Privacy Policy

Privacy Policy (v.1.0)

I. Introduction

Last Updated: March 31, 2024

This Privacy Policy explains how Freedom Du Jour LLC and FDJ News (“we,” “us,” or “our”) collect, use, disclose, and safeguard information belonging to and/or gathered from our users (“user,” “you,” or “consumer”) while accessing our website, FDJNews.com, including any other media form, media channel, mobile website, mobile application, or service related or connected thereto (collectively, our “Website”). Please read this Privacy Policy carefully. If you do not agree with the terms of this Privacy Policy, you are not permitted to access our Website.

We reserve the right to make changes to this Privacy Policy at any time and for any reason. We will alert you about any changes by updating the date contained in the “Last Updated” line at the top of this Privacy Policy. Any changes or modifications will be effective immediately upon posting the updated Privacy Policy on our Website, and you waive the right to receive specific notice of each such change or modification.

You are encouraged to periodically review this Privacy Policy to stay informed of updates. You are deemed to have accepted the changes in any revised Privacy Policy by your continued use of our Website after the date such revised Privacy Policy is posted.

II. Collection of Your Information

The personal information that we collect depends on the context of your interactions with us and our Website, the choices you make, features you use, and the products or services you purchase. The personal information we collect may include the following:

A. Personal Data

We may collect personal identifiable information, such as your name, shipping address, email address, and telephone number; and demographic information, such as your age, gender, and interests, that you voluntarily give to us when using features of our Website or when you choose to participate in various activities related to our Website, such as our Website store, contact form, public comments form, and lead forms embedded in advertisements posted on third-party websites such as Facebook. While you are under no obligation to provide us with personal information of any kind, your refusal to do so may prevent you from using certain features of our Website.

B. Financial Data

Through use of an embedded Stripe widget, our Website will collect your financial information in the form of your payment method (e.g., credit/debit card number, card brand, expiration date, and security code) when you order products from our Website store and choose to pay using Stripe. We do not access, view, or store financial data, but our payment processor, Stripe, may access, view, and store your financial data. For more information, you may review Stripe’s privacy policy here

Through use of an embedded Paypal widget, our Website will collect your financial information in the form of your payment method (e.g., credit/debit card number, card brand, expiration date, and security code) when you order products from our Website store and choose to pay using Paypal. We do not access, view, or store financial data, but our payment processor, Paypal, may access, view, and store your financial data. For more information, you may review Paypals’s privacy policy here

C. Native Login Data

We may collect passwords, password hints, and similar security information used for authentication and access to your account on our Website.

D. Third-Party Account Login Data

Our Website may offer you the ability to register and login using your third-party service provider account details (each such account, a “Third-Party Account”), e.g., your Facebook or Google account login. If you choose to do this, we will receive certain profile information about you from your third-party service provider. The profile information we receive may vary depending on the third-party service provider, but will often include your name, email address, friends, followers, or subscribers, profile picture, and other information you choose to make public.

We will use the information we receive only for the purposes described in this Privacy Policy or that are otherwise made clear to you on our Website. Please note that we do not control, and are not responsible for, other uses of your personal information by your third-party service provider. We recommend that you review their privacy policies to understand how they collect, use, and share your personal information and how you can set your privacy preferences on their websites and apps.

E. Derivative Data

We may automatically collect information via our servers when you visit, use, or navigate our 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 internet protocol (“IP”) address, web browser, device characteristics, device name, operating system, language preferences, general location as it may be obtained from your IP address, the pages you have viewed on our Website, including referral URLs and external links clicked from our Website, and other technical information. We also collect information through cookies and similar technologies, as described in the Cookies and Similar Technologies section of this Privacy Policy below.

F. Data from Contests, Giveaways, and Surveys

We may collect personal and other information you may provide when entering contests or giveaways and/or responding to surveys on our Website.

III. Use of Your Information

We use your personal information collected via our Website for our legitimate business interests (“Business Purposes”), in order to enter into or perform a contract with you (“Contractual”), with your consent (“Consent”), and/or for compliance with our legal obligations (“Legal Reasons”). We indicate the specific use grounds we rely on next to each use case listed below. We may use information collected about you via our Website as follows:

Facilitate account creation and logon process via native login data or social login data (Consent).
Administer sweepstakes, promotions, and contests (Business Purposes and/or Consent).
Compile anonymous statistical data and analysis for use internally (Business Purposes).
Deliver targeted advertising, coupons, newsletters, updates, and other information relating to our Website (Business Purposes and/or Consent).
Contact you regarding a donation you made on our Website (Business Purposes and/or Legal Reasons).
Contact you regarding an order you placed through our Website store (Business Purposes, Contractual, and/or Legal Reasons).
Contact you in response to a lead form you submitted on a third-party website (Business Purposes and/or Consent).
Contact you to provide administrative information relating to our Website (Business Purposes and/or Contractual).
Fulfill and manage purchases, orders, payments, and other transactions related to our Website store and gift donations feature (Business Purposes, Contractual, and/or Legal Reasons).
Increase the efficiency, operation, and security of our Website (Business Purposes).
Enforce our terms, conditions, and policies (Business Purposes, Contractual, and/or Legal Reasons).
Manage your orders placed through our Website store and your gift donations (Business Purposes).
Monitor and analyze usage and trends to improve the user experience on our Website (Business Purposes).
Offer new products, services, and/or recommendations to you (Business Purposes and/or Consent).
Enable user-to-user communications (Consent).
Perform other business activities as needed (Business Purposes).
Prevent fraudulent transactions, monitor against theft, and protect against criminal activity (Business Purposes and/or Legal Reasons).
Process payments and refunds (Business Purposes and/or Contractual).
Request your feedback about your use of our Website (Business Purposes and/or Consent).
Resolve disputes and troubleshoot problems (Business Purposes and/or Legal Reasons).
Respond to messages sent via the contact methods listed on our Website (Business Purposes and/or Consent).
Respond to product and customer service requests (Business Purposes, Contractual, and/or Consent).
Respond to legal process in the form of a subpoena from a civil court (Legal Reasons). To date, we have not received any civil court subpoenas relating to any user of our Website.
Respond to legal process in the form of an order from a civil court (Legal Reasons). To date, we have not received any civil court orders relating to any user of our Website.
Respond to legal process in the form of a subpoena from a criminal court (Legal Reasons). To date, we have not received any criminal court subpoenas relating to any user of our Website.
Respond to legal process in the form of an order from a criminal court (Legal Reasons). To date, we have not received any criminal court orders relating to any user of our Website.
Respond to legal process in the form of a warrant from a criminal court (Legal Reasons). To date, we have not received any criminal court warrants relating to any user of our Website.
Respond to legal process in the form of a subpoena from the United States Foreign Intelligence Surveillance Court (Legal Reasons). To date, we have not received any United States Foreign Intelligence Surveillance Court subpoenas relating to any user of our Website.
Respond to legal process in the form of an order from the United States Foreign Intelligence Surveillance Court (Legal Reasons). To date, we have not received any United States Foreign Intelligence Surveillance Court orders relating to any user of our Website.
Respond to legal process in the form of a warrant from the United States Foreign Intelligence Surveillance Court (Legal Reasons). To date, we have not received any United States Foreign Intelligence Surveillance Court warrants relating to any user of our Website.
Respond to data preservation requests, as required by law (Legal Reasons). To date, we have not received any data preservation requests relating to any user of our Website.

IV. Disclosure of Your Information

We only share information we have collected about you with your consent, to comply with laws, to protect your rights, or to fulfill business obligations. Your information may be disclosed as follows:

A. By Law or to Protect Rights

If we believe the release of information about you is necessary to respond to legal process, to investigate or remedy potential violations of our policies, or to protect the rights, property, and safety of others, we may share your information as permitted or required by any applicable law, rule, or regulation. This includes exchanging information with other entities for fraud protection and credit risk reduction purposes, and using information as evidence in litigation in which we are involved.

B. Vendors, Consultants, and Other Third-Party Service Providers

We may share your data with third-party vendors, service providers, contractors, and agents who perform services for us or on our behalf and require access to such information to perform those services. Examples include: payment processing, data analysis, email delivery, web hosting services, customer service, and marketing. Unless described in this Privacy Policy, we do not share, sell, rent, or trade any of your information with third parties for their promotional purposes.

Specifically, we disclose consumer personal information to third-party service providers as follows:

a. Stripe Payment Processor

If you place an order for products on our Website store and choose to pay using Stripe payment processor, Stripe may receive the financial data you provide for use in billing for the order you placed. Stripe’s privacy policy is located here.

b. Paypal Payment Processor

If you place an order for products on our Website store and choose to pay using Paypal payment processor, Paypal will receive the financial data you provide for use in billing for the order you placed. Paypal’s privacy policy is located here.

c. Printful Fulfillment Service

If you place an order for a print-on-demand product through our Website store, Printful fulfillment service receives your name and shipping address for use in fulfilling your order. Your order will ship directly from Printful’s warehouse. Printful’s privacy policy is located here.

d. Mailerlite Newsletter Service

If you opt-in to receiving marketing emails from us, Mailerlite newsletter service receives your name and email address so we can use the Mailerlite servers to send you opt-in marketing emails. If we enable read receipts for our marketing emails, Mailerlite will receive your IP address upon opening our marketing emails. Mailerlite’s privacy policy is located here.

e. Vonage SMS Text Message Service

If you opt-in to receiving marketing SMS text messages from us, Vonage SMS text message service receives your phone number so we can use the Vonage SMS gateway servers to send you opt-in marketing SMS text messages. Vonage’s privacy policy is located here.

f. The Things We Do PR, LLC Mail Digitization Service

If you send physical mail to our business address or to our registered agent address, The Things We Do PR, LLC, will open, scan, and upload a digital copy of your mail to our web based account with The Things We Do PR, LLC. Physical copies of all received mail are destroyed after being digitized. If you do not want your physical mail correspondence digitized, destroyed, and stored in this manner, do not send us physical mail. The Things We Do PR, LLC’s privacy policy is located here.

C. Marketing Communications

With your consent, we may share your information with third parties for marketing purposes, as permitted by law.

D. Online Postings

When you post comments, contributions, or other content to our Website, your posts may be viewed by all users and may be publicly distributed outside our Website in perpetuity.

E. Third-Party Advertisers

We may use third-party advertising companies to serve ads when you visit our Website. These companies may use information about your visits to our Website and other websites to provide you with advertisements about goods and services of interest.

F. Affiliates

We may share your information with our affiliates, in which case we will require those affiliates to honor this Privacy Policy. Affiliates include any parent company, subsidiaries, joint venture partners, or other companies that we control or that are under common control with us.

G. Business Partners

We may share your information with our business partners to offer you certain products, services, or promotions.

H. Social Media Users

If you connect to our Website through a social network, other users of the social network may see your name, profile photo, and descriptions of your activities. For example, if you comment on a blog post using our Website’s embedded Facebook comments widget, other Facebook users may see your comment in relation to our Website.

I. Other Third Parties

We may share your information with advertisers and investors for the purpose of conducting general business analysis. We may also share your information with such third parties for marketing purposes as permitted by law.

J. Business Transfers

We may share or transfer your information 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.

K. Sale or Bankruptcy

If we reorganize or sell all or a portion of our assets, undergo a merger, or are acquired by another entity, we may transfer your information to the successor entity. If we go out of business or enter bankruptcy, your information would be an asset transferred or acquired by a third-party. You acknowledge that such transfers may occur and the transferee may decline to honor commitments we make in this Privacy Policy.

V. Third-Party Use of Your Data

Our Website may contain advertisements from third parties that are not affiliated with us that may link to other websites, online services, or mobile applications. We cannot guarantee the safety and privacy of data you provide to third parties. Any data collected by third parties is not covered by this Privacy Policy. We are not responsible for the content or privacy and security practices and policies of third parties, including other websites, services, or applications that may be linked to or from our Website. You should review the policies of such third parties and contact them directly for responses to your questions. If you no longer wish to receive correspondence, emails, or other communications from a third party, you are responsible for contacting the third party directly.

A. Permanent Public Record of Your Data

The following features of our Website that are associated with third-party services will result in the creation of a permanent public record of your data:

a. Cryptocurrency Donations Made to Us

We list donation methods on the Donate page of our Website which may include the option to donate via cryptocurrency. Making a cryptocurrency donation to us using a coin or token that has a permanent public transaction ledger, such as Bitcoin or Ethereum, will result in the creation of a permanent public record of your data. It is not possible for us to delete that data.

VI. International Transfer of Your Data

Our internet servers are located in the United States. If you are accessing our Website from outside the United States, your information may be transferred to, stored on, and processed by our servers and by other servers operated by the third parties with whom we may share your personal information.

If you are a resident in the European Economic Area, the United Kingdom, or Switzerland, the server locations noted above may not have data protection or other laws as comprehensive as those in your country. We will, however, take all necessary measures to protect your personal information in accordance with this Privacy Policy and applicable law.

VII. Data Retention

No purpose described in this Privacy Policy necessitates us keeping your personal information for longer than three (3) years. We will only keep your personal information for as long as it is necessary for the purposes set out in this Privacy Policy, unless a longer retention period is required or permitted by law (such as tax, accounting, or other legal requirements).

If we have no ongoing legitimate business need to process your personal information, we will either delete or anonymize it, or, if this is not possible (for example, because your personal information has been stored in backup archives), we will securely store your personal information and isolate it from any further processing until deletion is possible.

VIII. Data Security

We use administrative, technical, and physical security measures to help protect your personal information. While we have taken reasonable steps to secure the personal information you provide to us, no security measures are perfect or impenetrable, and no method of data transmission can be guaranteed against any interception or other type of misuse. Any information disclosed online is vulnerable to interception and misuse by unauthorized parties. Therefore, we cannot guarantee complete security if you provide us with personal information. By accessing and using our Website, you agree that the transmission of personal information to and from our Website is at your own risk.

IX. Minor Access and Data Collection

We do not knowingly solicit data from or market to individuals under eighteen (18) years of age. By using our Website, you represent that you are at least eighteen (18) or that you are the parent or guardian of such a minor and consent to the minor dependent’s use of our Website. If we learn that personal information from users less than eighteen (18) years of age has been collected, we will deactivate the account (if applicable) and take reasonable measures to promptly delete such data from our records. If you become aware of any data we have collected from children under age eighteen (18), please contact us using the information contained in the Contact Us section of this Privacy Policy below.

X. Cookies and Similar Technologies

We may use cookies, web beacons, tracking pixels, and other tracking technologies when you visit our Website to help customize our Website and improve your experience.

A. Use of Cookies

A “cookie” is a string of information containing a unique identifier that we store on your computer. Your browser then provides that unique identifier to us each time you submit a query to our Website. We use cookies on our Website to, among other things, keep track of services you have used, record registration information, record your user preferences, keep you logged into our Website, facilitate purchase procedures, and track the pages you visit. Cookies help us understand how our Website is being used and improve your user experience. The following types of cookies may be used when you visit our Website:

B. Cookies We Use

Our cookies are “first-party cookies,” and can be either permanent or temporary. These are necessary cookies, without which our Website won’t work properly or be able to provide certain features and functionalities.

a. Website Management Cookies

Website management cookies are used to maintain your identity or session on our Website so that you are not logged off unexpectedly, and any information you enter is retained from page to page. These cookies cannot be turned off individually, but you can disable all cookies in your browser.

b. Personalization Cookies

Personalization cookies are used to recognize repeat visitors to our Website. We use these cookies to record the pages you have visited on our Website, and your settings and preferences each time you visit our Website.

c. Analytics Cookies

Analytics cookies monitor how users reach our Website, and how they interact with and move around once on our Website. These cookies let us know which features on our Website are working the best and which features on our Website can be improved.

d. Security Cookies

Security cookies help identify and prevent security risks. We use these cookies to authenticate users and protect user data from unauthorized parties.

e. Advertising Cookies

Advertising cookies are placed on your computer by advertisers and ad servers in order to display advertisements that are most likely to be of interest to you. These cookies allow advertisers and ad servers to gather information about your visits to our Website and other websites, alternate the ads sent to a specific computer, and track how often an ad has been viewed and by whom. These cookies are linked to a computer and do not gather any personal information about you.

f. Third-Party Cookies

We use embedded code widgets from selected third-party service providers to add functionality to our Website. These third-party service providers use first-party cookies and third-party cookies to, among other things, analyze and track use of our Website, determine the popularity of certain content, better understand online activity, and maintain the security of our Website. By accessing our Website you consent to the collection and use of your information by these third-party vendors via cookies.

The third-party vendors that use cookies to collect information on and/or track users of our Website are listed below:

DocumentCloud PDF Widget by MuckRock; view MuckRock’s privacy policy here.
Facebook Comment Widget; view Facebook’s privacy policy here.
Google Analytics; view Google’s privacy policy here.
Google YouTube Video Embed; view Google’s privacy policy here.
hCaptcha by Intuition Machines, Inc; view hCaptcha’s privacy policy here.
Paypal Payment Widget; view Paypal’s privacy policy here.
Stripe Payment Widget; view Stripe’s privacy policy here.

You are encouraged to review the privacy policies of the third-party vendors listed above and contact them directly for responses to your questions. If you do not want any information to be collected and used by tracking technologies, you should contact the third-party vendors listed above. You can also try using the Network Advertising Initiative Opt-Out Tool available here and/or the Digital Advertising Alliance’s Consumer Choice Tool available here.

C. Control of Cookies

Most web browsers are set to accept cookies by default. You can, however, remove or reject cookies in your browser’s settings. Removing or rejecting cookies could affect the availability and functionality of our Website. For more information on how to control cookies, check your browser or device settings for how you can control or reject cookies, or visit the following links:

D. Do-Not-Track Feature

Most web browsers and mobile operating systems include a Do-Not-Track (“DNT”) feature or setting you can activate to signal your privacy preference to not have data about your online browsing activities monitored and collected. No uniform technology standard for recognizing and implementing DNT signals has been finalized. As such, we do not currently respond to DNT browser signals or any other mechanism that automatically communicates your choice not to be tracked online. If a standard for online tracking is adopted that we must follow in the future, we will inform you about that practice in a revised version of this Privacy Policy.

In any case, our Website does not engage in any type of user tracking that would normally be turned off in response to a DNT signal.

E. Other Tracking Technologies

In addition to cookies, we may use single-pixel images and other embedded objects in HTML code (“web beacons”) that are designed to track your activity. Our web beacons track the number of users who have visited a web page or viewed an email, and acquire other statistical data. They collect only a limited set of data, such as a cookie number, time and date of page or email view, and a description of the page or email on which they reside. Web beacons cannot be declined, but you can limit their use by controlling the cookies that interact with them.

XI. Deleting, Updating, or Obtaining Your Personal Information

Depending on your location, you may have certain rights under applicable data protection laws. These rights may include the right (1) to request access and obtain a copy of your personal information, (2) to request rectification or erasure, (3) to restrict the processing of your personal information, and (4) if applicable, to data portability. In certain circumstances, you may also have the right to object to the processing of your personal information and, if we are relying on your consent to process your personal information, you may have the right to withdraw your consent. To exercise any of these rights, please contact us using the information contained in the Contact Us section of this Privacy Policy below. We will consider and act upon any request in accordance with applicable data protection laws.

If you make a request to delete, update, or obtain your personal information pursuant to this Privacy Policy, and you are not satisfied with the action we take or the action we refuse to take, you may appeal our decision by contacting us again and noting that you are appealing the result of your initial request.

If you believe we have unlawfully processed, obtained, or stored your personal information, and if you are a resident of a state in the United States that has enacted data protection laws, you may have the right to file a complaint about us to your applicable state Attorney General.

If you are a resident in the European Economic Area, the United Kingdom, or Switzerland, and you believe we have unlawfully processed, obtained, or stored your personal information, you have the right to complain to your local data protection supervisory authority. For more information on filing a complaint, visit the following links:

Note: Pursuant to GDPR Art. 27(2)(a), we are not required to have a data controller or data processor representative located in the European Union.

Regardless of your location, we will always comply with user requests to obtain, change, or delete personal information as follows:

A. Your Account Information

If our Website offers user accounts, you may at any time review or change the information in your account or terminate your account by (1) logging into your account and using your account settings, or (2) contacting us using the information contained in the Contact Us section of this Privacy Policy below.

Upon a request to terminate your account, we will delete your account and account information from our active databases. Some information may be retained in our files to prevent fraud, troubleshoot problems, assist with any investigations, enforce our Terms and Conditions and/or comply with legal requirements.

B. Purchase History

If our Website offers user accounts, your purchase history from our Website store will be saved in your user account. To delete your purchase history, follow the instructions to terminate your account contained in the Your Account Information section of this Privacy Policy immediately above. If our Website does not offer user accounts, your purchase history from our Website store will be automatically deleted ninety (90) days after the fulfillment of your last order.

Our Website store payment processor, Stripe, may continue to maintain some of your personal information even after we delete your purchase history from our servers. Stripe’s privacy policy is available here.

Our Website store payment processor, Paypal, may continue to maintain some of your personal information even after we delete your purchase history from our servers. Paypal’s privacy policy is available here.

C. Email Address on Email Lists

You can unsubscribe from our email lists at any time by (1) clicking on the unsubscribe link in the emails that we send, or (2) contacting us using the information contained in the Contact Us section of this Privacy Policy below. Your email address will then be removed from the email list—however, we may still need to send you service-related or transactional emails that are necessary for the administration and use of your account or in relation to orders you have placed through our Website.

D. Phone Number on SMS Text Message Lists

You can unsubscribe from our SMS text message list at any time by (1) sending a text to our SMS phone number containing just the word “STOP” without the quotation marks, or (2) contacting us using the information contained in the Contact Us section of this Privacy Policy below. Your phone number will then be removed from the SMS text message list—however, we may immediately send you one final text message to confirm that you have been removed from our list.

E. Website Push Notifications

You can unsubscribe your device from our Website push notifications at any time by using your device settings to remove the subscription that you previously added. You will then no longer receive push notifications from our Website.

XII. Information We Do Not Access or Control

Our Website contains author profiles for the authors who write articles for our Website. Those author profiles may contain information on how to (1) contact authors in their personal capacities, and (2) make gift donations to authors in their personal capacities. We do not access or control any information resulting from your direct interactions with authors. The information we do not access or control is as follows:

A. Author Gift Donation History

All author gift donations requested on our Website are made directly to the authors in their personal capacities using websites and services that we do not control. The donation buttons embedded on the author profile pages of our Website link to external third-party services set up by the authors. We do not have access to any information relating to any of your gift donations. Authors may use the following third-party services to facilitate the receival of gift donations:

Stripe Payment Processor; view Stripe’s privacy policy here.
Donorbox Donation Widget; view Donorbox’s privacy policy here.
Decentralized Cryptocurrency Blockchains; no privacy policies apply.
PayPal Payment Processor; view PayPal’s privacy policy here.
Cash App Payment Processor; view Cash App’s privacy policy here.
Venmo Payment Processor; view Venmo’s privacy policy here.
Amazon Wish List; view Amazon’s privacy policy here.

B. Correspondence Sent to and From Authors

We do not have access to any correspondence (whether physical or digital) sent to or from the authors listed on our Website, as those messages never enter our possession. We do not send or receive physical mail on behalf of the authors and we do not provide email addresses for the authors. All contact methods listed on author profile pages of our Website are entirely setup and controlled by the authors themselves.

XIII. CCPA and CPRA Privacy Notice

This CCPA and CPRA Privacy Notice applies to visitors, users, and others who reside in the State of California (“consumers” or “you”). We are adopting this notice to comply with the California Consumer Privacy Act of 2018 (“CCPA”), the California Privacy Rights Act (“CPRA”) of 2020, and other California privacy laws. Any terms defined in the CCPA and CPRA have the same meaning when used in this notice.

Pursuant to Cal. Civ. Code §§ 1798.140(c) et seq., we meet the definition of a “business,” and the CCPA and CPRA therefore applies.

The California Code of Regulations, Cal. Code Regs. Tit. 18, § 17014, defines a “resident” as every individual who is in the State of California for other than a temporary or transitory purpose, and; every individual who is domiciled in the State of California who is outside the State of California for a temporary or transitory purpose. All other individuals are defined as “non-residents.”

If this definition of “resident” applies to you, certain rights and obligations apply regarding your personal information.

A. Information We Collect

Pursuant to Cal. Civ. Code §§ 1798.110(c), 1798.130(a)(5)(B) et seq., 1798.130(c) and 1798.140(o), we are required to disclose that we collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or device (“personal information”), and provide details on disclosure of that information.

Pursuant to Cal. Civ. Code § 1798.130(a)(5)(B)(i), we are required to disclose that we have collected the following categories of personal information from consumers within the last twelve (12) months:

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Cal. Civ. Code § 1798.140(o)(1)(A).
Any categories of personal information described in subdivision (e) of Section 1798.80. Cal. Civ. Code § 1798.140(o)(1)(B).
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Cal. Civ. Code § 1798.140(o)(1)(D).
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. Cal. Civ. Code § 1798.140(o)(1)(F).
Geolocation data. Cal. Civ. Code § 1798.140(o)(1)(G).

Note: Collected geolocation data is as precise as can be ascertained from a consumer’s IP address.

Pursuant to Cal. Civ. Code § 1798.130(a)(5)(B)(ii), we are required to disclose that we have collected consumer personal information from the following categories of sources:

The categories of sources from which we have collected consumer personal information are described in the Collection of Your Information section of this Privacy Policy above.

Pursuant to Cal. Civ. Code § 1798.130(a)(5)(B)(iii), we are required to disclose the following business or commercial purposes for collecting, selling, or sharing consumers’ personal information:

The business or commercial purposes for which we collect, sell, or share consumers’ personal information are described in the sections of this Privacy Policy titled Use of Your Information and Disclosure of Your Information above.

Pursuant to Cal. Civ. Code § 1798.130(a)(5)(B)(iv), we are required to disclose the following categories of third parties to whom we have disclosed consumers’ personal information:

Service Providers. For specifics, see the Disclosure of Your Information section of this Privacy Policy above.

B. Information We Sell, Share, and Disclose

Pursuant to Cal. Civ. Code § 1798.115(c)(1) & (2), we are required to disclose the following:

We have not and do not sell or share any consumer personal information. We have disclosed the following categories of personal information from consumers for a business purpose within the last twelve (12) months (Cal. Civ. Code §§ 1798.130(a)(5)(C)(ii), 1798.130(c) and 1798.140(o)):

Identifiers such as a real name, alias, postal address, unique personal identifier, online identifier, IP address, email address, account name, social security number, driver’s license number, passport number, or other similar identifiers. Cal. Civ. Code § 1798.140(o)(1)(A).
Any categories of personal information described in subdivision (e) of Section 1798.80. Cal. Civ. Code § 1798.140(o)(1)(B).
Commercial information, including records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies. Cal. Civ. Code § 1798.140(o)(1)(D).
Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding a consumer’s interaction with an internet website, application, or advertisement. Cal. Civ. Code § 1798.140(o)(1)(F).
Geolocation data. Cal. Civ. Code § 1798.140(o)(1)(G).

Note: Collected geolocation data is as precise as can be ascertained from a consumer’s IP address.

C. Data Retention Time Limit

Pursuant to Cal. Civ. Code §§ 1798.100(a)(3), we are required to inform consumers of the length of time we intend to retain each category of personal information, or if that is not possible, the criteria used to determine that period.

The length of time we intend to retain each category of personal information, or if that is not possible, the criteria used to determine that period, are described in the sections of this Privacy Policy titled Data Retention, Deleting, Updating, or Obtaining Your Personal Information, and Permanent Public Record of Your Data above.

D. Your Rights Under the CCPA

Pursuant to Cal. Civ. Code §§ 1798.130(a)(5), we are required to provide a description of a consumer’s rights pursuant to Cal. Civ. Code §§ 1798.100, 1798.105, 1798.106, 1798.110, 1798.115, and 1798.125. What follows is a word-for-word duplication of the three aforementioned California civil code sections describing a consumer’s rights under the CCPA.

a. Rights Under Cal. Civ. Code § 1798.100

General Duties of Businesses that Collect Personal Information

(a) A business that controls the collection of a consumer’s personal information shall, at or before the point of collection, inform consumers of the following:

(1) The categories of personal information to be collected and the purposes for which the categories of personal information are collected or used and whether that information is sold or shared. A business shall not collect additional categories of personal information or use personal information collected for additional purposes that are incompatible with the disclosed purpose for which the personal information was collected without providing the consumer with notice consistent with this section.
(2) If the business collects sensitive personal information, the categories of sensitive personal information to be collected and the purposes for which the categories of sensitive personal information are collected or used, and whether that information is sold or shared. A business shall not collect additional categories of sensitive personal information or use sensitive personal information collected for additional purposes that are incompatible with the disclosed purpose for which the sensitive personal information was collected without providing the consumer with notice consistent with this section.
(3) The length of time the business intends to retain each category of personal information, including sensitive personal information, or if that is not possible, the criteria used to determine that period provided that a business shall not retain a consumer’s personal information or sensitive personal information for each disclosed purpose for which the personal information was collected for longer than is reasonably necessary for that disclosed purpose.

(b) A business that, acting as a third party, controls the collection of personal information about a consumer may satisfy its obligation under subdivision (a) by providing the required information prominently and conspicuously on the homepage of its internet website. In addition, if a business acting as a third party controls the collection of personal information about a consumer on its premises, including in a vehicle, then the business shall, at or before the point of collection, inform consumers as to the categories of personal information to be collected and the purposes for which the categories of personal information are used, and whether that personal information is sold, in a clear and conspicuous manner at the location.

(c) A business’ collection, use, retention, and sharing of a consumer’s personal information shall be reasonably necessary and proportionate to achieve the purposes for which the personal information was collected or processed, or for another disclosed purpose that is compatible with the context in which the personal information was collected, and not further processed in a manner that is incompatible with those purposes.

(d) A business that collects a consumer’s personal information and that sells that personal information to, or shares it with, a third party or that discloses it to a service provider or contractor for a business purpose shall enter into an agreement with the third party, service provider, or contractor, that:

(1) Specifies that the personal information is sold or disclosed by the business only for limited and specified purposes.
(2) Obligates the third party, service provider, or contractor to comply with applicable obligations under this title and obligate those persons to provide the same level of privacy protection as is required by this title.
(3) Grants the business rights to take reasonable and appropriate steps to help ensure that the third party, service provider, or contractor uses the personal information transferred in a manner consistent with the business’ obligations under this title.
(4) Requires the third party, service provider, or contractor to notify the business if it makes a determination that it can no longer meet its obligations under this title.
(5) Grants the business the right, upon notice, including under paragraph (4), to take reasonable and appropriate steps to stop and remediate unauthorized use of personal information.

(e) A business that collects a consumer’s personal information shall implement reasonable security procedures and practices appropriate to the nature of the personal information to protect the personal information from unauthorized or illegal access, destruction, use, modification, or disclosure in accordance with Section 1798.81.5.

(f) Nothing in this section shall require a business to disclose trade secrets, as specified in regulations adopted pursuant to paragraph (3) of subdivision (a) of Section 1798.185.

b. Rights Under Cal. Civ. Code § 1798.105

Consumers’ Right to Delete Personal Information

(a) A consumer shall have the right to request that a business delete any personal information about the consumer which the business has collected from the consumer.

(b) A business that collects personal information about consumers shall disclose, pursuant to Section 1798.130, the consumer’s rights to request the deletion of the consumer’s personal information.

(c)

(1) A business that receives a verifiable consumer request from a consumer to delete the consumer’s personal information pursuant to subdivision (a) of this section shall delete the consumer’s personal information from its records, notify any service providers or contractors to delete the consumer’s personal information from their records, and notify all third parties to whom the business has sold or shared the personal information to delete the consumer’s personal information unless this proves impossible or involves disproportionate effort.
(2) The business may maintain a confidential record of deletion requests solely for the purpose of preventing the personal information of a consumer who has submitted a deletion request from being sold, for compliance with laws or for other purposes, solely to the extent permissible under this title.
(3) A service provider or contractor shall cooperate with the business in responding to a verifiable consumer request, and at the direction of the business, shall delete, or enable the business to delete and shall notify any of its own service providers or contractors to delete personal information about the consumer collected, used, processed, or retained by the service provider or the contractor. The service provider or contractor shall notify any service providers, contractors, or third parties who may have accessed personal information from or through the service provider or contractor, unless the information was accessed at the direction of the business, to delete the consumer’s personal information unless this proves impossible or involves disproportionate effort. A service provider or contractor shall not be required to comply with a deletion request submitted by the consumer directly to the service provider or contractor to the extent that the service provider or contractor has collected, used, processed, or retained the consumer’s personal information in its role as a service provider or contractor to the business.

(d) A business, or a service provider or contractor acting pursuant to its contract with the business, another service provider, or another contractor, shall not be required to comply with a consumer’s request to delete the consumer’s personal information if it is reasonably necessary for the business, service provider, or contractor to maintain the consumer’s personal information in order to:

(1) Complete the transaction for which the personal information was collected, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, provide a good or service requested by the consumer, or reasonably anticipated by the consumer within the context of a business’ ongoing business relationship with the consumer, or otherwise perform a contract between the business and the consumer.
(2) Help to ensure security and integrity to the extent the use of the consumer’s personal information is reasonably necessary and proportionate for those purposes.
(3) Debug to identify and repair errors that impair existing intended functionality.
(4) Exercise free speech, ensure the right of another consumer to exercise that consumer’s right of free speech, or exercise another right provided for by law.
(5) Comply with the California Electronic Communications Privacy Act pursuant to Chapter 3.6 (commencing with Section 1546) of Title 12 of Part 2 of the Penal Code.
(6) Engage in public or peer-reviewed scientific, historical, or statistical research that conforms or adheres to all other applicable ethics and privacy laws, when the business’ deletion of the information is likely to render impossible or seriously impair the ability to complete such research, if the consumer has provided informed consent.
(7) To enable solely internal uses that are reasonably aligned with the expectations of the consumer based on the consumer’s relationship with the business and compatible with the context in which the consumer provided the information.
(8) Comply with a legal obligation.

c. Rights Under Cal. Civ. Code § 1798.106

Consumers’ Right to Correct Inaccurate Personal Information

(a) A consumer shall have the right to request a business that maintains inaccurate personal information about the consumer to correct that inaccurate personal information, taking into account the nature of the personal information and the purposes of the processing of the personal information.

(b) A business that collects personal information about consumers shall disclose, pursuant to Section 1798.130, the consumer’s right to request correction of inaccurate personal information.

(c) A business that receives a verifiable consumer request to correct inaccurate personal information shall use commercially reasonable efforts to correct the inaccurate personal information as directed by the consumer, pursuant to Section 1798.130 and regulations adopted pursuant to paragraph (8) of subdivision (a) of Section 1798.185.

d. Rights Under Cal. Civ. Code § 1798.110

Consumers’ Right to Know What Personal Information is Being Collected. Right to Access Personal Information

(a) A consumer shall have the right to request that a business that collects personal information about the consumer disclose to the consumer the following:

(1) The categories of personal information it has collected about that consumer.
(2) The categories of sources from which the personal information is collected.
(3) The business or commercial purpose for collecting, selling, or sharing personal information.
(4) The categories of third parties to whom the business discloses personal information.
(5) The specific pieces of personal information it has collected about that consumer.

(b) A business that collects personal information about a consumer shall disclose to the consumer, pursuant to subparagraph (B) of paragraph (3) of subdivision (a) of Section 1798.130, the information specified in subdivision (a) upon receipt of a verifiable consumer request from the consumer, provided that a business shall be deemed to be in compliance with paragraphs (1) to (4), inclusive, of subdivision (a) to the extent that the categories of information and the business or commercial purpose for collecting, selling, or sharing personal information it would be required to disclose to the consumer pursuant to paragraphs (1) to (4), inclusive, of subdivision (a) is the same as the information it has disclosed pursuant to paragraphs (1) to (4), inclusive, of subdivision (c).

(c) A business that collects personal information about consumers shall disclose, pursuant to subparagraph (B) of paragraph (5) of subdivision (a) of Section 1798.130:

(1) The categories of personal information it has collected about consumers.
(2) The categories of sources from which the personal information is collected.
(3) The business or commercial purpose for collecting, selling, or sharing personal information.
(4) The categories of third parties to whom the business discloses personal information.
(5) That a consumer has the right to request the specific pieces of personal information the business has collected about that consumer.

e. Rights Under Cal. Civ. Code § 1798.115

Consumers’ Right to Know What Personal Information is Sold or Shared and to Whom

(a) A consumer shall have the right to request that a business that sells or shares the consumer’s personal information, or that discloses it for a business purpose, disclose to that consumer:

(1) The categories of personal information that the business collected about the consumer.
(2) The categories of personal information that the business sold or shared about the consumer and the categories of third parties to whom the personal information was sold or shared, by category or categories of personal information for each category of third parties to whom the personal information was sold or shared.
(3) The categories of personal information that the business disclosed about the consumer for a business purpose and the categories of persons to whom it was disclosed for a business purpose.

(b) A business that sells or shares personal information about a consumer, or that discloses a consumer’s personal information for a business purpose, shall disclose, pursuant to paragraph (4) of subdivision (a) of Section 1798.130, the information specified in subdivision (a) to the consumer upon receipt of a verifiable consumer request from the consumer.

(c) A business that sells or shares consumers’ personal information, or that discloses consumers’ personal information for a business purpose, shall disclose, pursuant to subparagraph (C) of paragraph (5) of subdivision (a) of Section 1798.130:

(1) The category or categories of consumers’ personal information it has sold or shared, or if the business has not sold or shared consumers’ personal information, it shall disclose that fact.
(2) The category or categories of consumers’ personal information it has disclosed for a business purpose, or if the business has not disclosed consumers’ personal information for a business purpose, it shall disclose that fact.

(d) A third party shall not sell or share personal information about a consumer that has been sold to, or shared with, the third party by a business unless the consumer has received explicit notice and is provided an opportunity to exercise the right to opt-out pursuant to Section 1798.120.

f. Rights Under Cal. Civ. Code § 1798.125

Discrimination Prohibited

(a)

(1) A business shall not discriminate against a consumer because the consumer exercised any of the consumer’s rights under this title, including, but not limited to, by:

(A) Denying goods or services to the consumer.
(B) Charging different prices or rates for goods or services, including through the use of discounts or other benefits or imposing penalties.
(C) Providing a different level or quality of goods or services to the consumer.
(D) Suggesting that the consumer will receive a different price or rate for goods or services or a different level or quality of goods or services.

(2) Nothing in this subdivision prohibits a business from charging a consumer a different price or rate, or from providing a different level or quality of goods or services to the consumer, if that difference is reasonably related to the value provided to the business by the consumer’s data.

(b)

(1) A business may offer financial incentives, including payments to consumers as compensation, for the collection of personal information, the sale of personal information, or the deletion of personal information. A business may also offer a different price, rate, level, or quality of goods or services to the consumer if that price or difference is directly related to the value provided to the business by the consumer’s data.

(2) A business that offers any financial incentives pursuant to this subdivision shall notify consumers of the financial incentives pursuant to Section 1798.130.

(3) A business may enter a consumer into a financial incentive program only if the consumer gives the business prior opt-in consent pursuant to Section 1798.130 that clearly describes the material terms of the financial incentive program, and which may be revoked by the consumer at any time.

(4) A business shall not use financial incentive practices that are unjust, unreasonable, coercive, or usurious in nature.

E. Your Right to Request Information

Pursuant to Cal. Civ. Code § 1798.110(c)(5), you have a right as a consumer to request the specific pieces of personal information we have collected about you.

We are a business that operates exclusively online and, pursuant to Cal. Civ. Code § 1798.130(a)(1)(A), we only need to provide an email address to consumers for submitting requests for information required to be disclosed pursuant to Cal. Civ. Code §§ 1798.110 and 1798.115. Our email address for making requests under the CCPA is available here.

XIV. NRS § 603A Privacy Notice

This NRS § 603A Privacy Notice applies to consumers who are residents of the State of Nevada (“consumers” or “you”). We are adopting this notice to comply with Nevada Revised Statutes Chapter 603A (“NRS § 603A”) of 2022, and other Nevada privacy laws. Any terms defined in NRS § 603A have the same meaning when used in this notice.

Pursuant to NRS § 603A.330(1), we meet the definition of an “Operator,” and NRS § 603A therefore applies.

If you are a resident of Nevada and a consumer of our products and/or services, certain rights and obligations apply regarding your personal information.

Pursuant to NRS § 603A.340(1)(a), we are required to disclose that we collect the following categories of covered information from consumers via our Website:

First and last names. NRS § 603A.320(1).
Home or other physical addresses which include the name of a street and the name of a city or town. NRS § 603A.320(2).
Electronic mail addresses. NRS § 603A.320(3).
Telephone numbers. NRS § 603A.320(4).
Identifiers that allow specific persons to be contacted either physically or online. NRS § 603A.320(6).

Additional covered information we collect are disclosed in the Collection of Your Information section of this Privacy Policy above.

Pursuant to NRS § 603A.340(1)(a), we are required to disclose the categories of third parties to whom we disclose consumers’ covered information. The required disclosure is contained in the Disclosure of Your Information section of this Privacy Policy above.

Pursuant to NRS § 603A.340(1)(b), we are required to provide a description of the process for an individual consumer who uses or visits our Website to review and request changes to any of his or her covered information collected through our Website. The required description is contained in the Deleting, Updating, or Obtaining Your Personal Information section of this Privacy Policy above.

Pursuant to NRS § 603A.340(1)(c), we are required to provide a description of the process by which we notify consumers who use or visit our Website of material changes to the notice required to be made available by NRS § 603A.340. The required description is contained in the Introduction section of this Privacy Policy above.

Pursuant to NRS § 603A.340(1)(d), we are required to disclose whether a third party may collect covered information about an individual consumer’s online activities over time and across different Internet websites or online services when the consumer uses our Website. The required description is contained in the Third-Party Cookies section of this Privacy Policy above.

Pursuant to NRS § 603A.340(1)(e), we are required to state the effective date of this notice. The effective date of this notice is contained in the Introduction section of this Privacy Policy above.

Pursuant to NRS § 603A.344(1) and (2), we are required to establish a designated request address through which a consumer may submit a verified request directing us to not make any sale of any covered information we have collected or will collect about the consumer. Our designated request address is contained in the Contact Us section of this Privacy Policy below.

XV. DOPPA Privacy Notice

This DOPPA Privacy Notice applies to consumers who are residents of the State of Delaware (“consumers” or “you”). We are adopting this notice to comply with the Delaware Online Privacy and Protection Act of 2015 (“DOPPA”), and other Delaware privacy laws. Any terms defined in the DOPPA have the same meaning when used in this notice.

Pursuant to Del. C. § 1202C(14), we meet the definition of an “Operator,” and the DOPPA therefore applies.

If you are a resident of Delaware and a user of our Website, certain rights and obligations apply regarding your personal information.

Pursuant to Del. C. § 1205C(b)(1), we are required to disclose that we collect the following categories of personally identifiable information from users via our Website:

First and last names. Del. C. § 1202C(15).
Physical addresses. Del. C. § 1202C(15).
E-mail addresses. Del. C. § 1202C(15).
Telephone numbers. Del. C. § 1202C(15).
Identifiers that permits the physical or online contacting of the user. Del. C. § 1202C(15).

Additional personally identifiable information we collect are disclosed in the Collection of Your Information section of this Privacy Policy above.

Pursuant to Del. C. § 1205C(b)(1), we are required to disclose the categories of third parties to whom we disclose users’ personally identifiable information. The required disclosure is contained in the Disclosure of Your Information section of this Privacy Policy above.

Pursuant to Del. C. § 1205C(b)(2), we are required to provide a description of the process for a user of our Website to review and request changes of that user’s personally identifiable information collected through our Website. The required description is contained in the Deleting, Updating, or Obtaining Your Personal Information section of this Privacy Policy above.

Pursuant to Del. C. § 1205C(b)(3), we are required to provide a description of the process by which we notify users of our Website of material changes this Privacy Policy. The required description is contained in the Introduction section of this Privacy Policy above.

Pursuant to Del. C. § 1205C(b)(4), we are required to state the effective date of this Privacy Policy. The effective date of this Privacy Policy is contained in the Introduction section of this Privacy Policy above.

Pursuant to Del. C. § 1205C(b)(5), we are required to disclose how we respond to web browser “do not track” signals or other mechanisms that provide users the ability to exercise choice regarding the collection of personally identifiable information about a user’s online activities over time and across third-party internet websites, online or cloud computing services, online applications, or mobile applications. The required disclosure is contained in the Do-Not-Track Feature section of this Privacy Policy above.

Pursuant to Del. C. § 1205C(b)(6), we are required to disclose whether other parties may collect personally identifiable information about a user’s online activities over time and across different internet websites, online or cloud computing services, online applications, or mobile applications when a user uses our Website. The required disclosure is contained in the Third-Party Cookies section of this Privacy Policy above.

XVI. VCDPA Privacy Notice

This VCDPA Privacy Notice applies to consumers who are residents of the State of Virginia (“consumers” or “you”). We are adopting this notice to comply with the Virginia Consumer Data Protection Act of 2021 (“VCDPA”), and other Virginia privacy laws. Any terms defined in the VCDPA have the same meaning when used in this notice.

Pursuant to Va. Code Ann. § 59.1-575, we meet the definition of a “Controller,” and the VCDPA therefore applies.

If you are a resident of Virginia and a user of our Website, certain rights and obligations apply regarding your personal information.

Pursuant to Va. Code Ann. § 59.1-578(C)(1), we are required to disclose the categories of personal data that we process. The required disclosure is contained in the Collection of Your Information section of this Privacy Policy above.

Pursuant to Va. Code Ann. § 59.1-578(C)(2), we are required to disclose our purpose for processing personal data. The required disclosure is contained in the Use of Your Information section of this Privacy Policy above.

Pursuant to Va. Code Ann. § 59.1-578(C)(3), we are required to disclose how consumers may exercise their consumer rights pursuant Va. Code Ann. § 59.1-577, including how a consumer may appeal a decision we make regarding a consumer’s request. The required disclosure is contained in the Deleting, Updating, or Obtaining Your Personal Information section of this Privacy Policy above.

Pursuant to Va. Code Ann. § 59.1-578(C)(4), we are required to disclose the categories of personal data we share with third parties. The required disclosure is contained in the Disclosure of Your Information section of this Privacy Policy above.

Pursuant to Va. Code Ann. § 59.1-578(C)(5), we are required to disclose the categories of third parties with whom we share personal data. The required disclosure is contained in the Disclosure of Your Information section of this Privacy Policy above.

Pursuant to Va. Code Ann. § 59.1-578(E), we are required to establish, and shall describe in a privacy notice, one or more secure and reliable means for consumers to submit a request to exercise their consumer rights. The required description is contained in the Deleting, Updating, or Obtaining Your Personal Information section of this Privacy Policy above.

XVII. Contact Us

Freedom Du Jour LLC
Attn: FDJ News Data Protection Officer
1309 Coffeen Ave STE 1200
Sheridan, WY 82801, USA

Phone: +1 (631) 405-2688
Email: Our email address is available here.