News IQ Privacy Notice

Updated: January 1, 2020

News IQ, an offering of NC Audience Exchange (NCAE, or “Company”, “we” or “us”), leverages the power and knowledge of the users of the News Corporation family of brands and properties, together with compelling market research and data science, to bring the most relevant content and advertising to users. News IQ serves as an advertising exchange to help our advertisers target their messaging to our users through interest-based and contextual means. This Privacy Notice (“Notice”) applies to Personal Data obtained by NCAE about you as a user of our Company affiliates’ websites and mobile applications, and from other sources as described below. This Privacy Notice also applies to Personal Data obtained by NCAE from potential advertisers, partners and other users who visit our sales/promotional site to learn more about our offerings. “Personal Data” means any information relating to you in identified or identifiable form.

We do not target children, and we do not knowingly collect Personal Data from children under 18 years of age.

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Data We Obtain

Personal Data From Participating Company Affiliates

We receive Personal Data about:

A current list of our participating affiliated companies is available here.

As further discussed below, we collect Personal Data to offer advertising services that we have a legitimate interest to believe are of interest to our customers and/or that you have requested, to manage the relationship we have with our customers, and to perform other activities based on your consent where required by law.

The types of Personal Data the Company may obtain from Company affiliates, surveys, and publicly and commercially available sources include:

Data Obtained by Automated Means

We also obtain certain data by automated means, though the use of cookies (including HTTP and HTML5 local storage), web beacons, web server logs, JavaScript and similar technologies, including technologies designed to obtain information regarding your usage of various Company affiliate sites and mobile applications, and other offerings and services. A “cookie” is a file that websites send to a user’s computer or other Internet-connected device to identify the user’s browser or to store information or settings in the browser. A “web beacon” also known as an Internet tag, pixel tag or clear GIF, links web pages to web servers and their cookies and may be used to transmit information collected through cookies back to a web server.

The data the Company obtains and receives from users of its affiliates’ sites and applications through these automated collection methods may include:

We may link this data, such as browser or device information, with other data obtained by automated means, including what search queries you may have run and what advertisements you may have seen on Company affiliate sites.

You can learn more and control Flash Cookies by visiting the Adobe Flash Website Storage Settings Panel and Global Storage Settings Panel. Please note, however, that without cookies some or all of the features of the Company affiliate services may not be available to you. User device settings also may limit mobile application platforms (such as Apple and Google) from sharing certain data obtained by automated means with us through our Company affiliate mobile applications.

News IQ ID & ID Syncing

NCAE associates data it collects about a browser or device with a randomly generated, pseudonymous identifier known as the “NCG ID”. To the extent permitted by your browser settings, NCAE syncs the NCG ID with identifiers and the data obtained from cookies placed on the participating Company affiliate sites you or the specific browser or device have visited to serve you advertisements on our Company affiliate sites and apps tailored to your interests, as further described in the Interest-Based Advertising Section below.

ID syncing, also known as cookie syncing or cookie matching, is a common industry practice that enables businesses to use data to coordinate an advertising campaign across multiple publishing platforms and advertising service providers. As an example, an individual uses a web browser to visit a publisher’s website and then leaves the website. The publisher wants to advertise relevant services to that visitor after he/she leaves the website. To do so, the publisher stores a cookie on the visitor’s browser with an ID (such as “123”) and associates the ID with information about what the visitor viewed on the publisher’s website, and buys advertising through an online advertising exchange or marketplace. In order to buy appropriate advertising to display to that visitor, the publisher would need to match the “123” ID with the ID that the exchange has assigned to the same visitor (for example, exchange ID “XYZ”). Using ID syncing, the publisher “123” ID is associated with the same browser or device as the exchange ID “XYZ”. In addition, the publisher may be able to show more relevant advertisements to the visitor based on the initial information the publisher collected from that visitor when the visitor was on the publisher’s site. For example, the syncing allows the publisher to match the data collected from the visitor while on the publisher’s site with other sources of data also associated with the visitor. This syncing can be done across multiple sites.

Personal Data about Users of NCAE’s Sales/Promotional Site

NCAE also maintains a business-to-business sales/promotional site, where potential advertisers, third party partners and other business users may learn about NCAE’s offerings and services. When such user visits such site, we may collect such visitor’s contact information (name, email address and phone number), company name and title of position within the visitor’s company, all to the extent such Personal Data is provided to us. Data collected from a visitor of NCAE’s sales/promotional site is not comingled with any other data that NCAE may otherwise have obtained regarding that visitor through the advertising exchange services described above.

We use the data collected from and about you, and rely on legitimate interest to use the data, to:

With your consent, when required under applicable law, we use the data to:

We also may use your Personal Data in other ways for which we will provide specific notice, and if necessary, seek your consent, at the time of collection. In addition, when the data collected from or about you does not identify you as a specific person, we may use it in any lawful manner.

Interest-Based Advertising

On our Company affiliate sites, applications and/or emails, we and our service providers obtain data about your activities to provide you with advertising about products and services tailored to your individual interests.

Throughout the News IQ advertising exchange, we can gather information about online activities over time and across Company affiliate sites and applications by obtaining data, as described above. Collection of such data currently takes place on the Company affiliate sites, applications and emails that participate in our advertising exchange. Our exchange uses all such data to show users advertisements on our Company affiliate sites and applications that aim to be tailored to your individual interests. We also track the effectiveness of marketing campaigns conducted through the News IQ advertising exchange.

The Company adheres to the Digital Advertising Alliances Self-Regulatory Principles and provides users choice with respect to the Company advertising exchange interest-based advertising. To learn how to opt out of the News IQ interest-based advertising see the section on Your Choices below.

The Company also participates in the IAB Europe Transparency & Consent Framework (the “Framework”) and complies with its Specifications and Policies. The goal of the Framework is to inform users about the storing and/or accessing of information on their devices and the personal data about them that is being processed, the purposes for such processing and the companies that are seeking to process their personal data for such purposes, and to provide users with choice about such processing. For more information on the Framework, please visit the following site: https://iabeurope.eu/transparency-consent-framework/.

Transfers of Data

The data obtained by the Company may be hosted in and managed from a country outside the country in which users initially provided the information. We transfer the Personal Data we collect about you to the United States, and may also transfer Personal Data to another country, which may not be deemed to have the same data protection laws as the country in which you initially provided the Personal Data. When your Personal Data is in such countries, it may be accessed by the courts, law enforcement and national security authorities in accordance with applicable law.

When we transfer your Personal Data from the European Union/European Economic Area and from the United Kingdom, we will do so in compliance with the EU-US and Swiss-US Privacy Shield Frameworks (collectively, “Privacy Shield”) as set forth by the U.S. Department of Commerce regarding the collection, use and retention of Personal Data transferred from the European Union, Switzerland and the United Kingdom to the United States, and have certified to the Department of Commerce that the Company adheres to the Privacy Shield Principles. If there is any conflict between the terms in this Privacy Notice and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view our certification, please visit https://www.privacyshield.gov/.

When we otherwise transfer your Personal Data, we will protect that information as described in this Notice and will implement appropriate safeguards to ensure that your Personal Data remains protected. This may include data transfer agreements, a copy of which you can obtain by contacting us as indicated in the How To Contact Us Section below.

Data We Share

We may share your data with:

Our affiliates, service providers and advertising clients are obligated to process the Personal Data in a manner consistent with the Privacy Shield Principles, and News IQ remains responsible under the Principles for its affiliates and service providers. We have agreements in place with our service providers and advertising clients that ensure the adequacy of data protection practices.

In addition, when the information collected from or about you is aggregated and otherwise does not identify you as a specific person, we may share it with third parties at our discretion. For example, we may include and share your data in a report that consists of aggregated demographics of an audience against which an advertising campaign was served.

We may further disclose Personal Data about you (1) if we are required to do so by law or legal process, (2) to law enforcement authorities or other government officials, and (3) when we believe disclosure is necessary or appropriate to prevent physical harm or financial loss, or in connection with an investigation of suspected or actual fraudulent or illegal activity. We also reserve the right to transfer data in the event of a proposed or completed sale or transfer of all or a portion of our business or assets (including in the event of a reorganization, dissolution or liquidation).

Your Choices

We offer you certain choices in connection with the Personal Data we obtain.

Opting Out of Receiving News IQ Targeted Advertising

If you wish to opt out of receiving personalized advertisements from News IQ, you may click here or visit www.aboutads.info/choices, or www.youronlinechoices.eu for EU/EEA users. Please note that opting out of receiving personalized or interest-based advertisements from the Company will only opt you out of receiving personalized or interest-based advertisements from News IQ, and you may continue to receive personalized or interest-based advertisements from others, including the Company affiliates, and each of their advertising networks, and/or other advertisements that are not tailored to your interests. For more information about interest-based advertisements, and to opt out of other advertising for companies participating in self-regulatory programs, please visit: www.aboutads.info/choices and www.networkadvertising.org/choices.

If you are an advertiser, partner or other user of our sales/promotional site, you may ask us to remove your Personal Data from our mailing lists by contacting us as outlined in the How To Contact Us Section below.

Accessing, Reviewing, Updating and Modifying Personal Data

Subject to applicable law, you may be provided access to, and/or be able to review, update, and correct inaccuracies in the Personal Data obtained about you in the Company’s control by emailing or writing to us at the contact information set out below. We may request certain Personal Data for the purposes of verifying the identity of the individual seeking access to his/her Personal Data records.

If you are in the European Union/European Economic Area, you may request to access, rectify or erase (under certain circumstances) your Personal Data. If you ask us to delete your Personal Data, we may not be able to do so due to technical, legal, regulatory or contractual constraints. You have the right to object to the processing of your Personal Data, restrict the processing of your Personal Data and exercise your right to data portability (under certain circumstances). Where you have given us your consent for specified uses of your Personal Data, you have the right to withdraw such consent at any time and we will apply your preferences for the future. EU users may opt out of having their Personal Data disclosed to third parties by contacting us as specified in the How To Contact Us section below. We will respond to your questions or complaints relating to the processing of your Personal Data. If you are not satisfied with our responses, you have the right to lodge a complaint with a supervisory authority, although we would like the opportunity to resolve any concerns you may have, so do get in touch with us.

Privacy Shield Inquiries and Complaints

In compliance with the Privacy Shield Principles, we are committed to resolve complaints about our collection or use of your Personal Data. European Union, Swiss and United Kingdom individuals with inquiries or complaints regarding our Privacy Shield policy should first contact us as outlined in the How To Contact Us Section below.

News IQ has further committed to refer unresolved Privacy Shield complaints to JAMS, an alternative dispute resolution provider located in the United States. If you do not receive timely acknowledgement of your complaint from us, or if we have not resolved your complaint, please contact or visit https://www.jamsadr.com/eu-us-privacy-shield for more information or to file a complaint. The services of JAMS are provided at no cost to you.

Under certain limited circumstances, individuals from the European Union, Switzerland and United Kingdom may invoke binding Privacy Shield arbitration as a last resort if all other forms of dispute resolution have been unsuccessful. To learn more about this method of resolution and its availability to you, please visit https://www.privacyshield.gov/.

NCAE is subject to the jurisdiction of the Federal Trade Commission for purposes of Privacy Shield enforcement.

How We Protect and Retain Personal Data

We maintain administrative, technical and physical safeguards designed to protect the Personal Data we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of Personal Data.

We retain Personal Data for the period needed to fulfill the purposes for which Personal Data was collected, or while there is a legitimate reason for doing so, and as otherwise required or permitted by applicable law, such as in relation to our record retention obligations.

Updates to Our Privacy Notice

This Privacy Notice may be updated periodically and without prior notice to reflect changes in our Personal Data practices. For significant changes, we will notify you by posting a notice where the Notice is accessible and indicating at the top of the Notice when it was most recently updated.

How To Contact Us

The entity responsible for the collection and processing of Personal Data through the News IQ products and services is NC Audience Exchange, LLC, 1211 Avenue of the Americas, New York, NY 10036.

For any questions about this Privacy Notice or the manner in which we or our service providers treat your Personal Data, or if you would like to exercise your choices as described above, please contact us as follows:

privacypolicy@newscorp.com

Users also may write to:

Privacy Office
News IQ
c/o News Corporation
1211 Avenue of the Americas
New York, NY 10036
Attn: Legal Department

EU/EEA users may contact our Data Protection Officer, using the subject line “News IQ”, at:

dataprotection@news.co.uk

or the News IQ Article 27 Representative, using the subject line "News IQ Rep", at:

News UK & Ireland Limited
1 London Bridge Street
London, SE1 9GF
United Kingdom
dataprotection@news.co.uk

Notice to California Residents

California Shine the Light Law

Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us at privacypolicy@newscorp.com.

For all such requests, please indicate "CA Shine the Light" in the subject field of your request and include the name of “NewsIQ” with respect to which you are requesting the information.

California Consumer Privacy Protection Act

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Consumer”) and uses our services. This notice supplements the information in the Privacy Notice. Certain terms used below have the meanings given to them in the CCPA.

The following sets forth the categories of information we collect and purposes for which we may use California Consumers’ personal information by NewsIQ:

Categories of Personal Information We Collect About You

The categories of personal information we may collected about you or your use of our Services are:

More details on the categories of personal information we may collect are set forth in the Data We Obtain section of our Privacy Notice.

Categories of Sources From Which We Collected Personal Information

The sources from which we may have collected personal information about are:

as otherwise set forth in the Data We Obtain section of our Privacy Notice.

Business or Commercial Purposes for Which We Collected or Sold the Personal Information

The business or commercial purposes, as defined under the CCPA, for which we collected or sold the personal information, are:

More details concerning the business or commercial purposes are set forth in the The Purposes & Legal Bases for Which We Use the Data We Obtain section of our Privacy Notice. We may disclose the categories of personal information identified in Data We Obtain section of our Privacy Notice about our California consumers for our operational purposes where the use of such personal information is reasonably necessary and proportionate to achieve the operational purpose for which the personal information was collected or processed or for another operational purpose that is compatible with the context in which the personal information was collected.

Categories of Third Parties With Whom We Shared the Personal Information

The categories of third parties, as defined by the CCPA, with whom we shared the personal information, are set forth in the Data We Share section of our Privacy Notice, and include:

Categories of Personal Information Sold

The categories of personal information we may sell, as defined under CCPA, include:

More details on the categories of personal information we may sell are set forth in the Data We Obtain and Data We Share sections of our Privacy Notice. We do not sell the personal information of consumers under the age of 16 if we have actual knowledge of the individual’s age.

Categories of Personal Information Disclosed for a Business Purpose

The categories of personal information disclosed for a business purpose, as defined under the CCPA, include all of the categories of information listed above.

More details on the categories of personal information we may disclose for a business purpose are set forth in the Data We Obtain and Data We Share sections of our Privacy Notice.

California Consumer Privacy Rights and Choices

California Consumers may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:

The right to access and disclosure . You may have the right to request, twice during a twelve month period, the following information about the personal information we have collected about you during the past 12 months:

The right to deletion . You may have the right to request that we delete the personal information we have collected from you. Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

How to exercise your access and deletion rights. California residents may exercise their California privacy rights by sending an email to privacypolicy@newscorp.com, indicating “CA Privacy Rights” in the subject field of your email. To the extent permitted by applicable law, we may charge a reasonable fee to comply with your request.

For security purposes, we will verify your identity – in part by requesting certain information from you -- when you request to exercise your California privacy rights. For instance, you may need to provide your name and email address. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may also need to ask you for additional information to verify your identity.

Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

The right to opt-out of the sale of your personal information. California residents may opt out of the “sale” of their personal information. California law broadly defines sale such that it may include your information that may be “sold” to third party advertising clients as described in the Data We Share section of our Privacy Notice. You have the right to opt out of the sale of your personal information. If you would like to opt out, you may do so clicking here

Authorized Agents. You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps both to verify the identity of the person seeking to exercise their rights as listed above, and to verify that your agent has been authorized to make a request on your behalf through providing us with a signed written authorization or a copy of a power of attorney.

News IQ Participating Affiliate Brands and Properties