Effective Date: 11/26/2018
Our Commitment to Transparency
Swift Communications is committed to providing the information you need to make informed choices about the ways you use this Site. This Policy describes the personal information we collect when you use this Site, for example, by registering with this Site, creating a blog, subscribing to one of our newspapers, or submitting news items. It also describes how we use the personal information you share with us, some of the steps we take to protect your privacy and your choices with respect to how we use your personal information. “Personal information” is information about an identified or identifiable individual. Examples of personal information include your name, your e-mail address, and your photograph. If you have any questions about this Policy or our privacy practices, please contact us by e-mail at firstname.lastname@example.org or by mail at 314 E. Hyman Ave, #101, Aspen, CO 81611.
This Policy May Change
Types of Personal Information We Collect
Information You Provide to us. Swift Communications collects the personal information you provide when you use this Site to register for an account, subscribe to one of our newspapers, or submit news items or use our social networking tools such as when you: comment on news stories, create blogs, submit photographs and videos and send public or private messages to your friends on the Site. This includes your contact information, such as your name, e-mail address, postal address and telephone number or your billing information, such as your credit or debit card information and the content of the communications. We process your payment card payments using a third party and only see the last 4 digits of the number and the maker of the card. If you choose to participate in one of our surveys or sweepstakes – we will collect the information you provide in your answers. Information Sent to Us by Your Web Browser. We collect information that is sent to us automatically by your Web browser. This information typically includes your IP address, the identity of your Internet service provider, the name and version of your operating system, the name and version of your browser, the date and time of your visit, and the pages you visit. Please check your browser if you want to learn what information your browser sends or how to change your settings. Generally, we do not link the information provided by your browser to information that identifies you by name. More About IP Addresses. An “IP address” is a unique number that is automatically assigned to your device when you connect to the Internet. It is used to identify your device’s “location” in cyberspace, so that the information you request can be delivered to you. If you use a dial-up connection or a connection that assigns dynamic IP addresses, your device will be assigned a new IP address each time you connect to the Internet. If, however, your device is permanently connected to the Internet using a static IP address, the IP address assigned to your device will generally be the same each time you use your device. IP addresses do not include your name, email address or other information that identifies you personally, but in some cases, they can be used to identify you. For example, if you have registered with this Site, we may link your IP address to account information that identifies you personally. We may also provide your IP address to our third-party service provider who can use it to identify your state and zip code. This gives us valuable demographic information about the individuals who use this Site. Our service providers are bound by contract to use the IP addresses we provide only for this purpose. In addition, if, for example, we suspect fraud or a threat to the security of this Site, we may share our server logs-which contain users’ IP addresses-with the appropriate investigative authorities, who could use that information to trace and identify individuals.
“Cookies” and Other Tracking Technologies
- You can find out more about the cookies we use from each of the categories in the table below.
|Categories of Cookies||Purposes||Description|
|Strictly Necessary||Security||Some cookies help us detect, prevent, and mitigate malicious and fraudulent activities on our Services. Security cookies also support and enable other security features.|
|Functional||Analytics and Research||We use some cookies to collect information about how people are using our Services. For example, these cookies allow us to know which pages are visited the most often, our site’s page load times and page response times. Overall, these cookies provide us with analytical information about how our Services are performing and how we can improve them.|
|Functional||Preferences and Settings||Your preferences may be stored in our cookies so you do not have to reset them every time you visit our Services. These cookies allow us to remember the choices you make to tailor this website and provide enhanced features and content to you. For example, these cookies can be used to remember your user name and region information.|
|Advertising||Advertising||These cookies are used to deliver advertisements that are more relevant to you and your interests. They are also used to limit the number of times you see an advertisement as well as help measure the effectiveness of the advertising campaign. They remember that you have visited a website and this information may be shared with other organizations such as advertisers. This means after you are done using our Service you may see some advertisements about our Services elsewhere on the Internet and that For example, if you visit a number of sports pages on our websites, you may be placed in a “sports enthusiast” interest category and may be presented with advertisements associated with sports in subsequent Internet searches|
To learn about your choices regarding cookies & how to opt out of interest based advertising, click here. If you do not wish to receive cookies, you may set your browser to reject cookies or to alert you when a cookie is placed on your computer. You may also delete our cookies as soon as you leave this Site. Although you are not required to accept our cookies when you visit this Site, if you set your browser to reject cookies, you will not be able to use all of the features and functionality of this Site. If you choose to opt out, we will place an “opt-out cookie” on your computer. The “opt-out cookie” is browser specific and device specific and only lasts until cookies are cleared from your browser or device. The opt-out cookie will not work for some cookies that are important to how our Site works (“essential cookies”). If the cookie is removed or deleted, if you upgrade your browser or if you visit us from a different computer, you will need to return and update your preferences. Google Analytics: We use tools provided by “Google Analytics” to collect some information we listed above about your use of the Services. We use the information we get from these tools to improve the Services. In order to collect this information, Google Analytics may set cookies on your browser or mobile device, or read cookies that are already there. Google Analytics may also receive information about you from apps you have downloaded that partner with Google. We do not combine the information collected through the use of Google Analytics with personally identifiable information. To learn what you can do about how Google Analytics use your information click here.
Information Collected From Third Parties
In order to provide you with the Services, we collect and store information from the following third parties:
- We receive from third party data brokers: information about individuals that includes their cookie stream information and information collected through tags. We also receive information from public databases like the census bureau.
- We receive information from social media networks if you choose to engage with our social media widget
We combine information collected through the app or cookies on our customers’ sites with information we receive from data brokers and public databases to analyze it to better understand your behaviors and attributes and to improve our content offerings.
How We Use Personal Information Collected Through This Site
We process your information for the following purposes as necessary to provide the services to you and perform our contract with you or to take steps at your request, before entering a contract :
- to provide the information, products and services you request;
- to provide you with effective customer service;
- to contact you with information and notices related to your use of our Sites;
We process your information for the following purposes as part of our legitimate interest in the improvement and marketing of our services as well in the security of our services. We apply appropriate safeguards to protect your information as described here and here:
- for security, credit or fraud prevention purposes;
- to provide you with a personalized experience when you use our Sites;
- to contact you with special offers and other information we believe will be of interest to you (in accordance with any privacy preferences you have expressed to us);
- to invite you to participate in surveys and provide feedback to us (in accordance with any privacy preferences you have expressed to us);
- to better understand your needs and interests;
- to improve the content, functionality and usability of this Site and other sites owned by Swift Communications;
- to improve our products and services; and
- to improve our marketing and promotional efforts;
In our processing of your information, we also share your personal information to defend our rights and those of others, to efficiently maintain our business and to comply with the law as described in how we share personal information. Please see Your Choices below for information about the choices you have about the ways we use your personal information.
How We Use Survey Information
From time to time, we may post a survey on this Site or, if we have your contact information and your consent, we may send you a questionnaire or survey. Your participation in any survey is always voluntary. We compile statistical information from the responses to our surveys. These statistics do not identify you personally. These statistics help us understand the needs and preferences of the groups we serve and improve the content and functionality of this Site. In addition, when we conduct a poll that gauges reader reaction to a particular news event, we may make the results of that poll available on this Site.
For our legitimate interests:
We share your information with our service providers, among our entities, in connection with a business transaction, to prevent harm, to comply with the law and to protect our legal rights. The legal basis for this is our legitimate interest in providing our services, complying with the law, and protecting our rights and those of others. We apply appropriate safeguards for this sharing of your information as described below. Third-Party Vendors. Swift Communications shares personal information collected through this Site with third-party vendors who act for or on behalf of Swift Communications. For example, we use third-party vendors to design and operate our websites, including this Site; to conduct surveys; and to help us with our promotional efforts. These third-party vendors would need information about you to perform their functions. These companies are required by contract to keep your personal information confidential and may use it only to provide services on our behalf. With our newspapers. We use content you post to public areas of this Site in connection with our news gathering and reporting activities. For example, we may select certain photographs you submit on or through this Site for publication in one of our newspapers. We may or may not use your name in connection with such use.
EU Individuals: Your Rights Under the General Data Protection Regulation
If EU data protection law applies to our use of your information, you have rights that are explained below. The rights available to you depend on the reason for our use of your information. These rights include:
- The right to access: You have the right to ask us for copies of your personal information. This right has some exemptions, which means you may not always receive all the information we process.
- The right to rectification: You have the right to ask us to rectify information you think is inaccurate. You also have the right to ask us to complete information you think is incomplete.
- The right to erasure: You have the right to ask us to erase your personal information in certain circumstances.
- The right to restrict processing: You have the right to ask us to restrict the processing of your information in certain circumstances.
- The right to object to processing: You have the right to object to processing if we are able to process your information because the process is in our legitimate interests.
- The right to data portability: This only applies to information you have given us. You have the right to ask that we transfer the information you gave us from one organization to another, or give it to you.
- The right to lodge a complaint with the supervisory authority. A list of Supervisory Authorities is available here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you need further assistance regarding your rights, please contact us using the contact information provided below <a href=”/contact-us”>click here</a> and we will consider your request in accordance with applicable law. Please note that these rights are not absolute and certain exemptions apply. In some cases, our ability to uphold these rights for you may depend upon our obligations to process personal information for security, safety, fraud prevention reasons, compliance with regulatory or legal requirements, or because processing is necessary to deliver the services you have requested. Where this is the case, we will inform you of specific details in response to your request.
You can delete your account or request that we delete your account by writing us at email@example.com. We will keep your information only for as long as it is relevant and useful for the purpose for which it was originally collected. We retain your information after you request deletion for longer periods for specific purposes to the extent that we are obliged or authorized to do so in accordance with applicable laws and regulations and/or as necessary to protect our legal rights or for certain business requirements. Some examples of specific reasons we would retain some data for longer periods of time are:
- Freedom of speech and historical archiving: We may need to retain certain information, and in particular information posted or published publicly if it is necessary for exercising our freedom of expression or necessary for archiving in the public interest as permitted by law.
- Security, fraud & abuse prevention. We may need to retain certain information to protect you, other people, and us from fraud, abuse, and unauthorized access.
- Financial record-keeping. When you make a payment to us we are often required to retain this information for a longer period of time for purposes of accounting, dispute resolution and compliance with tax, anti-money laundering, and other financial regulations.
- Complying with legal or regulatory requirements. We may need to retain certain information to meet any applicable law, regulation, legal process or enforceable governmental request, as required to enforce our terms of service, including investigation of potential violations.
- Direct communications with us. If you have directly communicated with us, through a customer support channel, feedback form, or a bug report, we may retain reasonable records of those communications.
Even if you delete your account, keep in mind that the deletion by our third party providers may not be immediate and that the deleted information may persist in backup copies for a reasonable period of time. For any privacy or data-protection-related questions, please write to firstname.lastname@example.org
We maintain reasonable administrative, physical and technological measures to protect the confidentiality and security of personal information you submit on or through this Site. For example, when collecting credit card information for online purchases, we offer secured-service transactions that encrypt your information in transit to thwart others from intercepting or misusing it. Unfortunately, no website, server or database is completely secure or “hacker proof.” We therefore cannot guarantee that your personal information will not be disclosed, misused or lost by accident or by the unauthorized acts of others. Further, we cannot control dissemination of personal information you post on or through this Site using our social networking tools, and we strongly urge you not to post any personal identifying or financial information using our social networking tools.
Do Not Track Disclosure
We do not support Do Not Track (“DNT”). Do Not Track is a preference you can set in your web browser to inform websites that you do not want to be tracked. You can enable or disable Do Not Track by visiting the Preferences or Settings page of your web browser. For further details, visit donottrack.us.
Children Under the Age of Thirteen
This Site is not intended for use by persons under the age of eighteen years without the permission of a parent or guardian. We do not knowingly collect, maintain, or use personal information from children under the age of 16. If we become aware that a child under the age of 16 has submitted personal information to us through the Site, we will immediately delete such information. If you believe that a child under the age of 16 has submitted personal information on or through this Site, please contact us by e-mail at email@example.com or by mail at 314 E. Hyman Ave, #101, Aspen, CO 81611 so that we can take appropriate action.
CROSS BORDER TRANSFERS OF INFORMATION
Transfers of information not from the EEA
The laws in the United States may not be as protective of your privacy as those in your location. For example, United States law does not provide you with the right to access, modify and delete personal information in all cases. Further, government entities in the United States may have certain rights to access your personal information. When transferring personal information to and processing personal information in the United States we will implement appropriate safeguards and process the personal information in accordance with the terms of this Privacy Notice. By using our Websites or our Services, you agree to the transfer and processing of your personal information to the United States.