Las Vegas Review-Journal, Inc. Privacy Notice for California Residents

Effective Date: January 1, 2020

Last Reviewed on January 1, 2020

This Privacy Notice for California Residents supplements the information contained in Las Vegas Review-Journal, Inc.’s general privacy policy found at https://www.reviewjournal.com/privacy/” and applies solely to all visitors, users, and others who reside in the State of California (“consumers” or “you”). Las Vegas Review-Journal, Inc. (“Company” or “we”) adopts this notice to comply with the California Consumer Privacy Act of 2018 (as the same has been amended and may be amended in the future, the “CCPA”) and any terms defined in the CCPA have the same meaning when used in this notice.

Information We Collect

This Privacy Notice sets forth the privacy practices we use in conjunction with any personal information from consumers subject to the CCPA that we use or process in connection with our print and digital products and services. These services include the Las Vegas Review-Journal, Pahrump Valley Times, Boulder City Review, Tonopah Times, El Tiempo newspapers, the Views, Nifty Nickel publications, or RJ magazine, Best of Las Vegas, our websites, email newsletters, social media pages, mobile and other applications owned and operated by us, and any other services that display this notice (collectively referred to as the “ LVRJ Services”). The LVRJ Services collect information that identifies, relates to, describes, references, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“ personal information”). In particular, the LVRJ Services have collected the following categories of personal information from its consumers within the last twelve (12) months:

Category	Examples	Collected
A. Identifiers.	A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.	YES
B. Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).	A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information.Some personal information included in this category may overlap with other categories.	YES
C. Protected classification characteristics under California or federal law.	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	YES
D. Commercial information.	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	YES
E. Biometric information.	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	NO
F. Internet or other similar network activity.	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	YES
G. Geolocation data.	Physical location or movements.	YES
H. Sensory data.	Audio, electronic, visual, thermal, olfactory, or similar information.	YES
I. Professional or employment-related information.	Current or past job history or performance evaluations.	YES
J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	YES
K. Inferences drawn from other personal information.	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	YES

Personal information does not include:

Publicly available information from government records.
Deidentified or aggregated consumer information.
Information excluded from the CCPA’s scope, like:
- health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality
  of Medical Information Act (CMIA) or clinical trial data; or
- personal information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.

Company obtains the categories of personal information listed above from the following categories of sources:

Directly from you. For example, from forms you complete or products and services you purchase.
Indirectly from you. For example, from observing your actions on the LVRJ Services.
From third parties. For example, from consumer reporting agencies.

Use of Personal Information

We may use or disclose the personal information we collect for one or more
of the following business purposes:

To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to ask a question about our products or services, we will use that personal information to respond to your inquiry. If you provide your personal information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
To process your requests and provide you with the LVRJ Services, including to deliver customized content or recommendations. Note that we use your payment card information (such as your card number and expiration date) for limited purposes such as to process your transaction (including recurring payments, if applicable), to provide you with the requested products or services and to protect our rights or the rights of others.
To provide, support, personalize, and develop the LVRJ Services and its content for you.
To create, maintain, customize, and secure your account with us.
To learn about users of the LVRJ Services and analyze how you and others interact with and respond to the LVRJ Services.
To communicate with you, including to send you marketing and promotional communications.
For advertising and marketing purposes, including to deliver interest-based ads, for cross-device linking and to analyze the performance of advertising and marketing activities.
To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
To help maintain the safety, security, and integrity of the LVRJ Services, databases and other technology assets, and business.
For testing, research, analysis, and product development, including to develop and improve the LVRJ Services.
To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
To enforce or apply our policies, terms and conditions, and other agreements, including for billing and collection purposes.
As described to you when collecting your personal information or as otherwise set forth to protect our rights and the rights of others in the CCPA.
To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about users of the LVRJ Services is among the assets transferred.

We may also use your information to contact you about our own and third-parties’ (including our affiliate’s or subsidiary’s) goods and services that may be of interest to you. If you do not want us to use your
information in this way, please contact us by email at privacy@reviewjournal.com. For more information, see the General Privacy Policy.

We will not collect additional categories of personal information or use the personal information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We may disclose your personal information to a third party for a business purpose. When we disclose personal information for a business purpose, we enter a contract that describes the purpose and requires the recipient to both keep that personal information confidential and not use it for any purpose except performing the contract.

We share your personal information with the following categories of third parties:

To our affiliates and subsidiaries.
To contractors, service providers, and other third parties we use to support our business and who are bound by contractual obligations to keep personal information confidential and use it only for the purposes for which we disclose it to them.
With advertisers, advertising- and marketing-related services providers and partners as well as companies that help us learn how you and others interact with our content.
With social media platforms and similar services, including when you interact with our LVRJ Services that integrate tools and services provided by social media platforms.
With business partners, such as when we partner with a third party to offer products or services on a co-branded basis.
To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of Company’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by Company about users of the LVRJ Services is among the assets transferred.
To third parties (other than our affiliates and subsidiaries) to market their products or services to you if you have not opted out of these disclosures. We contractually require these third parties to keep personal information confidential and use it only for the purposes for which we disclose it to them.
Data aggregators.

Disclosures of Personal Information for a Business Purpose

In the preceding twelve (12) months, Company has disclosed the following categories of personal information for a business purpose:

Category A: Identifiers.
Category B: California Customer Records personal information categories.
Category C: Protected classification characteristics under California or federal law.
Category D: Commercial information.
Category F: Internet or other similar network activity.
Category G: Geolocation data.
Category H: Sensory data.
Category I: Professional or employment-related information.
Category J: Non-public education information.
Category K: Inferences drawn from other personal information.

We disclose your personal information for a business purpose to the following categories of third parties:

Service providers, including marketing service providers, information technology services providers, software providers, shipping service providers and credit card processors.
Legal and accounting service providers.
Our affiliates and subsidiaries.

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability Rights

You have the right to request that we disclose the categories and specific pieces of information we have collected and certain information to you about our collection and use of your personal information over the past 12 months. Once we receive and confirm your verifiable consumer request (see Exercising Access, Data Portability, and Deletion Rights), we will disclose to you:

The categories of personal information we collected about you.
The categories of sources for the personal information we collected about you.
Our business or commercial purpose for collecting or selling that personal information.
The categories of third parties with whom we share that personal information.
The specific pieces of personal information we collected about you (also called a data portability request).
If we sold or disclosed your personal information for a business purpose,two separate lists disclosing:
- sales, identifying the personal information categories that each category of recipient purchased; and
- disclosures for a business purpose, identifying the personal information categories that each category of recipient obtained.

Deletion Request Rights

You have the right to request that we delete any of your personal information that we collected from you and retained, subject to certain exceptions. Once we receive and confirm your verifiable consumer request
(see Exercising Access, Data Portability, and Deletion Rights), we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies.

We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the personal information, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service that
you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform our contract with you.

2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.

3. Debug products to identify and repair errors that impair existing intended functionality.

4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.

5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).

6. 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, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.

7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.

8. Comply with a legal obligation.

9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

Exercising Access, Data Portability, and Deletion Rights

To exercise the access, data portability, and deletion rights described above, please submit a verifiable consumer request through one of the following:

Phone: 833-761-0220
E-mail: privacy@reviewjournal.com
Website: https://www.reviewjournal.com/ccpa-deletion-request/
Postal Address: P.O. Box 70, Las Vegas, NV 89125, Attn: Privacy Officers

Only you, or a natural person or person registered with the California Secretary of State that you authorize in writing, or otherwise properly authorize, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.
We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.
Making a verifiable consumer request does not require you to create an account with us. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

Response Timing and Format

We endeavor to respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding the verifiable consumer request’s receipt. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

No Personal Information Sales

We do not sell any personal information that we collect or use.

Non-Discrimination

We will not discriminate against you for exercising any of your CCPA rights. Unless permitted by the CCPA, we will not:

Deny you goods or services.
Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties.
Provide you a different level or quality of goods or services.
Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

However, we may offer you certain financial incentives permitted by the CCPA that can result in different prices, rates, or quality levels. Any CCPA-permitted financial incentive we offer will reasonably relate to the value to us of your personal information and contain written terms that describe the program’s material aspects. Participation in a financial incentive program requires your prior opt in consent, which you may revoke at any time.

Other California Privacy Rights

California’s “Shine the Light” law (Civil Code Section § 1798.83) permits users of our Website that are California residents to request certain information regarding our disclosure of personal information to third parties for their direct marketing purposes. To make such a request, please send an email to privacy@reviewjournal.com or write us at: P.O. Box 70, Las Vegas, NV 89125, Attn: Privacy Officers.

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will post the updated notice on the Website and update the notice’s effective date.

Contact Information

If you have any questions or comments about this notice, the ways in which we collect and use your information described in this Privacy Notice and in the General Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Phone: 1-833-761-0220

Email: privacy@reviewjournal.com

Postal Address: Las Vegas Review-Journal, P.O. Box 70, Las Vegas, NV 89125 Attn: Privacy Officers

Website: https://www.reviewjournal.com/ccpa-deletion-request/