Privacy Policy
Last updated: January 15, 2018
Your Privacy
This privacy policy (this "Privacy Policy"), as amended from time to time, applies to all of the products and services created and offered by The Erie Reader/Great Lakes Online Media LLC. or its subsidiaries and affiliates (collectively, "The Erie Reader").
The Erie Reader respects the privacy rights of its customers and visitors (the "Users") and is committed to protecting the information collected through its online or mobile applications, services and websites (collectively, "Services"). The Erie Reader has adopted this Privacy Policy to explain how The Erie Reader collects, stores, and uses the information collected in connection with the Services.
The English version of the Privacy Policy is the governing version. Any translation of the Privacy Policy is just a reference for your convenience and should not be relied on in legal proceedings.
BY INSTALLING, USING, REGISTERING TO OR OTHERWISE ACCESSING THE ERIE READER'S SERVICES, YOU AGREE TO THIS PRIVACY POLICY AND GIVE AN EXPLICIT AND INFORMED CONSENT TO THE PROCESSING, USE AND DISCLOSURE OF YOUR PERSONAL DATA IN ACCORDANCE WITH THIS PRIVACY POLICY. IF YOU DO NOT AGREE TO THIS PRIVACY POLICY, YOU MUST NOT INSTALL, USE, REGISTER TO OR OTHERWISE ACCESS THE SERVICES.
Information We Collect & How We Use It
The Erie Reader may collect and use both personal and non-personal data from Users using the Services. This section of the Privacy Policy will describe the type of information that may be collected and how the information may be used.
- Personal Data
- Definition
For the purposes of this Privacy Policy, "personal data" means personally identifiable information that specifically identifies Users as individuals and includes those items listed below.
- Registering for Services
Users may make personal data such as their name, email address, username and password available to The Erie Reader when they register for Services, enter contests and special events, subscribe to newsletters, request technical support or otherwise communicate with The Erie Reader, and when using The Erie Reader's Services where personal data is required for use and/or participation.
Users may also disclose their banking or credit card information and age in order to make in-application purchases ("In-Application Purchases") from third party providers via the Services, including but not limited to food and beverage items and physical or digital merchandise. We may use information provided by Users in registering for the Services to facilitate registration for In-Application Purchases by them.
- Information about Users Received from an SNS
When Users access the Services through a social networking site ("SNS") such as Facebook or Google +, Users allow The Erie Reader to access certain information from their profile for that site. The information Users allow The Erie Reader to access varies by application and SNS, and it is affected by the privacy settings Users and their friends establish at the SNS. Users can control and find out more about these settings at the SNS sites that they use. For example, The Erie Reader may access and store some or all of the following information, as allowed by Users, the SNS and their preferences:- first and last name;
- profile picture or its URL;
- user ID number, which is linked to publicly available information such as name and profile photo;
- the user ID numbers and other public data for Users' friends;
- the login e-mail provided to that SNS when Users register;
- Users' physical location and that of Users' access devices;
- gender; and
- birthday.
- Optimize User Experience
The Erie Reader may collect, store and use personal data to provide Users with an optimized user experience. For example, the information collected may be used to create Users' accounts, provide enhanced interaction with The Erie Reader's apps and websites, manage any in-application features, notify Users of in-application updates, provide technical support and respond to Users' inquiries.
- Mobile Devices
If Users access The Erie Reader's Services on mobile and tablet devices, The Erie Reader may collect device identifiers, including MAC Address and IP Address, and The Erie Reader may assign to devices an identifier that is similar to an account number. The Erie Reader may collect the name Users have associated with their device, device type, telephone number, country, and any other information Users choose to provide, such as user name, character name, geo-location or e-mail address. We may also access Users' contacts to enable Users to invite friends to join them in the Services.
- Location Data
If The Erie Reader makes location enabled Services available and Users use such Services, then The Erie Reader may collect and process location data to provide location related Services and advertisements. The Erie Reader may use various technologies to determine location, such as GPS, Wi-Fi or other network-based data such as IP address. Your GPS location is not accessed without your consent. Notwithstanding The Erie Reader's partners who are providing location related parts of the Service, The Erie Reader will not share Users' geo-location with third parties without your consent. To the extent The Erie Reader makes available geo-location to third parties in accordance with this Privacy Policy, it will be provided anonymously. Please note that The Erie Reader may share Users' anonymous coarse location with its partners.
End Users can turn off the location enabled Services (if applicable) by visiting the "settings" page within the relevant application on their mobile device. If End Users choose to disable any location enabled Services, they will not be able to utilize certain features of the Services.
- Other Purposes
Additionally, The Erie Reader may collect, store, and use personal data to solicit Users' feedback to help improve the Services and other The Erie Reader products, inform Users about new products or promotional material offered by The Erie Reader or its trusted third party business partners and affiliates, notify Users about changes to The Erie Reader's Services or other products, provide Users with advertising and marketing material from The Erie Reader and its trusted business partners and communicate with Users for other commonly accepted purposes such as notifying them that they are a potential winner of a contest.
Finally, The Erie Reader may collect and use personal data as required or permitted by applicable law.
- Data Storage
The Erie Reader may store and/or transfer personal data outside of the United States in accordance with applicable legislation and this Privacy Policy.
- Third Party Privacy Policies
While accessing or using the Services, Users may interact with third parties, such as application stores, mobile software platforms, social networking services and payment providers. Users recognize and agree that The Erie Reader is not liable for their use of Users' personal data and Users should review the privacy policies of these third parties.
The Erie Reader may make available links through advertisements or otherwise enable you to access third party products or services. While using such products or services, Users are using products or services that are not affiliated with or controlled by The Erie Reader. The Erie Reader is not responsible for those people or companies, the content of their products or services, the use of information Users provide to them, or any products or services they may offer. Providing links or otherwise enabling access to third party products or services does not constitute sponsorship of, or affiliation with those people or companies.
- User Generated Content
Users should be aware of the open nature of certain social networking and other open features of the Services The Erie Reader may make available to Users. Users may choose to disclose data about themselves in the course of contributing user generated content to the Services including, but not limited to account personas, pictures, forum posts, chat posts, tweets, Facebook postings, profiles and any other text, widgets, messages, links, emails, video, sound, graphics, code and all other audio visual or other material appearing on or emanating to and/or from the Services and any content contributed by the User to the Services ("User Content"). Any User Content that is disclosed during use of the Services is public information, and there is no expectation of privacy or confidentiality. The Erie Reader is not responsible for any personal data Users choose to make public in any of these forums.
- Minors
The Erie Reader does not knowingly collect any personal data from children below the age of 13 without receiving the consent of a legal guardian. If The Erie Reader learns that it has inadvertently collected or stored personal data from children under the aforementioned age without the consent of their legal guardian, The Erie Reader will take reasonable measures to promptly erase such personal data from their records.
- Definition
- Non Personal Data
- Definition
For the purpose of this Privacy Policy, "non-personal data" means: (1) information that does not directly identify Users; and (2) "aggregate" and "de-personalized" information, which is data The Erie Reader collects about the use of The Erie Reader Services, from which any personally identifiable data has been removed.
The Erie Reader may use tools or third party analytical software to automatically collect and use certain non-personal data. You will not be identifiable through the use of these tools or third party analytical software. The types of non-personal data The Erie Reader may collect and use include, but are not limited to:- Device properties, including, but not limited to:
- IP address;
- Media Access Control ("MAC") address; and
- Unique device identifier or other device identifier ("UDID");
- Device software platform and firmware;
- Mobile device carrier;
- Geographical data such as zip code, area code and coarse location;
- Game progress, score and achievements; and
- Other non-personal data that The Erie Reader may require to enhance the Services and other The Erie Reader products.
- Device properties, including, but not limited to:
- Trusted Partners and Contractors
The Erie Reader may use and disclose to its affiliated companies, contractors, participating sports leagues and teams or other trusted businesses or persons the collected non-personal data for the purpose of auditing, researching and analyzing usage of the Services, ensuring the technical functionality of The Erie Reader's Services, offering products and services to Users and to further develop the Services and other The Erie Reader products.
- Cookies, Beacons and Tracking
The Erie Reader may use "cookies" and other technologies such as pixel tags, locally shared objects, clear GIFs and web beacons. The Erie Reader treats information collected by cookies and similar technologies as non-personal data.
A "cookie" is a small bit of record-keeping information that is sent to the Users' computer. The Erie Reader's cookies do not include personal data and may be used to: (1) facilitate Users' login authentication, (2) help Users navigate around the The Erie Reader website, (3) monitor how many people are using the Services, and (4) store Users preferences and track trends.
Most browsers are initially set up to accept cookies, but Users can disable cookies or set their browser to indicate when a cookie is being sent. However, disabling cookies may affect Users' ability to use the Services.
The Erie Reader may also use Flash cookies (locally shared objects) and HTML5 storage (locally stored objects). Locally shared objects are small files similar to browser cookies and are used to remember Users' settings to personalize the look and feel of the Services. Locally shared objects only collect data in the aggregate.
Users may prevent locally shared objects from being placed by disabling locally stored objects in their browser or by visiting www.adobe.com. Locally stored objects, such as HTML5 Web Storage, are used for similar purposes as cookies but typically may contain a greater amount and different types of data than browser cookies.
The Erie Reader may also use web beacons and pixel tags to count Users who have visited certain pages or viewed certain advertisements. Web beacons, like cookies, do not include personal data. E-mails and other electronic communications The Erie Reader sends to you may contain pixel tags that enable The Erie Reader to track your usage of the communication, including whether the communication was opened and/or what links were followed.
- Ad Serving Technology
The Erie Reader reserves the right to use and disclose the collected non-personal data for purposes of advertisement by The Erie Reader or The Erie Reader's trusted partners and contractors. The Erie Reader may employ third party ad serving technologies that use certain methods to collect information as a result of ad serving through the Services.
The Erie Reader or third parties operating the ad serving technology may use demographic and location information as well as information logged from Users' hardware or device to ensure that appropriate advertising is presented within the Service. The Erie Reader or third parties may collect and use data for this purpose including, but not limited to IP address (including for purposes of determining your coarse location), UDID, MAC, software, applications, hardware, browser information, internet and on-line usage information and in-app information.
The foregoing data may be used and disclosed in accordance with this Privacy Policy and the privacy policy of the company providing the ad serving technology. Users recognize and agree that the advertising companies who deliver ads for The Erie Reader may combine the information collected with other information they have independently collected from other services or products. These companies collect and use information under their own privacy policies. These ad serving technologies may be integrated into the Services; if Users do not want to be subject to this technology, do not use or access the Services. Although The Erie Reader may take commercially reasonable steps to instruct such advertising companies to comply with the terms and conditions of this Privacy Policy, The Erie Reader does not have access to or control of third party technologies.
- Definition
Who We Disclose Personal Data To
- Disclosure of Personal Data
In providing the Services, The Erie Reader may disclose the personal data to other companies or individuals in the following limited circumstances:- In accordance with the purposes outlined in this Privacy Policy;
- In cases where The Erie Reader receives Users' consent;
- With application stores as part of Users' purchase and use of the Services (including In-Application Purchases);
- The Erie Reader has a good faith belief that access, use, preservation or disclosure of such personal data is reasonably necessary to;
- satisfy any applicable law, regulation, legal process or enforceable governmental request;
- enforce applicable Terms of Use including investigation of potential violations thereof;
- detect, prevent, or otherwise address fraud, security or technical issues; or
- protect against imminent harm to our rights and/or property, or
- As required or authorized by applicable law.
- Data Processing
The Erie Reader may also disclose Users' personal data to its affiliated companies, contractors or other trusted businesses or persons for the purpose of processing personal data on its behalf. The Erie Reader requires that these parties agree to process such personal data based on The Erie Reader's instructions and in compliance with the Privacy Policy and any other appropriate confidentiality and security measures.
- Sale of Business
As The Erie Reader continues to develop and grow, we may buy or sell parts of a business, which could include personal data as one of the transferred business assets. If The Erie Reader becomes involved in a merger, acquisition, or any form of sale of some or all of its assets, it will provide notice before personal data is transferred and becomes subject to a different privacy policy.
Choices for Personal Data
If The Erie Reader proposes to use personal data for any purposes other than those described in this Privacy Policy, The Erie Reader will obtain the Users' prior consent or offer the Users an effective way to opt out of the use of personal data for those other purposes.
Users may choose to withdraw their consent to the use, collection or disclosure of personal data outlined in this Policy at any time. If a User withdraws his or her consent, then The Erie Reader may no longer be able to provide the same level of Services.
Users are also given the opportunity to "opt-out" of having their personal data used for purposes such as receiving newsletters or other information from The Erie Reader.
Withdrawals of consent will not have an effect on data that The Erie Reader has provided to third parties in accordance with this Privacy Policy prior to such withdrawals.
Information Security
The Erie Reader takes appropriate security measures to protect against unauthorized access to or unauthorized alteration, disclosure or destruction of data. The Erie Reader employs physical, electronic and/or procedural safeguards to protect its systems and all personal data under its control against unauthorized access and use. All safety and security measures are appropriate to the sensitivity level of the information collected.
Accuracy and Access/Control over Personal Data
The Erie Reader processes personal data only for the purposes for which it was collected and in accordance with this Policy. The Erie Reader may take reasonable steps to ensure that the personal data processed is accurate, complete and current, but The Erie Reader is not responsible for verifying the correctness of personal data.
The Erie Reader will allow Users to access their personal data in the custody or control of The Erie Reader, and will allow them to:
- update or correct such personal data;
- change User preferences with respect to communications, push notifications and other information received from The Erie Reader or third parties; or
- delete the personal data of the Users on The Erie Reader's systems (by submitting a request to Customer Support).
Such updates, corrections and changes will not have an effect on other information that The Erie Reader maintains, or information that The Erie Reader has provided to third parties in accordance with this Privacy Policy prior to such update, correction or change.
Retention of Personal Data
The Erie Reader stores personal data collected pursuant to this Privacy Policy only as long as is reasonably required to fulfil the purposes for which it was collected or as required or authorized by law.
The Erie Reader may still retain some of the data to the extent such retention is necessary to resolve disputes, enforce The Erie Reader's user agreements, and comply with technical and legal requirements and constraints related to the security, integrity and operation of the Services.
Enforcement
It is The Erie Reader's policy to contact a complaining user regarding his or her concerns. The Erie Reader will cooperate with the appropriate regulatory authorities, including local data protection authorities, to resolve any complaints regarding the transfer of personal data that cannot be resolved between The Erie Reader and an individual.
Changes to this Policy
The Erie Reader reserves the right to modify this Privacy Policy from time to time, so please review it frequently. If The Erie Reader makes material or significant changes to this Privacy Policy, The Erie Reader may post a notice on The Erie Reader's website at www.eriereader.com, along with the updated Privacy Policy. Your continued use of the Services will signify your acceptance of the changes to this Privacy Policy.
Contact Information
Should you have any questions relating to this Privacy Policy, please contact our offices at 1001 State Street, Erie, PA 16501 or at (814) 314-9364.
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