Your California Privacy Rights

Effective as of 6-25-2020

This California Privacy Notice (“Notice”) applies to Evening Telegram Company d/b/a Morgan Murphy Media and its subsidiaries (“MMM”) and its affiliates and provides additional information regarding the sale, collection and/or disclosure of personal information, as defined under the California Consumer Privacy Act of 2018 (“CCPA”) and applicable California law (“Personal Information”) that is related to a California resident or household (“you”). This notice describes Personal Information that MMM has collected, disclosed or sold within the meaning of the CCPA, and it applies only to California residents.

This notice supplements our Global Privacy Policy, which describes the Personal Information we collect and the purposes for which it is used. In addition, we outline for California residents your rights to know, rights to delete and rights to opt-out as set forth in the CCPA.

Categories of Personal Information

MMM has collected the following categories of Personal Information in the preceding 12 months, as these categories are set forth in the CCPA.

Category of Personal Information Collected	Disclosed to
Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, internet protocol address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers.	Business partners, subsidiaries and/or affiliates
Any categories of personal information described in subdivision (e) of Section 1798.80, the California Customer Records statute (name, signature, address, telephone number, education, employment, billing and transactions information.)	Business partners, subsidiaries and/or affiliates
Characteristics of protected classifications under California or federal law.	Business partners, subsidiaries and/or affiliates
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Business partners, subsidiaries and/or affiliates
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement.	Business partners, subsidiaries and/or affiliates
Geolocation data.	Business partners, subsidiaries and/or affiliates
Audio, electronic, visual, thermal, olfactory, or similar information.	Business partners, subsidiaries and/or affiliates
Professional or employment-related information.	Business partners, subsidiaries and/or affiliates
Education information, defined as information that is not publicly available personally identifiable information as defined in the Family Educational Rights and Privacy Act (20 U.S.C. Sec. 1232g; 34 C.F.R. Part 99).	Business partners, subsidiaries and/or affiliates
Inferences drawn from any of the information identified in this subdivision to create a profile about a consumer reflecting the consumer’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	Business partners, subsidiaries and/or affiliates

MMM generally does not directly sell your personal information for money, but we use services to help deliver tailored ads to you based on your interests, and we may transfer Personal Information to business partners for their use. Over the last 12 months we have collected the following such Personal Information: online identifiers, IP addresses, cookies or browsing activity. Making such Personal Information available to these companies may be considered a “sale” for CCPA purposes.

Your CCPA Rights to Personal Information

This section describes the CCPA’s rights provided to California residents and describes how those rights may be exercised.

Right to Request Deletion. You have the right to request the deletion of your Personal Information. Once we receive and confirm a verifiable consumer request from a consumer to delete your personal information, unless an exception applies, we will delete the information from our records and will direct any service providers to delete the Personal Information from their records. We may deny your deletion request if it is necessary for us to maintain the Personal Information in order to:

1. Complete the transaction for which the personal information was collected, provide a good or service you requested, or reasonably anticipated within the context of our ongoing business relationship with you, or otherwise perform a contract between us.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity; or prosecute those responsible for that activity.
3. Debug to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise his or her right of free speech, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the businesses’ deletion of the information is likely to render impossible or seriously impair the achievement of such research, if the consumer has provided informed consent.
7. To enable solely internal uses that are reasonably aligned with your expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Otherwise use your personal information, internally, in a lawful manner that is compatible with the context in which you provided the information.

IF you are a California resident under 18 years of 18 and you use the Website where this policy is posted, you may request removal of content or information that you have publicly posted. There may be circumstances where the law does not require or allow removal, and granting such a request does not ensure complete removal of the content from the Internet.

Right to Request Disclosure of Certain Information. To the extent that we collect Personal Information about you that the CCPA governs, you have the right to request disclosure of the following, which will be disclosed to you once we receive and confirm a verifiable consumer request consistent with CCPA requirements:

1. The categories of personal information we have collected about you;
2. The categories of sources from which the personal information is collected;
3. The business or commercial purpose for collecting or selling personal information;
4. The categories of third parties with whom we share personal information.
5. The specific pieces of personal information we have collected about you (“data portability”).

To the extent that we sell your personal information or disclose it for a business purpose, you also have the right to

1. request disclosure of the categories of personal information.
   a) that we have collected about you.
   b) that the we have sold and the categories of third parties to whom the personal information was sold, by category or categories of personal information for each third party to whom the personal information was sold.
   c) that we disclosed about you for a business purpose.
2. opt out of the sale of personal information about you to third parties, as set forth on our “Do Not Sell My Personal Information” Page. We automatically opt-out consumers whom we actually know are at least 13 and less than 16 years old, and for CCPA purposes, we “do not sell” their personal information unless they opt in.

You may request a list of categories and a copy of the Personal Information in a portable and (if technically feasible) readily usable format covering the 12-month period preceding the request.

Nondiscrimination Rights. We do not discriminate against you if you exercise any of your consumer rights under this California Privacy Policy, including discrimination by:

1. Denying goods or services to you.
2. Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
3. Providing a different level or quality of goods or services to you.
4. Suggesting that you will receive a different price or rate for goods or services or a different level or quality of goods or services.

As permitted under the CCPA, MMM may charge a consumer a different price or rate, or may provide a different level or quality of goods to the consumer, if the difference is reasonably related to the value provided to our business by the consumer’s data.

To Exercise Your CCPA Rights:

To exercise your rights to access information, data portability or deletion rights, please submit a verifiable consumer request by either calling us at (855) 593-3139 toll free or emailing us at Privacy@embtv.com. Only you or a person registered with the California Secretary of State that you authorize to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must contain sufficient information to allow us to reasonably verify that personal information was collected about you, and it must sufficiently allow us to properly understand and respond to your request. If we cannot verify your identity or authority to make the request, we cannot respond to it adequately. We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We endeavor to respond to verifiable consumer requests within 45 days of receipt.

Certain Exclusions

This California Privacy Policy does not apply to information other than “personal information,” including

• aggregate consumer information, which means information that relates to a group or category of consumers, from which individual consumer identities have been removed, that is not linked or reasonably linkable to any consumer or household, including via a device;
• deidentified information, which means “information that cannot reasonably identify, relate to, describe, be capable of being associated with, or be linked, directly or indirectly, to a particular consumer, provided that we: 1) have implemented technical safeguards that prohibit reidentification of the consumer to whom the information may pertain; 2) Have implemented business processes that specifically prohibit reidentification of the information; 3) Have implemented business processes to prevent inadvertent release of deidentified information; and 4) makes no attempt to reidentify the information; or
• excluded information, such as information excluded from the CCPA’s scope and covered by other laws

Changes to Our Privacy Notice

We reserve the right to amend this privacy notice at our discretion and at any time. When we make changes to this privacy notice, we will notify you by email or through a notice on our Website homepage.