California users you can find out about your privacy rights here.
- 2. About this privacy notice
- 3. Changes to this privacy notice
- 4. Personal data we collect
- 5. Aggregated data
- 6. How we collect personal data
- 7. What we use your personal data for and the legal bases we rely on
- 8. Marketing
- 9. Sharing personal data
- 10. EU users: international transfer of your data
- 11. Protecting your data
- 12. Retaining your personal data
- 13. Third party sites, apps and platforms
- 14.1 Essential cookies
- 14.2 Third party cookies: advertising and affiliate links
- 15. Your legal rights
- 15.1 EU users
- 15.2 California privacy rights
- 16. Russian Insider legal entities
- Who we are
Local Media & Marketing Inc. is the data controller of your personal data. When we mention Russian Insider, we, us or our in this privacy notice, we mean Local Media & Marketing Inc., or the relevant Russian Insider company responsible for processing your data.
- About this privacy notice
This privacy notice tells you how Russian Insider collects and processes information that may identify you (personal data) when you use our sites and apps, sign in as a user, buy products or services, or interact with us in other ways. We may show you other privacy notices when we collect or share your personal data and this privacy notice is in addition to those.
- Changes to this privacy notice
Our privacy notice was last updated on 24 October 2018. We’re likely to update in future and we’ll let you know about any significant changes. Please come back and check from time to time. If you have questions about this privacy notice you can get in touch with us by emailing [email protected].
- Personal data we collect
We may collect the following information about you:
4.1 Information that directly identifies you. This may include your name, address, email address, username and password.
4.2 Information that indirectly identifies you. We automatically receive and record information from your device or web browser when you interact with our sites and apps, for example your internet protocol (IP) address, mobile device ID, time zone setting, location data, language preference, operating system, platform, and links you have clicked on or shared with others, including through email and social media. We may also create a user ID that may similarly indirectly identify you. We may use this information to collect data about your activities on our sites and apps and on third-party sites, apps and platforms, such as Facebook. We may associate information that indirectly identifies you with your user account (if you have one) and other information we have collected about you.
4.3 Location data. We may collect geo-data, which tells us where you are, when we collect other information about you. We may also collect the language option or country you choose. We may link location data to other information we have collected about you.
4.4 Profile data. This may include your username and password and other information you give us (if you are a registered user), information you give us in connection with purchases or orders made by you, your interests, preferences, feedback and survey responses. Profile data you enter in your account profile (if you are a registered user), including your username may be shown to other users to facilitate user interaction on our sites and apps. We do not disclose email addresses to other users.
4.5 Marketing and communications data. This may include information about your subscriptions to newsletters and your marketing preferences.
4.6 Transaction and financial data. We may collect or receive transactional and financial information relating to you when you buy something through our sites and apps (for example payment details) or because you have bought something from a third party after clicking on an affiliate link in our content.
4.7 Special category data. When we conduct research or carry out surveys we may collect sensitive personal data about you, for example information about your racial or ethnic origin, political opinions, religious or philosophical beliefs, sex life or sexual orientation. We will not use or share this information without your explicit consent.
- Aggregated data
5.1 We aggregate personal data we collect, such as the number and frequency of your visits to our sites and apps, to produce metrics and statistical information. We may share this data with third parties.
5.2 We share aggregated, anonymized, information with our ad partners and service providers so that we, and they, can understand how people use our sites and apps; this helps us grow our business and improve and develop our products and services. These third parties may share with us information about you that they have independently developed or acquired.
5.3 We combine information about you with information about other users to create audience segments of aggregated data, for example, statistical, demographic and usage data. If we combine or connect aggregated data with personal data we treat the combined data as personal data and deal with it in accordance with this privacy notice.
- How we collect personal data
6.1 You may give us your personal data directly, for example when you create a user account, buy products or services, subscribe to our newsletters, opt in to marketing, publish posts or comments, enter a competition, participate in a promotion or survey, ask for user support, or contact us for any reason.
6.3 Third parties who provide advertising and related services may give us your personal data, these including analytics providers and ad networks.
6.4. We may receive your personal data from third parties when you buy things through our sites and apps or when you buy things from a third party after clicking on an affiliate link in our content. This information may include your contact details and financial and transaction data from providers of technical, payment and delivery services.
6.5 If you access our sites and apps using your Facebook credentials, we will automatically collect certain information, such as your name, picture, and email address. We will use all information available through Facebook, including the user ID Facebook attributes to you, in accordance with Facebook’s policies and your preferences selected through Facebook.
- What we use your personal data for and the legal bases we rely on
We will use your personal data only for the purposes for which we collect it, unless we reasonably consider that we need to use it for another reason that is compatible with the original purpose. If we need to use your personal data for another purpose we will explain the legal basis we rely on.
We do not always need your consent to process your personal data. The table below shows what we use your personal data for and the lawful basis for processing it in each case.
|Purpose||Type of data||Lawful basis|
|Communicate legal information to you.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information you include in your user profile).||Legitimate interest.|
|Analyze comments and feedback you have given us including comments, feedback and reviews you have posted on our sites and apps.||Data that directly identifies you (such as your name, username, and email address) and data that indirectly identifies you (such as your IP address or mobile device ID and location data).||Legitimate interest.|
|Provide you with communications and services you’ve signed up, for such as our newsletters.||Data that directly identifies you such as your name, username, email address and location data.||Consent.|
|Register you as a user of our sites and apps and other products and services and administer your account.||Data that directly identifies you (such as your name, username, and email address and other information included in your user profile).||Creation or performance of a contract.|
|Publish content on our sites and apps including articles, feedback, reviews and user comments about our posts.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address and information included in your user profile).||Creation or performance of a contract.|
|Fulfill orders for products or services placed through our sites or apps.||Data that directly identifies you including your name and address, email address, other contact details, financial and transactional data.||Creation or performance of a contract.|
|Collect money you owe us.||Data that directly identifies you including your name and address, email address, other contact details and financial and transactional data.||Legitimate interest.|
|Verify or obtain payments due to us when you buy something from a third party after clicking on an “affiliate” link in our content, measure the performance of affiliate links, analyze and develop this part of our business.||Data that indirectly identifies you (such as your IP address or mobile device ID) or data that directly identifies you (such as your name, username, email address and location data).||Legitimate interest.|
|Communicate our terms, notify you about changes to them and communicate with you about non-compliance.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username and email address).||Creation or performance of a contract.|
|Communicate our privacy notices and notify you of changes to them||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) or data that directly identifies you (such as your name, username, and email address).||Compliance with a legal obligation.|
|Ask you to take part in a survey or other research about our sites and apps and other products and services.||Data that indirectly identifies you (such as your IP address, mobile device ID and location data) or data that directly identifies you (such as your name, username, and email address).||Legitimate interest.|
|Conduct surveys or undertake research so that we can improve and develop our business, our sites and apps and our products and services.||Data that directly identifies you (such as your name, username, name, email address and location data)||Consent.|
|Allow you to take part in a prize draw, sweepstake, or other competition or other promotional activity.||Data that directly identifies you such as your name, username, and email address.||Creation or performance of a contract.|
|Administration and protection of our business including troubleshooting, data analysis, testing, system maintenance, user support, reporting and hosting data, administration and IT services, network security, fraud prevention, customer services and business reorganisation, including exchanging information with third parties for fraud protection and spam/malware prevention.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and data that directly identifies you (such as your name, username, and email address).||Legitimate interest.|
|Serve content and ads and analyze their performance and effectiveness.||Data that indirectly identifies you such as your IP address or mobile device ID and location data.||Legitimate interest.|
|Use of data analytics to improve and develop our products and services and inform our marketing strategy.||Data that indirectly identifies you such as your IP address or mobile device ID and location data.||Legitimate interest.|
|Send marketing communications to you if you subscribe to our newsletters or other products and services. We explain how we comply with the law and how you can manage your preferences in section 8(marketing).||Data that directly identifies you such as your name and email address.||Consent.|
|Communicate with you about our services, and content, including published content, content you submit for publication, and content posted by you (including your comments on content, feedback and reviews).||Data that directly identifies you such as your name and email address.||Legitimate interests|
|Comply with applicable laws, regulations and legal and regulatory processes.||Data that indirectly identifies you (such as your IP address or mobile device ID and location data) and/or data that directly identifies you (such as your name, username, and email address).
|Compliance with a legal obligation.|
Advertising networks. We may share certain information with third parties to provide advertising to you based on your interests. For more information, please see Ad Choices below.
We may use your personal data to help us decide which products, services and offers may be of interest to you. We will send marketing messages to you if you have asked us to send you information, bought goods or services from us, or if you provided us with your details when you entered a competition or registered for a promotion. If you opt out of receiving marketing messages we will not send them to you. We will ask for your consent before we share your personal data with any third party.
You may unsubscribe from marketing messages through a link we include on messages we send you. You can also ask us to stop sending you marketing messages at any time by contacting us at: [email protected].
- Sharing personal data
9.1 We may share your personal data within Russian Insider.
9.2 We share your personal data with third parties who process your data on our behalf when they provide services to us, for example data analytics, ad networks, research, marketing and financial services.
9.3 We may share your personal data with third parties who use it for their own purposes if you have provided consent.
9.4 You share your personal data with third parties when you publish content including articles, comments and reviews on our sites and apps.
9.5 If we sell, transfer, or merge parts of our business, or if we buy or merge with another business we may share your personal data. If a change happens to our business, then the new owners may use your personal data as set out in this privacy notice.
9.6 We may be legally required to disclose or share your personal data without your consent in some circumstances, for example to comply with a court order or law enforcement.
- EU users: international transfer of your data
10.1 When we process your personal data within Russian Insider this may involve processing and transferring your data outside the European Economic Area (EEA), which includes all EU member states plus Iceland, Liechtenstein and Norway.
10.2 Third parties with whom we share your data may be based outside the EEA and their processing of your personal data may involve a transfer of data outside the EEA.
10.3 When your data is transferred outside the EEA we take steps to make sure it has the same level of protection as it would have in the EEA. Our agreements with third parties make clear the standards we expect of them in order to safeguard your information and your legal rights.
- Protecting your data
11.1 We take steps to safeguard your information by putting in place appropriate security measures to prevent personal data from being accidentally lost, used, accessed in an unauthorized way, altered or disclosed.
11.2 We limit access to your personal data to employees, agents, contractors and other third parties who need to access it. They are subject to a duty of confidentiality and we require them to process your personal data only in accordance with our instructions.
11.3 We do not guarantee or warrant that security measures will prevent data breaches. We have procedures to deal with suspected data breaches. We will notify you and the relevant regulator of any data breach as legally required.
- Retaining your personal data
12.1 We keep your personal data for as long as we need it for the purposes for which it was collected.
12.2 When we decide how long we will keep your information we consider the amount, nature, and sensitivity of the personal data, the potential risk of harm from unauthorized use or disclosure, why we need it, and any relevant legal requirements.
12.3 We may anonymize your personal data (so that it can no longer be associated with you) for research or statistical purposes, in which case we may use this information indefinitely.
- Third party sites, apps and platforms
Our sites and apps may include links to third-party sites, apps and social media platforms, including Facebook, Twitter and Instagram. Clicking on those links may allow third parties to collect or share data about you. We do not control third-party sites, apps and social media platforms and we encourage you to read their privacy notices so that you understand how they process information about you.
Browsers and devices have tools that allow you to disable cookies on sites and apps. If you disable cookies you may not be able to access all the features of our services. We suggest that you keep our essential cookies (described below) active for a better user experience and to help us keep improving and developing our products and services.
14.1 Essential cookies
Session cookies remember you during your session on our sites and apps they are deleted when you log out of the site and when you close your web browser.
Analytics cookies are used by us and by third parties who process data for us for data analytics purposes (for example Google Analytics) so that we can manage and improve the performance and design of our sites and apps and for monitoring, auditing, research and reporting.
Consent cookies may be used by consent management tools we employ to allow us to record your preferences about third party cookies described in section 14.2 below, and to store and share your preference with us.
We may collect the following personal data through essential cookies: a unique ID assigned to your device; IP address; device and browser type; operating system; referring URLs; content viewed or other actions taken on our sites and apps; time and date of those actions; country and language selected.
14.2 Third party cookies: advertising and affiliate links
Our ad partners and our affiliate links partners may collect personal data from you for their own purposes.
- Ad partners include ad networks such as third party ad servers, ad agencies, ad technology vendors and research firms.
- Affiliate links partners pay us when you buy things from them or another third party after clicking on an affiliate link in our content.
Marketing communications and sharing with third parties. We provide you with an opportunity to express your preferences with respect to receiving certain marketing communications from us, and our sharing of personal information with unaffiliated third parties for their direct marketing purposes. If you ever decide in the future that you would like to update these preferences, you may (i) log in to an account you have created with us at one of our Sites to adjust your settings, or (ii) send us an email at [email protected]. To opt out of receiving our email marketing communications, you can also follow the “unsubscribe” instructions provided in any marketing email you receive from us. If you previously chose to receive push notifications on your mobile device from us, but no longer wish to receive them, you can manage your preferences through your device or app settings, depending on the type of device. For California residents, please see below for additional information on the choices we provide to you.
For more information about interest-based advertising on your desktop or mobile browser, and your ability to opt out of this type of advertising by third parties that participate in self-regulatory programs, please visit the Network Advertising Initiative and/or the DAA Self-Regulatory Program for Online Behavioral Advertising. To learn more about interest-based advertising in mobile apps and to opt out of this type of advertising by third parties that participate in the DAA’s AppChoices tool, please download the version of AppChoices for your device here. Please note that any opt-out choice you exercise through these programs will apply to interest-based advertising by the third parties you select, but will still allow the collection of data for other purposes, including research, analytics, and internal operations. You may continue to receive advertising, but that advertising may be less relevant to your interests.
You may have more options depending on your mobile device and operating system. For example, most device operating systems (e.g., iOS for Apple phones, Android for Android devices, and Windows for Microsoft devices) provide their own instructions on how to limit or prevent the delivery of tailored in-application advertisements. You may review the support materials and/or the privacy settings for the respective operating systems to learn more about these features and how they apply to tailored in-app advertisements.
Precise location information. To disable the collection of precise location information from your mobile device through our mobile apps, you can access your mobile device settings and choose to limit that collection.
See also Cookies and Other Technical Information for more choices about managing other technical and usage information.
- Your legal rights
15.1 EU users
Legal rights you may exercise over your personal data are briefly described below:
Right to request access
You have the right to ask for a copy of personal data we hold about you and to check we are dealing with it lawfully by asking for information about how we process it.
Right to request correction
You have the right to ask us to correct incomplete or inaccurate information about you.
Right to request erasure
You have the right to ask us to delete or remove your personal data.
Right to object to processing
If we are relying on a legitimate interest to process your personal data, you have the right to object. Our legitimate interest in processing your information may override your rights and freedoms. You also have the right to object to us processing your personal data for direct marketing purposes.
Right to withdraw consent
If we are processing your personal data on the basis of your consent, you can withdraw your consent at any time.
Right to request restriction of processing.
You can ask us to suspend processing of your personal data where: (a) you contest the data’s accuracy; or (b) processing of your data is unlawful but you do not want us to erase it; or (c) we no longer need your data but you need us to hold it for a legal claim; or (d) you object to our processing of your data and we are checking whether the legitimate interest we rely on overrides your rights.
Right to request transfer
You have the right to ask us to transfer your personal data to you, or to a third party. This right applies only to automated information you gave us consent to use, or where we used the information to perform a contract with you.
Right to object to automated decision-making
You have the right not to be subject to automated decision-making, including profiling, which has legal or other significant effects on you. This right does not apply when the automated decision is necessary for entering into or performing a contract with you, or is based on your explicit consent.
How to exercise your rights
To exercise your rights email [email protected]. As a security measure we will ask you to verify your identity. If a third party is making a request on your behalf we will ask them to prove that they have your permission to act for you.
We may contact you to ask you for further information to help you exercise your legal rights, or to speed up our response. We will try to respond to requests within one month and we will let you know if we need to take longer, for example because your request is complicated. We may have an overriding lawful basis for processing your personal data, or certain exemptions may apply. If we refuse your request we will explain why.
You have the right to complain about data privacy matters to the Information Commissioner’s Office (www.ico.org.uk), or the relevant data protection regulator in your country of residence. We invite you to raise your concerns with us first, so that we can try to resolve them.
15.2 California privacy rights Under California Civil Code sections 1798.83- 1798.84, California residents are entitled to ask for a notice identifying the categories of personal customer information which we share with our affiliates and/or third parties for marketing purposes, and providing contact information for such affiliates and/or third parties. If you are a California resident and would like a copy of this notice, please send your request (along with your full name, email address, postal address, and the subject line labeled “Your California Privacy Rights”) by email at [email protected].
Local Media Co.
132 Norfolk Street
Brooklyn NY 11235