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FingerLakes1.com Privacy Policy

Last Modified: October 12, 2022

FingerLakes1.com, Inc. (“Company,” “we,” “us,” or “our”), publisher of FingerLakes1.com and the FingerLakes1.com App, respects your privacy and understands that you care about your personal data and how it is used. We value your trust in sharing your personal data with us and are dedicated to protecting your privacy, as further described in this Privacy Policy.

1. SCOPE

This Privacy Notice (“Notice”) applies to personal data about subscribers to our print publications, users of our websites, mobile applications and direct marketing programs (collectively, the “Services”) collected by the Company or by third parties on our behalf. This Privacy Notice describes in detail the types of data we collect about you; how we use your data (the purposes for processing your data) and with whom we share it; the choices and rights you
have with regard to your data; how we protect your data; and how you can contact us about our privacy practices.

The Services are intended for a general audience and are not targeted to children under 16 years of age. In addition, please review our Terms of Use which governs your use of the Services.

2. DATA WE COLLECT AND OBTAIN

We obtain personal data about you from a variety of sources. This includes personal data you provide to us directly, data we obtain from other sources, and data we gather through automated means.

Data you provide to us through the Services. When you register for or participate in certain Services, seek access to certain content or features, or directly correspond with us, we may collect certain types of data from you:Contact information (such as name, postal address, email address and telephone and/or mobile numbers);Username and password when you register through our Services;Survey responses, reviews and/or comments;Household income;Credit card or other payment information; and Other information you may provide to us, such as through our “Contact Us” feature.

Data obtained from other sources. We may obtain personal data about you in connection with the Services from publicly and commercially available sources, from our affiliates and/or our business partners (such as advertising providers; analytics providers; marketers; public data bases; consumer data resellers; social media networks, in accordance with your privacy preferences on such services; researchers; payment processors; and surveys), including:Demographical data (such as gender, age range, educational level, household income range, number of children in household, ethnicity to the extent permitted);Purchasing data, including membership in loyalty programs or information about advertisements you have seen or acted upon, including your interaction with advertisers’ products and services;Occupational data (such as profession, position, title, industry);Preferences and shopping interests;Geo-location;Your activities on other Internet sites or mobile Apps;If you log-in with or connect a social networking profile with the Services (e.g., Facebook or YouTube), we may obtain data about you, such as your user ID and/or user name and other data you have permitted those networks to share with us consistent with your privacy settings on the applicable social networking service.

Data Collected by Automated Means Through Our Services. We also gather by automated means (such as cookies, web beacons, web server logs, JavaScript and other similar technologies) certain information through our Services:Your Internet Protocol (IP) address;Device information, including unique identifiers and connection information, including mobile device IDs (e.g., Apple’s IDFA or Google’s AAID) and the means of internet connection (e.g., WiFi connection, ISP) that can identify the physical location of such devices, in accordance with applicable law;Your device type and settings, software used, browser type and operating system;Language preferences;Websites or other services you visited before and after visiting the Services (referring URL);Web pages and advertisements you view and links you click on within, and what search queries you may have run on, the Services (clickstream);Viewing behavior, including the content you view (text, images, video) and for how long, and advertisements you have been shown or interacted with;Dates and times you access or use the Services;Location information, including the city, state and zip code associated with your IP Address, information derived through WiFi triangulation, and precise location information from GPS-based functionality on your mobile Apps, with your consent; andYour phone number and mobile carrier details in connection with our mobile app.

3. HOW WE USE THE INFORMATION WE OBTAIN

We, or service providers acting on our behalf, may use the personal data collected from and about you to:Provide our products and services, including authorizing a purchase, or completing a transaction that you requested;Create and manage online accounts;Send promotional materials, alerts regarding available offers and other communications;Communicate about, and administer participation in, special events, promotions, programs, offers, surveys, contests and market research;Respond to inquiries from you and other third-parties, including inquiries from law enforcement agencies;Anonymize or de-identify personal information to provide third parties with aggregated data reports showing anonymized information and other non-personal information;Provide technical support;Generate suggestions about the type of content, including video, you may enjoy;Supplement your personal information collected directly from you and/or from automated means with additional information from publicly and commercially available sources, and/or information from Company affiliates and our business partners;Associate your browser and/or device with other browsers or devices you use for the purpose of providing relevant and easier access to content, advertising across browsers and devices, and other operational/business purposes;Operate, evaluate and improve our business (including developing, enhancing, analyzing and improving our Services; managing our communications; reviewing and processing employment applications, performing data and statistical analytics; and performing accounting, auditing and other internal functions);Protect against, identify and prevent fraud and other unlawful activity, claims and other liabilities;Comply with and enforce applicable legal requirements, relevant industry standards, contractual obligations and our terms of service and other policies; andIn other ways for which we provide specific notice at the time of collection.

INTEREST-BASED ADVERTISING

As described in this Privacy Notice, we, as well as our third-party service providers, may obtain information about your online activities to provide you with advertising about products and services tailored to your individual interests. We and our third party service providers also may obtain information for this purpose from third party websites and apps. We engage third-party advertising networks to help us target our messaging to visitors through interest-based and contextual means.

We participate in ad networks that allow your online activities to be tracked over time by us and by the third-party websites and apps that participate in the same network by obtaining information through automated means, as described above. This data collection takes place both on our websites and apps and on third-party websites and apps that participate in these ad networks and then is used by the ad networks to show you advertisements on our Services and/or on third-party websites and apps that may be tailored to your individual interests. This information also helps us understand and analyze the effectiveness of our marketing efforts. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising.

4. INFORMATION WE SHARE

We may share your information with affiliated business partners and advertisers.

5. YOUR CHOICES AND RIGHTS

We offer you certain choices and you also may have certain rights in connection with the personal information we collect about you.

A.YOUR CHOICES

You can choose to use our Services without providing any information about yourself to us directly, but please note, as described above, some personal data may be collected automatically or be requested by us to enable you to take advantage of certain features of the Services.

To ask us to remove your personal data from our marketing mailing lists, please contact us.

You also can unsubscribe from our marketing mailing lists by following the “Unsubscribe” link in our emails. Even if you unsubscribe from our marketing communications, we may still need to send you communications relating to your use of the Services, such as service announcements or personalized communications about your home-delivery account.

You also have choices about whether cookies and other similar technologies are placed on your computer or mobile device.

We may use third-party analytics services on our Services, such as Google Analytics. The analytics providers that administer these services use technologies such as cookies, web beacons and similar technologies to help us analyze your use of the Services. To learn more about how to opt out of Google Analytics services, please visit the link below:Google Analytics: https://tools.google.com/dlpage/gaoptout

You may also choose to opt out of use of data that we or our third party service providers collect about your activities to provide you with tailored advertising about products and services of interest to you. We and our third party service providers also may obtain information for this purpose from third-party websites or apps. To learn more about how to opt out of ad network interest-based advertising, visit the customer opt-out pages at http://www.aboutads.info/choices/ and http://www.networkadvertising.org/choices/ or https://www.youronlinechoices.eu/

B.ACCESS, CORRECTION AND DELETION RIGHTS

Subject to applicable law, you may have certain rights to access, review, update and/or correct inaccuracies in your personal data in our custody and control by emailing or writing to us. Subject to applicable law, you may also have certain rights to delete your personal data in our custody and control by emailing or writing to us. We may request certain personal information for the purposes of verifying the identity of the individual seeking access to or deletion of his/her personal data records. Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate.

C.CALIFORNIA PRIVACY RIGHTS

For additional information for residents of the State of California see below.

D.INFORMATION FOR VISITORS FROM THE UNITED KINGDOM AND
THE EUROPEAN UNION/EEA

For additional information about our privacy practices in the United Kingdom and the European Union/EEA, please see below.

6. HOW WE PROTECT PERSONAL INFORMATION

We maintain administrative, technical and physical safeguards designed to protect the personal data we have about you against accidental, unlawful or unauthorized destruction, loss, alteration, access, disclosure or use. However, no data transmission or storage, or use of the Internet, can be guaranteed to be 100% secure.

7. TRANSFERS OF INFORMATION

The Services are hosted in and managed from the United States or the country in which we engage service providers. We may transfer the personal data we collect about you to another country, which may be outside your country of residence, including the United States, and that country may have different data protection laws than in your country.

If you are a user located outside the United States or the country to which your information may be transferred, you understand (and, as permitted under applicable law, consent to) having any personal data processed in the United States and/or such country. When we transfer your data, we will protect that data as described in this Privacy Notice.

8. CHANGES TO OUR PRIVACY NOTICE

From time to time, we may change our Privacy Notice to reflect changes to our privacy practices and Services. If we modify the Privacy Notice, we will update the “Last Modified Date” and the changes will be effective as of the date we post such Notice. For material changes, we will notify you by posting a prominent notice on our Services indicating at the top of the Privacy Notice when it was most recently updated.

9. HOW TO CONTACT US

If you have any questions or comments about this Privacy Notice or the manner in which we or our service providers treat your personal data, would like to exercise your choices, or would like us to update information we have about you or your preferences, please contact us at:

[email protected]

You also may write to:

FingerLakes1.com, Inc.
P.O. Box 85
Seneca Falls, NY 13148

California Residents Privacy Rights

NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA SHINE THE LIGHT LAW

Residents of the State of California may ask us to provide them with a list of the types of personal information that we have disclosed during the preceding year to third parties for their direct marketing purposes, and the identity of those third parties. If you are a California resident and would like such a list, please contact us at [email protected].

For all such requests, please indicate “CA Shine the Light” in the subject field of your request and include the name of the Service with respect to which you are requesting the information. You must also include your full name, street address, city, state, zip code and email address.

NOTICE TO CALIFORNIA RESIDENTS – CALIFORNIA CONSUMER PRIVACY PROTECTION ACT

The California Consumer Privacy Act of 2018 (“CCPA”) provides certain rights to residents of California. This section of the Privacy Notice applies if you are a natural person who is a resident of California (“California Resident”) and uses our Services. This notice supplements the information in the Privacy Policy above. Certain terms used below have the meanings given to them in the CCPA.

Categories of Personal Information We Collect:

  • Identifiers (such as your contact information (name, email address, postal address, phone number), or unique personal identifiers (wireless device ID, cookies, IP address, username, password) (“Identifiers”);
  • Commercial information (such as transaction data, purchase history, or delivery information) (“Commercial Data”);
  • Financial information (such as credit or debit card information, verification number, and expiration date) (“Financial Data”);
  • Internet or other network or device activity (such as browsing history, browser type and language, operating system or app usage) (“Internet Data”);
  • Geo-location information (such as city, state and zip code associated with your IP address or derived through Wi-Fi triangulation; and with your permission in accordance with your mobile device settings, precise geolocation information from GPS-based functionality on your mobile devices (“Geo-location Data”);
  • Inference information about you (such as preferences, characteristics, and behaviors) (“Inference Data”);
  • Profile data about you and any inferences drawn from the profile data (such as characteristics, behaviors, attitudes) (“Profile Data”); and
  • Information that identifies or can be reasonable associated with you (“Associated Data”).

Business or Commercial Purposes for which We Collect or Share Personal Information:

  • performing services, including maintaining or servicing accounts, providing customer service, processing or fulfilling orders and transactions, verifying customer information, processing payments, providing advertising or marketing services, providing analytics services, or providing similar services (“Performing Services”);
  • auditing related to a current interaction with you and concurrent transactions, including, but not limited to, counting ad impressions to unique visitors, verifying positioning and quality of ad impressions, and auditing compliance (“Auditing”);
  • short-term, transient use, including, but not limited to, the contextual customization of ads shown as part of the same interaction (“Short-term Use”);
  • detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and prosecuting those responsible for that activity (“Data Security & Fraud Prevention”);
  • debugging to identify and repair errors that impair existing intended functionality (“Repairs”);
  • undertaking internal research for technological development and demonstration (“Research and Development”);
  • undertaking activities to verify or maintain the quality or safety of a service or device that is owned, manufactured, manufactured for, or controlled by us, and to improve, upgrade, or enhance the service or device that is owned, manufactured, manufactured for, or controlled by us (“Quality and Safety”); and
  • to advance the commercial or economic interests of the Company, such as by inducing another to buy, rent, lease, join, subscribe to, provide, or exchange products, goods, property, information, or services, or enabling or effecting, directly or indirectly, a commercial transaction (“Commercial Interests”).

Categories of Sources from which We Collect Personal Information:

  • Directly from you (“You”);
  • From other sources (such as Company affiliates and/or business partners; advertising providers; analytics providers; marketers; public data bases; consumer data resellers; social media networks, in accordance with your privacy preferences on such services; researchers; payment processors; and surveys)(“Affiliates and Partners”); and
  • Through your use of the Services (“Services Use”).

CALIFORNIA CONSUMER PRIVACY RIGHTS AND CHOICES

California Residents may have certain rights in connection with the personal information we collect about you, many of which are subject to exceptions under applicable law:

The right to access and disclosure. You may have the right to request, twice during a twelve-month period, the following information about the personal information we have collected about you during the past 12 months:

  • the categories and specific pieces of personal information we have collected about you;
  • the categories of sources from which we collected the personal information;
  • the business or commercial purpose for which we collected or sold the personal information;
  • the categories of third parties with whom we shared the personal information; and
  • the categories of personal information that we sold or disclosed for a business purpose, and the categories of third parties to whom we sold or disclosed that information for a business purpose.

The right to deletion. You may have the right to request that we delete the personal information we have collected from you.

Certain information may be exempt from such requests under applicable law. We need certain types of information so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

How to exercise your access and deletion rights.

California residents may exercise their California privacy rights by submitting your request to Submit Request, or by contacting us at 1-800-552-7678.

For security purposes, we will verify your identity – in part by requesting certain information from you — when you request to exercise your California privacy rights. For instance, you may need to provide your name and email address. To request that we provide you with the specific pieces of personal information we have from you or to delete personal information we have collected from you, we may also need to ask you for additional information to verify your identity.

Once we have verified your identity (and your agent, as applicable), we will respond to your request as appropriate:

  • Where you have requested the categories of personal information that we have collected about you, we will respond by email providing such categories.
  • Where you have requested specific pieces of personal information, we will provide the information you have requested, except where not permitted under applicable law or otherwise exempted by the CCPA. For instance, we may not disclose government ID or financial account number as such disclosure may create an unreasonable risk to your personal information, your account with us, or our business systems.
  • Where you have requested that we delete personal information that we have collected from you, we will delete, deidentify or aggregate any information about you that is not necessary for the purposes indicated above. Certain information may be exempt from such requests under applicable law.

If we are unable to complete your requests fully for any of the reasons above, we will provide you additional information about the reasons that we could not comply with your request.

The right to nondiscrimination. We will not deny, charge different prices for, or provide a different level of quality of goods or services if you choose to exercise these rights.

The right to opt-out of the sale of your personal information. You have the right to opt out of the sale of your personal information. California law broadly defines “sale” such that it may include allowing third parties to receive certain information, such as IP address and/or browsing behavior, to deliver targeted advertising.

If you would like to opt out, you may do so by contacting us at 1-315-712-0104.

Authorized Agents

You may also designate an agent to make requests to exercise your rights under CCPA as described above. We will take steps to verify both (1) the identity of the person seeking to exercise their rights as listed above and (2) that your agent has been authorized to make a request on your behalf by providing us with a copy of a signed written authorization or a copy of a power of attorney.

For EU/EEA & UK Users

This section of the Privacy Policy applies if you are in the United Kingdom or a country that is a Member of the European Union or European Economic Area, and supplements the information in the Privacy Policy posted above on this page.

FingerLakes1.com, Inc., the owner and operator of FingerLakes1.com, is the data controller for the processing of your personal data as defined under the GDPR.

LEGAL BASIS FOR DATA PROCESSING

In addition to the purposes for which we collect and process your personal data as set out in the Privacy Policy above, we do so under the following legal bases:

To provide our Services to you, we process your personal data for certain purposes with your consent; for example, to select personalized ads. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

We sometimes use your personal data on the grounds that there is a legitimate reason to do so. For example, we may use your data where it would help achieve our business objectives or to facilitate a benefit to you. We only rely on legitimate interests if the reason for using your information is fair and lawful. We will carry out a balancing test between our legitimate interests and your privacy rights where we want to rely on legitimate interest as a legal basis. Our legitimate interests in processing personal data include:To show you ads based on the content you’re viewing, your approximate location and/or your device type;To measure the performance and effectiveness of ads that you see or interact with;To measure the performance and effectiveness of content that you see or interact with;To learn more about the audiences who visit our websites and view ads, using market research; andTo improve existing systems and software and to develop new products.We also process your personal data when we have a legal or regulatory obligation or to defend claims.

UK/EU/EEA DATA SUBJECT RIGHTS

As UK/EU/EEA data subjects, you have rights of access, correction or rectification, and deletion, as well as certain additional rights. Below is an overview of your rights, many of which are subject to exceptions under applicable law. You can exercise any of your rights at any point in time by sending an email to [email protected].

The right to access and rectification or correction. You may have the right to access, correct and update your personal data at any time.

The right to deletion. Under certain circumstances, you may have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with applicable legal requirements. If the personal data is no longer needed for any purposes that justify its retention and we are no required by law to retain it, we will do what we can to delete, destroy or permanently de-identify it. Certain data may be exempt from such requests under applicable law. We may need certain types of data so that we can provide our Services to you. If you ask us to delete it, you may no longer be able to access or use our Services.

The right to object to or restrict processing. Under certain circumstances, you have the right to object to or restrict our processing of your personal data. For example, where we process personal data based on our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your data.

The right to withdraw consent. If you have given your consent to anything we do with your personal data and we rely on your consent as a legal basis for processing your personal data, you have the right to withdraw your consent to the processing of your personal data by contacting us. This will not affect the lawfulness of the processing based on your consent before its withdrawal.

The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with the relevant Supervisory Authority about how we process your personal data.

The right to data portability. With respect to the personal data you have provided to us, in addition to the general right of access described above, you may have, subject to certain exceptions, rights to (i) receive a copy of it in a structured, commonly used and machine-readable format, (ii) transmit the data to another data controller, and (iii) depending on the circumstances, have us perform that transmission.

RETENTION OF PERSONAL DATA

We will keep your personal data for as long as we need it to fulfill the purposes set out in our Privacy Notice, or while there is a legitimate reason for doing so, and as otherwise required or permitted by applicable law, such as in relation to our record retention obligations.

We review the personal data we hold and delete it securely, or in some cases anonymize it, when there is no longer a legal, business or consumer need for it to be retained.

INTERNATIONAL DATA TRANSFERS

As the Services are hosted in the United States, the personal data of our UK/EU/EEA users is hosted in the United States, and we may further transfer such personal data to countries that may not have data protection rules that require the same level of protection as in the EU/EEA/UK; however, we will make sure that there are appropriate mechanisms and controls in place to protect your data. This may include data transfer agreements, a copy of which you can obtain by contacting us at [email protected]. We may use these data transfer mechanisms – and not consent – as the legal basis for our own transfers of personal data (even when other aspects of our handling of personal data take place on the basis of consent).

THIRD PARTY ONLINE ADVERTISING

We enable certain third party advertising exchanges to place advertisements on our sites.

The European Digital Advertising Alliance (“EDAA”) has developed a guide to online behavioral advertising and has developed an opt-out page to manage online behavioral advertising preferences with EDAA member companies available at
www.YourOnlineChoices.eu. In addition, we participate in the IAB Europe Transparency & Consent Framework and comply with its specification and policies. We use a consent management platform with the identification number 28.