For the purposes of the European General Data Protection Regulation 2016/679 (the “GDPR”), NewsGuard Technologies, Inc. is the “data controller” of, and is responsible for, European personal information collected through the website www.newsguardtech.com (the “Website”).
By email: email@example.com
By post: NewsGuard Technologies, Inc.
25 West 52nd Street
New York, NY 10019
Attn.: Privacy Counsel
By telephone: +1-740-480-1850
VeraSafe has been appointed as NewsGuard’s representative in the European Union for data protection matters, pursuant to Article 27 of the GDPR. VeraSafe can be contacted, in addition to NewsGuard, for matters related to the processing of your personal data only. To make such an inquiry, please contact VeraSafe using the details set out below:
By post: VeraSafe Ireland Ltd.
Unit 3D North Point House
North Point Business Park
New Mallow Road
By telephone: +420 228 881 031
Categories of Personal Information Collected by NewsGuard
- Account Information
If you decide to create an account in order to purchase our browser extension, we will ask you to provide us with some specific information, including: your name, email address, login details such as username and password, the country where you reside, and payment details.
- Personal Information That You Provide to Us
Website visitors and users of our browser extension and mobile apps provide Personal Information to us in a number of ways, for example when choosing to subscribe to our browser extension, our mobile apps, or our newsletter, or by providing us with feedback, reporting an error or factual mistake in one of our nutrition labels.
The Personal Information you provide to us may include “Contact Information,” such as first name, surname, email address, telephone number, and postal address.
- Personal Information We Collect
When you visit our Website or use our browser extension or mobile apps, we may collect “Electronic Identification Data,” including: Internet protocol (IP) address; Information about the computer, mobile device or other device you use to access the Website, browser extension, or mobile apps, such as web browser type, language and version, screen size and other transactional information; Geolocation information (this is limited to the region from which you access our Website, browser extension, or mobile apps); and Information about your visit, including pages you viewed or searched for, page response times, download errors, length of visits to certain pages, page interaction information (such as scrolling, clicks, and mouse-overs), and methods used to browse away from the page, etc.
Use of Your Personal Information
We will process your Personal Information for the following purposes as is necessary for the performance of a contract between you and us (including our Terms of Service) or to answer questions or take steps at your request prior to entering into a contract:
- To provide our services;
- To notify you about changes to our services; and
- To respond to queries or requests and to provide technical support
We will process your Personal Information for the following purposes as is reasonably necessary in our legitimate business interests, or where you have given your informed consent to such processing if required by applicable law (such consent may be withdrawn at any time):
- To respond to feedback submissions;
- To respond to errors or factual mistakes reported in one of our nutritional labels;
- To prevent or detect fraud, malicious activity or abuses of our Website, browser extension, or mobile apps and to keep our Website, browser extension, and mobile apps safe and secure;
- To administer our Website, browser extension, and mobile apps and for troubleshooting, data analysis, testing, research and statistical analysis;
- To create products and services that might meet your needs;
- To know basic information about the use of our Website, browser extension, and mobile apps, such as which nutrition labels are getting the most traffic or which geographical areas are yielding the most users;
- To operate, improve and optimize our services, for example by reviewing visits to our Website and its various subpages and use of our browser extension and mobile apps;
- To protect our legal rights and property in connection with our services;
- To investigate and prevent fraud or potentially illegal activities and to investigate potential violations of and to enforce our Terms of Service;
- To keep you updated by sending you NewsGuard newsletters; and
- To send you personalized marketing communications, in order to keep you informed of our and products and services which we consider may be of interest to you.
Does NewsGuard Share Your Personal Information?
We may share Personal Information in the following ways:
- We will share Personal Information with our service providers, who are bound by law and contract to protect your Personal Information and only use your Personal Information in accordance with our instructions.
- We will share Personal Information when needed to enforce our rights, protect our property or protect the rights, or safety of NewsGuard and others or to support external auditing, compliance and corporate governance functions.
- We may share Personal Information with one or more third parties in connection with or during negotiation of any merger, financing, acquisition or dissolution, transition, or proceeding involving the sale, transfer, divestiture, or disclosure of all or a portion of our business or assets.
- We will disclose Personal Information when legally required to do so and in response to lawful requests by public authorities, including to meet national security or law enforcement requirements, such as in response to a subpoena or other request, including to law enforcement agencies and courts in the United States and other countries where we operate.
- To bill our customers: Our authorized payments processors use your Personal Information to take payments, give refunds and to detect and prevent fraudulent activity. You can manage your subscription and payment information by visiting the Account Section.
We will only transfer your Personal Information to trusted third parties who provide sufficient guarantees in respect of the technical and organizational security measures governing the processing to be carried out and who can demonstrate a commitment to compliance with those measures.
Where Personal Information relating to individuals based in the European Economic Area (“EEA”) is shared with a third party located in a non-EEA country that has not received an adequacy decision by the European Commission, we rely on appropriate safeguards, such as the European Commission-approved Standard Contractual Clauses and EU-U.S. Privacy Shield Framework, to transfer the Personal Information.
How Do We Store Your Personal Information and For How Long?
We store your Personal Information on internal databases for no longer than is necessary for the purpose for which such Personal Information is processed.
Personal Information from the contact form is deleted six months after your submission. Backups are kept for a maximum of six months, after which they are securely deleted. You can always request this information be deleted at any time.
Personal Information for subscribers has two parts: information we store in our internal databases and information stored within our third-party processor, Stripe. We retain the data stored in our internal databases for two years after your cancellation date to comply with legal, tax, and accounting obligations. If you have never subscribed to NewsGuard but have provided Personal Information as part of registering to subscription, you can request your registration deleted.
If you purchased your subscription from NewsGuard directly, your Personal Information is also stored indefinitely within Stripe to comply with their respective legal, tax, accounting, and financial obligations.
We design our data collection and storage systems with the priority of your security and privacy. We use standard industry practices to protect your data, including firewalls, SSL encryption, and co-location at 24/7 secured, controlled environments. Additionally, if you purchased a subscription from NewsGuard, your financial data is stored by a certified PCI Level 1 Service Provider, the most stringent level of certification available in the payments industry.
Changing Personal Information
You have the right to request copies of your personal submissions to the User-Generated Feedback form NewsGuard within the last six months.
You have the right to access, correct and request removal of your Personal Information by e-mailing us at firstname.lastname@example.org.
European Privacy Rights
In certain circumstances, you may have the following rights in relation to your Personal Information:
- Request access to your Personal Information. You may have the right to request access to any Personal Information we hold about you as well as related data, including the purposes for processing the Personal Information, the recipients or categories of recipients with whom the Personal Information has been shared, where possible, the period for which the Personal Information will be stored, the source of the Personal Information, and the existence of any automated decision making
- Request correction of your Personal Information. You may have the right to obtain without undue delay the rectification of any inaccurate Personal Information we hold about you.
- Request erasure of your Personal Information. You may have the right to request that Personal Information held about you is deleted.
- Request restriction of processing your Personal Information. You may have the right to prevent or restrict processing of your Personal Information.
- Request transfer of your Personal Information. You may have the right to request transfer of your Personal Information directly to a third party where this is technically feasible.
- Right to object. You may have the right to object to the processing of your Personal Information when you have legitimate reasons to do so.
- Right to withdraw consent. Where processing is based on consent, you may have the right to withdraw such consent.
We aim to respond to requests made by you within one month but may extend that period by two further months where necessary.
Exercising Your Rights
To exercise the above-mentioned rights, please send an e-mail to email@example.com. We reserve the right to request the provision of additional information necessary to confirm the identity of the enquirer.
Data Processing in the United States
If you are visiting our websites and/or using our services or otherwise providing Personal Information to us from outside the U.S., be aware that your Personal Information may be transferred to, stored, and processed in the United States where our servers are located, and our central database is operated.
We also allow select third parties (e.g. Google Analytics) to collect Electronic Identification Data about our Website visitors and browser extension users to provide us with better insights into the use of the Website and browser extension provided you have given your valid consent to such collection. Such Electronic Identification Data is received on an aggregated basis and cannot be used to identify you personally. When using the browser extension, this tracking only occurs if you interact with the browser extension (e.g. hovering/clicking on a shield). We do not track when a shield appears on a page or what pages they appear on. The URL that the interaction occurs from is never tracked.
We offer you the opportunity on our Website to provide feedback on our ratings and nutrition labels. This feedback is shared internally only and is not shared with the public and is not a “public activity.”
However, if you represent a website we have rated and written about, we may post any comment or complaint you may have shared with us about that rating or write-up, but only if you have first given your consent. Separately, if we share a comment or complaint you have made, we will only share your name if you have first provided your consent to us doing so, such consent may be withdrawn at any time.
When you visit a website with the NewsGuard browser extension enabled, the browser extension sends the website domain to NewsGuard’s servers to check whether a rating and nutrition label exists for that site and, if one does, to display that rating and nutrition label in your browser.
However, NewsGuard does not collect or store this information or any information about the websites you visit. The servers and load balancers that receive this information do not store or transmit any logs of this traffic.
NewsGuard cannot and does not use data about the websites you visit for any purpose other than to serve its ratings and nutrition labels to you as you use the browser extension.
If you submit your name and email address on our Website, we may periodically send you email newsletters about our services, provided you have given your consent.
If you no longer wish to receive our newsletters, you may opt out at any time by following the “unsubscribe” instructions located near the bottom of each email.
Last updated: February 3, 2020