Privacy Policy

Effective Date: January 1, 2020

The Washington Times LLC (“TWT”, “we” or “us”) recognizes the importance of protecting the information it collects from users in the operation of its Web site, washingtontimes.com (“TWT’s Web site”), The Washington Times Digital Edition, and other related digital products or resources of TWT including email newsletters, (collectively referred to hereinafter as “TWT Digital Products”), as well as other activities. As such, TWT takes reasonable steps to maintain the security, integrity and privacy of this information.

TYPES OF INFORMATION WE COLLECT

The information we gather falls into two categories: (1) information voluntarily supplied by visitors to the site when they register, sign up to receive our email newsletters, subscribe to the print and/or digital editions, post comments in any of the public posting areas on our site, respond to user surveys, participate in interactive activities such as polls, or view more information about a story, and the like; and (2) anonymous tracking information that is automatically gathered as visitors navigate through our site and review our email newsletters and other email messages.  This information may be collected directly by us or it may be collected by third-party partners or service providers on our behalf.  Third parties featured on or linked to by our Web site, such as advertisers and others that display promotional messages on our site or offer products and services through our site (“Advertisers”), may be gathering information as well, through processes we don’t control.

 Information You Voluntarily Supply to Us

We may collect and store information that you voluntarily supply to us while on our site.  This may include personally identifying information if you choose to provide it.  In accessing and using TWT’s Web site, you may have the opportunity to voluntarily submit some or all of the following types of information:

• Contact information, such as your name, telephone number, postal mailing address and email address;
• Delivery information, such as your newspaper delivery address;
• Demographic information, such as gender, country (and, where applicable, your postal code);
• Login information, such as a username and password;
• Communications preferences, such as which email messages you would like to receive from us;
• Payment information (such as a credit card number or bank account information) necessary to process a requested transaction; and
• Information posted in public posting areas and other interactive areas of our site.

You are not required to provide information about yourself to visit our site.  However, if you wish to receive any of our newsletters, you will be required to provide us the email address to which you want us to send the newsletters as well as your name, the country in which you reside, and, where applicable, your postal code.  If you wish to participate in any of the interactive features of our site – for example, by posting comments, voting in a poll, viewing additional information about a story, or viewing premium content, you may be required to register with Spot.IM.  When you register with Spot.IM, you’ll be asked for your email address or Web site address.  You’ll also have to provide a username and a password. With Spot.IM you have the choice of registering your account with an email address, or by using your Facebook, Google, Twitter, or Disqus credentials. You may view Spot.IM’s privacy policy at https://www.spot.im/disclaimer/privacy/index.html.

Information That Is Collected Automatically

We also may collect and store, and permit our service providers to collect and store, information that does not identify you personally that is generated automatically as you navigate through the site.  For example, we and our service providers may collect limited information about the configuration of your computer or other device through which you visit our site, including the type of browser software you use, the operating system you’re running, the resolution of your computer monitor, the Web site that referred you, the type of mobile device you’re using to access our site (for example, iPad, iPhone, BlackBerry, Android device, tablet, etc.), and your IP address.  (Your IP address is a numerical address that is used by computers connected to the Internet to identify your computer so that data – such as the Web pages you want to view – can be transmitted to you.  We also use IP address information for systems administration and troubleshooting purposes.)  We use this information to make our site as useful as we can for as many users as possible.

 Cookies and Pixel Tags

We may use “cookies,” a standard feature found in browser software, to enhance your experience on the site.  Cookies are small files that your Web browser places on your hard drive for record-keeping purposes.  We also may use pixel tags (sometimes referred to as “clear GIFs” or “Web beacons”) to collect non-personally identifying information about how our visitors use our site.  By showing how and when visitors and registered users use the site, cookies and pixel tags help us deliver more relevant content to users, identify how many unique users visit our site and various pages within our site, and anonymously track user interests, trends and patterns.  For example, we may use these technologies to collect aggregate information about the time visitors spend on each page of our site, the number of visits made to each page or section of our site, and the content that visitors select and copy using the standard copy and paste tool provided in standard Web browsers.  Providers of web analytics services may use cookies and pixel tags to gather this sort of information on our behalf.  And Advertisers that display ads or other promotional messages (“Ads”) on our site (and their providers of ad serving and other advertising services) may use cookies and pixel tags of their own in connection with Ads displayed on our site, as described below under the heading “Data Collected in Connection with Ads.”  

Providers of email transmission services use pixel tags to record whether an email is opened and whether you click on any of the links in the email, as described below under the heading “Data Collected in Connection with Emails.”

We also may use cookies to record certain preferences that you enter or set while using the site.  For example, if you are a registered user and you opt to have the site “remember you,” we’ll use cookies to automatically store your log-in information so that you won’t have to re-enter it the next time you visit.

The help function on most Web browsers contains information on how to set your browser to notify you before accepting a cookie or to disable cookies entirely.  However, if you don’t accept cookies, you won’t be able to take advantage of various features on our site that are available to other visitors.  For example, we won’t be able to store your log-in information, so that you don’t have to log in each time you visit, unless you accept cookies. 

HOW WE USE COLLECTED INFORMATION

Generally

We use the information we collect from you while you are using the site in a variety of ways, including, for example, to process your registration, to provide you with services and communications that you have requested, to send you email updates, newsletters, and other communications which you have elected to receive, to deliver our site content to you, to measure site traffic, to measure user interests and traffic patterns, and to improve the site and the services and features offered via the site.

 Your Email Address

In addition, we may use your email address to contact you for customer service purposes, to inform you of important changes or additions to our site or the services offered over our site, to send you administrative notices and other information about our site, and to tell you about other products or services offered by TWT, or other companies, that we think may be of interest to you.  If you subscribe to any of our newsletters, we’ll use your email address to send the newsletters to you.  Although we hope you’ll find these communications informative and useful, if you don’t, you can always unsubscribe to either type of message by following the simple instructions included in each email.

 Information You Provide When Making a Purchase

When you purchase any product or service on our site, we collect the information necessary to process the requested transaction, such as your name, email address, mailing address, billing address, and credit/debit card or PayPal account information.  Your credit/debit card information is sent to our third-party credit card processor and is secured during transmission over the Internet using industry-standard secure sockets layer (SSL) encryption.  Our credit card processor is authorized to use your credit/debit card information only to process your requested transaction, and for no other purpose.

 Data Collected in Connection with Ads

Advertisers that display Ads on our site (and other advertising services) may use cookies and pixel tags of their own to record your Web browser’s interaction with a given Ad.  This technique allows the Advertiser (and its providers of ad serving and other advertising services) to track how Ads are displayed, and which are clicked on, and to limit the number of times a given Ad is shown to you.  The use of cookies and pixel tags may also enable these Advertisers (and their providers of ad serving and other advertising services) to serve ads to our users based on their perceived interests as gleaned from their visits to this and other Web sites.  For example, DoubleClick, a provider of ad serving and other advertising services, may set cookies in connection with Ads displayed on our Web site through our relationship with Google.  For a detailed description of Google’s interest-based advertising program, or to opt out of receiving interest-based ads from Google, click here.

 Similarly, LiveRamp, another provider of advertising services, may set cookies in connection with Ads displayed on our Web site, and may use behavioral targeting methods to select which ads to display. These cookies contain no personally identifiable information.  The cookies may reflect de-identified demographic or other data linked to data you voluntarily have submitted to us, e.g., your email address, which we may share with a data provider solely in hashed, non-human readable form. To opt-out of these data provider cookies, please go to: http://optout.aboutads.info/. Another provider of advertising services, Nativo, may collect certain information, through the use of cookies, about the Web site and its users. To opt-out of this data collection please go to: https://www.nativo.net/. Another third-party vendor who processes personal data on our behalf is Connatix. You may view Connatix’s privacy policy at https://connatix.com/privacy-policy.

  If you supply us with your postal address on-line you may receive periodic mailings from us with information on new products and services or upcoming events. If you do not wish to receive such mailings, please let us know by e-mailing us at privacypolicy@washingtontimes.com. If at any point you wish to access your personal information to (1) change your preferences, (2) review the accuracy, (3) correct, supplement, modify or delete your information or opt-out of your consent to use your information, you may either send an e-mail to privacypolicy@washingtontimes.com, call 1-888-442-6397 or send a written request to:

The Washington Times LLC, Attn: Privacy Policy/ Data Protection Officer, 3600 New York Avenue, NE, Washington, D.C., 20002

Data Collected in Connection with Emails

Email newsletters you elect to receive from us are transmitted through Boomtrain, a Zeta Global Company. Boomtrain uses pixel tag technology to determine whether an email has been opened. In addition, when you click on any link in an email newsletter or marketing message you have elected to receive, Boomtrain recognizes that fact. This information is used in the aggregate to measure the rate at which emails are opened and various links are clicked, to measure user interests and traffic patterns, and to improve the content of the email newsletters and the services and features offered through the email newsletter and marketing messages.

Because some of this information is linked to individual email addresses, it is personally identifiable. You can view Boomtrain/ Zeta Global’s privacy policy at https://zetaglobal.com/privacy-policy/. Our email newsletters contain advertisements, some of which are supplied by a company named LiveIntent, and are from companies that comply with the Digital Advertising Alliance Principles and the Newspaper Association of America, as well as the Network Advertising Initiative and the Online Behavioral Advertising self-regulatory program. LiveIntent is the first email ecosystem company to implement AdChoices. AdChoices is a self-regulatory system that gives the user the ability to:

1.    See who served the ad

2.    Read the LiveIntent Privacy Policy

3.    Opt-out of cookie based portion of LiveIntent’s advertising program

To see LiveIntent’s privacy policy, click here.

 Disclosure to Third Parties

To help Advertisers (and their ad agencies) understand our audience and confirm the value of advertising on TWT’s Web site, we may present them with aggregate information on our audience and how our audience uses our site (for example, information on traffic to various pages within our site).  This information does not identify you personally. 

We may share the information that is collected through this site with our third-party service providers for purposes related to site administration and operation.  In some cases, we may permit our third-party service providers to collect such information directly, on our behalf.  For example, this Web site may use third-party Web analytics services to help analyze how users use the site.  These services may use cookies and pixel tags to collect non-personally identifying tracking data directly from our site on our behalf, and then use that data to provide us with statistical reports on Web site activity.  If you use a credit or debit card to complete a transaction on our site, your personal information and credit card number will be sent directly to our credit card processing service provider to complete your transaction.  We also may share your email address and name with third-party email services providers that send newsletters and other communications on our behalf.

We also may occasionally release information about our visitors and registered users if required to do so by law or if, in our judgment, such disclosure is reasonably necessary to comply with legal process, or to protect the rights, property, or personal safety of visitors to our site, our employees, our donors, sponsors or Advertisers, or others.  In the unlikely event that we sell some or all of our assets, information about visitors to our site may be among the transferred assets.

 Information You Post to Public Areas of Our Site

If you post a comment on our site or otherwise submit content for display in a public posting area of our site, we will identify you as the author of your posts by your username only. 

Please keep in mind that whenever you make your personal information or other information available for viewing by other users online – whether in comments posted to our site, or in other public posting areas of our site – that information can be seen, collected and used by anyone with access to the Internet; we are not able to control how they may use this information.  We cannot be responsible for any use of such information by third parties. We also reserve the right to eliminate any offensive or inappropriate comments you may post.

 Storage of Information

The information that we collect through TWT’s Web site is stored within databases that we control (or databases hosted on our behalf) on servers maintained in protected environments within the United States.  Any credit card information you provide on our site is secured for transmission over the Internet using industry-standard secure sockets layer (SSL) encryption.  However, no physical or electronic security system is impenetrable.  We cannot guarantee the security of our servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted to us or our third-party service providers over the Internet.

GDPR Compliance

The General Data Protection Regulation (“GDPR”), which took effect on May 25, 2018, is a new version of the existing data protection laws defined and enforced by the European Union. The GDPR imposes new rules regarding the processing of personal data of data subjects’ located in the EU. TWT is fully committed to comply with GDPR since its effective date.

We may engage secure third-party companies to store or process your personal data in the United States or in other countries. If you are a resident of the European Economic Area (“EEA”) we will take appropriate measures to ensure that your personal data receives an adequate level of data protection upon its transfer outside of the EEA. If you are a resident of a jurisdiction where transfer of your personal data requires your consent, then your consent to this Privacy Policy includes your express consent for such transfer of your data.

CALIFORNIA PRIVACY COMPLIANCE

The California Consumer Privacy Act (“CCPA”) which took effect on January 1, 2020, givesCalifornia residents new rights regarding how certain companies may handle their “personal information” (as defined by CCPA). Although it has not been confirmed that CCPA applies toTWT, out of an abundance of caution, TWT is providing compliance to the law. As detailed above, TWT may collect certain categories of personal data from users of TWT Digital Products as part of providing you with products and services. These categories may include identifiers(e.g. name, address, email address), financial data (such as credit card information), internet or internet device usage (IP address, browsing history) geolocation or other information that can be reasonably linked to you.
Under the CCPA’s broad definition of the word “sale”, TWT’s use of personal data may also include a type of “sale” to third party service providers by allowing them to receive your information through cookies, IP addresses or browsing history as part of their providing services to us. TWT’s provision of personal information such as demographic, geographic and personal identifiers may be used by third parties to provide targeted advertising. If you would like to know about your personal information involved in these activities or if you would like to opt-out of TWT’s “sale” of your personal information please fill out the form located at washingtontimes.com/CCPA or send an email to privacypolicy@washingtontimes.com. Once a year, subject to certain limitations, California residents may request we provide you with the types of personal information being received from you, allow you to access such information and permit you to delete certain personal information. To begin this process please email privacypolicy@washingtontimes.com stating your request.

PROTECTING THE PRIVACY OF CHILDREN

Children should always get permission from their parents before sending any information about themselves (such as their names, email addresses, and phone numbers) over the Internet, to us or to anyone else.  Our Web site is not directed at children under the age of 13 and we won’t knowingly allow anyone under the age of 13 to provide us any personal information.  If you’re under 13, please don’t provide any information about yourself on this Web site. 

 CHANGES TO THIS PRIVACY POLICY

The Web is an evolving medium.  If we need to change this Privacy Policy in the future, we will post the revised Privacy Policy on our site and update the “Effective Date,” above, to reflect the date of the changes.  By continuing to use this Web site after we post such changes, you agree to the terms of this Privacy Policy, as modified.