Last updated: July 20, 2020
Table of contents
If we make a significant or material change in the way we collect, use or share your personal information, we will notify you at least 30 days prior to the changes taking effect. We will do this via email or prominent notice within the Services. If you object to any change, you can stop using the Services.
The information we collect depends on the context. By and large, it is information about you that can personally identify you—either on its own or when combined with other information.
The following describes the information we collect and how we obtain it.
Information collected through the Services.
i. Information You Voluntarily Give Us
When you sign up to receive our emails, newsletters or other communications, we collect your email address;
When you choose to participate in contests, sweepstakes or other promotions offered via the Services, you give us your name, email, and any other information required;
When you contact our customer service, or request any other assistance, we collect information from you;
When you choose to take a survey, whether online or offline, or participate in an in-person reader interview, we gather information about you.
ii. Information Collected Automatically.
Through Tracking Technologies in Your Browser or Device:
Like many services, our Services use tracking technologies. These technologies include cookies, web beacons, tags and scripts, software development kits (or SDKs) and beyond. They help us monitor traffic, improve the Services and make it easier and relevant for your use.
We track and store data about how you visit and use the Services, particularly through our Site. The items we log include:
- Your Media Access Control (MAC) address
- Your computer type (Windows or Mac)
- Your screen resolution
- Your IP address
- Your location
- Your operating system name and version
- Your device manufacturer and model
- Your browser provider and version
- Your browser language
- Your internet service provider name
- The URLs of any pages you visit on our Site
- Device identifiers
- Advertising identifiers
- Additional “traffic data” such as time of access, anonymous visitor ID, traffic channel, traffic source, traffic medium, campaign name, date of access, session identification number, access times, and referring website addresses;
- Search terms and results;
- Other usage information.
If your computer doesn’t accept our tracking technologies, you cannot access certain parts of our Services (e.g. comments). Because the “Do Not Track” browser-based standard signal has yet to gain widespread acceptance, we don’t currently respond to those signals.
iii. Information collected from other sources.
iv. Social media platforms and other third-party services:
(Social media platforms include Facebook. Third-party services include MailChimp)
We receive information from you when you interact with our pages, emails, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “like,” comments, shares, reposts, and clicks), awareness data (e.g, number of impressions and reach) and individual users’ public profiles.
A note about future updates:
We are always improving our products and services, and we create new features regularly. These updates sometimes require us to collect new information, or use what we already have differently. If there is a significant or material change in the way we handle your personal information, we will notify you as detailed above.
A. We Provide the Services.
We use your information to help you use and navigate the Services, such as:
- Making the Services available to you
- Sending service-related communication (e.g., changes to our policies)
- Providing customer service
- Send you newsletters and emails
- Letting you take part in contests, sweepstakes, promotions, surveys and comments
- Optimize or improve our products, services and operations
- Arrange access to and communicate with you about your account
- Respond to your inquiries, requests, suggestions or complaints
- Send you information about features and enhancements of the Services
B. We Personalize Your Experience.
We perform statistical and marketing analyses of users of the Services. We highlight articles you might be interested in. We also show you promotions, products or services we believe you’ll find interesting based on usage data.
C. We Allow You to Share User-Generated Content.
Any information you disclose in your content becomes public – along with your chosen screen name and uploaded photo.
D. We Develop Products and Services, and Do Analysis.
We analyze data on our users’ purchase and usage behaviors, this helps us make business and marketing decisions.
For example, our analysis lets us predict preferences for our products and services. It helps us determine whether our marketing is successful. It also shows us characteristics about our users, which we sometimes share in aggregate with advertisers.
Google Analytics is one of the analytics providers we use. You can find out how Google Analytics uses data and how to opt out of Google Analytics.
E. We Carry Out Administrative Tasks.
For auditing: We verify that our internal processes work as intended, and comply with legal, regulatory and contractual requirements.
For fraud and security monitoring: We detect and prevent cyberattacks or unauthorized robot activities.
For customer satisfaction: We assess users’ satisfaction with the Services and our customer care team.
The above activities can involve outside companies, agents or contractors (“service providers”) with whom we share your personal information for these purposes (discussed further below).
F. We offer sweepstakes, contests and other promotions.
You can take part in our sweepstakes, contests, and other promotions. Some might have additional rules about how we use and disclose your personal information.
G. We allow for personalized advertising on the Services.
We gather data and work with third parties to provide you with advertising, including personalized ads. This data comes from ad tracking technologies (e.g., cookies), data collected as you use the Services (e.g., your reading history), data from advertisers or advertising vendors (e.g., demographic data) and anything inferred from any of this information based on your activity on the Services or activity on third-party sites and applications.
For more about targeted advertising, and how to opt out with your specific browser and device, go to the DDA Webchoices Browser Check and NAI Opt Out of Interest-Based Advertising. You can download the AppChoices app to opt out in mobile apps. You can also follow the instructions in the “What Are Your Rights?” section below.
We try to limit how our third-party advertising technology vendors use the information they gather from you. Many of these providers require us to enter into contracts that allow them to optimize their own services and products, or that help them create their own.
Essentially, these providers combine any information they gather about you from the Services with information they receive from their other clients. This helps them target advertisements to you on behalf of their other clients, not just us.
H. We advertise the Services to you.
We market our Services to you. Sometimes we use marketing vendors to do this.
We serve ads through websites, locations, platforms, and services operated and owned by third parties. Often, these ads are targeted at people who have visited the Site but have not purchased anything. Often these ads are targeted at people with similar traits or behaviors to our Services users.
We target our advertising to these users by incorporating a tracking technology from a third party onto our Services. We will also opt you out of such tracking technology if you are a California resident and you exercise your right not to have your personal information “sold” after January 1, 2020, as discussed further below.
To opt out of receiving these matched ads, contact the applicable third party. For example, when we use the “Custom Audience” to serve you our ad through Facebook, you should be able to hover over the box in the right corner of that Facebook ad and opt out. We are not responsible for any third party’s failure to comply with opt-out requests.
We periodically send you targeted email newsletters or promotional emails. For information on opting out of these emails, see “What Are Your Rights?”
I. We aggregate (or de-identify) personal information into larger findings.
Sometimes we aggregate or de-identify information so that it will no longer identify you, under applicable laws. This helps us better understand and represent our users, such as when we measure ad performance statistics or compile survey results. We can use and disclose this aggregated or de-identified information for any purpose, unless an applicable law says otherwise.
With Service Providers. We share information collected from you with service providers, as defined above, to provide support services or perform functions on our behalf, such as marketing, analytics, and customer service. We sometimes allow them to use aggregated or de-identified information for other purposes, in accordance with applicable law.
With Other Third Parties. There are situations when we share your information with third parties beyond our service providers. We never share your email address with these third parties without your consent, except in encrypted form to engage in the matched ads process described above.
We share information about participants in our sweepstakes, contests and similar promotions on the Services with the promotions’ sponsors. In those cases, we notify you provide us the information.
We can preserve or share personal information if the law requires us to do so. We can also preserve or share personal information if we believe it would be necessary to:
Comply with the law or with legal process;
Protect and defend our rights and property;
Protect against misuse or unauthorized use of the Services;
Protect the safety or property of our users or the general public (e.g., if you provide false information or attempt to pose as someone else, we could share your information to help investigations into your actions); and
Cooperate with government authorities, which could be outside your country of residence.
In the event of any reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we would have a legitimate interest in disclosing or transferring your information to a third party – such as an acquiring entity and its advisors.
We share information with third parties to help us determine how people use parts of the Services so we can improve our Services and develop new product offerings.
We generally do not want to gather any sensitive information about you. This includes:
- Your social security number
- Your racial or ethnic origin
- Your political opinions
- Your religion or other beliefs
- Your health, biometrics or genetic characteristics
- Any trade union membership
- Any criminal background
There are rare situations when we request this information (e.g., surveys), but you can decline to answer. Outside those situations, we would prefer you never share that information with us.
We protect your personal information with a series of organizational, technical and physical safeguards – but we cannot guarantee its absolute security.
If you have reason to believe that your interaction with us is no longer secure, notify us immediately.
A. How Do I Opt-Out of Email?
If you do not want to receive email newsletters from us, you can unsubscribe from them by following the “unsubscribe” instructions near the bottom of the email. You can also send a request to firstname.lastname@example.org.
We will comply with your request(s) as quickly as we can. This opt out request, won’t prohibit us from sending you important non-marketing notices.
B. What Are Your California Shine the Light Privacy Rights?
Under the California “Shine The Light” law, California residents may opt out of our sharing their information to third parties (and sometimes affiliates) for their direct marketing purposes.
We do not share your personal information with third parties for their direct marketing purposes.
C. How You Can Access, Change, Delete, or Update Your Personal Information or Exercise Your Right to Know About Your Personal Information Collected, Disclosed, or Sold?
In some parts of the world, you have the right to:
- Access, modify, or delete the personal information we have about you.
- Receive an electronic copy of the personal information we have about you, for data portability.
- Restrict, or object to, how we process personal information about you.
- Not to receive discriminatory treatment by us for the exercise of your privacy rights.
If you’d like to exercise any of the above rights, contact us via email email@example.com. In your request, please be specific. State the information you want changed, whether you’d like your information suppressed from our database or whether there are limitations you’d like us to put on how we use your personal information. Please use the email address linked to that personal information – we only complete requests on the information linked to your email address. This is how we verify your identity before complying. To verify your identity, we will email the email address you provide us, and which matches our records, and wait for your response. In some instances we may also ask for additional information. This is how we verify your identity before complying.
You can designate an authorized agent to make a request on your behalf. In order to do that, please provide us a notarized power of attorney.
We will respond to your request consistent with applicable law.
We might need to keep certain information for recordkeeping purposes, or to complete a transaction you began prior to requesting a change or deletion (e.g., when you enter a promotion, you may not be able to change or delete the personal information provided until after the completion of such promotion).
In some cases, your request doesn’t ensure complete removal of the content or information (e.g., if another user has reposted your content).
If you’d like, you can lodge a complaint with a data protection authority. A list of EU data protection authorities is available.
D. What Are My California “Do Not Sell My Personal Information” Rights?
If you’re a California resident, you can request that we stop sharing your personal information with third parties who are not our service providers (in accordance with the California Consumer Privacy Act). Follow this link, email us at firstname.lastname@example.org with the subject line “California Residents – Do Not Sell” with the subject line “California Resident – Do Not Sell.”
It depends. We store your personal information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law).
When deciding how long to keep your information, we consider:
How long we’ve had a relationship with you, or provided the Services to you.
Whether we are subject to any legal obligation (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them).
Whether we have taken any legal positions (e.g., in connection with any statutes of limitations).
Rather than delete your data, we might de-identify it by removing identifying details.
In addition, we are not responsible for the information collection, use, disclosure or security policies or practices of other organizations, such as Disqus, Facebook, Twitter, Apple, Google, Microsoft, RIM or any other app developer, app provider, social media platform provider, operating system provider, wireless service provider or device manufacturer, including with respect to any personal information you disclose to other organizations through or in connection with our Social Media Pages.
The Services are intended for a general audience, and are not directed to children under (13) years of age.
We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or “COPPA”) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us email@example.com. We will remove the data to the extent required by applicable law.
In California, we do not knowingly “sell” the personal information of minors under 16 years old (to understand what “sell” means).
HES is headquartered in the United States. If you are located outside the United States, your information is collected in your country and then transferred to the United States – or to another country in which we (or our affiliates or service providers) operate.
If we transfer your data out of the European Economic Area (EEA), we implement at least one of the three following safeguards:
We transfer your information to countries that have been recognized by the European Commission as providing an adequate level of data protection according to EEA standards (the full list of these countries).
We use a service provider in the United States that is Privacy-Shield certified.
We take steps to ensure that the recipient is bound by EU Standard Contractual Clauses, to protect your personal data. You can see a copy of these clauses.
In certain circumstances, courts, law enforcement agencies, regulatory agencies or security authorities in those other countries may be entitled to access your personal information.
In some jurisdictions, like the European Union and the European Economic Area, we only collect, use or share information about you when we have a valid reason. This is called “lawful basis.” Specifically, this is one or more of the following:
The consent you provide to us at the point of collection of your personal information
The performance of the contract we have with you
The compliance of a legal obligation to which we are subject or
The legitimate interests of HES, a third party or yourself. “Legitimate interest” is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are good reasons for the processing of your personal information and that we take measures to minimize the impact on your privacy rights and interests. “Legitimate interest” also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact.
We have a legitimate interest in gathering and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within HES; (3) to prevent fraud; and (4) to conduct our marketing activities.
If you have any questions, email us at firstname.lastname@example.org or write us at:
Attn.: Privacy Department
9202 S. Northshore Drive, Suite 202
Knoxville, TN 37922