Denver Westword, LLC
Last Updated: September 29, 2023
Voice Media Group (Voice Media Group, LLC, 1201 E. Jefferson, Phoenix, AZ 85034) ("us", "we", or "our") operates the http://www.westword.com website (the "Service"). For users located in the United Kingdom or European Economic Area, and to the extent applicable, Voice Media Group is the data controller and is responsible for the personal information (as defined below) of UK and EEA users of the Service.
WHAT’S IN THIS POLICY?
- Categories of Personal Information We Collect About You
- How We Use Your Information
- How We Disclose the Information We Collect
- Discussion Boards and Similar Features
- Marketing Communications
- Security of Your Information
- Third Party Links
- Additional Disclosures Under Applicable Laws
- Contact Us
- Changes to this Policy
The summary provided below describes all information collected on our sites. Keep in mind that collection includes information you provide to us for our services and passive information regarding your activity on our webpages. You can opt out of receiving interest-based advertising, but opting out does not mean you will no longer receive advertising. It means that the company or companies from which you opted out will no longer deliver ads tailored to your preferences.
II. CATEGORIES OF PERSONAL INFORMATION WE COLLECT ABOUT YOU
Depending on your interaction with us, we may collect the following categories of personal information about you directly from you, from third parties, and automatically through your use of our Site.
- Identifiers, such as your name, postal address, telephone number, date of birth, IP address, unique online identifier, or similar identifier.
- Protected classifications, such as age and gender.
- Payment information, such as your financial account information, credit card number, debit card number, or other payment card information.
- Commercial Information, such as records of products or services purchased or obtained, membership records, and records of gifts.
- Professional information, such as the name of your employer and business title.
- Internet or other electronic network activity, such as your browser type and operating system; web pages you view, links you click, search history on the site, and other information regarding your interaction with an internet website, email, newsletter, or advertisement; the length of time you visit our site; and the referring URL, or the webpage that led you to our site.
- Geolocation data, as defined under applicable law.
- Inferences, such as inferences drawn to create a profile reflecting your preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, or aptitudes.
- Sensitive personal information, as defined under applicable law, such as your precise geolocation data and financial account information.
Information We Collect Directly From You. We collect personal information directly from you when you use our Service. If you sign-up to receive information or services from us or if you register for an account on our site, we may collect your contact information (e.g., name, home address, telephone number, or email address) and account login credentials. If you contact us, we may collect your contact information, as well as the contents of a message or attachments that you may send to us, and other information that you choose to provide.
Information We Collect From Other Sources. We may collect personal information from our parent, affiliate, and other related entities, as well as from third-parties that perform functions on our behalf, such as our advertising and analytics partners. When you sign in to our Service using a social media account, you give permission to the social media platform to share your personal information with us.
III. HOW WE USE YOUR INFORMATION
Depending on your interaction with us, we may use the categories of personal information described above for the following business and commercial purposes:
- To provide our Service and fulfill your requests. We use your information to provide and maintain our Service, to process and fulfill your requests, to communicate with you about your use of our Service or changes to our Service, to respond to your inquiries, and for other customer service and business administration purposes. For example, when you enroll in a newsletter, we may use your personal information to deliver that newsletter to you.
- To improve our Service. We use your information to understand and analyze our user base and how you use the Service, to improve and enhance the Service, and to develop new products, services, features, and functionality.
- Identification and authentication purposes. We may use your information for identification and authentication purposes. For example, when you enter your account login ID and password to enter one of our registration or login portals, we use your login credentials to authenticate your identity.
- Personalization. We use your information to tailor the content and information that we may send or display to you, to offer location customization, and personalized help and instructions, and to otherwise personalize your experience while using the Service. For example, if you allow us to collection geolocation data, we use this information to deliver content that is around your specific location and identify business location/listings around your location.
- Marketing and promotional purposes. We may use your information to send you news and newsletters, event updates, and to communicate with you about new features, offers, events, or products, or to otherwise contact you about information we think may be of interest to you. In relation to marketing communications, we may provide you with an “opt in” or “opt-out” mechanism depending on where in the world you are located. An “opt-in” mechanism will provide you the opportunity to positively indicate that you would like or do not object to our sending you such further communications and we will not send you any unless you have “opted-in”. An “opt-out” mechanism will provide you the opportunity to indicate that you do not want us to send you such further communications, and if you “opt-out” we will not send you any.
We may also use your information to display advertisements to you on our site (including to sell advertising space on the Service) and on other unaffiliated websites and services.
- Research and reporting. We may use your information to administer surveys and questionnaires (online and offline) for research and reporting purposes to help us better serve individuals by learning more about their needs and the quality of the products, services, and educational information we provide. The survey responses may be utilized to determine the effectiveness of our Service, various types of communications, advertising campaigns and/or promotional activities.
- Combining information. We (and our third party business partners on our behalf) may merge, co-mingle, or otherwise combine information, including your personal information, in furtherance of the purposes described above.
- To comply with legal obligations. We may use your information to comply with our legal obligations or to exercise or defend our rights or the rights of a third party, including complying with law enforcement or government authority requests and participating in compliance audits.
- To protect us and others. We may use your information where we believe it necessary to investigate, prevent, or take action regarding suspected or actual illegal activities, fraud, situations involving potential threats to the safety of any person or to otherwise enforce this Policy, our Terms and Conditions, and the integrity of the Service.
- Deidentified data. We may also deidentify or anonymize your data in such a way that you may not reasonably be re-identified by us or another party, and we may use this deidentified data for any purpose permitted under applicable law. To the extent we deidentify any data originally based on personal information, we will maintain and use such data in deidentified form and will not attempt to reidentify the data.
IV. HOW WE DISCLOSE THE INFORMATION WE COLLECT
We may disclose each of the categories of personal information described above for our business and commercial purposes as follows:
- Related Entities. We may disclose the personal information we collect about you to our parent, affiliate, and related entities in the Voice Media Group.
- Service Providers. We may disclose the personal information we collect about you to service providers, contractors, and agents who perform functions and business operations on our behalf, for the purposes set out above. For example, we engage service providers to help us with the provision of IT and related services, the provision of information that you have requested, to conduct surveys and questionnaires, and for payment processing and order fulfillment purposes.
- Third Parties. We may disclose the personal information we collect about you to third party business partners, such as entities that provide us with advertising and analytics services, as well as business partners with whom we may jointly offer products, services, or educational information or whose products or services we believe may be of interest to you.
We may also disclose your personal information in the following circumstances:
- Business Transfers. If (i) we or our affiliates are or may be acquired by, merged with, or invested in by another company, or (ii) if any of our assets are or may be transferred to another company, whether as part of a bankruptcy or insolvency proceeding or otherwise, we may transfer the information we have collected about you to the other company. As part of the business transfer process, we may disclose certain of your information to lenders, auditors, and third party advisors, including attorneys and consultants.
- In Response to Legal Process. We may disclose your personal information to comply with the law, a judicial proceeding, court order, or other legal process, such as in response to a court order or a subpoena.
- To Protect Us and Others. We may disclose your personal information where we believe it is appropriate to do so to investigate, prevent, or take action regarding illegal activities, suspected fraud, situations involving potential threats to the safety of any person, violations of our Terms and Conditions or this Policy, or as evidence in litigation in which we are involved.
- Aggregate and Deidentified Information. We may disclose aggregate, anonymized, or deidentified information about you for any purpose permitted under applicable law.
- Consent. We may disclose your personal information with your consent.
- Cookies. Cookies are small text files containing a string of alphanumeric characters. We may use both session and persistent cookies. A session cookie disappears after you close your browser. A persistent cookie remains after you close your browser and may be used by your browser on subsequent visits to our Site. Please review your browser’s “Help” file to learn the proper way to modify your cookie settings. Please note that if you delete or choose not to accept cookies from the Service, you may not be able to utilize the features of the Service to their fullest potential. To learn more about cookies, visit http://www.allaboutcookies.org.
- Clear GIFs, pixel tags, and other technologies. Clear GIFs are tiny graphics with a unique identifier, similar in function to cookies. In contrast to cookies, which are stored on your computer’s hard drive, clear GIFs are embedded invisibly on web and app pages. We may use clear GIFs (a.k.a. web beacons, web bugs, or pixel tags) to among other things, track the activities of site visitors, help us manage content, and compile statistics about Service usage. A clear GIF can collect information such as: the IP address of the computer that downloaded the page on which the tag appears; the URL of the page on which the pixel tag appears; the time the page containing the pixel tag was viewed; the browser type and language; the device type; geographic location; and, the identification number of any cookie on the computer previously placed by that server. We and our third party business partners may also use clear GIFs in HTML emails to our customers, to help us track email response rates, identify when our emails are viewed, and track whether our emails are forwarded.
- Analytics. We may use Google Analytics and Google Analytics Demographics and Interest Reporting to collect information regarding visitor behavior and visitor demographics on some of our Sites, and to develop website content. For more information about Google Analytics, please visit www.google.com/policies/privacy/partners/. You can opt out of Google's collection and processing of data generated by your use of the Services by going to http://tools.google.com/dlpage/gaoptout.
We may use Chartbeat to monitor and analyze the use of our Service. Chartbeat is a web analytics service offered by Chartbeat that tracks and reports website article traffic. For more information on Chartbeat’s privacy practices, please see Chartbeat’s Privacy and Terms: https://chartbeat.com/privacy and https://chartbeat.com/terms.
- Interest-based advertising. We may set tracking tools (e.g., cookies, clear GIFs) provided by third-party advertising partners on our site to collect information regarding your activities on our site (e.g., your IP address, page(s) visited, time of day) for advertising purposes. We may also share such information with third party advertising partners. These advertising partners may use this information (and similar information collected from other websites) for purposes of delivering targeted advertisements to you when you visit non-Voice Media Group related websites within their networks. This practice is commonly referred to as "interest-based advertising" or "online behavioral advertising." If you do not want interest-based advertising, you may be able to opt-out by visiting US-based www.networkadvertising.org/managing/opt_out.asp and www.aboutads.info/choices/.
We use Google’s AdSense and DoubleClick services to show advertisements to you to help support and maintain our Service. You can use Google’s Ads Settings to manage the Google ads you see and opt out of Ads Personalization. For more information on Google’s privacy practices, please see Google’s Privacy and Terms: https://policies.google.com/?hl=en
We use the remarketing services below to advertise on third party websites to you after you have visited our Service:
- Do Not Track (DNT). Your browser setting may allow you to automatically transmit a "Do Not Track" (DNT) signal to websites and online services that you visit. There is no consensus as to what DNT means in this context, and since some browsers apply DNT signals by default it does not necessarily reflect our visitors’ choice as to whether they wish to receive advertisements tailored to their interests. As a result, like many websites, we do not alter our practices when the Service receives a DNT signal from a visitor's browser. For information about "do-not-track", visit http://www.allaboutdnt.org.
VI. DISCUSSION BOARDS AND SIMILAR FEATURES
When you post information on a discussion board or comment publicly on an article on our Service, the information you post and your username are publicly accessible. This information can be viewed online and collected by other people. We are not responsible for the way these other people use this information. When contributing to a discussion, we strongly recommend you avoid sharing any personal details, and especially information that can be used to identify you directly such as your name, age, address and name of employer. We are not responsible for the privacy of any identifiable information that you post in our online community or other public pages of the Service.
VII. MARKETING COMMUNICATIONS
We may send periodic promotional emails to you. You may opt-out of promotional emails by following the opt-out instructions contained in the email. Please note that it may take up to 10 business days for us to process opt-out requests. If you opt-out of receiving promotional emails, we may still send you emails about your account or any services you have requested or received from us.
VIII. SECURITY OF YOUR INFORMATION
We implement physical, technical, and organizational security measures designed to safeguard personal information. These measures are aimed to protect the personal information we collect from loss, misuse, and unauthorized access, disclosure, alteration, and destruction. Please be aware that despite our efforts, no data security measures can guarantee security.
IX. THIRD PARTY LINKS
Our Site may contain links to third-party websites. Any access to and use of such linked websites is not governed by this Policy but is instead governed by the privacy policies of those third-party websites. We are not responsible for the information practices of such third-party websites, and we encourage you to review the privacy policies of any third-party sites you choose to visit.
Our Service is not intended for children or minors under the age of sixteen years. Accordingly, we do not store information from minors under the age of sixteen years. If you believe that a child has submitted personal information to us, please contact us at [email protected] and we will take reasonable steps to delete the information.
We do not knowingly “sell” or “share” the personal information of children under the age of 16.
XI. ADDITIONAL DISCLOSURES UNDER APPLICABLE LAWS
You may have certain rights regarding our processing of your personal information under applicable local law. If our processing of your personal information is governed by such laws, this section provides you with additional information regarding your rights and our processing of your personal information under applicable local law.
- US STATE LAWS
We may disclose each of the categories of personal information described above for our business and commercial purposes to:
- IT providers
- Payment processing providers
- Hosting service providers
- Email and communications providers
- Accounting vendors
We may “sell” or “share” each of the categories of personal information described above for cross-context behavioral advertising (as those terms are defined under applicable local law) to:
- Social media platforms
- Website and mobile application analytics providers
- Providers of advertising services
- Business partners with whom we jointly market products
We do not disclose your sensitive personal information for purposes other than permitted under applicable local law.
Your personal information will be held for only so long as it is necessary for the purpose for which it was originally collected, and in accordance with applicable local law. We will retain your personal information for the period necessary to fulfill the purposes outlined in this Policy. When assessing retention periods, we first examine whether it is necessary to retain the personal information collected and, if retention is required, work to retain the personal information for the shortest possible period permissible under applicable law.
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 the personal information, the purposes for which we process the personal information, and whether we can achieve those purposes through other means, and the applicable legal, regulatory, tax, accounting or other requirements.
YOUR PRIVACY CHOICES AND RIGHTS
Depending on the jurisdiction in which you live, you may have the following rights under applicable local law:
- Right to request access and a copy of your personal information and information relating to how it is processed;
- Right to request deletion of your personal information;
- Right to request the correction or update of the personal information we hold about you;
- Right to opt-out of “sales” of your personal information and “sharing” of your personal information for cross-context behavioral advertising purposes (as these terms are defined under applicable law)
- Right to opt-out of targeted advertising;
- Right to limit our use of your sensitive personal information;
- Right to not be unlawfully discriminated against for exercising your rights.
These rights may be limited or denied in some circumstances. For example, we may retain your personal information where required or permitted under applicable law.
You may also opt-out of our “sale” or “sharing” of your personal information through privacy preference signals recognized under applicable local law, such as the Global Privacy Control (GPC), but please note that this signal will be linked to your browser only. For more information on the GPC and how to use a browser or browser extension incorporating the GPC signal, see https://globalprivacycontrol.org/.
In order to protect your information, we will confirm a requestor’s identity before responding to any request. To start the process, you must provide your name and email. We will ask you at least one question, and you must reply by email with the correct answer for each question based on your previous interaction with us. If we still cannot verify your identity as required by applicable laws, we will let you know and may ask additional questions. Otherwise, we will acknowledge your request and contact you later with our full response.
We will only send verification questions from [email protected]. Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our verification email address listed above, do not respond.
Any information we gather through this process will only be used for consumer verification, security procedures, or fraud-prevention. We will delete any verification information as soon as practical after processing your request.
You may designate an authorized agent to exercise your rights under applicable laws on your behalf.
Pursuant to applicable laws:
- You must provide the authorized agent written permission to exercise your rights under applicable laws on your behalf.
- We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by you to act on your behalf if we request such proof, as permitted by applicable laws.
- Even if you use an authorized agent to exercise your rights under applicable laws on your behalf, pursuant to applicable laws we may still require that you verify your own identity directly to us.
You may have a right to appeal a decision we make relating to requests to exercise your rights under applicable local law. To appeal a decision, please contact us at [email protected].
ADDITIONAL CALIFORNIA PRIVACY RIGHTS
California Civil Code Section § 1798.83 permits users of our web site that are California residents to request certain information regarding our disclosure of personal information to other parties for their direct marketing purposes. To make such a request, please send an email to [email protected] with the subject “Shine the Light Request.”
- INFORMATION FOR VISITORS FROM OUTSIDE THE UNITED STATES
If you are located outside United States and choose to provide information to us, please note that this information, including personal information, is processed in the United States.
LEGAL BASIS FOR PROCESSING PERSONAL INFORMATION UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
Generally, Voice Media Group processes your personal information on the basis of one or more of the following legal grounds:
- We need to perform a contract with you;
- You have given us permission to do so;
- The processing is in our legitimate interests and it’s not overridden by your rights. Such “legitimate interests” include:
- to study how customers use the Service,
- to develop the Service and grow our business,
- to manage our business, including the provision of administration and IT services, network security, to prevent fraud and in the context of a business reorganization or group restructuring exercise,
- to inform our marketing and advertising strategy; or
- To comply with our legal and regulatory obligations.
- We may process your personal information for more than one lawful ground depending on the specific purpose for which we are using your data. Please contact us if you need details about the specific legal ground we are relying on to process your personal information.
YOUR DATA PROTECTION RIGHTS UNDER GENERAL DATA PROTECTION REGULATION (GDPR)
If you are located in the UK or EEA, and subject to national or local law exemptions, you have certain data protection rights in certain circumstances. Please contact us if you would like to exercise any of these rights.
- Right to withdraw consent at any time: This applies where we are relying on consent to process your personal information.
- Access: This enables you to receive a copy of the personal information we hold about you and to check that it is accurate and that we are processing it lawfully.
- Object: This enables you to object to processing of your personal information where we are relying on a legitimate interest and there is an impact on your fundamental rights and freedoms. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override certain of your rights and freedoms. You also have the right to object where we are processing your personal information for direct marketing purposes.
- Correction: This enables you to have any incomplete or inaccurate personal information we hold about you corrected, though we may need to verify the accuracy of the new personal information you provide to us.
- Erasure: This enables you to ask us to delete or remove personal information where there is no good reason for us continuing to process it. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.
- Portability: This enables you to request the transfer of your personal information to you or to a third party. We will provide to you, or a third party you have chosen, your personal information 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.
- Restriction: This enables you to ask us to suspend the processing of your personal information in the following circumstances: (a) if you want us to establish the information’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 personal information 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 personal information but we need to verify whether we have overriding legitimate grounds to use it.
Please note that we may ask you to verify your identity before responding to such requests.You have the right to complain to the relevant UK or EEA Data Protection Authority about our collection and use of your personal information at any time. However, we would appreciate the opportunity to address your complaint in the first instance.
XII. CONTACT US
If you have any questions, comments, concerns, or complaints regarding your personal information or our privacy practices, please contact us at [email protected].
XIII. CHANGES TO THIS POLICY
This Policy is current as of the Last Updated date set forth above. We may change this Policy from time to time, so please be sure to check back periodically. If we make any changes to this Policy that materially affect our practices with regard to the information we have previously collected about you, we will endeavor to provide you with notice in advance of such change by highlighting the change on the Service or sending you an email.