Last updated September 15, 2023
The website you have entered (newlinesmag.com, its sub-domains, affiliated websites, or applications, and any services available therefrom, including any mobile versions of the website or mobile applications) (the “Site” or “Website”) is published and operated by New Lines Institute for Strategy and Policy, LLC, a District of Columbia limited liability company, d/b/a New Lines Magazine (“New Lines,” “Company”, “We”, “Us”, “Our”).
We publish this Public Policy to inform you of Our policies and procedures regarding the collection, use, and disclosure of personal information that We receive through the Site and through the use of any services provided by Us through the Site (the “Services”).
1. WHAT INFORMATION DO WE COLLECT?
a. Personal information you disclose to us
In Short: We collect personal Information that you provide to Us (such as when you submit an inquiry).
The personal information that we collect depends on the context of your interactions with Us and the Website, the choices you make and the products and features you use. In general, “Personal Information” means information that can reasonably be used to identify you personally (such as your name, phone number, address, and email address).
We also collect personal Information that you voluntarily provide to Us when you express an interest in obtaining information about Us or our products and Services, when you participate in activities on the Website, or otherwise when you contact Us.
We also collect payment information such as your credit card number (processed by our third-party payment processor) and expiration date, where appropriate to process a financial transaction that you have requested.
We may also collect other Personal Information where you interact with us in-person, online, or by phone or mail in the context of:
- Receiving help through our customer support channels;
- Participation in customer surveys or contests;
- Making a donation; and
- Facilitation in the delivery of our Services and to respond to your inquiries.
If you make a donation via the Website, your information will be added to one or more of our supporter lists and databases, and you may be contacted about our other activities, news, and/or fundraising campaigns.
All Personal Information that you provide to us must be true, complete, and accurate, and you must notify Us of any changes or errors to such Personal Information.
If we are relying on your consent to process your Personal Information, you have the right to withdraw your consent at any time. Please note however that this will not affect the lawfulness of the processing before its withdrawal, nor will it affect the processing of your Personal Information conducted in reliance on lawful processing grounds other than consent.
b. Information automatically collected
In Short: When you access and use the Site, Our technology and tools may automatically collect and record certain data about your use of the Site (such as your Internet Protocol (IP) address and/or browser and device characteristics).
We automatically collect certain information when you visit, use, or navigate the Website. This information does not reveal your specific identity (like your name or contact information) but may include device and usage information, such as your IP address, browser and device characteristics, operating system, language preferences, referring URLs, device name, country, location, information about how and when you use our Website, and other technical information. This information is primarily needed to maintain the security and operation of our Website and for Our internal analytics and reporting purposes.
More specifically, the information that we may automatically collect includes:
- Log and Usage Data. Log and usage data is service-related, diagnostic, usage and performance information that our servers automatically collect when you access or use Our Website and which We record in log files. Depending on how you interact with us, this log data may include your IP address, device information, browser type and settings and information about your activity in the Website (such as the date/time stamps associated with your usage, pages and files viewed, searches and other actions you take such as which features you use), device event information (such as system activity, error reports (sometimes called ‘crash dumps’) and hardware settings).
- Device Data. We collect device data such as information about your computer, phone, tablet or other device you use to access the Website. Depending on the device used, this device data may include information such as your IP address (or proxy server), device and application identification numbers, location, browser type, hardware model, Internet service provider and/or mobile carrier, operating system and system configuration information.
- Location Data. We collect location data such as information about your device’s location, which can be either precise or imprecise. How much information we collect depends on the type and settings of the device you use to access the Website. For example, We may use GPS and other technologies to collect geolocation data that tells Us your current location (based on your IP address). You can opt out of allowing Us to collect this information either by refusing access to the information or by disabling your Location setting on your device. Note, however, if you choose to opt out, you may not be able to use certain aspects of the Services.
In addition, We use social media features, such as the Facebook Like button, and widgets, such as the ‘Share This’ button on our Website. Such features may process your Internet Protocol (IP) address and track which page you are visiting on our Website. We may place a cookie to enable the feature to work correctly. If you are logged in on a certain social media platform and you interact with a widget or button belonging to that social media platform, this information may be recorded to your profile of such social media platform. To avoid this, you should log out from that social media platform before accessing or using the Website. Social media features and widgets may be hosted by a third party or hosted directly on our Website. Your interactions with these features are governed by the privacy notices of the companies that provide them. By agreeing to the use of any social media plug-in or related application, you agree to the use of this plugin and consequently the transfer of Personal Information to the corresponding social media service. We have no control over the essence and extent of these transmitted data as well as their additional processing.
c. Information collected from other sources
In Short: We may collect data from public databases, marketing partners, and other outside sources that may concern you.
In order to enhance our ability to provide relevant marketing, offers, and services to you and update our records, We may obtain information about you from other sources, such as public databases, joint marketing partners, affiliate programs, data providers, social media plugins, as well as from other third parties. This information includes mailing addresses, job titles, email addresses, phone numbers, intent data (or user behavior data), Internet Protocol (IP) addresses, social media profiles, social media URLs and custom profiles, for purposes of targeted advertising and event promotion.
d. Third parties may also automatically collect data about you
In Short: Some embedded content on the Site may be served by third-party content providers.
e. Categories of Personal Information collected
We have collected the following categories of Personal Information in the past twelve (12) months:
|A. Identifiers||Contact details, such as real name, alias, postal address, telephone or mobile contact number, unique personal identifier, online identifier, Internet Protocol address, email address and account name||YES|
|B. Personal information categories listed in the California Customer Records statute||Name, contact information, education, employment, employment history and financial information||YES|
|C. Protected classification characteristics under California or federal law||Gender and date of birth||NO|
|D. Commercial information||Transaction information, purchase history, financial details and payment information||NO (unless you have a subscription with New Lines)|
|E. Biometric information||Fingerprints and voiceprints||NO|
|F. Internet or other similar network activity||Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements||NO|
|G. Geolocation data||Device location||NO|
|H. Audio, electronic, visual, thermal, olfactory, or similar information||Images and audio, video or call recordings created in connection with our business activities||NO|
|I. Professional or employment-related information||Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply for a job with us||NO|
|J. Education Information||Student records and directory information||NO|
|K. Inferences drawn from other personal information||Inferences drawn from any of the collected personal information listed above to create a profile or summary about, for example, an individual’s preferences and characteristics||NO|
f. Opting-out of Personal Information use
If We have processed your Personal Information based on your consent and you wish to revoke your consent, please email us at [email protected].
You may remove certain tracking technologies and opt-out of online behavioral advertising messaging by using the opt-out tools available from the Digital Advertising Alliance (DAA Opt-Out Tool) and the Network Advertising Initiative (NAI Opt-Out Tools). Please note that these opt-out tools are device and browser specific, so you must repeat the opt-out from each of your browsers and devices.
You may also adjust your advertising preferences on various social media websites by adjusting your settings on the platform (for example, you may adjust the types of Facebook ads you receive HERE).
2. HOW DO WE USE YOUR INFORMATION?
In Short: We process your information for purposes based on legitimate business purposes, in order to enter into or perform a contract with you, with your consent, and/or for compliance with our legal obligations.
We indicate the specific processing grounds we rely on next to each purpose listed below.
- Facilitate account creation and logon process. If you choose to link your account with us to a third-party account (such as your Google or Facebook account), we use the information you allowed us to collect from those third parties to facilitate account creation and logon process for the performance of the contract. In addition, you may access or modify your account, update your subscriptions, and email newsletters associated with that account, and view your history on the User Profile page.
- Request feedback. We may use your information to request feedback and to contact you about your use of Our Website.
- Enable user-to-user communications. We may use your information in order to enable user-to-user communications with each user’s consent.
- Manage user accounts. We may use your information for the purposes of managing our account and keeping it in working order.
- Send administrative information to you. We may use your Personal Information to send you product, service and new feature information and/or information about changes to our terms, conditions, and policies.
- Protect our Services. We may use your information as part of our efforts to keep our Website safe and secure (for example, for fraud monitoring and prevention).
- Enforcement. We may use your Personal Information to enforce our terms, conditions, and policies for business purposes, to comply with legal and regulatory requirements, or in connection with our contract.
- Respond to legal requests and prevent harm. If we receive a subpoena or other legal request, we may need to inspect the data we hold to determine how to respond.
- Fulfill and manage your orders. We may use your Personal Information to fulfill and manage your orders, payments, returns, and exchanges made through the Website
- Administer prize draws and competitions. We may use your Personal Information to administer prize draws and competitions when you elect to participate in our competitions.
- Deliver and facilitate delivery of services to the user. We may use your Personal Information to provide you with the requested service.
- Respond to user inquiries/offer support to users. We may use your Personal Information to respond to your inquiries and solve any potential issues you might have with the use of our Services.
- Internal Research. We may use your Personal Information to conduct internal research or technological development and demonstration, including but not limited to developing, improving, and targeting Our promotional messaging to you and others via retargeting, online behavioral advertising, and use of social media platform tools for advertising (such as creation of Facebook Lookalike Audiences).
- Send you marketing and promotional communications. We and/or our third-party marketing partners may use the Personal Information you send to us for our marketing purposes. For example, when expressing an interest in obtaining information about Us or Our Website, subscribing to marketing or otherwise contacting Us, We will collect Personal Information from you. You can opt-out of our marketing emails at any time (see the “WHAT ARE YOUR PRIVACY RIGHTS” below).
- Deliver targeted advertising to you. We may use your Personal Information to develop and display personalized content and advertising (and work with third parties who do so) tailored to your interests and/or location and to measure its effectiveness.
- Promotions. We may use your Personal Information to provide you with additional information regarding products and services from us or our affiliates or from others that may be of interest to you, including but not limited to co-branded services and features (such as contests, sweepstakes, or other promotions). We may contact you via email, text message, or through advertising on various social media platforms or websites (both desktop and mobile) that you may visit.
- Site and Services Improvement. We may use your Personal Information to improve the Site or our products, events, and Services and for other business or commercial purposes.
- Other Business Purposes. We may use your Personal Information to carry out any other purpose described to you at the time the data was collected, or to carry out any other purpose with your consent or as permitted by law.
- Donors. We may use your Personal Information with other organizations with whom we participate in exchange of supporter or donor information and the service providers that facilitate such exchange.
You agree that the aforementioned activities are not considered “selling” of your personal data.
3. WILL YOUR INFORMATION BE SHARED WITH ANYONE?
We may process or share your Personal Information that we hold based on the following legal basis:
- Consent: If you have given us specific consent to use your Personal Information for a specific purpose.
- Legitimate Interests: When it is reasonably necessary to achieve our legitimate business interests or purpose.
- Performance of a Contract: Where we have entered into a contract with you.
- Legal Obligations: Where we are legally required to do so in order to comply with applicable law, governmental requests, a judicial proceeding, court order, or legal process, such as in response to a court order or a subpoena (including in response to public authorities to meet national security or law enforcement requirements).
- Vital Interests: Where we believe it is necessary to investigate, prevent, or take action regarding potential violations of our policies, suspected fraud, situations involving potential threats to the safety of any person and illegal activities, or as evidence in litigation in which we are involved.
Furthermore, we may process or share your Personal Information in the following situations:
- Business Transfers. In connection with, or during negotiations of, any merger, sale of company assets, financing, or acquisition of all or a portion of our business to another company.
- Vendors, Consultants and Other Third-Party Service Providers. With third-party vendors, service providers, contractors, or agents who perform services for us or on our behalf and require access to such information to do that work. Examples include: payment processing, data analysis, email delivery, hosting services, customer service and marketing efforts. We may allow selected third parties to use tracking technology on the Website, which will enable them to collect data on our behalf about how you interact with our Website over time. This information may be used to, among other things, analyze and track data, determine the popularity of certain content, pages or features, and better understand online activity.
- Sponsors. With Our sponsors, promotional partners, or event partners in connection with certain contests, sweepstakes, promotions or other events.
- Affiliates. With Our affiliates, including our parent company and any subsidiaries, joint venture partners, or other companies that We control or that are under common control with Us.
- Business Partners. With our business partners to offer you certain products, services or promotions.
We use commercially reasonable technical and organizational measures to help secure and safeguard your data in our possession. However, no data transmission over the Internet is completely secure. Therefore, although we take steps to protect your data, we cannot guarantee the security of the data that we collect from you or the security of our servers or the Site. By accessing the Site, any transmission of Personal Information is at your own risk and you agree to assume all risk in connection with the Personal Information sent to us or collected by us.
4. WHO WILL YOUR INFORMATION BE SHARED WITH?
Third parties with whom we may share and disclose your Personal Information include, but are not limited to:
- Facebook, Instagram, and X, formerly called Twitter, (and other Cloud Computing Services)
Google Cloud Platform
Google Site Search and YouTube video embed
- Google Drive Backup and Dropbox Backup
- Social Media Sharing and Advertising
- Facebook social plugins, LinkedIn social plugins, Twitter social plugins and YouTube social plugins
- Website Hosting (including WordPress.com)
- Website Testing
- Google Website Optimizer
Cookies are small bits of information that may be placed on your computer by websites you visit, applications you use, or advertisements you view. Cookies alone tell us nothing about who you are. Most Web browsers are set to accept cookies by default. If you prefer, you can usually choose to set your browser to remove cookies and to reject cookies. If you choose to remove cookies or reject cookies, this could affect certain features or services of our Website. To opt-out of interest-based advertising by advertisers on our Website visit http://www.aboutads.info/choices/.
Pixel tags generate a generic notice of a visit to the Site. Pixel tags are used in conjunction with cookies to anonymously track the activity on the Site by a particular browser on a particular site.
6. IS YOUR INFORMATION TRANSFERRED INTERNATIONALLY?
In Short: We may transfer, store, and process your Personal Information in countries other than your own.
The Site is designed for and targeted to the United States. Our servers are located in the United States. If you are accessing the Site from outside the United States, please be aware that your information may be transferred to, stored, and processed by us in our facilities and by those third parties with whom we may share your Personal Information (see “WILL YOUR INFORMATION BE SHARED WITH ANYONE?” above), in and other countries. Please note that United States may have different standards for how your data is used and secured than the standards in place in your country.
7. HOW LONG DO WE KEEP YOUR INFORMATION?
When we have no ongoing legitimate business need to process your Personal Information, we will either delete or anonymize such information, or, if this is not possible (for example, because your Personal Information has been stored in backup archives), then we will securely store your Personal Information and isolate it from any further processing until deletion is possible.
8. DO WE COLLECT INFORMATION FROM MINORS?
In Short: We do not knowingly or intentionally collect data from or market to children under 18 years of age.
By using the Website, you represent that you are at least 18 or that you are the parent or guardian of such a minor and consent to such minor dependent’s use of the Website. If you are under the age of 18, you may not use the Site except as otherwise provided herein with the consent of a parent or guardian.
If we learn that Personal Information from users less than 18 years of age has been collected, we will deactivate the account and take reasonable measures to promptly delete such data from our records. If you become aware of any Personal Information that we may have collected from children under age 18 without their parent/legal guardian’s consent, please contact us at [email protected].
9. WHAT ARE YOUR PRIVACY RIGHTS?
In Short: In some regions, such as the European Economic Area, the United Kingdom, and Switzerland, you have rights that allow you greater access to and control over your Personal Information. You may review, change, or terminate your account at any time.
These rights may include the right (i) to request access and obtain a copy of your Personal Information, (ii) to request rectification or erasure; (iii) to restrict the processing of your Personal Information; and (iv) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your Personal Information. To make such a request, please contact us at [email protected]. We will consider and act upon any request in accordance with applicable data protection laws.
If you are a resident in the European Economic Area, the United Kingdom, or Switzerland and you believe we are unlawfully processing your Personal Information, you also have the right to complain to your local data protection supervisory authority. You may find their contact details here: http://ec.europa.eu/justice/data-protection/bodies/authorities/index_en.htm.
If you are a resident in Switzerland, the contact details for the data protection authorities are available here: https://www.edoeb.admin.ch/edoeb/en/home.html.
10. CONTROLS FOR DO-NOT-TRACK FEATURES
In short: Some websites have “do not track” features that allow you to tell a website not to track you.
11. DO CALIFORNIA RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
Under California law, you have the right to send us a request at the designated address listed below to receive the following information:
- the categories of information we disclosed to third parties for their direct marketing purposes during the preceding calendar year;
- the names and addresses of the third parties that received the information; and
- if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed.
This information may be provided in a standardized format that is not specific to you. The designated email address for these requests can be found at: [email protected].
Additionally, if you are a California resident and are under the age of 18 and you have posted content or information to our Site or Services, you can request that we remove content or information that you have posted to our Site or Services.
Also, please note that we have not yet developed a response to browser “Do Not Track” signals, and do not change any of our data collection practices when we receive such signals. We will continue to evaluate potential responses to “Do Not Track” signals in light of industry developments or legal changes.
12. DO EUROPEAN OR SWISS RESIDENTS HAVE SPECIFIC PRIVACY RIGHTS?
In short: If you are located in the European Union (“EU”) or Switzerland, you have certain rights with respect to your Personal Information. The following is a summary of those rights and additional information applicable to our collection and use of your Personal Information.
a. Data Controller
b. Legal basis for processing information
If you are located in the EU or Switzerland, we rely on several legal bases to process your Personal Information. These legal bases include where:
- The processing is necessary to perform our contractual obligations, such as to provide you with our Services;
- You have given your prior consent (such as for marketing purposes or other purposes for which we obtained your consent), which you may withdraw at any time;
- The processing is necessary to comply with a legal obligation, a court order, or to exercise or defend legal claims;
- The processing is necessary for the purposes of our legitimate interests, such as in improving, personalizing, or developing our Site and services, marketing new features or products that may be of interest, and promoting safety and security.
If you have any questions about or would like further information concerning the legal bases on which we collect and use your Personal Information, please contact us by emailing [email protected].
c. Rights Under the General Data Protection Regulation
If you are located in the EU or Switzerland, you have the following rights in respect of your Personal Information that we hold:
- Right of access. The right to obtain access to your Personal Information.
- Right to rectification. The right to obtain rectification of your Personal Information without undue delay where that Personal Information is inaccurate or incomplete.
- Right to erasure. The right to obtain the erasure of your Personal Information without undue delay in certain circumstances, such as where the Personal Information is no longer necessary in relation to the purposes for which it was collected or processed.
- Right to restriction. The right to obtain the restriction of the processing undertaken by us on your Personal Information in certain circumstances, such as where the accuracy of the Personal Information is contested by you, for a period enabling us to verify the accuracy of that Personal Information.
- Right to portability. The right to portability allows you to move, copy, or transfer Personal Information easily from one organization to another.
- Right to object. You have a right to object to processing based on legitimate interests and direct marketing.
Further information about how to contact your local data protection authority is available HERE.
If you wish to exercise one of these rights, please email us at [email protected]. You also have the right to lodge a complaint to your local data protection authority.
d. Retention of Personal Information.
We reserve the right to retain any Personal Information as long as it is needed to: (1) fulfill the purposes for which we collected the Personal Information; and (2) comply with applicable law.
e. Transfers of Personal Information.
f. Obligations to Data Protection Authorities (DPAs)
We will respond diligently and appropriately to requests from DPAs about this policy or compliance with applicable data protection privacy laws and regulations. We will, upon request, provide DPAs with names and contact details of the individuals designated to handle this process. With regard to transfers of Personal Information, we will (1) cooperate with inquiries from the DPA responsible for the entity exporting the data and (2) respect its decisions, consistent with applicable law and due process rights. With regard to transfers of data to third parties, we will comply with DPAs’ decisions relating to it and cooperate with all DPAs in accordance with applicable legislation.
g. Contacting Our Data Protection Officer
To contact our designated Data Protection Officer, please send an email to: [email protected].
14. WHAT DO WE DO WITH YOUR CREDIT CARD INFORMATION?
In short: we do process any payment card information.
New Lines Magazine
1776 Massachusetts Ave N.W.
Washington, DC 20036 United States
16. HOW CAN YOU REVIEW, UPDATE, OR DELETE THE DATA WE COLLECT FROM YOU?
a. Your rights
Based on the applicable laws of your country, you may have the right to request access to the Personal Information that we collect from you, change that information, or delete it in some circumstances.
In addition, depending on the circumstances, you have a right to know:
- whether we collect and use your Personal Information;
- the categories of Personal Information that we collect;
- the purposes for which the collected Personal Information is used;
- whether we sell your Personal Information to third parties;
- the categories of Personal Information that we sold or disclosed for a business purpose;
- the names and addresses of the third parties that receive the Personal Information;
- if the nature of the third party’s business cannot be determined from their name, examples of the products or services marketed;
- the categories of third parties to whom the Personal Information was sold or disclosed for a business purpose; and
- the business or commercial purpose for collecting or selling Personal Information.
Furthermore, you may have the following rights:
- you may object to the processing of your Personal Information;
- you may request correction of your Personal Information if it is incorrect or no longer relevant, or ask to restrict the processing of the Personal Information;
- you can designate an authorized agent to make a request under the CCPA on your behalf;
- you may request to opt-out from future selling of your Personal Information to third parties.
b. Making the request
To request to review, update, or delete your Personal Information, please submit a request form by emailing [email protected]. We will respond to your request within 30 days.
You may opt out of receiving New Lines Magazine newsletters at any time, by unsubscribing, either through the newsletter email, or by contacting Us at [email protected]. Newsletter subscriptions are currently serviced by Mailchimp. Upon receiving a request to opt-out, we will act upon the request as soon as feasibly possible, but no later than 15 days from the date of the request submission.
Upon receiving your request, we will need to verify your identity to determine if you are the same person about whom we have the information in our system. These verification efforts require us to ask you to provide information so that we can match the submitted information with information you have previously provided to us. For example, depending on the type of request you submit, we may ask you to provide certain information so that we can match the information you provide with the information we already have on file, or we may contact you through a communication method (e.g. phone or email) that you have previously provided to us. We may also use other verification methods as the circumstances dictate.
We will only use Personal Information provided in your request to verify your identity or authority to make the request. To the extent possible, we will avoid requesting additional information from you for the purposes of verification. If, however, we cannot verify your identity from the information already maintained by us, we may request that you provide additional information for the purposes of verifying your identity, and for security or fraud-prevention purposes. We will delete such additionally provided information as soon as we finish verifying you.
We may deny a request from an authorized agent that does not submit proof that they have been validly authorized to act on your behalf.
D. Our response
If you ask us to delete your Personal Information, we will respect your request and delete your Personal Information, subject to certain exceptions provided by law or as the circumstances may permit, such as (but not limited to) the exercise by another consumer of his or her right to free speech, our compliance requirements resulting from a legal obligation, or any processing that may be required to protect against illegal activities.
In accordance with applicable law, we are not obligated to provide or delete consumer information that is de-identified in response to a consumer request or to re-identify individual data to verify a consumer request.
We will not discriminate against you if you exercise your privacy rights.