Privacy policy

Last modified: November 9, 2018

MaineToday Media and its affiliated entities 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 had using our Services.

This privacy policy aims to give you information on how MaineToday Media receives, collects and processes your Personal Information in connection with our websites (including PressHerald.com, CentralMaine.com, SunJournal.com, MaineToday.com, JournalTribune.com, TimesRecord.com, and other websites controlled by MaineToday Media or its affiliates), social media channels, electronic newsletters, and other MaineToday Media digital properties, the Portland Press Herald newspaper and our other print publications, and any of our other products or services (for example, podcasts, classified ads, events, contests and promotions, surveys, and the like). These are collectively referred to as “Services” throughout this privacy policy.

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
  • International Transfers
  • Data Integrity and Security
  • Data Retention
  • Lawful Basis for Processing
  • Your Data Subject Rights and Choices
  • Changes to this Policy
  • How to Contact Us

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.

Information You Give Us:

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.

If you purchase any of our Services, you also give us bank account or credit card data.

If you participate in one of our promotions or surveys, use the comment features on our websites or apps, or contact us for customer service, you may give us your Personal Information.

Information We Collect About You

When you access our Services, we may collect technical data such as your internet protocol (IP) address, internet service provider (ISP), your login data, browser type and version, browser language, referring/exit pages, operating system, date/time stamp, clickstream data, time zone setting and basic geolocation, device type, unique device identifiers, browser plug-in types and versions, operating system and platform and other technology on the devices you use.

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.

Like many websites, our Services use cookies and other tracking technologies in order to function effectively and deliver certain features. For more information on how we use cookies and other tracking technologies, please review our cookie policy.

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 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.

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.

How We Use Your Personal Information

We may collect, receive, and use your Personal Information in a number of different ways:

  1. To Provide, Measure and Improve our Services. We may collect your Personal Information in order to maintain, support, personalize, and improve our Services, deliver and provide the requested Services, communicate with you about those Services (including to request feedback) or request your participation in surveys, discuss your account or renew your subscription, and comply with and enforce contractual obligations. In order to process your orders and manage your payment methods, it may be necessary for us to share your information with a third party service provider and/or to combine your information with other information we have collected from you, third parties, or public sources.
  2. To Provide Relevant Information about MaineToday Media Services that may be of interest to you. When you sign up to receive our Services, we may collect and use your Personal Information in order to provide you with information about our Services that may be of interest to you, major changes to MaineToday Media properties, an upcoming event, or other marketing communications on our behalf, and we may share your information between MaineToday Media entities and affiliates for these purposes. We may share your Personal Information with third party service providers to facilitate these communications on our behalf and at our direction.
  3. To Deliver Targeted Advertising from MaineToday Media and Our Partners. To make your experience more interesting and personalized, we may use any of the Personal Data and other information we collect to assist us in delivering content, including advertisements, on any of our Services. We may collect your Personal Information and share that information 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, your Personal Information may be used to inform advertisers about the nature of our subscriber base and the number of unique visitors that have viewed a particular ad or visited a particular webpage. We may also use your Personal Information to publish summary information regarding, for example, our publications’ readers or online visitors for promotional purposes and as a representative audience for advertisers, sponsors, and affiliates.
  4. To Provide Location-Specific Content and Advertising. With your consent, which may be provided when you enable certain features on your mobile or electronic device, we may collect your Mobile Device Location Data, and use such data to provide you with content, Services, offers, or advertising through your app or device that are relevant to your precise location.
  5. Customer Service. We may collect your Personal Information when you contact us for information or support for our Services in order to respond and provide the appropriate assistance and response.
  6. Participating in Promotions. We may need to collect Personal Information when you choose to participate in a promotion, prize draw or other competition. The information we collect will be needed to administer such promotions as well as communicate with you about the same. For example, we may need to collect 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.
  7. 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. Also, we may use reader testimonials or exemplars in or on our websites, publications, or other MaineToday Media marketing materials, which may require the inclusion of Personal Information, such as your name, photograph, or other identity or profile data.
  8. Monitor Usage, Trends, and Experience. 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.

For example, some are strictly necessary for the core functionality of our Services, including performance analytics, personalization, and in order 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.

Finally, with your consent (depending on your settings), we may use cookies for advertising purposes, which could include helping us collect your technical, usage, and profile data if you visit other websites employing our cookies, or to allow us to deliver relevant, personalized advertisements and content to you on our Services and other third party sites. For more information about our use of cookies and how you can manage your settings, please see our cookie policy here. You can learn more about certain types of targeted advertising by visiting the Digital Advertising Alliance website.

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.

  1. Marketing Research/Statistics. We may collect your Personal Information directly or through our third party marketing partners (“Marketing Partners”) as necessary to help us and our Marketing Partners research and develop new products, services, updates, generate business 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 obtain certain data about you 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 and digital properties, other users, or third parties to enhance your experience and improve our content, products and services.
  2. Social Media Platforms. If you chose to link your social media account to our Services, we may share your information with that social media service. The social media services’ use of the shared information will be governed by the social media services’ privacy policy and your social media account settings. If you do not want your information shared in this way, do not connect your social media service account with your Services.
  3. Events. We may collect or receive your Personal Information when you register for or attend an event hosted or sponsored by us.
  4. Online Forum Engagement. We may collect 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 MaineToday Media. 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.
  5. Government Reporting/Audit/Requests Requirements. We may use or share Personal Information in order to satisfy governmental reporting, tax, and other requirements, as required by law.
  6. To verify and/or authenticate an identity, access rights, privileges, etc. We may use Personal Information to authenticate and permit online access to subscriber and/or user account information.
  7. As Required by Law or Legal Process. We may access, preserve and disclose Personal Information if we are required to do so by law or we have a good faith belief that such action is necessary to (a) comply with the law or with legal process; (b) protect and defend our rights and property; (c) protect against misuse or unauthorized use of the Services; (d) protect the personal safety or property of our users or the public (among other things, this means 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); and (e) cooperate with public and government authorities (which may be outside your country of residence).

With Whom We Share Your Personal Information

Within MaineToday Media. We share Personal Information among our affiliates for the purposes listed in this privacy policy.

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, IT infrastructure, processing and analytics, promotion management. In the course of performing these services, our service providers may have access to your Personal Information.

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 (and we will let you know at the point of collection of your information if the information will be shared).

We may share aggregate results from research surveys or panels with advertisers.

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.

Compliance with Legal Process. We may disclose your Personal Information if we have a good faith belief that disclosure is necessary to comply with the law or with legal process, such as to comply with a subpoena, protect and defend our rights and property, to protect against misuse or unauthorized use of our websites, or to protect the personal safety or property of our users or the public. For example, we may release Personal Information to comply with a court order or subpoena. Or, if you provide false information or attempt to pose as someone else, we may release Personal Information as part of any investigation into your actions.

California Privacy Rights.

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. Please email requests for such information to [email protected].

International Transfers

MaineToday Media 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 which may be outside of your own, such as the United States. By providing us with your Personal Information you acknowledge such transfer of information out of your jurisdiction.

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 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 [email protected].

Data Retention

We will only retain your Personal Information for as long as necessary to fulfil the purposes we collected it for, including, for example, for so long as we provide you with Services, and for the purposes of satisfying any legal (including but not limited to enforcement of agreements or resolving disputes), accounting, or reporting requirements.

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

  • The length of time we have an ongoing relationship with you and provide Services to you (for example, for as long as you have an account with us);
  • Whether there is a legal requirement mandating that we retain records of a transaction with you; or
  • Whether data retention is prudent in light of applicable statutes of limitations, litigation 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 [email protected].

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 ground depending on the specific purpose for which we are using your information. Please contact us if you need additional details about the specific legal ground 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 [email protected], 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 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, and our provision, of our Services may be limited or impossible to facilitate.

Your Data Subject Rights

Under certain circumstances, you have rights under applicable data protection laws with respect to Personal Information we knowingly collected.

If you have subscribed to our Services, you can make changes to your account information by logging into your account on the applicable website. If you have subscribed to any of our email communications, you may also change your subscription information by following any of the links at the bottom of the communication.

You can ask us to erase or delete Personal Information we have collected from you; however applicable laws or regulations may require that we keep such information even after you ask us to delete it.

You can also ask us for a copy of your personal data (including in machine readable form).

Changes to this Privacy Policy

We reserve the right to update this privacy policy from time to time in light of changes business practices, technology and legal requirements. If we make any significant or material change to this privacy policy, we will notify you via 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.

How to Contact Us

If you have any questions or concerns about this privacy policy, please contact us via email at [email protected] or via mail at: MaineToday Media, 295 Gannett Drive, South Portland, Maine 04106.