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PRIVACY POLICY




Last modified: May 24, 2018.

Boston Globe Media Partners, including its affiliates and subsidiaries respects
your privacy and is committed to protecting your Personal Information (defined
below). This privacy notice will let you know how we collect, use, process,
maintain, and share your Personal Information, as well as your choices regarding
the use, access, and correction of your Personal Information. What Personal
Information we collect may vary based on your interaction with us.

We encourage you to read this privacy notice together with any other privacy
notice or fair processing notice we may provide on specific occasions when we
are collecting or processing Personal Information about you so that you are
fully aware of how and why we are using your data. This privacy notice
supplements the other notices and is not intended to override them.

I. IMPORTANT INFORMATION AND WHO WE ARE

II. WHAT CATEGORIES OF PERSONAL INFORMATION DO WE GATHER ABOUT YOU?

III. HOW IS YOUR PERSONAL INFORMATION RECEIVED, COLLECTED, AND USED?

IV. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

V. INTERNATIONAL TRANSFERS (EU/EEA, UK, AND OTHER APPLICABLE JURISDICTIONS)

VI. DATA INTEGRITY AND SECURITY

VII. MINIMIZATION, RETENTION, AND DELETION OF PERSONAL INFORMATION

VIII. EU/EEA AND UK SPECIFIC CLAUSES

IX. ACCEPTANCE AND CHANGES TO THIS POLICY

X. WHO SHOULD YOU CONTACT IF YOU HAVE QUESTIONS?





--------------------------------------------------------------------------------





I. IMPORTANT INFORMATION AND WHO WE ARE


Boston Globe Media Partners is made up of different legal entities, including
its affiliates and subsidiaries. When we mention ”Boston Globe”, “we”, “us” or
“our” in this privacy notice, we are referring to the relevant affiliate or
subsidiary of Boston Globe Media Partners responsible for processing your
information. Data and privacy law in certain jurisdictions differentiates
between the “controller” and “processor” of information. Boston Globe Media
Partners is the controller and responsible for its websites.

This privacy notice aims to give you information on how the Boston Globe
receives, collects and processes your Personal Information in connection with
our websites (including Boston.com, BostonGlobe.com, statnews.com, statplus.com,
and other websites controlled by the Boston Globe or its affiliates), mobile
applications or “apps” (including Boston Globe ePaper. Boston.com News, and any
current or future apps of Boston Globe Media Partners or its affiliates), social
media channels, electronic newsletters, and other Boston Globe digital
properties (the “Digital Properties”), the Boston Globe 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
notice.

“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 on our
Digital Properties. It does not include data where the identity has been removed
(anonymous data). Certain information may not be personally identifiable when
standing alone (e.g., your age), but may become so when combined with other
information (e.g., your age and name).

Children’s Online Privacy Protection.

Our Digital Properties and 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.

Third party links and applications.

Our Digital Properties may include links to third party websites, platforms,
plug-ins and applications. Clicking on those links or enabling those connections
may allow third parties to collect or share data about you. We do not control
these third party websites, platforms and applications and are not responsible
for their privacy statements. We encourage you to read the privacy notice of
every website you visit or application you use when you use or enable these
platforms and applications, or leave our Digital Properties.






II. WHAT CATEGORIES OF PERSONAL INFORMATION DO WE GATHER ABOUT YOU?

We may collect, use, store and transfer different kinds of Personal Information
about you which we have grouped together follows:

• Identity Data (for example, your first name, maiden name, last name, username
or similar identifier, birth year, gender, marital status, title, or other basic
demographic information).

• Contact Data (for example, your billing address, delivery address, email
address and telephone numbers).

• Financial Data (for example your bank account and payment card details).

• Transaction Data (for example, details about payments to and from you and
other details of Services you have purchased from us).

• Technical Data (for example, 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 to access our Services and Digital
Properties).

• Mobile Device Location Data (for example, if you use our mobile applications
and permit certain precise location settings and permissions, you consent to
providing us with access to your precise geolocation information—such as
information based on your GPS coordinates—so that we can deliver customized
content or advertising to you based on your current location. You may withdraw
this consent at any time by turning off those same settings and permissions in
your app and mobile device, but such withdrawal will not affect the lawfulness
of processing the previously collected information).

• Usage Data (for example, information about how you use our Digital Properties
and Services, including, for example, if you contact the Boston Globe, we may
log information about the means through which you contacted us and our
interaction with you).

• Profile Data (for example, your username and password, purchases or orders
made by you, your interests, preferences, feedback and survey responses).

• Marketing and Communications Data (for example, your preferences in receiving
marketing from us and our third parties, if any, and your communication
preferences).

We also collect, use and share Aggregated Data such as statistical or
demographic data for any purpose. Aggregated Data may be derived from your
Personal Information but is not considered Personal Information in law as this
data does not directly or indirectly reveal your identity. For example, we may
aggregate your Usage Data to calculate the percentage of users accessing a
specific website feature. However, if we combine or connect Aggregated Data with
your Personal Information so that it can directly or indirectly identify you, we
treat the combined data as Personal Information which will be used in accordance
with this privacy notice.

Personal Information does not include, and this privacy notice does not cover,
data from which individual persons cannot be identified, where the identity of
an individual has been irretrievably removed, or situations in which personal
information is anonymized.

Special Categories of Data (EU/EEA, UK, and Other Applicable Jurisdictions)

We do not collect any Special Categories of Personal Information about you (this
includes details about your race or ethnicity, religious or philosophical
beliefs, sex life, sexual orientation, political opinions, trade union
membership, information about your health and genetic and biometric data), nor
any information about criminal convictions and offences, in connection with our
Services and Digital Properties.

If you fail to provide Personal Information

Where we need to collect Personal Information by law, under the terms of a
contract we have with you, or for our legitimate interests, and you fail to
provide that information when requested, we may not be able to perform the
contract we have or are trying to enter into with you (for example, to provide
you with Services). In this case, we may have to cancel a product or service you
have with us but we will notify you if this is the case at the time.






III. HOW IS YOUR PERSONAL INFORMATION RECEIVED, COLLECTED, AND USED?

We may collect, receive, and use your Personal Information in different
situations, including:

1. To Provide Services/Products. We may collect your Personal Information from
you, third parties, online, offline or public resources in order to process your
order and provide Services, including in order to maintain, support,
personalize, and improve our Services (including products and Digital
Properties), 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 Boston Globe 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 a
Globe Service that may be of interest to you, major changes to Boston Globe
properties, an upcoming event, or other marketing communications on our behalf,
and we may share your information between Boston Globe 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. We may also obtain information about you from other companies that
have your permission to share that information, as well as from other online and
offline sources, which we may then combine with information that we collect
directly and indirectly from you, for these purposes.

3. To Deliver Targeted Advertising from the Boston Globe and Our Partners. When
you sign up to use our Services, we may collect and use your Personal
Information to communicate with you about products and services that may be of
interest to you, and which may be provided by the Boston Globe, or by our
advertisers, partners, third party marketing partners, or other third parties.
You can manage which communications you would prefer to receive, or elect to not
receive these direct marketing communications by: a) not initially selecting the
option provided to receive such communications, b) using the unsubscribe link in
a direct marketing email, or c) emailing us at support@bostonglobe.com.
Subscribers to The Boston Globe may also adjust their newsletter preferences
within the Member Center. Please note that some Boston Globe and third party
advertising is contained within newsletters to which you can subscribe that
contain editorial content. This advertising is not targeted to you, but is sent
to all subscribers to the particular newsletter. If you would like to avoid this
advertising, you must opt out of the newsletter. If you wish to opt out of
receiving any direct mail or telephone solicitations from the Boston Globe, you
may notify us by calling 617-929-2233 or emailing csadvocate@globe.com. Please
note that, in such cases, it will remain necessary for us to process your
Personal Information to the extent it is needed to maintain a suppression list,
and we may also be required to disclose your opt-out information to third
parties so they can suppress your name, from future solicitations. Also, if you
are a subscriber to our products or services, you will continue to receive
information and communications pertaining to your Boston Globe account and/or
Boston Globe services even where you have opted out of marketing communications.

4. Inquiry/Request Response. We may collect your Personal Information when you
contact us for information or support for our Digital Properties, Services, or
other information, in order to respond and provide the appropriate assistance
and response.

5. Purchasing a Classified Ad. We may collect Personal Information from you, for
example your Contact and Financial Data, when processing your purchase of a
classified ad.

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 Digital Properties, publications, or other Boston Globe marketing
materials, which may require the inclusion of Personal Information, such as your
name, photograph, or other identify or Profile Data.

8. Monitor Digital Properties Usage, Trends, and Experience. As is true with
most websites and digital properties, when you interact with our digital
properties, or by email, we may automatically collect, or facilitate the
collection of, Personal Information on your interactions with us and our Digital
Properties 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
Digital Properties and providing our Services, including performance analytics,
personalization, and in order to provide secure Digital Properties and Services,
and are automatically deployed. For certain Digital Properties, we may tailor
your interactions with our Digital Properties when you are logged in using your
user account by remembering information you entered on our websites or to
provide information you requested on our Digital Properties, including
subscriber content access. 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 Digital
Properties and 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 Digital Properties, Services, and other third party sites. For more
information about our use of cookies and how you can manage your settings,
please see Frequently Asked Questions about Cookies for bostonglobe.com and
Boston.com and for STAT or manage your settings 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.

9. Vendors, Consultants, and other Service Providers. We may receive your
Personal Information from various third parties and public sources in connection
with the operation of our business and the Services we provide you, including
for the functionality and security of our Digital Properties and other Boston
Globe properties, to satisfy legal obligations or enforce legal rights, to
enhance and otherwise improve our Digital Properties, Services and content, and
to provide you with enhanced experiences. These third parties and public sources
could include: our business partners, subcontractors in technical, payment, and
delivery services, advertising networks, analytics providers, marketing
partners, search information providers, social media platforms, or credit
reference agencies.

For example, some third parties gather Personal Information on our behalf for
the purpose of understanding how users are using our sites, making improvements
to our sites, services, content, and products, and for providing or delivering
the Services. A third party service provider (such as BlueConic, Inc. may use
cookies to build individual reader profiles, which we use to provide you with
content, advertising and messaging tailored to your interests. We do not control
third party service provider websites, platforms and applications collecting
your Personal Information, in this regard, and are not responsible for their
privacy statements. We encourage you to read the privacy notice of every website
you visit or application you use when you use or enable these platforms and
applications, or leave our Digital Properties. You may also be able to manage
the automated technologies being used for these purposes, and your preferences,
which is explained further in our Cookie FAQ or manage your settings here.

10. Third Party Sites. We may allow you to register and pay for third party
products and services or otherwise interact with a third party’s website, mobile
application, or digital property (collectively “Third Party Sites”) through our
own websites, apps, or digital properties. For example, if you are searching for
a job, you will be redirected to monster.com, which is framed within the
boston.com website. Or, when listening to podcasts on our website it is through
SoundCloud. When doing so, we may collect Personal Information that you share
with Third Party Sites depending upon that Third Party’s privacy practices. We
do not control these third party websites, platforms and applications collecting
your Personal Information and are not responsible for their privacy statements.
We encourage you to read the privacy notice of every website you visit or
application you use when you use or enable these platforms and applications, or
leave our Digital Properties. Some sections of our websites are operated by
third parties.

11. 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.

12. Marketing and Advertisers. 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.

13. User Experience and Advertisements. With your consent, your Personal
Information may also be collected by us or by third parties with services or
advertisements on our Digital Properties in order to customize your interactions
and provide a more meaningful advertisement experience (for example, so you do
not see the same advertisement repeatedly). Depending upon your settings,
cookies may also allow third parties engaged in interest-based advertising on
our site to recognize your browser software on other sites, as well. Your
consent for this collection and use may be managed in a variety of ways at the
operating system level of your device or equipment, through third-party platform
extensions, or EEA users can exercise the option not to accept these cookies by
clicking here. Your access to our Boston Globe properties should not be affected
if you do not accept cookies served by these third party advertisers.

14. When we provide you geographically relevant Services, offers, or
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. We may also use such information to improve our Digital Properties,
content, and Services. Note: this precise location data will be stored on your
mobile device, unless you elect to have it saved to your search history and
stored on our servers. You may have the right to withdraw your consent at any
time by changing the settings on your app but such withdrawal will have no
impact on the lawfulness of the prior processing. Please note some features and
functions may not work properly if location services is/are disabled.

15. Social Media Platforms. If you log into the Services with a social media
service or if you connect a social media account with the 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.

16. Events. We may collect or receive your Personal Information when you
register for or attend an event hosted or sponsored by us. If the event is in
partnership with a third party, we may share your Personal Information with that
interested 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 notice, but will not
be required in order to attend.

17. Creating a Public Profile. We may collect your Personal Information, such as
content ID, and Profile Data, when you create a “Public Profile” or when you
provide information in order to comment on any of our Digital Properties. If you
create a Public Profile with us to comment on articles or share content on our
forums or discussion groups, the information that you share becomes public.

18. Online Forum Engagement. Whether or not you created a Public Profile, we may
collect your Personal Information when you engage with our websites, digital
properties and online communities. 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 the
Boston Globe. 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 Service,
available here for BostonGlobe.com here for boston.com and here for STAT .

19. Government Reporting/Audit/Requests Requirements. We may use or share
Personal Information in order to satisfy governmental reporting, tax, and other
requirements (e.g., import/export), as required by law. This may include having
to meet U.S. national security or law enforcement, regulatory, or self-
regulatory requirements.

20. To verify and/or authenticate an identity, access rights, privileges, etc.
For example, we may use Personal Information to authenticate and permit online
access to subscriber and/or user account information. 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

21. At your Direction. We may collect and use your Personal Information at your
direction or as otherwise needed to fulfill the purposes for which you provided
the Personal Information or that were distributed when it was collected.

22. Other Business-Related Purposes. For other business-related purposes
permitted or required under applicable local law and regulation or to enforce
our agreements, policies, and terms of service.

23. As otherwise obligated by law. For example, subpoena or similar legal
process compliance, if we have a good faith belief the disclosure is legally
necessary for the protection of rights, safety, or fraud investigations, to
protect the Boston Globe, you, our readers and subscribers, or the public from
harm or illegal activities.

24. Emergency. To respond to an emergency which we believe in good faith
requires us to assist in preventing the death or serious bodily injury of any
person.

25. Consent. If we otherwise notify you and you consent to the sharing.

26. Publicly available sources. 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.

Thirty Party Personal Information.

Please keep in mind, before you disclose to use the Personal Information of
another person, you must obtain that person’s consent to both the disclosure and
the processing of that information in accordance with this Privacy Notice. If
you choose to provide us with that Personal Information, you represent that you
have that other person’s permission to do so.

Change of purpose.

We will only use your Personal Information for the purposes for which we
collected it, unless we reasonably consider that we need to use it for another
reason and that reason is compatible with the original purpose. If you wish to
get an explanation as to how the processing for the new purpose is compatible
with the original purpose, please contact us, as set forth in Section X of this
privacy notice.




IV. WITH WHOM DO WE SHARE YOUR PERSONAL INFORMATION?

Except as set out in this privacy notice or as required by law we do not sell,
license, rent, or swap your Personal Information without your permission. We may
have to share your Personal Information with the categories and types of parties
set out herein for the purposes outlined in Section III. For example, we may
share your Personal Information between the Boston Globe entities, with our
service providers and vendors, with our advertising and Marketing Partners,
social media platform providers, online forum visitors, or research and
analytics solution providers. We require all third parties to respect the
security of your Personal Information and to treat it in accordance with the
applicable law. Here are some examples of how we may share your information:

1. Boston Globe entities. Your Personal Information may be shared among Boston
Globe entities to provide our Services and to better understand our business,
analyze our operations, improve the Services, and to develop new Services to
support our business and journalism goals. In addition, we share Personal
Information to provide readers with information on the Services that we think
are most relevant to them and to enable us to measure the success of our
marketing activities.

2. Service Providers and Vendors. Service Providers. We contract with service
providers to help us with credit card and bill processing, shipping, email
distribution, list processing, analytics and promotions management, and ad
serving. We provide service providers only with the information they need to
perform their services. We prohibit them from sharing, reselling, or using our
data for their own marketing purposes. For example, if you are a print
subscriber or registered member of The Boston Globe, we may share your email
address with a service provider necessary to send you emails (including
newsletters) on our behalf. That service provider may not share your email
address or Personal Information with other companies, and may only send you
emails on behalf of the Boston Globe. Other service providers may help us with
delivering or shipping to you our print newspapers and publications, or other
products you may order, and to ensure fulfillment of your orders and purchases.
Another we may share, or facilitate the sharing of, your Personal Information is
with third party retail or payment processing platforms or vendors in order to
process and confirm payment. Or, we may share your Personal Information with
third party customer service providers and vendors that allow us to assist in
answering consumer inquiries and complaints and address our readers’ technical
issues, as well as to receive and collect reader feedback on our Services, etc.
As described in Section III, we may also engage service providers to collect and
analyze information about our readers’ use of our Digital Properties in order
for us to improve our Services and grow our business.

3. Social Media Platforms. We may use widgets and tools from third party social
media platforms on our Digital Properties to enable sharing and other functions
through social media platforms, which facilitates the collection and sharing of
your Personal Information by these social media platforms.

4. Promotions, Contests, Surveys, and Events. We may facilitate the collection
of, or share your Personal Information with a third party service provider,
vendor, co-host, co-sponsor, or the like when we conduct, administer, host, or
co-sponsor promotions, contests, surveys, or events.

5. Marketing and Advertising Partners. We share personal data with third parties
for marketing and advertising, such as Google and Facebook, so they can assist
us in promoting our Services on and off our Digital Properties to current and
future readers and subscribers through targeted advertisements.

6. Third Party Advertisers. We may share your Personal Information with third
party advertisers. Generally we will only share aggregated statistical,
demographic and marketing analyses of readers and their browsing and purchasing
patterns to inform advertisers about the nature of our reader base, which does
not contain Personal Information.

7. Merger or Acquisition Partners. We may share your Personal Information with
third parties to whom we may choose to sell, transfer, or merge parts of our
business or our assets. Alternatively, we may seek to acquire other businesses
or merge with them. If a change happens to our business, then the new owners may
use your Personal Information in the same way as set out in this privacy notice.

8. With other third parties, as required for legal compliance, law enforcement,
public safety, or security purposes. For example, 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 feedback@boston.com.




V. International Transfers (EU/EEA, UK, And Other Applicable Jurisdictions)

The Boston Globe 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. If you do not wish for certain
Personal Information to be so transferred, please do not provide your Personal
Information to us and/or take such steps described herein to prevent the
collection of your Personal Information. Please note in your doing so, and
without such information, we may be unable to provide this Service to you. If
you have any questions, please contact us.


VI. DATA INTEGRITY AND SECURITY

We have put in place commercially appropriate security measures to prevent your
Personal Information from being accidentally lost, used or accessed in an
unauthorized way, altered or disclosed, and to maintain its accuracy and
integrity. While no security is impenetrable, we implement and maintain
commercially appropriate technical, physical, administrative and organizational
measures to ensure a level of security appropriate to the risk for our use of
the Personal Data, taking into account the state of the art, the costs of
implementation, and the nature, scope, context and purposes of processing. For
Personal Information of EU/EEA and UK residents, we also take into account the
risk of varying likelihood and severity for the rights and freedoms of natural
persons. We maintain, monitor, test, and upgrade information security policies,
practices, and systems to assist in protecting the Personal Information that we
knowingly collect from you, and to maintain the ongoing confidentiality,
integrity, availability and resilience of our systems and services. Boston Globe
personnel receive training, as applicable, to effectively implement our privacy
policies. We also employ access restrictions, limiting the scope of employees
who have access to Personal Information and are subject to a duty of
confidentiality. Only employees who need the information to perform a specific
job are granted access to personally identifiable information and/or Personal
Information.

The Boston Globe has implemented physical and technical safeguards, online and
offline, to protect Personal Information from loss, misuse, and unauthorized
access, disclosure, alternation, or destruction. Despite these precautions, no
data security safeguards guarantee 100% security all of the time. We have put in
place procedures to deal with any suspected personal information breach and will
notify you and/or any applicable regulator of a breach where we are legally
required to do so.




VII. Minimization, Retention, And Deletion Of Personal Information

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 amount, nature, and sensitivity of the Personal Information, the
potential risk of harm from unauthorized use or disclosure of your Personal
Information, the purposes for which we process your Personal Information and
whether we can achieve those purposes through other means, and the applicable
legal requirements. In some circumstances you can ask us to delete your data:
see Request Erasure below for further information. At your request, when we have
no ongoing legitimate business need to process your Personal Information, we
will either delete or anonymize it, or, if this is not possible (for example,
because your Personal Information has been stored in backup archives), then we
will securely store your Personal Information and isolate it from any further
processing until deletion is possible. If you wish to cancel your account or
request that we no longer use your information to provide you Services, contact
support@bostonglobe.com.

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.




VIII. EU/EEA And UK Specific Clauses

Lawful Basis for Processing (EU/EEA; UK)

Regardless of your jurisdiction, we will only use your Personal Information when
the law allows us to. That said, if you are a resident of the EU/EEA or the
United Kingdom, our lawful basis for collecting and using your Personal
Information will depend on the Personal Information concerned and the specific
context in which we collect it. 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.

What we mean by legitimate interests is the interest of our business in
conducting, managing, and growing our business to enable us to give you the best
service/product and the best and most secure experience. We make sure we
consider and balance any potential impact on you (both positive and negative)
and your rights before we process your Personal Information for our legitimate
interests. For example, Personal Information which may be necessary for the
daily operation of the Boston Globe’s services, handling our readers’ inquiries,
direct marketing of products and services, completing transactions, making
disclosures under the requirements of any applicable law, and the provision of
our services and products to our subscribers and prospective subscribers (and
which may be further described in Section III above). Without such information,
the Boston Globe may be unable to provide its services and products to you, our
readers, subscribers, and prospective subscribers or readers. We do not use your
Personal Information for activities where our interests are overridden by the
impact on you (unless we have your consent or are otherwise required or
permitted to by law). You can obtain further information about how we assess our
legitimate interests against any potential impact on you in respect of specific
activities by contacting us.

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
support@bostonglobe.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 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 Digital Properties or
Services may be limited or impossible to facilitate.

Your Data Subject Rights (EU/EEA and UK)

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

• Choice

• Request access to your personal data

• Request correction of your personal data

• Request erasure of your personal data

• Object to processing of your personal data

• Request restriction of processing your personal data

• Request transfer of your personal data

• Right to withdraw consent

We will try to comply with any of these requests pertaining to your Personal
Information in accordance with applicable law. Please recognize that we may in
certain circumstances be unable to provide the access or information sought, or
correction or deletion requested. For example, we may be unable to fulfil a
request if it requires us to release commercial confidential information, the
disclosure of Personal Information relating to another person that is not the
requestor, or would result in impracticability, excessive redundancy, and/or an
undue burden or expense to the Boston Globe. We may need to verify your identity
before acting on your request. This is a security measure to ensure that
personal data is not disclosed to any person who has no right to receive it. We
may also contact you to ask you for further information in relation to your
request to speed up our response.

You will not have to pay a fee to access your Personal Information (or to
exercise any of the other rights). However, we may charge a reasonable fee if
your request is clearly unfounded, repetitive or excessive. Alternatively, we
may refuse to comply with your request in these circumstances.

We try to respond to all legitimate requests within one month. Occasionally it
may take us longer than a month if your request is particularly complex or you
have made a number of requests. In this case, we will notify you and keep you
updated.

• Choice. The Boston Globe enable its readers and subscribers the ability to
determine certain privacy preferences that can serve to modify the Personal
Information collected. For example, through email marketing preferences, browser
cookies, settings, and location settings. However, cookies are very important
for our Digital Properties to properly function and disabling or limiting their
use may limit or interfere with your experiences or ability to access website
features, functions and customizations, particularly user accounts. Certain
cookies are essential to the functioning of the Boston Globe websites and may
not be disabled.

• Right to Access. A person who has provided his or her Personal Information
directly to us may have certain access to their Personal Information and to
check that we are lawfully processing it.

• Correction. You may request correction of the Personal Information that we
hold about you. This enables you to have any incomplete or inaccurate data we
hold about you corrected, though we may need to verify the accuracy of the new
data you provide to us. In making modifications to your Personal Information,
you must provide only truthful, complete, and accurate information. In your
request, please be as clear as possible what Personal Information you have
provided to us and what Personal Information you would like edited and/or
updated.

• Erasure. You may request that we will delete the Personal Information that we
hold about you. In your request, please be as clear as possible what Personal
Information you have provided to us and what Personal Information you would like
deleted. If you ask us to delete your information before we have used it for the
necessary purposes set out in this policy, we may not be able to do so, due to
technical, legal, regulatory and contractual constraints. For example, we would
need to retain your name and contact details for suppression purposes if you do
not want to receive direct marketing from us.

• Object to processing. You may object to the processing of your personal data
where we are relying on a legitimate interest (or those of a third party) and
there is something about your particular situation which makes you want to
object to processing on this ground as you feel it impacts on your fundamental
rights and freedoms. You also have the right to object where we are processing
your personal data for direct marketing purposes. In some cases, we may
demonstrate that we have compelling legitimate grounds to process your
information which override your rights and freedoms.

• Restriction. You may request restriction of processing of your personal data
which enables you to ask us to suspend the processing of your personal data in
the following scenarios: (a) if you want us to establish the data’s accuracy;
(b) where our use of the data is unlawful but you do not want us to erase it;
(c) where you need us to hold the data even if we no longer require it as you
need it to establish, exercise or defend legal claims; or (d) you have objected
to our use of your data but we need to verify whether we have overriding
legitimate grounds to use it.

• Transfer. You can request the transfer of your personal data to you or to a
third party. We will provide to you, or a third party you have chosen, your
personal data in a structured, commonly used, machine-readable format. Note that
this right only applies to automated information which you initially provided
consent for us to use or where we used the information to perform a contract
with you.

• Withdraw consent. You may withdraw consent at any time where we are relying on
consent to process your personal data. However, this will not affect the
lawfulness of any processing carried out before you withdraw your consent. If
you withdraw your consent, we may not be able to provide certain products or
services to you. We will advise you if this is the case at the time you withdraw
your consent.

If you wish to exercise any of the rights set out above, please contact our
privacy manager at:

Email: feedback@boston.com or support@bostonglobe.com.

Phone: 617-929-7900 (between 9:00am and 5:30pm EST)

Fax: 617-929-7975, Attention Privacy Manager

Mail: 1 Exchange Place, Boston, MA 02109, Attention Privacy Manager



IX. ACCEPTANCE AND CHANGES TO THIS POLICY

This Privacy Notice may be amended from time to time, consistent with the
applicable data protection and privacy laws and principles. We will make you
aware of changes to this Privacy Notice either by posting to our intranet,
through email, or other means. We will post those changes on our websites and in
our apps so that you are always aware of what information we collect, how we use
it, and under what circumstances we disclose it. We reserve the right to modify
this Privacy Notice at any time, so please review it frequently. We will also
notify you by email or a means of a notice on our websites and apps prior to the
changes becoming effective, if we make changes that materially affect the way we
handle Personal Information. If you do not wish your information to be subject
to the revised Privacy Notice, you will need to deactivate with us and stop
using our Digital Properties and Services. Your use of our Digital Properties
and Services after the posting of such changes will constitute your consent to
such changes

By using the Boston Globe’s Services and our Digital Properties, and/or
submitting any of your Personal Information to us, you agree to the terms of
this Privacy Notice. Please do not send us any Personal Information if you do
not want that information used in this way.



X. WHO SHOULD YOU CONTACT IF YOU HAVE QUESTIONS?

For questions or concerns about this Privacy Notice or our security practices:
We have appointed a data privacy manager who is responsible for overseeing
questions in relation to this privacy notice and our security practices. If you
have any questions or concerns about this privacy notice, or seeking to exercise
any of your statutory rights, please contact the data privacy manager using the
details set out below.

Email:feedback@boston.com or support@bostonglobe.com.

Phone: 617-929-7900 (between 9:00am and 5:30pm EST)

Fax: 617-929-7975, Attention Privacy Manager

Mail: 1 Exchange Place, Boston, MA 02109, Attention Privacy Manager

EU/EEA, UK Residents.

Subject to applicable law, EU/EEA residents, including the United Kingdom, who
believe we maintain their Personal Information within the scope of the
applicable privacy laws have a right to make a complaint at any time to their
local supervisory authority or to the Information Commissioners Office, the UK
Supervisory Authority (www.ico.org.uk), for data protection issues. We would,
however, appreciate the chance to deal with your concerns before you approach
the ICO, so please contact us in the first instance.

Updates to Personal Information: If you would like to update the Personal
Information that we have about you, or if you no longer desire our services, you
can contact our privacy manager at the above contact information. Subscribers to
The Boston Globe may also revise their Personal Information within the Member
Center and subscribers to STAT Plus may revise their Personal Information within
the “My Account” page.

Unsubscribe Requests:If you would like to contact us about unsubscribing from
our email lists, you can do by clicking the link to “unsubscribe” at the bottom
of any email from us or by emailing feedback@boston.com and providing all of
your email addresses that could appear on our email lists, as well as the name
of the newsletter from which you would like to unsubscribe. Subscribers to The
Boston Globe may also manage their newsletters choices within the Member Center.

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