The Harmattan News Company Privacy Policy

What Information Do We Gather About You?

The information we gather about you depends on the context. By and large, it’s information about you that can personally identify you — either on its own or when combined with other information.
The following describes the information we collect and how we obtain it.

A) Information Collected Through The Harmattan News.

Information You Voluntarily Give Us

1. For Registration: When you sign up for a The Harmattan News (e.g., a subscription), we collect your contact information and account credentails. Once you’re registered, we assign you a unique ID number. This ID number helps us recognize you when you’re signed in.
   For some The Harmattan News, you can instead sign up by linking your Yahoo, Apple, Facebook or Google account. If you register for an event or conference, we might ask for additional information (e.g., your company name, your job title or your dietary restrictions).
2. For Billing: To process payments or donations, we collect and use your payment information.This can include your name, your address, your telephone number, your email address, your credit or debit card information and any other relevant information.
3. For User-Generated Content: We offer you the ability to post content that other users can read (e.g., comments or eye witness account report). Anyone can read, collect and use any personal information that accompanies your posts. We do not have to publish any of your content. If the law requires us to take down, remove or edit your personal information, we will comply to the required extent.
4. For Contests, Sweepstakes and Special Offers: When you sign up for these, you give us your name, email and any other required information.
5. For Reader Surveys, Research, Panels and Experience Programs: We gather information through questionnaires, surveys and feedback programs. We also conduct similar research for advertisers. We ask you for your consent to use this information when you participate in these programs and events.
6. During Contact With Our Call Centres: We collect information from you when you place an order over the phone or contact customer service through one of our toll-free numbers.
7. Personal Contacts Data: We never scan your device for your contacts or upload that data.

With your consent, we do comply with your requests to collect data about your friends, family or acquaintances (e.g., Refer a Friend campaigns). This functionality is only meant for UK residents. By using it, you acknowledge and agree that both you and your contacts are based in the United Kingdom — and that you have everyone’s consent for us to use their contact information.

Information Collected Automatically

With Tracking Technologies in Your Browser and Mobile Apps:
These technologies include cookies, web beacons, tags and scripts, software development kits (or SDKs) and beyond.
We track and store data about how you visit and use Times Services, particularly through our websites and apps. The items we log include:

• Your IP address
• Your location
• Your operating system
• Your browser
• Your browser language
• The URLs of any pages you visit on our sites and apps
• Device identifiers
• Advertising identifiers
• Other usage information.

1. Privately Owned Databases: Marketing, data analytic and social media-owned databases give us access to a range of information — like public data, survey data and beyond. This data sometimes includes your mailing address, your gender, your age, your household income and other demographic data.
2. Social Media Platforms and Other Third-Party Services: (Social media platforms include Facebook. Third-party services include Google and Nook.) You can link your social media or other third-party account to a The Harmattan News. By linking the services, you authorize us to collect, store and use any information they may give us (e.g., your email address). You can disconnect your nytimes.com registration from third-party accounts at any time. We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles. For more information, refer to our social login and Nook F.A.Q.
3. Workplace and Schools: When your employer or school buys an organization wide subscription to harmattan.com, they sometimes provide us with your name and organization email address to grant you access as a user.
4. A note about future updates: We are always improving our products and services, and we create new features regularly. These updates sometimes require us to collect new information, or use what we already have differently. If there is a significant or material change in the way we handle your personal information, we will notify you as detailed below.

What Do We Do With The Information We Collect About You?

A) We use your information to help you use and navigate The Harmattan, such as:

• Making The Harmattan available to you
• Arranging access to your account
• Providing customer service
• Responding to your inquiries, requests, suggestions or complaints
• Completing your payments and transactions
• Sending service-related messages (e.g., a change in our terms and conditions)
• Saving your reading list, recipes or property searches
• Displaying your Crossword stats
• Letting you take part in paid services, polls, promotions, surveys, panels, research and comments.

B) We Personalize Your Experience.

We track your interests and reading habits (e.g., the articles you read) to personalize your reading experience using technology like algorithmic recommendations and machine learning. This is how we highlight articles you might be interested in and de-emphasize articles you’ve already read. For more information about content personalization on The Harmattan, you can read the Personalization F.A.Q. We also show you prices, promotions, products or services we believe you’ll find interesting, based on demographic and usage data.

C) We Allow You to Share User-Generated Content.

Any information you disclose in your content becomes public — along with your chosen screen name and uploaded photo.

D) We Develop Products and Services, and Do Analysis.

We analyze data on our users’ subscription, purchase and usage behaviors. This helps us make business and marketing decisions.
For example, our analysis lets us predict preferences and price points for our products and services. It helps us determine whether our marketing is successful. It also shows us characteristics about our readers, which we sometimes share in aggregate with advertisers.
Google Analytics is one of the analytics providers we use. You can find out how Google Analytics uses data and how to opt out of Google Analytics.

E) We Carry Out Administrative Tasks.

• For auditing: We verify that our internal processes work as intended and comply with legal, regulatory and contractual requirements.
• For fraud and security monitoring: We detect and prevent cyberattacks or unauthorized robot activities.
• For customer satisfaction: We assess users’ satisfaction with The Harmattan and our customer care team.
  The above activities can involve outside companies, agents or contractors (“service providers”) with whom we share your personal information for these purposes.
  Another example is our affiliate link vendors, which we use in our guides and product recommendations. Times Services include links that will send you to vendor URLs and other services not operated or controlled by us. These vendors use cookies and other technologies to collect information about your navigation from the Times Services to the merchant you are visiting. If you buy a product after following a link to a link vendor’s URL, we may earn a commission.
  Additional notes:For more about targeted advertising, and how to opt out with your specific browser and device, go to the DAA Webchoices Browser Check and NAI Opt Out of Interest-Based Advertising. You can download the AppChoices app to opt out in mobile apps. You can also follow the instructions in the What Are Your Rights? section below.
• We try to limit how our third-party advertising technology vendors use the information they gather from you. Many of these providers require us to enter into contracts that allow them to optimize their own services and products, or that help them create their own.

Essentially, these providers combine any information they gather about you through The Harmattan with information they receive from their other clients. This helps them target ads to you on behalf of their other clients, not just us.
These third parties sometimes use other services in order to serve ads; check their privacy policies for more details. For further information on tracking technologies and your rights and choices regarding them, see the applicable

Cookie Policy.

With Whom Do We Share the Information We Gather?

A) Within The Harmattan News Company:We share your information with our affiliates for the purposes listed here. See a list of our affiliates.
B) With Service Providers: We work with service providers, as defined above, to carry out certain tasks:

• Processing your payments
• Fulfilling your orders
• Maintaining technology and related infrastructure
• Offering you customer service
• Serving and targeting ads
• Measuring ad performance
• Presenting surveys
• Shipping you products and mailings
• Distributing emails
• List processing and analytics
• Managing and analyzing research
• Managing promotions

When performing these tasks, service providers often have access to your personal information.
We sometimes allow them to use aggregated or de-identified information for other purposes, in accordance with applicable laws

C) With Other Third Parties: There are situations when we share your information with third parties beyond our service providers. We never share your email address with these third parties without your consent, except in encrypted form to engage in the matched ads process described above.

1. We may share your name and mailing address (among other information) with other reputable companies that want to market to you by mail.
2. We share information about our live event and conference attendees (e.g., your name, your company or your job title) with the event sponsors. In those cases we notify you when you provide us the information.
3. We share information about participants in our sweepstakes, contests and similar promotions with the promotions’ sponsors. In those cases we notify you when you provide us the information.
4. We process payments you make through The Harmattan with external services.
   There are two ways this can happen:
   We collect your information and share it with the third-party service for processing.
   The third-party service collects your information for processing.
5. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we would have a legitimate interest in disclosing or transferring your information to a third party — such as an acquiring entity and its advisers.
6. We can preserve or share personal information if the law requires us to do so. We can also preserve or share personal information if we believe it would be necessary to:

• Comply with the law or with legal process
• Protect and defend our rights and property
• Protect against misuse or unauthorized use of the Times Services
• Protect the safety or property of our users or the general public (e.g., if you provide false information or attempt to pose as someone else, we could share your information to help investigations into your actions)
• Cooperate with government authorities, which could be outside your country of residence.
• We disclose public activities in our RSS feeds, APIs and other distribution formats. Your public activities could thus appear on other websites, blogs or feeds.

What Are Your Rights?

A) How Do I Opt Out of Email, Phone, Mail and Push Notifications?

The opt-out methods described below are limited to the email address, phone or device used. They won’t affect subsequent subscriptions.
1.Email: We offer a variety of commercial emails and email newsletters. You can unsubscribe from them by following the “unsubscribe” instructions near the bottom of the email. You can also email us at privacy@theharmattannews.com. You can manage your theharmattannews.com newsletter preferences.
2.Mail or Telephone Promotions: You can ask us to unsubscribe from our mail or telephone solicitations. You can also ask us to not share your information with third parties for marketing purposes. To do so contact us, or chat with us. You may also email us at privacy@theharmattannews.com with “Opt Out” in the subject line, and your account number and phone number in the body of the email.
3.Push Notifications: You can opt out any time by adjusting your device settings, or uninstalling our app.
4.Text Messages: You can opt out of text alerts any time by replying “STOP,” or any alternative keyword we’ve shared with you.
We complete any opt-out request as quickly as we can. This opt-out request won’t prohibit us from sending you important nonmarketing notices.

B) How Do You Access, Change, Delete, Update or Exercise Your Other Rights in Relation to Your Personal Information?

In some parts of the world, you have the right to:

• Access, modify, or delete the personal information we have about you
• Receive an electronic copy of the personal information we have about you, for data portability
• Restrict, or object to, how we process personal information about you
• Not receive discriminatory treatment by us for the exercise of your privacy rights.
• You have the right to object to the processing of your personal information based on our legitimate interest or that of a third party — unless we demonstrate compelling legitimate grounds for the processing of, or the keeping of, your personal information for the establishment, exercise or defense of legal claims.
• If you’d like to exercise any of the above rights, contact us via this form or by calling us. In your request, please be specific. State the information you want changed, whether you’d like your information suppressed from our database or whether there are limitations you’d like us to put on how we use your personal information. Please use the email address linked to that personal information — we only complete requests on the information linked to your email address. To verify your identity, we will email the email address you provide us, and which matches our records, and wait for your response. In some instances we may also ask for additional information. This is how we verify your identity before complying.
• You can designate an authorized agent to make a request on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.
• We’ll respond to your request in a manner consistent with applicable law.
• We might need to keep certain information for recordkeeping purposes, or to complete a transaction you began prior to requesting a change or deletion (e.g., if you make a purchase or enter a promotion, you might not be able to change or delete the personal information provided until after the completion of the purchase or promotion).
• In some cases, your request doesn’t ensure complete removal of the content or information (e.g., if another user has reposted your content).
• If you’d like, you can lodge a complaint with a data protection authority. A list of E.U. data protection authorities is available.

C) How Do You Manage Your Digital and Home Delivery Accounts?

You can update your account information. If you need assistance, Contact Us. Register with us to access the Account area.
What About Sensitive Personal Information?

We generally don’t want to gather any sensitive information about you. This includes:

• Your racial or ethnic origin
• Your political opinions
• Your religion or other beliefs
• Your health, biometric or genetic characteristics
• Any trade union membership
• Any criminal background

There are rare situations when we request this information (e.g., a reader survey asks about your political leanings), but you can decline to answer. Outside those situations we would prefer you never share that information with us.

How Long Do You Retain Data?

It depends. We store your personal information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). This means we might retain your personal information even after you close your account with us.
When deciding how long to keep your information, we consider:

• How long we have had a relationship with you or provided a Times Service to you
• Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them)
• Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).
  Rather than delete your data, we might de-identify it by removing identifying details.

How Do You Protect My Information?

We protect your personal information with a series of organizational, technological and physical safeguards — but we cannot guarantee its absolute security. We recommend that you use complex and unique passwords for your Times accounts and for third-party accounts linked to them. Do not share your password with anyone.
If you have reason to believe your interaction with us is no longer secure, notify us immediately.

Are There Guidelines for Children? The Harmattan News are intended for a general audience, and are not directed at children under (13) years of age.
We do not knowingly gather personal information (as defined by the UK Children’s Convention on the Rights the of the Child and the Equality and Human Rights Commission) in a manner not permitted. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at privacythemarmattannews.com. We will remove the data to the extent required by applicable laws.

How Is Information Transferred Internationally?

The Harmattan News is headquartered in the United Kingdom. If you are located outside the United Kingdom, your information is collected in your country and then transferred to the United Kingdom — or to another country in which we (or our affiliates or service providers) operate.
If we transfer your data out of the European Economic Area (E.E.A.), we implement at least one of the three following safeguards:

• We transfer your information to countries that have been recognized by the European Commission as providing an adequate level of data protection according to E.E.A. standards (see the full list of these countries).
• We use a service provider in the United kingdom that is Privacy Shield certified.
• We take steps to ensure that the recipient is bound by E.U. Standard Contractual Clauses to protect your personal data. You can see a copy of these clauses.
  In certain situations, the courts, law enforcement agencies, regulatory agencies or security authorities in those countries might be entitled to access your personal information.

What Is Our Legal Basis?

In some jurisdictions, like the European Union and the European Economic Area, we only collect, use or share information about you when we have a valid reason. This is called “lawful basis.” Specifically, this is one of the following:

• The consent you provide to us at the point of collection of your information
• The performance of the contract we have with you
• The compliance of a legal obligation to which we are subject or
• The legitimate interests of The Harmattan or a third party. “Legitimate interest” is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights and interests. “Legitimate interest” also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact.
• We have a legitimate interest in gathering and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within The Harmattan News Company; (3) to prevent fraud; and (4) to conduct our marketing activities.