure our promotions and performance. We may also utilize pixel tags and web beacons provided by our affiliates and/or marketing partners for the same purposes.
4. Furthermore, The News’ website uses other industry standard technologies that collect information from visitors like the uniform resource locator ("URL") of the website visited before coming to our website, the URL of the website visited after leaving our website, the type of browser being used and the Internet Protocol ("IP") address of the visitor’s computer. Computer IP addresses identify computers and the networks or Internet service providers to which they are connected. The Buffalo News tracks computer IP addresses to help with system administration and to compile information about traffic patterns on the site. We, and/or our authorized third party service providers and advertisers, may automatically collect this information when you visit our website through the use of electronic tools like cookies (see Section III, later in this Policy), web beacons and pixel tags, as described in the preceding paragraph of this Policy. We use this information to troubleshoot, administer the website, analyze trends, gather demographic information, comply with applicable law, and cooperate with law enforcement activities. We may also share this information with our authorized third party service providers and our marketing partners in order to measure the overall effectiveness of our online advertising, content, and programming, and to identify and target potential customers.
5. We monitor Buffalo News websites to gather statistical information, including the number of visits to the site, the pages visited, which domains visitors come from and the browsers used to visit the site. We may use marketing partners or other third parties to gather, collect and report on this information. This statistical information enables us to evaluate the effectiveness of the services we provide, to monitor site performance and to make it easier for visitors to use the site.
6. From time to time, The Buffalo News will conduct surveys on its websites for research purposes. When you participate in a survey, the information you provide about yourself and your responses are collected by The Buffalo News. We will always inform you how we will use this information.
7. If you contact The Buffalo News, we may keep a record of your correspondence.
Children should always get their parents' permission before providing any Personal Information about themselves over the internet. The Buffalo News will not collect any Personal Information from any person who indicates they are 13 years of age or younger. The News will not transfer or sell to third parties any Personal Information of a person who indicates they are 16 years of age or younger unless that person’s parent or guardian has authorized the transfer or sale.
III. Cookies and How The Buffalo News Uses Them
A cookie is a small amount of data that is transferred from a web server through your browser and stored on the hard drive of your computer. The cookie contains your user name and password so that when you log on, the web server recognizes you. Using a mobile communication device to photograph a QR code may also result in some information being transferred from the mobile communication device to the source of the QR code.
IV. How Does The Buffalo News Use the Information It Gathers?
Information collected on Buffalo News websites, including traffic patterns and user behavior, is used primarily for the following purposes:
Internal research. The Buffalo News is continuously assessing how visitors use our websites. This data assists us in making decisions about how to improve the sites and to better serve our users. We may share research with our advertisers or marketing and business partners. As previously mentioned, The Buffalo News may use your information to contact you to ask for your participation in a focus group, survey, or some other type of research effort.
To customize your experience on Buffalo News websites. As The Buffalo News improves its service, it may offer users more opportunities to customize content and other aspects of the site. Information provided by you may be used to assist in the customization process, if you elect to participate in these features. Page views are not guaranteed to any individual. An IP address is used as a base for metering.
To tailor advertising efforts. Advertisers prefer to target their communication toward audiences who are most likely to be interested in their products. The information gathered on Buffalo News websites helps us advise advertisers and marketing partners about certain aspects of site visitors (e.g. how visitors use the site, general demographic attributes of visitors, usage patterns on various parts of our site, etc.). This information helps both The Buffalo News and its advertisers and marketing partners make better decisions about where to place advertising. Visitors who choose to conduct financial transactions with advertisers on Buffalo News websites may also provide specific data to those advertisers during the process of their transactions. Additionally, any information provided during the purchase of Buffalonews.com or The Buffalo News products or services will result in the collection of certain information required to complete the transaction.
To use third party service providers. We provide some services and products through third parties. These third party service providers may perform functions on our behalf, like sending out and distributing promotional emails. We may share your Personal Information with such service providers as necessary to allow those service providers to fulfill orders, send mail or email, administer contests or sweepstakes, remove repetitive information on customer lists, analyze data, provide marketing assistance, provide search results and links, process credit card payments, operate the website, troubleshoot, or provide customer service. and may share your information with service providers to accomplish our administrative tasks. For example, when you order a service, the third party payment processor we use releases your credit card information to the card-issuing bank to confirm payment for the service. The use of your Personal Information by these third parties is governed by the privacy policies of these third parties and is not subject to our control.
More specifically, here is how The Buffalo News may use information you provide:
- Email addresses. If you supply The Buffalo News with your email address, either by registering on one of the sites, by communicating with us via email, or signing up for promotional offers or emails, we may, from time to time, send you information that we believe would be of interest to you via email. This information may be from The Buffalo News, or sent by us on behalf of one of our quality advertisers. Note: If we send you email on behalf of another company, your Personal Information is not disclosed to that company unless you purchase a product or service from that company in which case it may need your information to fulfill your purchase. Rather, the company provides us with the information it wants to send, and we prepare and send the email directly to you. We may use a third party service provider to manage or send emails on our behalf, but that third party is only authorized to use your information as necessary to send our email to you and it is not authorized to sell or transfer your information. If The Buffalo News sends you an email, the email will allow you to opt of any further emails from The Buffalo News.
- Postal addresses. If you supply The Buffalo News with your postal address, we may send you periodic mailings with information on new products, coming events, surveys or other research materials, or other information we think might be of interest to you.
- Telephone numbers. If you provide your telephone number or cell phone number, The Buffalo News may call or text you regarding orders you have placed, to tell you about new products, services, or coming events, or to offer other information that may interest you. Additionally, The Buffalo News, or one of its agents may call you for research purposes.
- Sale transaction information. From time to time, we provide offers from our advertisers who, as part of their offer, request information on customers who purchased their offer in order to allow the advertiser to fulfill the purchase. In those cases, we share some of your Personal Information with that advertiser. Sharing this Information may allow that advertiser to market directly to you should it choose to do so. However, we will only share Personal Information with an advertiser if you provide us that information and enter into a transaction with that advertiser on or through our websites. We are not responsible or liable for the actions of such advertiser.
- Business transfer. We may also share your information in the event that our business is sold or transferred. If this occurs, the successor company would acquire the information we maintain, including Personal Information.
- Web usage information. As discussed earlier in this Policy the News tracks usage of our website pages and other websites by visitors, and collects other information, like the type of browser and the visitor’s IP address. The News shares this information with its business and marketing partners in order to tailor its advertising efforts and identify and target potential customers.
V. Disclosure of Personal Information
The Buffalo News may divulge a visitor's Personal Information to a third party in certain circumstances. For example:
- If we believe in good faith that the law requires such disclosure or we are compelled to do so by a court of competent authority.
- If we need to disclose the information in order to enforce the provisions of Buffalo News Terms of Service, or to stop or prevent damage or interference with The Buffalo News' legal rights or, to stop or prevent harm to Buffalo News users or others.
- In the event The Buffalo News contracts with an outside research firm, we may provide them with your contact information. The research firm will only be authorized to use the information to contact you to request your participation in surveys, focus groups or other research activities that will help us improve Buffalo News products and services. Your participation in any such research project is strictly voluntary. The research firm will be bound by its contract with The Buffalo News to use your information strictly for Buffalo News research purposes, to keep your information confidential, and to adequately secure or delete your information when the research is complete.
- As discussed elsewhere in this Policy, The News may disclose Personal Information to our advertisers and business and marketing partners in order to improve our online advertising, content, and programming, and to identify and target potential customers.
Credit card information provided directly to The Buffalo News is required to be secured in accordance with federal, state and local laws, and payment card industry data security standards. Often times, a third party vendor handles financial information on our behalf and the financial information is not accessible by The Buffalo News. In such case, the third party vendor is required to secure the information in accordance with federal, state and local laws, and payment card industry data security standards.
VI. Your Rights Regarding Your Personal Information
You have certain rights with respect to your Personal Information under the California Consumer Privacy Act (CCPA), as described in this Section.
1. Right to Request Disclosure of Information Collected or Transferred.
a) You have the right to request that The Buffalo News disclose to you the following:
- The categories of Personal Information it has collected about you, and the sources of the collected information,
- The categories of Personal Information with whom The News shares Personal Information, or to whom The News has sold or transferred Personal Information for a commercial or business purpose,
- The business or commercial purpose for collecting or selling your Personal Information,
- The categories of third parties to whom The News has sold or transferred Personal Information for a commercial or business purpose, and
- If feasible, the specific pieces of Personal Information that The Buffalo News has collected about you.
b) The categories of Personal Information that the News collects are listed in Section I.4(b) of this Policy.
c) You can request this disclosure by sending an email to email@example.com or by calling (toll free) 1 (800) 777-8640. In most cases, The Buffalo News will respond within 45 days of your request. The disclosure will cover information collected during the 12 months preceding the date of the request. You may not request such a disclosure more than twice in any 12 month period.
d) The Personal Information we will disclose will not include information collected for a single, one-time transaction if, in the ordinary course of business, we do not retain that information.
2. Right to Opt Out of Certain Transfers of Personal Information. As discussed in this Policy, The Buffalo News discloses Personal Information to its marketing partners and other third parties in order measure the effectiveness of its online advertising, content, and programming, and to target potential customers. You have the right to opt out of the sale or transfer of your Personal Information. To do so, click on the Do Not Sell My Personal Information link on the Buffalo News website.
3. No Discrimination. The News will never discriminate against an individual because the individual exercised any rights under the CCPA, by denying goods or services, charging different prices for goods or services (including through the use of discounts) , or providing a different level or quality of goods or services to the individual.
4. 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. To find out more about DNT, please visit http://allaboutdnt.com.
VII. What if I don't want The Buffalo News to contact me?
You may opt out of any or all contacts from The Buffalo News at any time. All emails sent to you from The Buffalo News will allow you to opt out of any further email from us. You may email us at firstname.lastname@example.org to opt out of our email programs. You may also write or call us at the following address and phone number to notify us regarding use of your information: One News Plaza, P.O. Box 100, Buffalo, NY 14240; (716) 849-4444.
VIII. Security Technologies
The Buffalo News uses industry-standard encryption technologies when transferring and receiving consumer data exchanged with our site. When we transfer or receive certain types of sensitive data, such as financial information, we will redirect you to a secure server. We have implemented appropriate security measures in our physical facilities to protect against the loss, misuse or alteration of information that we have collected from you.
Unfortunately, no data transmission over the Internet or any wireless network can be guaranteed to be secure all of the time. We employ commercially reasonable security measures to protect data and seek to do business with companies which do the same, but we cannot guarantee the security of any information transmitted to or from our website, and are not responsible for the actions of any third parties that may receive any such information.
IX. Making corrections to your information
Upon request, you may review all information that we maintain in your record, including unique identifier, Personal Information (name, address, phone number, email), or any other information we may keep in your record.
You may also request that inaccuracies be corrected in any information that we maintain in your record.
Submit your request by contacting The Buffalo News via email, postal mail, or telephone, as described in the next Section.
X. Contacting The Buffalo News
One News Plaza, P.O. Box 100
Buffalo NY 14240
Attention: Compliance Officer