Privacy Policy

Last modified: December 8, 2020

We respect your privacy and are committed to protecting your Personal Information. “Personal Information” is information that can be used to identify you, directly or indirectly, alone or together with other information. Personal Information may include, but is not limited to, your name, physical addresses, telephone numbers, e-mail addresses, company affiliations, and associated interests. It may also include your history of transactional activities that you  participated in by using our “Services,” which include:

• Our websites, including PressHerald.com and CentralMaine.com
• Our Affiliates’ websites, including SunJournal.com, and TimesRecord.com
• Our apps, like Press Herald e-Edition, Press Herald Headlines, Kennebec Journal e-Edition, Central Maine Headlines, and Morning Sentinel e-Edition
• Our Affiliates’ apps, like Sun Journal e-Edition and Sun Journal Headlines
• Our social media channels, like Twitter, Facebook, LinkedIn, and Instagram
• Our electronic newsletters and other email communications such as transactional notifications
• Other Masthead Maine digital properties, like our YouTube channels
• The Portland Press Herald newspaper and our other print publications, like Maine Sunday Telegram, Morning Sentinel, Kennebec Journal, and Central Maine Sunday
• Our Affiliates’ print publications, like Sun Journal, Advertiser Democrat, Bethel Citizen, Franklin Journal, Livermore Falls Advertiser, Rangeley Highlander, Rumford Falls Times, The Forecasters, American Journal, Lakes Region Weekly, Times Record, Scarborough Leader, South Portland Sentry, Kennebunk Post, and Biddeford Courier
• Any of our other products or services, like podcasts, classified ads, events, contests and promotions, surveys, and the like.

This Privacy Policy aims to give you information on how we, MTM Acquisition, Inc. d/b/a Masthead Maine, Masthead Maine Press, and MaineToday Media (hereinafter “we,” “us,” or “Masthead Maine”), and our affiliated entities, including SJ Acquisition, Inc. d/b/a Masthead Maine Lewiston, Masthead Maine Distribution, and Sun Media Group; and Alliance Printers, LLC d/b/a Masthead Maine Alliance, Mainely Media, and The Alliance Press, LLC (hereinafter “Affiliates”)receive, collect, and process your Personal Information in connection with our Services.

This Privacy Policy covers the following:

• What Personal Information We Gather About You
• How We Use Your Personal Information
• With Whom We Share Your Personal Information
• Your Rights
• Data Integrity and Security
• Data Retention
• California Privacy Rights
• Children’s Online Privacy Protection
• International Transfers
• Lawful Basis for Processing
• Changes to this Policy
• How to Contact Us

1. WHAT PERSONAL INFORMATION WE GATHER ABOUT YOU

What Personal Information we collect and how we use it may vary based on your interaction with us.

1. Information You Give Us
2. For Registration: When you subscribe to any of our Services, or register for an event we host, you give us information about your identity such as your name, username, birth year, gender, marital status, title, or other basic demographic information. You may also give us contact details such as your billing address, delivery address, email address and telephone numbers.
3. For Billing: If you purchase any of our Services, you also give us bank account or credit card data.
4. For Customer Service: We may collect your Personal Information if you contact us for information or support for our Services.
5. For Participation in Promotions: If you participate in one of our promotions, prize draws, or other competitions, you may give us your Personal Information, including name, contact information, and other required information.
6. For Surveys, Feedback, Testimonials, and Exemplars: We may collect your Personal Information when you choose to engage with us in a consumer panel, survey, or otherwise give us feedback.
7. For Online Forum Engagement: You may give us your Personal Information when you engage with our Services. This may occur when you click on advertisements, interact with our social media pages, submit content, leave reviews, or otherwise enter information into comment fields, blogs, message boards, events, and other online forums sponsored by or affiliated with Masthead Maine. Please note that our online forums are public, so we recommend that you exercise care in deciding what information and content you wish to disclose. For additional information, please view the Terms of Use provided for each of our websites.
8. For Events: We may collect or receive your Personal Information when you register for or attend an event hosted or sponsored by us.
9. Information We Collect About You
   1. With Tracking Technologies: As is true with most websites and digital properties, when you interact with our electronic Services, or communicate with us by email, we may automatically collect, or facilitate the collection of, Personal Information on your interactions with us and our Services and about your equipment. For example, we may collect Personal Information by using first and third party cookies, Flash cookies, HTML5 local storage, server logs, web beacons, clear gifs, and other similar technologies. We use these automated technologies and the Personal Information collected for different purposes.

Additionally, when you access our Services, we may collect technical data such as your:

• • • Internet protocol (IP) address
    • Internet service provider (ISP)
    • Login data
    • Browser type and version
    • Browser language
    • Referring/exit pages
    • Operating system and platform
    • Date/time stamp
    • Clickstream data
    • Time zone setting
    • Basic geolocation
    • Device type
    • Unique device identifiers
    • Browser plug-in types and versions
    • Other technology on the devices you use

We combine this data with other information we collect about you.

1. 2. With GPS Technologies: If you are using one of our mobile apps and have authorized the location feature within the app, we will collect information regarding your precise geolocation.
   3. Information Collected by Third Parties: Some third-party advertising network services we contract with may use cookies to identify you or they may use the behavioral retargeting technique, i.e. displaying ads tailored to your interests and behavior, including those detected outside our Services. Our Services may also be linked to sites or apps operated by third parties, and may carry advertisements or offer content, special offers, functionality, games, or applications developed and maintained by third parties (“Linked Services”). These third-party Linked Services may use automated means to collect information about you and your use of these features. We are not responsible for the privacy practices of third parties and, once you leave our Services, or click an advertisement or sign up for a special offer, you should check the privacy policy of that third-party provider.

We may also obtain information about you from our third-party marketing partners (“Marketing Partners”), other companies that have your permission to share information about you, as well as from other online and offline sources. We may combine that information with information that we collect directly and indirectly from you.

2. HOW WE USE YOUR PERSONAL INFORMATION

We use your Personal Information in several different ways:

1. To Provide, Measure, and Improve our Services: We may use your Personal Information to:
   • Maintain, support, personalize, and improve our Services
   • Deliver and provide the requested Services
   • Communicate with you about those Services (including to request feedback)
   • Request your participation in surveys
   • Discuss your account or renew your subscription
   • Comply with and enforce contractual obligations
   • Provide customer service, including responding to your feedback, questions, and complaints
2. To Provide Relevant Information about Masthead Maine Services that may be of interest to you: We provide you with information about our Services that may be of interest to you, such as major changes to our Services, an upcoming event, or other marketing communications on our behalf. We may also share your information with our Affiliates for these purposes.
3. To Deliver Targeted Advertising from Masthead Maine and Our Partners: We may use any of the Personal Information and other data we collect to assist us in delivering relevant, personalized advertisements to you on any of our Services or on third party sites. This may include the use of cookies to help us collect your technical, usage, and profile data. You can learn more about cookies in our cookie policy here.
4. To Provide Location-Specific Content and Advertising: If you have authorized us to collect information regarding your precise geolocation using your mobile or electronic device, we may use that information to provide you with content, Services, offers, or advertising through your app or device that are relevant to your precise location.
5. Participating in Promotions: We may use your Personal Information to administer promotions as well as communicate with you about the same. For example, we may need to use your name, age, birth year, contact information, and other Personal Information to comply with the rules and legal requirements governing the promotion and to verify participants and the winner’s identity.
6. Testimonials and Exemplars: We may use reader testimonials or exemplars in or on our websites, publications, or other Masthead Maine marketing materials, which may require the inclusion of Personal Information, such as your name, photograph, or other identity or profile data.
7. To Monitor Usage, Trends, and Experience: Like many websites, our Services use cookies and other tracking technologies in order to function effectively and deliver certain features. We use first and third party cookies, Flash cookies, HTML5 local storage, server logs, web beacons, clear gifs, and other similar technologies for different purposes. For example, some are strictly necessary for the core functionality of our Services, including performance analytics, personalization, and to provide secure Services, and are automatically deployed. If you subscribe to any of our Services, we use cookies to identify you when you visit one of our websites so that you can be automatically logged in. These cookies also help us know where you have indicated certain cookie and advertising preferences, including refusals, to ensure your preferences are honored.

We also use functional cookies and technologies to help us improve our Services, as well as reader relationships and experiences. For example, we may use third party applications and automated technologies, like Google Analytics, to determine how often our readers access or read our content, so we can enhance our Services, provide the most interesting content, and gain readership.

1. Marketing Research/Statistics: We may use your Personal Information to help us and our Marketing Partners generate business and research and develop new products, services, updates, or the like on our behalf. For example, we may analyze statistical, demographic, and marketing information for product development purposes and to understand usage and traffic trends to grow our readership and to improve our relationship with you. We may also use certain data about you obtained from third party sources, including our Marketing Partners or other vendors, consultants, and Service Providers, to help us provide and improve our content, products, services, websites, and digital properties, as well as for marketing and advertising. We may combine that data with information we obtain from our products, services, digital properties, other users, or third parties to enhance your experience and improve our content, products and services.
2. Government Reporting/Audit/Requests Requirements: We may use or share Personal Information to satisfy governmental reporting, tax, and other requirements, as required by law.
3. To Verify and/or Authenticate an Identity, Access Rights, Privileges, etc.: We may use Personal Information to verify your identity and allow you to access your subscription, account, or account information.
4. As Required by Law or Legal Process: We may use or preserve your Personal Information if we are required to do so by law or we have a good faith belief that such action is necessary to comply with the law or legal process or to protect our legal rights. We may also disclose your Personal Information for the same reasons, further described below.

3. WITH WHOM WE SHARE YOUR PERSONAL INFORMATION

1. Within the Masthead Maine Network: We share Personal Information among our Affiliates for the purposes listed in this Privacy Policy.
2. Service Providers: We contract with other companies and vendors (“service providers”) to provide services on our behalf. These services include:

• Credit card processing
• Fulfillment of orders
• Database management
• Email distribution
• Customer service
• Ad serving
• Marketing communications
• IT infrastructure
• Processing and analytics
• Promotion management

In the course of performing these services, our service providers may have access to your Personal Information.

1. Marketing and Advertising Partners: We share Personal Information with third parties, such as Facebook, for marketing and advertising purposes. These third parties use the Personal Information to help us promote our Services through targeted advertisements.
2. Third Party Advertisers: We may share aggregated behavioral data with third party advertisers or sponsors in order to support and grow our business and journalism as well as bring you relevant content, information, and advertisements. For example, we may share information with advertisers about the interests and habits of our subscriber base and the number of people that have viewed a particular ad or visited a particular webpage. We may also publish aggregate summary information about our readers or online visitors for promotional purposes or share aggregated results from research surveys or panels.
3. Other Third Parties: We will not sell, rent, swap, or authorize any third party (other than our service providers) to use your Personal Information without your permission.  However, nothing in this Privacy Policy is intended to restrict our use or sharing of aggregated or de-identified information in any way.

If you attend an event we sponsor with a third party, we may share your Personal Information with that third party, for example so they have an attendance list, or if they need to contact you with event details. We will not share your information with them for their marketing purposes without your consent, which may be obtained at the time of your registration or through a supplemental privacy policy but will not be required in order to attend.

We may also share Personal Information with third-party sponsors of sweepstakes, contests, and similar promotions, in which case we will let you know at the point of collection of your information if your Personal Information will be shared.

In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of any portion of our business, assets, or stock, we may disclose Personal Information to third parties, such as an acquiring entity and its advisors.

We may disclose your Personal Information if we are required to do so by law or we have a good faith belief that such action is necessary to:

• Comply with the law or with legal process, such as to comply with a court order or subpoena
• Protect and defend our rights and property
• Protect against misuse or unauthorized use of the Services
• Protect the personal safety or property of our users or the public. This means, among other things, that if you provide false information or attempt to pose as someone else, information about you may be disclosed as part of any investigation into your actions.
• Cooperate with public and government authorities, both domestically and internationally, as the case may be.

4.  YOUR RIGHTS

You can ask us for a copy of any Personal Information we have collected about you or ask us to delete your Personal Information by emailing us at privacy@mainetoday.com. However, deletion of your Personal Information may affect our ability to service your account, and applicable laws or regulations may require that we keep such information even after you ask us to delete it. Additionally, you can complete this form to request that that we not engage in any direct sale of your Personal Information.

Some of the advertisements on our Services are placed by third party advertising companies, who may place separate cookies on your computer that we cannot access or control. You can control your consent to cookies through your browser settings. You can choose to accept all cookies, reject all cookies, or be notified when a cookie is being delivered so that you can make a decision whether to accept each cookie on a case-by-case basis. If you refuse all cookies, our websites will no longer remember you when you return, which means that you will have to log in each time you visit. Additionally, if you decline or delete these cookies, some parts of our websites may not work properly.

For more information about our use of cookies and how you can manage your settings, please see our cookie policy here. In addition to disabling cookies and other tracking technologies, you may opt-out of receiving targeted advertising from participating ad networks, audience segment providers, ad serving vendors, and other service providers by visiting websites operated by the Digital Advertising Alliance. You can also opt out of the disclosure of your Personal Information to third party ad networks by clicking here: Do Not Sell My Personal Information.

Additionally, you can make changes to your account information by logging into your account on the applicable website or app, and you may unsubscribe from our emails or change your email preferences by following the links at the bottom of the communication.

5. DATA INTEGRITY AND SECURITY

We have implemented commercially appropriate organizational, technological, and physical safeguards to maintain the security of your Personal Information. Although we take appropriate measures to safeguard your Personal Information, no security method is absolute. To further protect your data, we recommend that you use complex, unique passwords for any accounts you maintain with us and any linked third-party accounts, and that you not share those passwords with unauthorized people. If you have reason to believe that an account you have created with us is no longer secure, please contact us at privacy@mainetoday.com.

6. DATA RETENTION

We will only retain your Personal Information for as long as needed, or permitted, based on the reason we obtained it. For example, we will keep your Personal Information while we provide you with Services, and for the purposes of satisfying any legal, accounting, or reporting requirements. This means we might store your personal information even after you close your account with us.

To determine the appropriate retention period for Personal Information, we consider:

• The length of time we have had an ongoing relationship with you and provided Services to you (for example, for as long as you have an account with us);
• Whether there is a legal requirement requiring that we retain records of a transaction with you; or
• Whether data retention is sensible considering applicable statutes of limitations, pending or ongoing legal disputes, or regulatory investigations.
• In some circumstances we may anonymize your Personal Information (so that it can no longer be associated with you) for research or statistical purposes in which case we may use this information indefinitely without further notice to you.

If you wish to cancel your account with us, you can do so through the “My Account” section of the applicable website or by contacting us at privacy@mainetoday.com.

7. CALIFORNIA PRIVACY RIGHTS

If you are a California resident, under the California Consumer Privacy Act of 2018 (CCPA), you have the right to:

• Request disclosure of your Personal Information that we have collected and/or shared;
• Request that we delete Personal Information that we have collected about you;
• Opt out of the sale of your Personal Information to third parties; and
• Not receive discriminatory treatment by us for exercising your legal rights.

You can request disclosure or deletion of your Personal Information by emailing us at privacy@mainetoday.com or calling us toll-free at (800) 442-6036.

1. Categories of Data Collected: The following are the categories of Personal Information we have collected from users of our Services, sold, and/or disclosed for a business purpose in the last 12 months:
   1. Identifiers — including name, address, email address, account name, IP address, cookie ID, mobile advertising ID, and an ID number assigned to your account (collected, sold, and disclosed).
   2. Other personal information — including phone number, billing address, credit or debit card information, employment or education information (collected, sold, and disclosed).

This category includes personal information protected under preexisting California law (Cal. Civ. Code 1798.80(e)) and overlaps with other categories.

3. Demographic and legally protected information — including your age, gender, and any protected classification characteristic under pre-existing California or federal laws you may voluntarily express when interacting with our Services, such as in comments on articles (collected and disclosed).
4. Commercial information on your interactions with our Services — including your payment information and history of your purchases from us (collected and disclosed).
5. Internet or other electronic network activity information — including browsing activity on our sites and apps, browser type, browser language, and other information regarding your interaction with our sites, apps, advertisements, and social media (collected and disclosed).
6. Geolocation data — including what may be determined by GPS, IP address, and other data from sensors on or around your device, depending in part on your device and account settings (collected).
7. Audio, electronic, visual (collected)
8. Professional or employment-related data — as part of our group subscriptions and when provided by you (collected).
9. Education information — as part of our group subscriptions and when provided by you (collected).
10. Inferences drawn from any of the above personal information to create a profile about you reflecting your preferences, characteristics, predispositions, behavior, and attitudes as they relate to our Services (collected and disclosed).

1. Notice of Your Right to Opt-Out of Sale of Personal Information:

Under the CCPA, “selling” of data means any transfer or disclosure for a benefit, even if not in exchange for payment. You have the right, at any time, to direct that we not sell your Personal Information to third parties. You can make this request by clicking here: Do Not Sell My Personal Information.

1. California “Shine the Light” Law

Additionally, if you are a California resident, you have the right, under California Civil Code Section 1798.83, to request and obtain from us, once a year and free of charge, a list of the third parties to whom we have disclosed Personal Information for their direct marketing purposes in the prior calendar year and the categories of information disclosed. Please email requests for such information to privacy@mainetoday.com with the subject line: “California ‘Shine the Light’ law.”

8. CHILDREN’S ONLINE PRIVACY PROTECTION

Our Services are not designed or intended for children under the age of 13. In accordance with the Children’s Online Privacy Protection Act, we do not knowingly collect or store any Personal Information for children under the age of 13. If you are under 13, please do not provide us any personally identifying information. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, please contact us at privacy@mainetoday.com. We will remove the data to the extent required by applicable laws.

9. INTERNATIONAL TRANSFERS

Masthead Maine is headquartered and operates in the United States, and many of our external third parties are based outside the EU/EEA. In order to perform our contractual obligations with you, if any, as well as for operational and other legitimate interest reasons, we may process, store, and transfer Personal Information in a country that may be outside of your own, such as the United States. “Legitimate interest” is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are valid business reasons for the processing of your Personal Information, such as fraud prevention, ensuring network and information security, or indicating possible criminal acts or threats to public security. “Legitimate interest” also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact. By providing us with your Personal Information you acknowledge such transfer of information out of your jurisdiction.

10. LAWFUL BASIS FOR PROCESSING

Regardless of where you live, we will only use your Personal Information when the law allows us to. Generally, we will not collect or access any Personal Information other than under the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.
• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.
• Where we need to comply with a legal, regulatory, or self-regulatory obligation.

We may also collect or access Personal Information with your consent.

Note that we may process your personal data for more than one lawful reason. Please contact us if you need additional details about the specific legal basis we are relying on to process your personal data.

Where we rely upon your consent to process the Personal Information, you have the right to withdraw or decline your consent at any time. Generally we do not rely on consent as a legal basis for processing your Personal Information other than in relation to sending third party direct marketing communications to you via email. You may withdraw consent to marketing at any time by contacting us at privacy@mainetoday.com, withdrawing your consent for the placement of certain cookies, or by clicking the unsubscribe link in the marketing email. Please note that this does not affect the lawfulness of the processing based on consent before its withdrawal.

We recognize and respect that your privacy and Personal Information is important, and that under certain circumstances you can make decisions about the Personal Information collected by us. Please keep in mind, though, that if you decide to not provide information required by us in order for us to provide a service or product, your use of our Services may be limited or impossible.

11. CHANGES TO THIS PRIVACY POLICY

We reserve the right to update this Privacy Policy from time to time considering changes business practices, technology, and legal requirements. If we make any significant or material change to this Privacy Policy, we will notify you by email (if you have given us your email address) or by posting a notice of the change to this site prior to making the change. If you object to any change, you can stop using our Services. After we post any changes on this site, your continued use of the Services is subject to the updated Privacy Policy.

12. HOW TO CONTACT US

If you have any questions or concerns about this Privacy Policy, please contact us via email at privacy@mainetoday.com or via mail at: Masthead Maine, 295 Gannett Drive, South Portland, Maine 04106.