Privacy Policy for MiddleEastMorning.com
At
MiddleEastMorning.com, our mission is to seek the truth and help people
understand the world, particularly focusing on the Middle East. We want you to
understand how we handle your personal information and ensure you are aware of
your rights and choices.
This
policy describes how we handle your personal information when you use the
following "MiddleEastMorning Services":
-
The MiddleEastMorning print newspaper, including any regional or international
editions
-
Our websites, including middleeastmorning.com and its subdomains
-
Our mobile applications
-
Our email newsletters
-
Our pages or ads on social media networks, such as our Facebook and Instagram
pages
-
Anywhere we gather information from or about you and refer you to this Privacy
Policy
How
we handle your information depends on which MiddleEastMorning Services you use
and how you use them. For example, we use different information about print
subscribers than website visitors.
Please
be aware that certain MiddleEastMorning Services work differently, and some
have additional terms that supplement this policy (e.g., Reader Submissions).
If
you have questions, please don’t hesitate to contact us at privacy@middleeastmorning.com.
You can also review our Privacy F.A.Q.
##
Table of Contents
1.
**What Information Do We Gather About You?**
- (A) Information Collected through
MiddleEastMorning Services
1. Information You Voluntarily Give Us
- For Registration
- For Billing
- For User-Generated Content
- For Contests, Sweepstakes, and
Special Offers; Notice of Financial Incentives
- For Reader Surveys, Research, Panels,
and Experience Programs
- During Contact with Our Call Centers
(Internal and Offshore)
- Personal Contacts Data/Refer-a-Friend
2. A Note about Sensitive Personal
Information
3. Information Collected Automatically
- (B) Inferences; Information We Create or
Generate
- (C) Information Collected from Other
Sources
1. Privately Owned Databases
2. Social Media Platforms and Other
Third-Party Services
3. Workplace and Schools
2.
**What Do We Do With the Information We Collect about You?**
- (A) We Provide the MiddleEastMorning
Services
- (B) We Personalize Your Experience
- (C) We Allow You to Share User-Generated
Content
- (D) We Develop Products and Services, and
Perform Analysis
- (E) We Carry Out Administrative or Legal
Tasks
- (F) We Offer Sweepstakes, Contests, and
Other Promotions
- (G) We Allow for Personalized Advertising
on MiddleEastMorning Services and Create Audiences for Third-Party Advertisers
- (H) We Advertise or Market
MiddleEastMorning Services to You
- (I) We Aggregate (or De-identify) Personal
Information into Larger Findings
3.
**To Whom Do We Disclose or Share the Information We Gather for Business and
Commercial Purposes?**
- (A) Within MiddleEastMorning.com
- (B) With Service Providers
- (C) With Other Third Parties
4.
**What Are Your Rights and Choices?**
- (A) In General
1. Communications Preferences
2. Access, Correct, Change/Update, Delete,
or Restrict Processing of Your Personal Information
3. Managing Your Digital and Home Delivery
Accounts
4. Browser and Platform Controls
5. Opt-Out of Targeted Advertising and
“Sales or Sharing” of Personal Information
6. Delete My Account
7. Other Rights and Choices
- (B) Privacy Notices and Rights
1.
Notice at Collection and Notice of Financial Incentives
2. Rights to Know, Correction, and
Deletion
3. “Do Not Sell or Share My Personal
Information”
4. Right to Limit Use and Disclosure of
Sensitive Personal Information
5. Authorized Agents
6. Non-Discrimination Rights
7. Record of Requests
5.
**How Long Do You Retain Data?**
6.
**How Do You Protect My Information?**
7.
**Are There Guidelines for Children?**
8.
**How Is Information Transferred Internationally?**
9.
**What Is Our Legal Basis?**
10.
**What about Third-Party Services?**
11.
**How Are Changes to this Privacy Policy Communicated?**
12.
**How Can You Contact Us? Who Is the Controller of Your Personal Information?**
This
privacy policy is designed to inform you about how MiddleEastMorning.com
collects, uses, and protects your personal information. Your privacy is
important to us, and we are committed to handling your data responsibly.
# Privacy Policy for MiddleEastMorning.com
## 1. What Information Do We Gather About You?
The information we gather about you depends on the context
in which you interact with us. Generally, it’s information that can personally
identify you—either on its own or when combined with other information.
The following outlines the information we collect and how we
obtain it.
### 1. (A) Information Collected through MiddleEastMorning
Services
#### i. Information You Voluntarily Give Us
**For Registration:**
When you sign up for a MiddleEastMorning Service (whether
through a subscription or a free account as a registered user), we collect
personal identifiers such as your contact information, including your name and
email address, and account credentials. We may also ask you to create an
account name. Once you’re registered, we assign you a unique ID number. This ID
number helps us recognize you when you’re signed in.
For some MiddleEastMorning Services, you can also sign up by
linking your Apple, Facebook, or Google account. See Information Collected From
Other Sources below.
If you register for an event or conference, we might ask for
additional information (e.g., your company name, job title, or dietary
restrictions). Some events and conferences may have different or additional
privacy policies and terms, which we recommend you review before registering.
**For Billing:**
To process payments or donations, we collect and use your
payment information. This can include your name, address, telephone number,
email address, credit or debit card information, and any other relevant
information.
**For User-Generated Content:**
We offer you the ability to post content that other users
can read (e.g., comments or feedback). Anyone can read, collect, and use any
personal information that accompanies your posts. See the Comments F.A.Q. and
the User-Generated Content section in our Terms of Service for more
information.
We are not obligated to publish any of your content. If the
law requires us to take down, remove, or edit your content, we will comply.
**For Contests, Sweepstakes, and Special Offers; Notice of
Financial Incentives:**
From time to time, we offer certain opportunities through
contests, sweepstakes, or other special promotions and offers. When you sign up
for these, you provide us with your name, email, and any other required
information.
Some such opportunities may allow you to earn “rewards” such
as discounts (“Incentive Programs”). If this is part of the contest,
sweepstake, promotion, or offer, we will provide you with a full description of
the Incentive Program, including the benefits offered and related legal terms.
Because these Incentive Programs involve the collection of personal
information, they may be interpreted as “financial incentive” programs under
applicable law. We use this information for the purposes described in this
Privacy Policy, including for targeted advertising. We may share your personal
information with third parties as described in this Privacy Policy, including
data analytics providers, advertising technology vendors, and social media
platforms.
The value of any financial incentive we offer is reasonably
related to the value of the personal information you provide to us. We estimate
this value by considering the expenses we incur from collecting your personal
information and/or providing the financial incentive to you, the revenue
generated by your use of the financial incentive, and any improvements we can
make to our products and services based on information obtained through the
financial incentive program.
Please note that we may provide additional terms that apply
to a particular financial incentive. If applicable, those terms will be
presented to you at sign-up. You may cancel your membership in such Incentive
Programs at any time by contacting privacy@middleeastmorning.com.
**For Reader Surveys, Research, Panels, and Experience
Programs:**
We gather personal information through questionnaires,
surveys, and feedback programs.
Surveys and Panels: Some of our surveys and feedback
programs, including panels, will request your consent to voluntarily provide
information regarding your interests in various topics, including travel,
entertainment, and health and wellness, as well as demographic information,
some of which may be considered sensitive under applicable laws, such as your
age, ethnicity, race, gender, sexual orientation, family characteristics, and
income. We use service provider platforms to support these programs, and
personal information is shared with them as described below with respect to
service providers in general.
We target these surveys based on a number of factors, including
information we automatically collect about your interests and usage, as
described below. These surveys are used for a variety of purposes described
throughout this Privacy Policy, including research for marketing of
MiddleEastMorning Services, as well as research for third-party advertisers
interested in targeting ads to specific groups of MiddleEastMorning readers.
As described in more detail below, we combine information
from these surveys and panels with information collected automatically from MiddleEastMorning
Services, and sometimes we apply internal or third-party machine learning or
artificial intelligence models or applications to this information (alone or in
combination with other personal information we collect about you). We do this
to improve MiddleEastMorning Services, for marketing research, to personalize
the marketing of MiddleEastMorning Services to you, and/or to create audiences
for third-party advertisers.
Recording Your Feedback: With your consent, we may record
interviews with you and ask for your permission to use your voice and likeness
for various purposes, including marketing, advertising, and/or
MiddleEastMorning events.
Reader Callouts: If you participate in a reader callout on
MiddleEastMorning Services, additional terms, such as our Reader Submissions
terms, may apply (and will be posted where we ask you to participate).
**During Contact with Our Call Centers (Internal and
Offshore):**
We collect information from you when you place an order over
the phone or contact customer service through one of our toll-free numbers.
This can include your name, contact information, information about your
account, and any other information you choose to provide.
**Personal Contacts Data/Refer-a-Friend:**
We never scan your device for your contacts or upload that
data.
With your consent, we comply with your requests to collect
data about your friends, family, or acquaintances (e.g., Refer-a-Friend
campaigns). This functionality is only meant for residents within our operating
regions. By using it, you acknowledge and agree that both you and your contacts
are within these regions—and that you have everyone’s consent for us to use
their contact information.
If you’d like to invite your friends to use
MiddleEastMorning Services, we will store this information solely to allow you
to send your friends referral offers, determine whether your friends use
MiddleEastMorning Services after a referral is sent, and remind your friends of
the referral sent on your behalf.
#### ii. A Note about Sensitive Personal Information
We generally don’t want to gather sensitive personal
information about you. This includes:
- Government-issued IDs (such as your driver’s license, passport,
or social security number)
- Your racial or ethnic origin
- Your political opinions
- Your religion or other beliefs
- Your health, biometric, or genetic characteristics,
including physical characteristics or descriptions
- Any trade union membership
- Your sexuality (information about your sex life or sexual
orientation)
- Citizenship or immigration status
- Any criminal background
- The content of your private communications (other than
messages you may send to us)
- Your precise geolocation (street level, GPS or lat/long
data, or other data that is derived from a device and locates you within a
geographic area equal to or less than the area of a circle with a radius of
1,850 feet). We sometimes collect precise geolocation information (which may be
considered a sensitive data type) to provide GPS-based location services you
choose to enable.
- Account access information, such as a username and
password (we collect that information only for the accounts you create directly
with us and not for any other account you may have with a third party in a
personal capacity).
However, as explained in detail above in the section on
"Reader Surveys, Research, Panels, and Experience Programs," there
are situations when we request certain of the above information (e.g., a reader
survey asks about your political leanings or ethnicity). You will always have
the option to decline to answer or participate in such surveys, panels, or
other feedback programs. Outside these situations, we would prefer you never
share sensitive personal information with us.
#### iii. Information Collected Automatically
When you use MiddleEastMorning Services, we collect some
information automatically. The technologies we use to assist with this data
collection include cookies, web beacons, tags, scripts, and software
development kits (or SDKs). We may also use newer technologies as many browsers
begin to deprecate third-party cookies. We use these technologies on our
digital properties, including our websites and apps, as well as in our email
communications and newsletters. For more information about how to manage
tracking methods on MiddleEastMorning Services, read our Cookie Policy and the
What Are Your Rights and Choices? section below.
The categories of personal information we collect
automatically include:
---
This policy aims to protect your privacy and ensure that you
are informed about how MiddleEastMorning.com collects, uses, and safeguards
your personal information.
**Effective Date: [Insert Date]**
**1. What Information Do We Gather About You?**
The information we gather about you depends on the context.
By and large, it’s information that can personally identify you — either on its
own or when combined with other information.
The following describes the information we collect and how
we obtain it.
**1. (A) Information Collected through Middle East Morning
Services**
**i. Information You Voluntarily Give Us**
**For Registration:**
When you sign up for a Middle East Morning Service (whether
via a subscription or a free account as a registered user), we collect personal
identifiers such as your contact information, including your name and email
address, and account credentials. We may also ask you to create an account
name. Once you’re registered, we assign you a unique ID number. This ID number
helps us recognize you when you’re signed in.
For some Middle East Morning Services, you can instead sign
up by linking your Apple, Facebook, or Google account. See Information
Collected From Other Sources below.
If you register for an event or conference, we might ask for
additional information (e.g., your company name, your job title, or your
dietary restrictions). Some events and conferences may have different or
additional privacy policies and terms, and we recommend that you review those
before you register.
**For Billing:**
To process payments or donations, we collect and use your
payment information. This can include your name, address, telephone number,
email address, credit or debit card information, and any other relevant
information.
**For User-Generated Content:**
We offer you the ability to post content that other users
can read (e.g., comments or recipe notes). Anyone can read, collect, and use
any personal information that accompanies your posts. Please review our
User-Generated Content section in our Terms of Service for more information.
We do not have to publish any of your content. If the law
requires us to take down, remove, or edit your content, we will comply.
**For Contests, Sweepstakes, and Special Offers; Notice of
Financial Incentives:**
From time to time, we offer certain opportunities through
contests, sweepstakes, or other special promotions and offers. When you sign up
for these, you give us your name, email, and any other required information.
Some such opportunities may allow you to earn “rewards” such
as discounts (“Incentive Programs”). If this is part of the contest,
sweepstakes, promotion, or offer, we will provide you with a full description
of the Incentive Program, including the benefits offered and related legal
terms. Because these Incentive Programs involve the collection of personal
information, they may be interpreted as “financial incentive” programs under
applicable law. We use this information for the purposes described in this
Privacy Policy, including for targeted advertising. We may share your personal
information with third parties as described in this Privacy Policy, including
data analytics providers, advertising technology vendors, and social media
platforms.
The value of any financial incentive we offer is reasonably
related to the value of any personal information you provide to us. We estimate
the value of your personal information by considering, without limitation, the
expenses we incur from collecting your personal information and/or providing
the financial incentive to you, the revenue generated by your use of the
financial incentive, and any improvements we can make to our products and
Middle East Morning Services based on information obtained through the
financial incentive program.
Please note that we may provide additional terms that apply
to a particular financial incentive. If applicable, those terms will be
presented to you at sign-up. You may cancel your membership in such Incentive
Programs at any time by contacting privacy@middleeastmorning.com.
**For Reader Surveys, Research, Panels, and Experience
Programs:**
We gather personal information through questionnaires, surveys,
and feedback programs.
**Surveys and Panels:**
Some of our surveys and feedback programs, including panels,
will request your consent to provide on a purely voluntary basis information
regarding your interests in various topics, including travel, entertainment,
and health and wellness, as well as demographic information, some of which may
be considered sensitive under applicable laws such as your age, ethnicity,
race, gender, sexual orientation, family characteristics, and income. We use
service provider platforms to support these programs, and personal information
is shared with them as described below with respect to service providers in
general.
We target these surveys based on a number of factors,
including information we automatically collect about your interests and usage,
as described below. These surveys are used for a variety of purposes described
throughout this Privacy Policy, including research for marketing of Middle East
Morning Services, as well as research for third-party advertisers that are
interested in targeting ads to particular groups of Middle East Morning
readers.
As described in more detail below, we combine information
from these surveys and panels with information collected automatically from
Middle East Morning Services, and sometimes we also apply internal or
third-party machine learning or artificial intelligence large language models
or applications to this information (alone or in combination with other
personal information we collect about you). We do this for the purposes of
improving Middle East Morning Services, for marketing research, to personalize
marketing of Middle East Morning Services to you, and/or to create audiences
for third-party advertisers.
**Recording Your Feedback:**
With your consent, we may record interviews with you and ask
for your permission to use your voice and likeness for a variety of purposes,
including marketing, advertising, and/or Middle East Morning events.
**Reader Callouts:**
If you participate in a reader callout on Middle East
Morning Services, additional terms such as our Reader Submissions terms may
apply (and will be posted where we ask you to participate).
**During Contact with Our Call Centers (Internal and
Offshore):**
We collect information from you when you place an order over
the phone or contact customer service through one of our toll-free numbers.
This can include your name, contact information, information about your
account, and any other information you choose to provide.
**Personal Contacts Data/Refer-a-Friend:**
We never scan your device for your contacts or upload that
data.
With your consent, we do comply with your requests to
collect data about your friends, family, or acquaintances (e.g., Refer-a-Friend
campaigns). This functionality is only meant for U.S. residents. By using it,
you acknowledge and agree that both you and your contacts are based in the
United States — and that you have everyone’s consent for us to use their
contact information.
If you’d like to invite your friends to use Middle East
Morning Services, we will store this information for the sole purposes of
allowing you to send your friends referral offers, for determining whether your
friends use Middle East Morning Services after a referral is sent, and to
remind your friends of the referral sent on your behalf.
**iii. A Note about Sensitive Personal Information**
We generally don’t want to gather sensitive personal
information about you. This includes:
- Government-issued IDs (such as your driver’s license,
passport, or social security number)
- Your racial or ethnic origin
- Your political opinions
- Your religion or other beliefs
- Your health, biometric, or genetic characteristics,
including physical characteristics or descriptions
- Any trade union membership
- Your sexuality (information about your sex life or sexual
orientation)
- Citizenship or immigration status
- Any criminal background
- The content of your private communications (other than
messages you may send to us)
- Account access information, such as a username and
password (we collect that information only for the accounts you create directly
with us and not for any other account you may have with a third party in a
personal capacity).
However, as explained in detail above in the section on
“Reader Surveys, Research, Panels, and Experience Programs,” there are
situations when we request certain of the above information (e.g., a reader
survey asks about your political leanings or ethnicity). You will always have
the option to decline to answer or participate in such surveys, panels, or
other feedback programs. Outside these situations, we would prefer you never
share sensitive personal information with us.
**iii. Information Collected Automatically**
When you use Middle East Morning Services, we collect some
information automatically. The technologies we use to assist with this data
collection include cookies, web beacons, tags, scripts, and software
development kits (SDKs). We may also use newer technologies, such as clean rooms,
matching services described below (such as Unified ID 2.0 and LiveRamp’s
Authenticated Traffic Solution), and Comscore’s Unified Digital Measurement
(UDM) 2.0, as many browsers begin to deprecate third-party cookies. We use
these technologies on our digital properties, including our websites and apps,
as well as in our email communications and newsletters. For more information
about how to manage tracking methods on Middle East Morning Services, read our
Cookie Policy and the “What Are Your Rights and Choices?” section below.
The categories of personal information we collect
automatically include:
- Information about your device, including your IP address,
browser type, operating system, device model, and unique device identifiers
- Information about your usage of Middle East Morning
Services, including your browsing history, search queries, and the content you
access
- Information about your location, including the city,
state, and country where you are located
- Information about your interactions with our emails, such
as whether you open or click on them
**2. How Do We Use Your Information?**
We use the information we collect about you for a variety of
purposes, including:
- To provide you with the Middle East Morning Services and
any other products or services you request
- To improve the quality of our services,
