This Privacy Policy describes how CNHI LLC and its affiliates and subsidiaries (collectively, “CNHI,” “we,” “us,” or “our”) collects, uses, shares, and protects personal information. This Privacy Policy also tells you about rights and choices with respect to your personal information, and how you can reach us to get answers to your questions.

Information We Collect

We collect information about you in a variety of ways depending on how you interact with us and our websites, mobile applications, newspapers, and services, including:

Directly from you when you provide it to us, such as when you subscribe to a newspaper, sign up to receive communications from us, or contact us by phone, email, or otherwise.
Automatically through the use of cookies, server logs, and other similar technologies when you interact with our websites, mobile applications, advertisements, and emails.
From other sources, including, for example, our affiliates, business partners, service providers, and other third parties, or from publicly available sources. For example, if you submit a job application, we may conduct a background check.

The following provides examples of the type of information that we collect and how we use that information.

Context	Types of Data	Primary Purpose for Collection and Use of Data
Account Registration	We collect your name and contact information when you create an account. We also collect information relating to the actions that you perform while logged into your account.	We have a business interest in providing account related functionalities to our users. Accounts can be used to save your subscription settings, preferences, and transaction history.
Location Information	When you use one of our Apps we collect your location from the Wi-Fi, and/or cellular technology in your device.	We have a business interest in understanding our users and providing tailored content, such as local news stories and weather updates. In some contexts our use is also based upon your consent to provide us with geolocation information.
Cookies and First-Party Tracking	We use cookies and clear GIFs. “Cookies” are small pieces of information that a website sends to a computer’s hard drive while a website is viewed.	We have a business interest in making our website operate efficiently.
Cookies and Third-Party Tracking	We may place tracking technology on our website that collects analytics, records how you interact with our website, or allows us to participate in behavior-based advertising. This means that a third party uses technology (e.g., a cookie) to collect information about your use of our website so that they can report analytics to us or provide advertising about products and services tailored to your interests. That third party might also collect information over time and across different websites in order to serve advertisements on our website or other websites.	We may collect consent with regard to some forms of third party tracking technologies.
Feedback/Support	If you provide us feedback or contact us for support we will collect your name and email address, as well as any other content that you send to us, in order to reply.	We have a business interest in receiving, and acting upon, your feedback or issues.
Job Applicants	We collect personal information from our job applicants, such as your age or location.	We have a business interest in understanding our job applicants.
Mailing List	When you sign up for one of our mailing lists we collect your email address or postal address.	We share information about our products and services with individuals that consent to receive such information.
Mobile Devices	We collect information from your mobile device such as unique identifying information broadcast from your device when visiting our website.	We have a business interest in identifying unique visitors, and in understanding how users interact with us on their mobile devices.
Partner Promotion	We collect information that you provide as part of a co-branded promotion with another company.	We have a business interest in fulfilling our promotions.
Subscriber Information	We collect your name, billing address, shipping address, email address, phone number, and credit card number when you sign up for a subscription.	We have a business interest in contacting our clients and communicating with them concerning normal business administration such as subscriptions, services, and billing. We use your information to perform our contract to provide you with products or services.
Surveys	When you participate in a survey, we collect information that you provide through the survey. If the survey is provided by a third party, the third party’s privacy policy applies to the collection, use, and disclosure of your information.	We have a business interest in understanding your opinions, and collecting information relevant to our organization.
Sweepstakes or contests	When you participate in a sweepstakes or contest we collect information about you which includes contact information to notify you if you are selected.	We have a business interest in operating the sweepstakes. In some contexts we are also required by law to collect information about those that enter into our sweepstakes, and we have a business interest in complying with those laws.
Website interactions	We use technology to monitor how you interact with our website. This may include which links you click on, or information that you type into our online forms. This may also include information about your device or browser.	We have a business interest in understanding how you interact with our website to better improve it, and to understand your preferences and interests in order to select offerings that you might find most useful. We also have a legitimate interest in detecting and preventing fraud.
Web logs	We collect information, including your browser type, operating system, Internet Protocol (IP) address (a number that is automatically assigned to a computer when the internet is used), domain name, click-activity, referring website, and/or a date/time stamp for visitors.	We have a business interest in monitoring our networks and the visitors to our websites. Among other things, it helps us understand which of our services is the most popular.

Some jurisdictions require that we describe the categories of personal information we collect and disclosure for a business purpose as well as disclose which categories of personal data are shared with third parties. Please note, in addition to the recipients identified below, we may disclose any of the categories of personal information we collect with government entities, as may be needed to comply with law or prevent illegal activity. We do not “sell” or “share” your personal information as those terms are defined under applicable law. As discussed elsewhere in the Privacy Policy, we use cookies and similar tracking technologies for purposes of targeted advertising. For more information, please see the Information We Collect section of the Privacy Policy and the Opt-out of Targeted Advertising bullet of the Your Choice section of the Privacy Policy. For information regarding how long we retain personal information, please refer to the How We Protect and Retain Information section of the Privacy Policy.

Category of Personal Information	Category of Recipients
Category of Personal Information	Disclosures for a Business Purpose
Identifiers – this may include real name, alias, postal address, unique personal identifier, online identifier, email address, account name, or other similar identifiers.	Affiliates or subsidiaries Business partners Data analytics providers Internet service providers Joint marketing partners Operating systems and platforms Payment processors and financial institutions Social networks Other Service Providers
Financial Information – this may include bank account number, credit card number, debit card number, and other financial information.	Payment processors and financial institutions Professional services organizations Other Service Providers
Characteristics of protected classifications – this may include age, sex, race, ethnicity, physical, or mental handicap, etc.	Affiliates or subsidiaries Other Service Providers
Commercial information – this may include information about products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	Payment processors and financial institutions Professional services organizations Other Service Providers
Internet or other electronic network activity information – this may include browsing history, search history, and information regarding an individual’s interaction with an internet website, application, or advertisement.	Internet service providers Operating systems and platforms Other Service Providers
Geolocation data – such as precise physical location.	Internet service providers Other Service Providers

How We Use Information.

In addition to the purposes and uses described above, we use information in the following ways:

To identify you when you visit our websites or our mobile apps.
To provide products and services.
To improve our services and news offerings.
To conduct analytics.
To communicate with you, such as to respond to and/or follow-up on your requests, inquiries, issues, or feedback.
To send marketing and promotional materials including information relating to our newspapers, services, sales, or promotions, or those of our business partners.
To detect and protect against malicious, deceptive, fraudulent, or illegal activity, including violation of our policies and terms and conditions, security incidents, and harm to the rights, property, or safety of our company and our users, employees, or others.
To debug, identify and repair errors that impair the functionality of our website and mobile applications.
To comply with our legal or regulatory obligations, to establish or exercise our rights, or to defend against a legal claim.
For internal administrative purposes, as well as to manage our relationships.
For such other purposes as you may consent (from time to time).

Although the sections above describe our primary purpose in collecting your information, in many situations we have more than one purpose. For example, if you subscribe to a newspaper, we may collect your information to perform our contract with you, but we also collect your information as we have a business interest in maintaining your information after your transaction is complete so that we can quickly and easily respond to any questions about your order. As a result, our collection and processing of your information is based in different contexts upon your consent, our need to perform a contract, our obligations under law, and/or our interest in managing our business.

How We Share Information.

In addition to the specific situations discussed elsewhere in this Privacy Policy, we may disclose personal information in the following situations:

Acquisitions. If another company acquires, or plans to acquire, our company, business, or our assets, we may also share information with that company, including at the negotiation stage.
Other Disclosures without Your Consent. We may disclose information in response to subpoenas, warrants, or court orders, or in connection with any legal process, or to comply with relevant laws. We may also share your information in order to establish or exercise our rights, to defend against a legal claim, to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of our policies, or to comply with your request for the delivery of news to or the provision of services by a third-party intermediary.
Public. Some of our websites may provide the opportunity to post announcements in a public forum. If you decide to submit information on these pages, that information may be publicly available.
Partner Promotion. We may offer contests, sweepstakes, or other promotions with third party partners. If you decide to enter a contest, sweepstakes, or promotion that is sponsored by a third party partner the information that you provide will be shared with us and with them. Their use of your information is not governed by this privacy policy.
Service Providers. We may share your information with service providers. Among other things service providers may help us to administer our website, conduct surveys, provide technical support, process payments, and assist in the fulfillment of subscriptions.
Other Disclosures with Your Consent. We may disclose your information to other third parties when we have your consent or direction to do so.
Targeted Advertising. We may make your personal information available to third parties for targeted adverting. For information about how to opt-out of targeted advertising, please see the Your Choices section below.

Your Choices

Some jurisdictions give you a right to make the following choices regarding your personal information:

Access To Your Personal Information. You may request access to your personal information or confirmation that we have information about you. In certain limited circumstances, you may also request to receive access to your data in a portable, machine-readable format.
Changes To Your Personal Information. We rely on you to update and correct your personal information. You may ask us to correct information that is inaccurate or incomplete. Note that we may keep historical information in our backup files as permitted by law.
Deletion Of Your Personal Information. You may request that we delete your personal information. If required by law, we will grant a request to delete information, but you should note that in many situations we must keep your personal information to comply with our legal obligations, resolve disputes, enforce our agreements, or for another business purposes.
Opt-out of Targeted Advertising. You may opt-out of online tracking based targeted advertising (e.g., cookies) by clicking the cookie settings link here. Please note that if you change browsers or computers, or if you clear your browser’s cache, you may need to click the link again to apply your preference.
Objection to Certain Processing. You may object to our use or disclosure of your personal information by contacting us at the address described below.
Online Tracking. We do not currently recognize the “Do Not Track” signal.
Promotional Emails. You may choose to provide us with your email address for the purpose of allowing us to send free newsletters, surveys, offers, and other promotional materials to you, as well as targeted offers from third parties. You can stop receiving promotional emails by following the unsubscribe instructions in emails that you receive. If you decide not to receive promotional emails, we may still send you service related communications.
Revocation Of Consent. Where we process your personal information based upon consent, you may revoke consent. Please note, if you revoke your consent for the processing of personal information then we may no longer be able to provide you services.

Please note, not all of the rights described above are absolute, and they do not apply in all circumstances. In some cases, we may limit or deny your request because the law permits or requires us to do so, or if we are unable to adequately verify your identity. FOR EXAMPLE WE DO NOT DELETE PERSONAL INFORMATION THAT HAS BEEN INCLUDED AS PART OF A NEWS STORY. We will not discriminate against individuals who exercise their privacy rights under applicable law.

Submitting Requests

You may exercise the rights described above through our online portal or by calling us at 1-833-912-208. If you use the telephone number, you will be guided through a process that will allow you to submit a verifiable request. If you disagree with how we handled a request, you may appeal our decision by contacting us by email with the subject line “Appeal.”

Note that, as required by law, we will require you to prove your identity. We may verify your identity by phone call or email. Depending on your request, we will ask for information such as your name and email address. We will ask you at least one question, and you must reply by email with the correct answer for each question based on your previous interaction with us. If we still cannot verify your identity as required by law, we will let you know and may ask additional questions. Otherwise, we will acknowledge your request and contact you later with our full response.

Before sending a verification response, please double-check the email address. If you receive an email that appears to be from us but is not from our verification email address listed above, do not respond.

In some circumstances, you may designate an authorized agent to submit requests to exercise certain privacy rights on your behalf. If an authorized agent is submitting a request on your behalf, the authorize agent must present written permission to exercise your rights under applicable law. We may deny a request from an authorized agent on your behalf if the authorized agent does not submit proof that he, she, or it has been authorized by the data subject to act on your behalf if we request such proof. Even if you use an authorized agent to exercise your rights under applicable law on your behalf, we may still require that you verify your own identity directly to us.

How We Protect and Retain Information

No method of transmission over the internet, or method of electronic storage, is fully secure. While we use reasonable efforts to protect your personal information from unauthorized access, use, or disclosure, we cannot guarantee the security of your personal information. In the event that we are required by law to inform you of a breach to your personal information we may notify you electronically, in writing, or by telephone, if permitted to do so by law.

Some of our websites permit you to create an account. When you do you will be prompted to create a password. You are responsible for maintaining the confidentiality of your password, and you are responsible for any access to or use of your account by someone else that has obtained your password, whether or not such access or use has been authorized by you. You should notify us of any unauthorized use of your password or account.

We retain your personal information for only as long as necessary to fulfil the purposes outlined in this Privacy Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements, unless a longer retention period is required or permitted by law. To determine the appropriate retention period for personal information, we consider the amount, nature, and sensitivity of the information, the potential risk of harm from unauthorized use or disclosure of the information, the purposes for which we obtained the information and whether we can achieve those purposes through other means, as well as applicable legal requirements.

Third-Party Applications/Websites

For your convenience, we may provide links to websites and other third-party content or services that we do not own or operate. The websites and third-party content to which we link may have separate privacy notices or policies. Please note, we have no control over the privacy practices websites, or services that we do not own. We encourage you to review the privacy policies of any third-party website or application for details about such third party’s privacy practices.

Changes To This Privacy Policy

We may change our privacy policy and practices over time. To the extent that our policy changes in a material way, the policy that was in place at the time that you submitted personal information to us will generally govern that information unless we receive your consent to the new privacy policy. Our privacy policy includes an “effective” and “last updated” date. The effective date refers to the date that the current version took effect. The last updated date refers to the date that the current version was last substantively modified.

Children

We encourage parents and guardians to be aware of and participate in their children's online activities. The Site is not intended or designed to attract children under the age of 13. If you believe that a child has submitted personal information on or through our Site without the consent and supervision of a parent or guardian, please contact us using the information provided below so that we can take appropriate action.

Contact Information

If you have any questions, comments, or complaints concerning our privacy practices, or if you need to access this Privacy Policy in an alternative format due to having a disability, please contact us at the appropriate address below. We will attempt to respond to your requests and to provide you with additional privacy-related information.

privacyrequests@cnhionline.com

CNHI LLC, Attn: General Counsel, 201 Monroe Street, Suite 450 Montgomery, AL 36104

1-833-912-2087

Additional Information For California Residents

If you are a California resident, the following privacy disclosures apply to you in addition to the rest of the Privacy Policy.

California Shine the Light. If you would like more information concerning the categories of personal information (if any) we share with third parties or affiliates for those parties to use for direct marketing, please submit a written request to us using the information in the Contact Information section above.
California Notice of Financial Incentive. Our newspapers may offer a limited number of contests to consumers with the primary purpose of community engagement. Consumers who participate in those contests allow us to retain and disclose their Personal Information. Only some newspapers offer contests and an individual newspaper will offer no more than five contest per calendar year. Contests with a financial incentive may range up to $5,000 per contest. You may withdraw from the incentive at any time. If you have previously opted-in to a contest and wish to opt-out, click here or call 1-833-912-2087.
California Sensitive Information Disclosure. We collect the following categories of sensitive personal information (as defined under California law): A consumer’s account log-in in combination with any required security or access code, password, or credentials allowing access to an account; and precise geolocation. This information is collected in order to process transactions, manage our business, or provide you with tailored news and services. Note that we do not use such information for any purposes that are not identified within the California Privacy Rights Act Section 1798.121. We do not “sell” or “share” sensitive personal information for purposes of cross-context behavioral advertising.

Effective Date: June 11, 2024

Last Update: June 11, 2024