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PRIVACY POLICY

By The Washington Post
Updated June 30, 2023 at 3:59 p.m. EDT|Published January 1, 2021 at 12:00 a.m.
EST


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Published: 06/30/2023

This Privacy Policy (or “Policy”) explains how WP Company LLC (“The Washington
Post,” “we,” or “us”) collects, uses, and discloses information about you when
you use our sites, mobile and tablet apps, and other online products and
services that link to this Policy; subscribe to our print newspaper; receive our
emails and newsletters; and attend our events (collectively, the “Services”) or
when you otherwise interact with us or receive a communication from us related
to the Services. For certain Services we may provide you with additional privacy
information that supplements this Policy. Other Washington Post services may
refer to a different privacy policy, and for those products or services this
Policy does not apply.


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For your choices about your information, you can visit Account Management,
Privacy Rights, and Other Choices and Jurisdiction-Specific Privacy Information
& Rights below and our Cookie Notice, which outlines your choices about
personalized advertising.

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Please note, this Policy includes sections with additional information for users
in specific jurisdictions, including Privacy Information for California
Residents and Information for Certain Users Outside of the United States. You
understand that your personal data, including any data you provide, is processed
by The Washington Post in the United States, which may have different data
protection standards if you reside in another country.

This Privacy Policy covers the following:

Information We Collect

How We Use Information

How We Disclose Information

Third-Party Content and Links

Account Management, Privacy Rights, & Other Choices

Jurisdiction-Specific Privacy Information & Rights

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 * California Residents
 * Nevada Residents
 * Information for Certain Users Outside the United States

Data Security

Children’s Privacy

Changes to Our Privacy Policy



Information We Collect

Information You Provide to Us. We collect the information you provide to us
directly when you use the Services, including when you:

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 * Register an account or for a newsletter; register for or attend an event;
   subscribe to or purchase a product (such as our newspaper); participate in a
   contest, promotion, or survey.
   * Contact information such as your name, e-mail address, street address, and
     phone number;
   * Demographic information such as year of birth, gender, general location
     such as city or state;
   * Professional Information such as job title, industry, and education; and
   * Payment information such as your credit card number (processed by our
     third-party payment processor) and expiration date, where appropriate to
     process a financial transaction that you have requested.
 * Submit Content to the Services or Interact with Content.
   * User-Generated Content such as comments on articles, content in message
     boards, images, photos, videos, online ads you post, or other content you
     provide to the Services. Please review our Discussion and Submission
     Guidelines for more information about our practices applicable to content
     that you submit to certain areas of our Services.
   * Actions You Take Related to Content such as sharing content; customizing
     newsletters, notifications, and alerts; and liking, replying to, or
     reporting (and providing additional information regarding) comments.
 * Contact Us or Provide Feedback.
   * Contact information such as your name, e-mail address, street address, and
     phone number;
   * Comments, requests, and questions you submit through customer service
     interactions with us; and
   * Survey responses, which may include your interests, opinions, and
     information about you including demographic information. From time to time
     our surveys offer you the option to voluntarily provide information that
     may be considered sensitive under applicable law such as your race or
     ethnicity. We process such information for disclosed purposes as permitted
     by and in compliance with applicable law.

Automatically Collected Information. We (and service providers on our behalf)
automatically collect certain information about your use of the Services or your
device. For example, we may collect:

 * Device information such as hardware model, IP address, device identifiers,
   operating system, browser type and settings (like language and available font
   settings) and settings of the device you use to access the Services.
 * Usage information such as the Services you use, the time and duration of your
   use, and other information about your interaction with content, such as the
   articles you read, where you click on our site, customer service
   interactions, cursor movements, and certain screen interactions and images
   (please note we do not capture personal information that you type into form
   fields (e.g., name or email address) before you submit such information), and
   how you interact with our emails.
 * Location information such as general location derived from your computer’s IP
   address, your mobile device’s GPS signal, or information about nearby WiFi
   access points and cell towers that may be transmitted when you use certain
   Services.

We and our service providers may use cookies, web beacons, and other tracking
technologies to collect such information. See our Cookie Notice for more
information about these technologies.

Information From Third-Party Sources. We may receive online or offline
information about you from other sources, which we may combine with other
information we receive from or about you. For example, we receive information
from:

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 * Other Users, including your contact information if they provide you a gift
   subscription.
 * Enterprise Subscribers, such as your employer or educational institution who
   provide us with your email address so you can register an account and use the
   Services.
 * Publicly and commercially available sources, as permitted by law, including
   contact information, demographic and professional data, and interests.
 * Social Media Services, if you interact with us through a social media service
   or log in using social media credentials. Depending on your social media
   settings, we may have access to your information from that service, such as
   your name, email address, friend or followers/following list, profile and
   demographic information, current city, comments about or reactions to our
   Services, and the people/sites you follow.
 * Data analytics providers and advertising partners, including usage
   information, and information about your activity and transactions on other
   websites or platforms or with other companies.

Other Information We Collect. We also may collect other information about you,
your device, or your use of the services in ways that we describe to you at the
point of collection or otherwise with your consent. You may choose not to
provide us with certain types of information but doing so may affect your
ability to use some of the Services. We also collect information from suppliers,
business partners, and similar businesses, including: contact and business
information such as name, phone number, email address, and postal address,
government identifier, and business name, industry, locations, other information
related to your employer; financial and transactional information if needed to
make or receive payments; and, communications with us including your name, email
address, and phone number and the contents of any communications you have with
us.

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How We Use Information

We may use your information:

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To Provide and Manage the Services, including to:

 * provide account access, process your registrations and subscriptions, send
   you electronic newsletters, and/or enable you to participate in the features
   (such as commenting) provided by the Services;
 * complete your payments and transactions;
 * provide customer service;
 * understand and resolve technical issues, app crashes and other issues being
   reported;
 * personalize the Services, including content and recommendations (including
   via email). Through such features, we are able to bring you information and
   content tailored to your individual interests and needs.

To Contact You. We may periodically contact you with Services-related updates,
new features you are entitled to access, legal information, customer service
communications, newsletters and alerts (where applicable, based on your
registrations and preferences), surveys, offers, promotions, and other
information that may be of interest to you.

To Better Understand Our Readers and Users and Improve our Services. We analyze
our users’ interactions with the Services along with demographics, interests,
and other information to better understand and serve our users and to improve
our Services.

To Deliver and Measure Advertising, Including Targeted Advertising. We and third
parties may use your information to deliver you ads, promotions, and offers that
may be personalized to you, and to measure the placement, frequency, efficacy,
and compliance of advertising and ad impressions (including contextual and
targeted ads). The ads are for us and third-party advertisers and appear both on
and off the Services.

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We and third parties may use cookies and other tracking technologies to
understand how you use the Services and facilitate serving relevant ads. This
helps us determine if you have seen an ad before, tailor ads to you, including
based on your activity, and avoid showing you duplicate ads. See our Cookie
Notice for more information about how we use cookies and other tracking
technologies and for your cookie choices, including how to opt out of
personalized advertising.

We may also use other information we have collected about you, such as
demographic and personal information (e.g., e-mail address) for purposes related
to advertising, including personalized advertising.

To Protect the Rights of the Services and Others. We may use your information
that we, in good faith, believe is necessary or appropriate to secure, protect,
enforce, or defend the legal rights, privacy, safety, or property of the
Services, its employees or agents, or other users, and to comply with applicable
law and legal process.

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With Consent. We may otherwise use your information with your consent or at your
direction.



How We Disclose Information

We may disclose your information to:

 * Affiliates within our family of affiliated companies.
 * Business Partners to provide you with services that you participate in or
   request, such as co-sponsors of a promotion that runs on our Services. We are
   not responsible for the privacy practices of these entities.
 * Service Providers that provide services on our behalf, such as hosting
   vendors, analytics or advertising service providers, list managers and
   payment processors.
 * Other Parties When Required by Law or As Necessary to Protect Our Users and
   Services including as we believe is necessary or appropriate to protect,
   enforce, or defend the legal rights, privacy, safety, or property of the
   Services, our employees or agents or users, or to comply with applicable law
   or legal process, including responding to requests from public and government
   authorities.
 * Social Media Services, if you log into the Services with a social media
   service or if you connect a social media account with the Services. In that
   case, we may disclose certain of your personal information to that social
   media service depending on your settings. The social media service’s privacy
   policy then applies to their practices regarding your information.
 * Third Parties that Provide Advertising, Content, or Other Functionality.
   Third parties may collect or receive certain information about you and/or
   your use of the Services to provide ads (including targeted ads), content, or
   functionality, or to measure and analyze ad performance, on our Services or
   other websites or platforms.
   * We may share or allow third parties to collect device information (e.g.,
     browser type, IP address, or device ID), usage information, or click
     information obtained through cookies or other tracking technologies. Some
     of this information may be combined with information collected across
     different websites, online services, and other linked or associated
     devices. We try to limit how our third parties can use the information they
     gather from you or that we provide. However, some advertising and analytics
     vendors may combine information they gather about you through our Services
     with information they receive from others in order to target ads to you
     across other services and to improve their own services. Our Cookie Notice
     provides more information about how these technologies are used.
   * We may also disclose information, including personal information about you
     (e.g., e-mail address) in hashed or other obscured format, for advertising
     purposes, including targeted advertising, either on our Services or for our
     products on other websites or platforms. Recipients may only use this
     information for the purposes for which it is provided.
 * Other Parties in Connection with a Corporate Transaction. We may disclose
   information we have about you in the event that we sell or transfer all or a
   portion of our business or assets to a third party, such as in the event of a
   merger, acquisition, or in connection with a bankruptcy reorganization, or in
   contemplation of or due diligence related to such a corporate transaction.
 * Otherwise With Your Consent or At Your Direction. We may also disclose
   information about you with third parties whenever you consent to or direct
   such sharing.

We also may disclose other information with third parties in a manner that does
not identify particular users, including, for example, aggregated data about how
users are using our Services.



Third-Party Content and Links

Our Services may embed content from, or link to, third-party websites and
services, including social media platforms, that are outside of our control. We
are not responsible for their practices and this Privacy Policy does not govern
those third parties’ content, services, or use of your information.

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Account Management, Privacy Rights, & Other Choices

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Account & Subscription Management. You may access or modify your Washington Post
account, update your subscriptions and email newsletters associated with that
account, and view your comment history on the User Profile page.

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Email Promotions. You may opt out of receiving commercial email messages from us
by following the instructions contained in those email messages.

Privacy Rights. Depending on where you live, you may have certain rights with
respect to your information.

 * California, Colorado, Connecticut, Utah and Virginia residents, in addition
   to residents of the EEA, UK, or Switzerland, may be able to request:
   * access to and/or a copy of certain personal information we hold about you;
   * correction of inaccurate information that we have about you;
   * deletion of certain personal information we have collected from you; and/or
   * provide information about financial incentives that we offer to you, if
     any.
 * California, Colorado, Connecticut, Utah and Virginia residents also have opt
   out rights described below.
 * California residents can also request information about the categories of
   personal information we collect, disclose or sell or share about you; the
   categories of sources of such information; the business or commercial purpose
   for collecting or selling or sharing your personal information; and the
   categories of third parties to whom we disclose personal information. Such
   information is also set forth in this Privacy Policy. Residents of certain
   other countries may be able request one or more of the above under applicable
   law.

Please note: Your rights and our responses will vary based on your state or
country of residency. You may be located in a jurisdiction where we are not
obligated, or are unable, to fulfill a request. In such a case, your request may
not be fulfilled.

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If you would like information regarding your rights or would like to make a
request (or if you are an authorized agent acting in accordance with applicable
law), please click here or email us at privacy@washpost.com.

 * We will take reasonable steps to verify your identity and requests, including
   by verifying your account information, residency or the email address you
   provide. If you are an authorized agent submitting a request on behalf of
   another individual, we may require proof of your written authorization before
   processing the request.
 * Certain information may be exempt from such requests under applicable law
   such as information we retain for legal compliance and to secure our
   Services. We may need certain information in order to provide the Services to
   you; if you ask us to delete it, you may no longer be able to use the
   Services.
 * Applicable law may further provide you with the right to not be discriminated
   against for exercising your rights.
 * If you have enabled a legally recognized browser-based opt out preference
   signal (such as Global Privacy Control) on your browser, we recognize such
   preference in accordance and to the extent required by applicable law.
 * Virginia, Colorado, and Connecticut residents may appeal the denial of a
   request here: please click here or email us at privacy@washpost.com.

Opt Out of Sale of Personal Information or Sharing or Processing of Personal
Information for Targeted Advertising (California, Colorado, Connecticut, Utah
and Virginia Residents Only).

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If you are a California, Colorado, Connecticut, Utah or Virginia resident, you
may opt out of certain processing of your personal information, including for
targeted advertising, under applicable law. Targeted advertising is when we or
our partners display ads to you based on your personal information that is
collected across different businesses.

We and our advertising partners collect certain information from our visitors,
such as device identifiers, cookies, advertising IDs, IP addresses and usage
activity. We and our ad partners share this information with third parties or
combine it with information from other businesses to deliver more relevant
(targeted) ads to you and for related advertising activities. We may also share
or use hashed contact information for this purpose. This activity is known as
“sharing” or processing your personal information for targeted ads and may be
considered “selling” your personal information under applicable law.

If you (or in applicable states, your authorized agent) would like to opt out of
our use or disclosure of your information for such purposes, you can follow the
steps at Your Privacy Choices. Note, if you use a cookie blocker such as
Ghostery, it may block visibility of this tool or link, including in your web
footer.

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Even if you opt out, you will still see advertising, it just may be less
relevant to you, or it may be personalized for you based only on the data that
the Washington Post has collected about you. Unless you sign in, you must opt
out on each device and each browser where you want your choice to apply. Your
preference may be lost if you clear, or your browser is set to clear, cookies.
If you have enabled a legally recognized browser-based opt out preference signal
(such as Global Privacy Control) on your browser, we recognize such preference
in accordance and to the extent required by applicable law. You will need to
turn this on for each browser you use unless you sign into your Washington Post
account.

Analytics. Some analytics providers we partner with may provide specific opt-out
mechanisms. For example, you may opt out of having Google Analytics use your
information for analytics by installing the Google Analytics Opt-out Browser
Add-on. You can visit our Cookie Notice for additional information on how to opt
out of certain analytics providers.

Targeted Advertising. In addition to other choices outlined above, our Cookie
Notice has information about how to manage cookies and other choices that may be
available to you with respect to personalized advertising. You may choose
whether to receive certain targeted advertising from participating ad networks,
audience segment providers, ad serving vendors, other service providers or
entities by visiting websites operated by the Network Advertising Initiative and
Digital Advertising Alliance or if you are a user in the European Economic Area,
Your Online Choices. These third-party tools may have limitations such as the
browsers on which they are effective. Many mobile devices also allow you to
opt-out of certain personalized advertising for mobile apps and related tracking
using the settings within the mobile app or your mobile device. For more
information, please check your mobile device settings.



Jurisdiction-Specific Privacy Information



Additional Information for California Residents

If you are a California resident, the California Consumer Privacy Act (“CCPA”)
requires us to provide you with some additional information.

 * We may collect, use, and disclose for our business and commercial purposes,
   the following categories of information about you or your use of the
   Services:
   * Identifiers (such as name, address, email address); commercial information
     (such as transaction data); financial data (such as credit card
     information); user-generated content; device information and identifiers
     (such as IP address); internet or other network or device activity (such as
     browsing history or app usage); professional and employment related
     information; location data; audio or visual information (such as if you
     participate in a phone survey or submit a photo); demographic data (such as
     gender); inference data; and other information that identifies or can be
     reasonably associated with you.
   * Please see Information We Collect above for more information
 * We may use the above categories of information:
   * to provide and manage the Services you request; to contact you; to deliver
     advertising; to better understand our readers and users and improve our
     Services; for bug detection and error reporting; to audit consumer
     interactions on the Services; to protect the rights of the Services and
     with your consent.
   * Please see How We Use Information above for more information.
 * We may disclose
   * any of the above categories of information we collect with: our affiliates;
     business partners to provide you with services that you request; service
     providers; other parties, including government entities, when required by
     law or to protect our users and services; social media services pursuant to
     that service and your settings; and with your consent or in connection with
     a corporate transaction.
   * commercial information and financial data, including your payment
     information, with payment processors and service providers, and
   * device information and identifiers and internet or other network or device
     activity with entities that provide content, advertising, and
     functionality.
   * Please see How We Disclose Information above for more information.

Sale or sharing of personal information. We engage in targeted (or cross context
behavioral) advertising on the Services or on other sites and when we advertise
our Services elsewhere. In connection with such advertising, we may share the
following categories of information with advertising networks and providers,
advertisers, and social media networks, which may be considered a sale under
California law and is the processing of personal information for targeted
advertising:

 * device information and identifiers, such as IP address, and unique
   advertising identifiers and cookies; hashed identifiers such as contact
   information, usage information, such as browsing history or app usage;
   location information, such as city; and inference data.

California residents can opt out of such targeted advertising as set forth here:
Your Privacy Choices. California residents can also turn on the Global Privacy
Control (GPC) to opt out of the “sale” or “sharing” of your personal information
that is browser based for each participating browser system that you use. Learn
more at the Global Privacy Control website.

Right to Limit. The CCPA also allows you to limit the use or disclosure of your
“sensitive personal information” (as defined in the CCPA) if your sensitive
personal information is used for certain purposes. Please note, in the limited
circumstances that we process sensitive personal information as defined by the
CCPA, we do not use or disclose it other than for disclosed and permitted
business purposes for which there is not a right to limit under the CCPA.

Retention. We keep your information to fulfill the purposes described above,
unless a longer retention is required or permitted by law. Our retention is
based upon the amount, nature and sensitivity of the information, the potential
risk of harm from unauthorized use or disclosure of the information, the
purposes for which we process the information, applicable legal requirements,
and our legitimate interests. The purposes for which we process information may
dictate different retention periods for the same types of information. For
example, we retain your email address as an authentication credential (where
applicable) as long as you have an account with us and an additional period of
time after that for our legitimate interests and for our fraud and legal
compliance purposes. If you opt out of email marketing, we maintain your email
on our suppression list for an extended time to honor your opt out. We may
delete or de-identify your information sooner if we receive a verifiable
deletion request, subject to exemptions under applicable law.

We received the following requests to know and requests to delete from
California consumers and other individuals from January 1, 2022 to December 31,
2022:

Average number of days
to complete
Requests to Know Received
53

Completed
7
41.4
Incomplete
(due to lack of verification or confirmation of request)
46
N/A
Requests to Delete Received
6252

Completed
1645
35
Incomplete (due to lack of verification or confirmation of request)
4607
N/A

We received approximately the following number of requests to opt out from
California consumers from January 1, 2022 to December 31, 2022:

Average number
of days to complete
CCPA Requests to Opt Out*


Completed
7,473
<1
Incomplete
N/A
N/A

*Number of requests to opt out is approximate due to certain technical
limitations and because certain requests are made through third party tools.

Once a year, California residents can also request certain information regarding
our disclosure, if any, of certain categories of personal information to third
parties for their direct marketing purposes in the preceding calendar year. We
do not share personal information with third parties for their own direct
marketing purposes.

California residents who are under 18 and registered users of the Services can
request removal of content that they have posted on the Services by emailing us
at comments@washpost.com with your name and email address and/or your Washington
Post username, birth year, mailing address, and the material that you want
removed and information that will enable us to locate it, and the subject line
“California Removal Request”. Your request does not ensure complete removal of
the material. For example, materials may be republished or reposted by another
user or third party.

Do Not Track. Some web browsers may transmit a “do-not-track” signal. Because
there currently is no industry standard concerning how to treat such signals,
the Services currently do not take action in response to do not track signals.
We respond to legally recognized browser-based opt out signals such as the
Global Privacy Control signal for California residents.



Nevada Residents

Nevada consumers who have purchased goods or services from us may opt out of the
“sale” of “covered information” as such terms are defined under Nevada law. We
do not engage in such activity, but if you have questions about this you can
email us at privacy@washpost.com.



Additional Information for Certain Users Outside the United States

Under applicable law in the EEA, UK, and Switzerland, the Washington Post is
considered the “data controller” of the personal information we handle under
this Policy. In other words, The Washington Post is responsible for deciding how
to collect, use and disclose this information, subject to applicable law. Our
contact information appears at the end of this Policy. Residents of certain
jurisdictions may be able to request one or more individual rights set forth in
“Individual Rights” below under applicable law.

International Transfers. The Services are headquartered in the United States,
where we process and store information. We may also store information on servers
and equipment in other countries depending on a variety of factors, including
the locations of our users and service providers. We will ensure that transfers
of personal data to a third country or an international organization are subject
to appropriate safeguards. By using the Services or otherwise providing
information to us, you consent to the processing, transfer, and storage of
information in and to the U.S. and other countries, where you may not have the
same rights as you do under local law. Our Data Privacy Framework Policy governs
use of personal information transferred to us from organizations in the EEA, UK,
and Switzerland under such transfer mechanism.



Users in the EEA, United Kingdom, and Switzerland

Purposes of processing and legal basis for processing. We process personal data
consistent with our disclosures in this Privacy Policy. We process personal data
on the following legal bases: (1) as necessary to perform our agreement to
provide Services to you; (2) as necessary for our legitimate interests in
providing the Services where those interests do not override your fundamental
rights and freedoms related to data privacy; or (3) with your consent.

If applicable, you may make a complaint to the data protection supervisory
authority in the country where you are based. Alternatively, you may seek a
remedy through local courts if you believe your rights have been breached.

Additional Marketing & Advertising Choices.

Our Cookies Notice has information about how to manage cookies and other choices
that may be available to you with respect to personalized advertising.

If you are a resident of the EEA, UK, Switzerland, or Canada, as described
above, you may opt out of (withdraw your consent to) receiving marketing emails
from us by following the instructions in such emails. You may also opt out of
(withdraw your consent to) our use of your email to provide you special offers
via email and through other platforms (such as social media) by completing our
webform here.



Data Security

We have in place physical, electronic and managerial procedures to help protect
the information we collect. However, as effective as these measures are, no
security system is impenetrable. We cannot guarantee the security of our
systems, nor can we guarantee that the information you supply will not be
intercepted while being transmitted to us over the Internet.



Children’s Privacy

We do not knowingly collect any personal information from children under the age
of 16 without parental consent, unless permitted by law. If we learn that a
child under the age of 16 has provided us with personal information, we will
delete it in accordance with applicable law.

Changes to this Privacy Policy

We may modify this Privacy Policy from time to time. We will notify you of
changes by posting changes here, or by other appropriate means. Any changes to
the Privacy Policy will become effective when the updated policy is posted on
the Services. Your use of the Services or your provision of information to us
following such changes indicates your acceptance of the revised Privacy Policy.

For More Information. Please contact us here.


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interest is used, or at any time in the privacy policy page. These choices will
be signaled to our partners and will not affect browsing data.

If you click “I accept,” in addition to processing data using cookies and
similar technologies for the purposes to the right, you also agree we may
process the profile information you provide and your interactions with our
surveys and other interactive content for personalized advertising.

If you do not accept, we will process cookies and associated data for strictly
necessary purposes and process non-cookie data as set forth in our Privacy
Policy (consistent with law and, if applicable, other choices you have made).


WE AND OUR PARTNERS PROCESS COOKIE DATA TO PROVIDE:

Actively scan device characteristics for identification. Create profiles for
personalised advertising. Use profiles to select personalised advertising.
Create profiles to personalise content. Use profiles to select personalised
content. Measure advertising performance. Measure content performance.
Understand audiences through statistics or combinations of data from different
sources. Develop and improve services. Store and/or access information on a
device. Use limited data to select content. Use limited data to select
advertising. List of Partners (vendors)

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