Information We May Collect and What We Do with It
SmallTownPapers may collect personal information about you in the following ways:
(1) directly from your verbal or written input (such as by consenting to receiving marketing emails or indirectly through third parties with whom we work closely (see below "Information We Receive From Other Sources"); or
(2) automatically through SmallTownPapers web site technologies including tracking online, such as by web cookies (which are small text files created by web sites that are stored on your computer), by smart devices, by combining data sets, by collecting data from a browser or device for use on a different computer or device, or by using algorithms to analyze a variety of data such as records of purchases, online behavioral data, or location data.
Information You Provide
The types of information that SmallTownPapers collects directly from you or through your use of our web site and services may include the following depending on how you interact with SmallTownPapers:
* Contact details, such as your name, email address, postal address, username, and telephone number;
* Internet Protocol ("IP") addresses used to connect your computer to the Internet;
* Educational and professional interests;
* Tracking codes such as cookies;
* Usernames and passwords;
* Payment information, such as a credit or debit card number and related information;
* Comments and feedback you provide to SmallTownPapers (including through the SmallTownPapers web site);
* Communication preferences;
* Purchase and search history;
* Location-aware services, the physical location of your device in order to provide you with more relevant content for your location;
* Information about your personal preferences, and interests; and
* Communications with other users of SmallTownPapers services.
In order to access certain content and to make use of additional functionality and features of SmallTownPapers web site and services, we may require you to register for a subscription account by completing and submitting a registration form, which may request additional information.
Information We May Receive from Other Sources
SmallTownPapers may receive information about you if you use the web site we operate or any other services we provide. We also work closely with third parties (including, for example, business partners and sub-contractors in technical, payment and delivery services; advertising networks; data and analytics providers; and similar organizations; and search information providers) from whom SmallTownPapers may receive information about you.
Use of Your Information
We may use your information in the following ways:
* To provide you with information about products and services that you request from us;
* To send you periodic services information from SmallTownPapers;
* To provide you with information about other products and services we offer that are either (i) similar to those you have already purchased or inquired about, or (ii) entirely new products, and services;
* For internal business and research purposes to help enhance, evaluate, develop, and create SmallTownPapers web site (including usage statistics, such as "page views" on SmallTownPapers web site and the products therein), products, and services;
* To notify you about changes or updates to our web site, products, or services;
* To provide, activate, and/or manage our services;
* For internal operations, including troubleshooting, data analysis, machine learning, testing, statistical, and survey purposes;
* To allow you to participate in interactive features of our service; and
* For any other purpose that we may notify you of from time to time.
Personal information will not be kept longer than is necessary for the purpose for which it was collected. This means that, unless information must be retained for legal or archival purposes, personal information will be securely destroyed, put beyond use or erased from SmallTownPapers systems when it is no longer required or, where applicable, following a request from you to destroy or erase your personal information.
Disclosure and Sharing of Your Information
SmallTownPapers will not disclose to or share your personal information with any unaffiliated third party except as follows:
* Where necessary in connection with services provided by third parties (i) who provide us with a wide range of office, administrative, information technology, web site and platform hosting, editing, production, payment, business management, analytics, content management, indexing, archiving, or marketing services; and (ii) who are required to comply with applicable privacy laws;
* Where you voluntarily provide information in response to an advertisement from a third party;
* Where third party has provided you with access to a SmallTownPapers product or service through an integration or access code, information may be shared regarding your engagement with the service or product, results of assessments taken and other information you input into the product or service;
* Where you participate in a program in which we partner with third parties, we may share your information with those third-party partners;
* Where all or substantially all of the business or assets of SmallTownPapers relating to our services are sold, assigned, or transferred to another entity; or
* Where, even if not described above, you have consented to such disclosure or SmallTownPapers has a legitimate interest in making the disclosure.
SmallTownPapers also may disclose navigational and transactional information in the form of anonymous, aggregate usage statistics and demographic information that does not reveal your identity or personal information.
We will use appropriate physical, technical and administrative safeguards to protect your data. Access to your personal data will be restricted to only those who need to know that information and required to perform their job function. In addition, we train our employees about the importance of maintaining the confidentiality and security of your information.
As is true of most web sites, we gather certain information automatically. This information may include IP addresses, browser type, Internet service provider ("ISP"), referring/exit pages, the files viewed on our site (e.g., HTML pages, graphics, etc.), operating system, date/time stamp, and/or clickstream data to analyze trends in the aggregate and administer the site.
You have the right to make a written request to be informed whether or not we hold or process any of your personal information (by emailing privacy@stpArchive.com). In your written request, you may:
* Request that we provide you with details of your personal information that we process, the purpose for which it is processed, the recipients of such information, the existence of any automated decision making involving your personal information, and what transfer safeguards we have in place;
* Request that we rectify any errors in your personal information;
* Request that we delete your personal information if our continued processing of such information is not justified;
* Request that we transfer your personal information to a third party;
* Object to automated decision-making and profiling based on legitimate interests or the performance of a task in the public interest (in which event the processing will cease except where there are compelling legitimate grounds, such as when the processing is necessary for the performance of a contract between us);
* Object to direct marketing from us; and
* Object to processing for purposes of scientific, historical research and statistics.
Where applicable under your local laws, we will not use your personal information for marketing purposes, nor disclose your information to any third parties, unless we have your prior consent, which we will seek before collecting your personal information. You can exercise your right to prevent such processing by checking certain boxes on the consent forms we use when collecting your personal information. If at any point you wish to review or change your preferences you can use the "opt-out" or unsubscribe mechanism or other means provided within the communications that you receive from us. Note that you may still receive transactional communications from SmallTownPapers. For queries, please contact privacy@stpArchive.com.
YOUR CALIFORNIA DATA PRIVACY RIGHTS
Information About Data We Have Collected or Disclosed About You
The California Consumer Privacy Act ("CCPA") provides additional data privacy rights to California residents. You have the right to request that we provide, not more than twice every 12 months, certain information about the data we have collected or disclosed about you over the past 12 months, including:
* the categories of personal information we have collected about you;
* the categories of sources from which we have collected your personal information;
* the business or commercial purpose for collecting your personal information;
* the categories of third parties with whom we share your personal information;
* the specific pieces of personal information we have collected about you; and
* the categories of personal information that we have disclosed about you for a business purpose.
For the purposes of your rights as a California resident, "personal information" means any non-publicly available information that identifies, relates to, describes, is capable of being associated with, or could reasonably be linked with you or your household, such as biometric information or information about your location.
Disclosure of Personal Information
For certain of our business functions, we may disclose personal information for a business purpose. When we disclose personal information for a business purpose, the third party must agree to retain, use, or disclose the personal information solely for the business purpose. We prohibit the third party from selling the personal information that we provide [for a business purpose]. In the past 12 months, depending on how you interact with SmallTownPapers, we may have disclosed your information as set forth in the section above entitled "Disclosure and Sharing of Your information."
Deletion of Data
California residents also have the right to request that we delete the personal information we have collected from you (and direct our service providers to do so), except where retaining your personal information is necessary for SmallTownPapers to:
* Complete your transaction, provide a good or service you requested, or perform a contract between you and us;
* Protect you or us from security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for that activity;
* Fix errors in our systems;
* Protect your, our, or others’ right to free speech, or exercise another right provided for by law;
* Comply with the California Electronic Communications Privacy Act (California Penal Code Section 1546 and following);
* Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws;
* Use your personal information internally in a way that is reasonably aligned with your expectations based on your relationship with us or in another lawful manner that is compatible with the context in which you provided the information; or
* Comply with a legal obligation.
"Do Not Track" (for California and Delaware Residents)
Please note that we do not respond to or honor "do not track" (a/k/a/ DNT) signals or similar mechanisms transmitted by web browsers. For more information about "do not track", go to https://allaboutdnt.com/.
How to Exercise Your Rights
To exercise your rights under CCPA, you may submit a verifiable consumer request to us by email at privacy@stpArchive.com. Only you, a person registered with the Secretary of State authorized to act on your behalf, or you on behalf of your minor child may submit a verifiable consumer request. The request must provide enough information for us to reasonably verify you are, or are the authorized representative of, the person about whom we collected personal information. We cannot reply if you do not comply with the foregoing.
Links to Third-Party Web sites
Any comments, complaints or questions concerning this policy or complaints or objections about our use of your personal information should be addressed by directing your comments to SmallTownPapers data protection email privacy@stpArchive.com.