Who We Are
Collection and Use of Personal Data
Personal Data We Collect
We may collect and process information that relates to identified or identifiable individuals (“Personal Data”). We collect and process the following categories of Personal Data (note, specific Personal Data elements listed in each category are only examples and may change):
Personal Data about you and your identity, such as your name, and other Personal Data you may provide on various forms or in an account profile (e.g. biographical information).
Contact Data: Personal Data used to contact an individual, e.g. email address, physical address, phone number, or social media or communications platform username, as well as a name or other salutation.
Device Data: Personal Data relating to your device, browser, or application e.g. IP addresses, MAC addresses, application ID/AdID/IDFA, session navigation history and similar browsing metadata, and other data generated through applications and browsers, including cookies and similar technologies.
Personal Data relating to your preferences, interests, personal demographics (e.g. location of residence, age group, gender, etc.), your “likes,” and other information provided to us via social media services and advertising technologies, including any other categories of information (such as Transaction Data or Identity Data linked to such information).
Comments or other content that a user provides in any free-text or unstructured format, as on a Contact Form (this may include Personal Data to the extent provided by the user).
Processing of Personal Data
In addition to processing each category of data in connection with marketing communications, behavioral advertising, and to improve our Digital Services, Personal Data may be processed for the following purposes.
Data: You may be able to register and create an account on our Digital Services. Registration is optional in most cases. If you choose to register, we will process Identity Data, Preferences Data, and Contact Data.
Uses: We use the Identity Data and Contact Data as necessary to create, maintain, and provide you with important information about your account.
Marketing Communications and Newsletters
Data: We may process Identity Data, Device Data, Preferences Data, and Contact Data when you are enrolled to receive, and when you open or interact with, our electronic marketing communications and newsletters.
We use Identity Data and Contact Data as necessary to provide marketing communications, when you consent to receive those messages, or consistent with our legitimate business interests. See Your Rights and Choices for information about how you can limit or opt out of this processing.
Special Promotions and Offers
We use this Identity Data and Contact Data as necessary to carry out special promotions and related transactions.
We process Identity Data, Contact Data, and any other data in or relating to your User Content if you choose to submit User Content (e.g. contact forms, posts on message boards, etc.) through our Digital Services.
Subject to Your Rights and Choices, we may use Identity Data and Preferences Data to create a personalized user experience.
We generally process the Identity Data, Contact Data, and Device Data as necessary to create your account, deliver the Digital Services and fulfill your requests.
Specific Processing Purposes
Cookies and Similar Technologies
We, and certain third parties, may process Identity Data, Contact Data, Preferences Data, and Device Data when you interact with cookies and similar technologies on our Digital Services. We sometimes receive this data from third parties, and the privacy policies of third parties may apply to these technologies and information collected.
Subject to Your Rights and Choices, we and our third party partners use:
Device Data for “essential” or “functional” purposes, such as to enable various features of the Digital Services or keep you logged in during your session, or;
Device Data for “analytics” purposes, consistent with our legitimate interests in how the Digital Services are used or perform, how Users engage with and navigate through the Digital Services, what sites Users visit before visiting our Digital Services, how often Users visit our Digital Services, understanding User behaviors and improve the design and functionality of the website, and other similar information; and
Identity Data, Contact Data, Preferences Data, and Device Data for “retargeting” and/or behavioral advertising purposes, so that you can see advertisements from us on other websites and ads that are more relevant to you based on content you have viewed.
Subject to your consent where required by law, we, and certain third parties operating on or through our Digital Services, may engage in online behavioral advertising. This form of advertising includes various parties and service providers, including third party data controllers, engaged in the processing of Personal Data in connection with advertising. This form of advertising uses Preferences Data, Device Data, Identity Data, and at times, Contact Data in order to deliver more relevant advertising to you. The parties that control the processing of Personal Data for behavioral advertising purposes may build a profile of you containing this information, and may be able to identify you across sites, devices, and over time. These services may also track whether you view, interact with, or how often you have seen an ad, or whether or not you complete a purchase for goods or services you were shown in an advertisement. These tracking technologies may also be used to help limit the number of times you see the same ads, or help determine whether you have interacted with or viewed ads delivered to you.
Processing of this data takes place on our Digital Services, on third-party websites that participate in ad networks, and through other services providers. Third party companies, for example social media companies, may also collect this information via third-party social media cookies, or when you share information using a social media sharing button or “like” button on our Digital Services or you link your account or engage with our content on or through a social networking website such as Facebook or Twitter.
In some cases, the third parties described above may also develop and assess aspects of a profile about you to determine whether you are a type of person a company wants to advertise to, and determine whether and how ads you see are effective, and may augment your profile with information derived from observations about you on other websites.
See Your Rights and Choices for information about how you can limit or opt out of this processing.
Consistent with our legitimate business interests, we may personalize our Digital Services. To do so, we may link together and analyze the Personal Data that we hold about you, which may be augmented with Preferences Data. We may create Preferences Data, or obtain it from third parties, using Personal Data we hold about you. We process Preferences Data so that our communications and Digital Services are more relevant to you. For example, we may greet you by name, provide better recommendations to you, tailor content and communications to your interests, and use the information to guide overall improvements to our products and services. See Your Rights and Choices for information about how you can limit or opt out of this processing.
Consistent with our legitimate business interests, we (or if appropriate, our affiliates or trusted third parties) may send you marketing and promotional communications (including if you sign up for such communications, purchase products or services from us or an affiliate, register on our Digital Services or for a promotion or contest with us or a partner, in connection with your communications with, or submission of User Content to, us, or otherwise as allowed by law). These communications may be personalized. See Your Rights and Choices for information about how you can limit or opt out of Marketing Communications.
Information we collect may be shared with a variety of parties, depending upon the purpose for and context in which that information was provided. We generally transfer data to the following categories of recipients:
In connection with our general business operations, product/service improvements, to enable certain features, and in connection with our other legitimate business interests, we may share your Personal Data with service providers who provide certain services or process data on our behalf.
In order to streamline certain business operations, improve personalization, share promotions and content we believe would be of interest to you, and develop products and services that better meet the interests and needs of our customers, we may share your Personal Data with any of our current or future affiliated entities, subsidiaries, and parent companies.
Partners: We may share your Personal Data with business or marketing partners in connection with promotions, events, products, and services that are promoted, managed, supported, or otherwise undertaken with that third party. If appropriate, these parties may engage in direct marketing or behavioral advertising.
Marketers: In order to improve personalization, deliver more relevant information and advertisements to you, and develop better products and services, we may share certain Personal Data with our affiliates and trusted third parties for marketing, advertising, or other commercial purposes, and we may allow our affiliates and other third parties (such as Facebook, ad exchanges, data management platforms, or ad servers) to operate on our Digital Services and process data for behavioral advertising.
The American Digest uses Personal Data and Monitoring Data it collects for editorial and feedback purposes, and to deliver relevant advertising, statistical analysis of users’ behavior, product development, delivering products and services, providing customer support, customizing and improving the content and layout of newsletters, completing business transactions, processing applications for employment, for marketing purposes, to maintain the security of our Sites, and as otherwise disclosed at the time of collection or use. Monitoring Data may be used for internal or external purposes such as researching and identifying market segments and needs, and marketing and promotion.
The American Digest may share data with service providers, partners, affiliates, and subsidiaries, including with these other businesses and all of their subsidiaries: Conservative Institute, Main Street Gazette LLC, and Conservative Journal Review LLC.
Your Personal Data may be processed if we go through a business transition, such as a merger, acquisition, liquidation, or sale of all or a portion of our assets. For example, Personal Data may be part of the assets transferred, or may be disclosed (subject to confidentiality restrictions) during the due diligence process for a potential transaction.
We operate in and use service providers located in the United States. If you are located outside the U.S., your Personal Data will be transferred to the U.S. by necessity in order to deliver the services to you. The U.S. does not provide the same legal protections guaranteed to Personal Data in the European Union. Accordingly, your Personal Data may be transferred to the U.S. pursuant to the EU-U.S. Privacy Shield Framework, the Standard Contractual Clauses, or other adequacy mechanisms, or pursuant to exemptions under EU law.
Retention of Personal Information
We retain your Personal Information for as long as we have a relationship with you. We also retain your Personal Information for a period of time after our relationship with you has ended where there is an ongoing business need to retain it. This includes retention to comply with our legal, regulatory, tax and/or accounting obligations. We do so in accordance with our data retention policies and applicable law.
You can unsubscribe from any of our newsletters by contacting us at firstname.lastname@example.org.
We may continue to send you certain transactional email communications (e.g. emails regarding account notifications, customer support questions and similar information) regarding your use of the Site and Services.
Your Legal Rights
You have the right to:
Request a copy of the Personal Information we hold about you;
Request that inaccurate information about you be corrected or deleted;
Object to having your Personal Information processed;
Request that we delete any and all Personal Information we hold about you;
Request that we restrict processing your Personal Information;
Request that you not be subject to automated decision making including profiling; or
Receive your Personal Information in a structured, prevailing, and machine-readable form and/or have your Personal Information transferred to another controller, where technically feasible.
Our email subscribers and subscribers of paid content may access and correct their contact information on file by accessing their account online. We may not accommodate a request to change information if we believe the change would violate any law or legal requirement or cause the information to be incorrect.
Residents of California (and others as required by applicable law) may request a list of Personal Data we have disclosed about you to third parties for direct marketing purposes during the preceding calendar year. This request must be written, signed, and mailed to us.
You have the right to contact or file a complaint with regulators about our processing of Personal Data. To do so, please contact your local data protection or consumer protection authority.
It is possible for you to use some of our Digital Services without providing any Personal Data, but you may not be able to access certain features or view certain content. You have the following choices regarding the Personal Data we process, which you may exercise by contacting us or otherwise as described below:
If you consent to processing, you may withdraw consent any time, to the extent required by law.
We follow and implement reasonable security measures to safeguard the Personal Data you provide us. However, we sometimes share Personal Data with third parties as noted above, and we do not have control over third parties’ security processes. Please note, we do not warrant perfect security and we do not provide any guarantee that your Personal Data or any other information you provide us will remain secure.
We retain information for so long as it, in our discretion, remains relevant to its purpose, and in any event, for so long as is required by law. We will review retention periods periodically, and may sometimes pseudonymize or anonymize data held for longer periods, if appropriate and requested.
Our Digital Services are neither directed at nor intended for use by minors under the age of majority in the relevant jurisdiction. Further, we do not knowingly collect Personal Data from such individuals. If we learn that we have inadvertently done so, we will promptly delete it.
Our Commitment to Data Security.
We strive to make certain that our servers and connections incorporate the latest encryption and security devices. We have implemented physical, electronic, and managerial procedures to safeguard and secure the information we collect. Credit card and personal information are transmitted by secure servers (SSL). Unfortunately, no data transmission is guaranteed to be 100% secure and we therefore cannot guarantee the security of information you transmit to or from the Site, Applications, or through the use of our services, and you provide this information at your own risk. ACCORDINGLY, WE DISCLAIM LIABILITY FOR THE THEFT, LOSS, OR INTERCEPTION OF, OR UNAUTHORIZED ACCESS OR DAMAGE TO, YOUR DATA OR COMMUNICATIONS BY USING THE SITE, APPLICATIONS, AND OUR SERVICES. YOU ACKNOWLEDGE THAT YOU UNDERSTAND AND ASSUME THESE RISKS.
IF YOU BELIEVE YOUR PRIVACY HAS BEEN BREACHED THROUGH USE OF OUR WEBSITE, APPLICATIONS, OR OTHER SERVICES PLEASE CONTACT US IMMEDIATELY AT (302) 307-3237.
Feel free to contact us with questions or concerns, to exercise your marketing choices, or otherwise at email@example.com.
The American Digest
1328 Highpoint Way
Roanoke, TX 76262