Wire Portal Privacy Policy

NewsForce AG ("NewsForce", "we", "our", or "us") is committed to safeguarding your privacy and ensuring transparency and fairness in how we process your Personal Data (as defined below) in connection with the provision and operation of the NewsForce Wire Portal (the "Portal").

This Privacy Policy ("Policy") is intended to help you understand the information we process, collect, store, use, and share, and it applies whenever you interact with the Portal. Please note that certain provisions of this Policy may vary depending on your jurisdiction and the applicable laws. This Policy is incorporated by reference into, and forms part of, the Wire Portal Terms of Use.

We strongly urge you to read this Policy carefully and ensure you fully understand and agree to it. If you do not agree to this Policy, please stop using the Portal. You are not legally required to provide Personal Data, but without it we cannot offer you the best experience.

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1. What is Personal Data?
"Personal Data" (also defined as "Personal Information" under US Privacy Laws) refers to any information that can directly or indirectly identify an individual, or that could be used to identify an individual with reasonable effort. Examples of Personal Data include, but are not limited to, a person's name, contact details such as email address or phone number, and online identifiers such as IP addresses or User IDs.

"Non-Personal Data" refers to information that is aggregated or anonymized such that it does not reveal, and cannot reasonably be used to reveal, the identity of any individual. We do not know the identity of the individual from whom Non-Personal Data is collected. Non-Personal Data may include aggregated usage statistics and technical data sent by your device, such as browser type and version, operating system type and version, mobile network details, device settings, and software-related information. For the avoidance of doubt, Any Non-Personal Data that is linked or connected to Personal Data shall be considered Personal Data for as long as such linkage exists.

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2. What types of Personal Data we collect?
We may collect and process the following categories of Personal Data:
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2.1 Account information.
When you sign up for the Portal, we may collect information such as your name, email address, and phone number.
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2.2 Communication information.
When you choose to reach out to us or otherwise provide us with any feedback, we may collect information such as your full name, email address, and any other information you may choose to provide us.
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2.3 Payment information.
We collect information such as your billing address and payment details when you purchase a sponsored placement through the Portal. Please note that payment information is processed by Stripe and is subject to its Privacy Policy, which we encourage you to review.
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2.4 Usage information.
When you interact with the Portal, we may collect technical information such as geolocation data, IP address, unique identifiers (e.g., MAC address and UUID), as well as other information which relates to your activity on the Portal.
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2.5 Professional information.
We may collect certain business-related information and content that you choose to upload or submit through the Portal, such as your company name, industry or field of business, company email address, phone number, and other related data which may constitute Personal Data.

Please note that the Portal is not intended to collect, and we do not knowingly collect, any "Special Categories of Personal Data", "Sensitive Personal Information", or any similar categories of Personal Data defined under applicable law, as part of our provision of the Portal. If you believe that the foregoing has been processed through the Portal, please contact us via the details provided below. Upon becoming aware of such processing, we will take the necessary steps to assess the matter and implement appropriate measures, which may include deletion or restriction of such data, all in accordance with applicable law.

Additionally, please note that you may choose to provide certain Personal Data relating to third-party individuals. Where providing this Personal Data, you confirm that the applicable individuals have been informed of this Policy.
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3. Why do we process your Personal Data?
This section explains the purposes for which we use your Personal Data and, where applicable, outlines the legal bases that underlie our usage.

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4. Tracking Technologies
When you visit or access the Portal, we use cookies, pixels, beacons, local storage and similar technologies (collectively, "Tracking Technologies"). These Tracking Technologies allow us to automatically collect information about you, your device, and your online behaviour, to enhance your navigation on the Portal, improve performance, perform analytics, and customize your experience.

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4.1 What types of Tracking Technologies do we use?
When you use or access the Portal, we use the following categories of Tracking Technologies:

(a) Strictly necessary Tracking Technologies: These Tracking Technologies are automatically placed on your device when you access the Portal and are essential for purposes such as maintaining the security of the Portal and user authentication. We do not need to obtain your consent in order to use these Tracking Technologies.

(b) Functionality Tracking Technologies: These Tracking Technologies enable us to provide basic operational features and functionality.

(c) Performance Tracking Technologies: These Tracking Technologies collect information about your online activity (for example the duration of your visit on the Portal), including behavioural data and content engagement metrics. These Tracking Technologies are used for analytics, research and to perform statistics based on aggregated information.

The Portal also uses Google Analytics, a web analysis service provided by Google LLC ("Google") which is based on Tracking Technologies. The information generated by these Tracking Technologies is usually sent to and stored in a Google server in the USA. On our behalf, Google will use the generated information to evaluate your use of the Portal to compile reports on activities and to provide us with additional services connected with such use. The IP address transmitted in connection with Google Analytics is not collated with other data by Google. We use the information we get from Google to maintain and improve the Portal. We do not combine the information collected through the use of Google with Personal Data we collect. Further information about the privacy practices of Google Analytics is available at: www.google.com/policies/privacy/partners/. Further information about your option to opt-out of Google Analytics is available at https://support.google.com/analytics/answer/9019185?hl=en#zippy=%2Cin-this-article. We reserve the right to remove or add new analytic tools.

4.2 How and by whom Tracking Technologies are stored on your device?
We may store Tracking Technologies on your device when you visit or access the Portal. These are called "First Party Tracking Technologies". In addition, Tracking Technologies are stored by other third parties (for example, our payment processors). These are called "Third-Party Tracking Technologies". Both types of Tracking Technologies will be stored either for the duration of your visit on the Portal or for repeat visits.

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There are various ways in which you can manage and control your Tracking Technologies settings:

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(a) You can change your preferences using our cookie settings tool (however, please note that this tool may only be available in certain jurisdictions).  
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(b) All modern web browsers allow you to change your cookie settings. You can usually find these settings in the "Options" or "Preferences" menu of your browser. Below is a list of useful links that can provide you with more information on how to manage your Tracking Technologies:

• Google Chrome
• Mozilla Firefox
• Safari (Desktop)
• Safari (Mobile)
• Android Browser
• Microsoft Edge
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  (c) On iOS, depending on the applicable iOS version, you may withdraw consent across all apps by either enabling the "Limit Ad Tracking" setting or disabling the "Allow Apps to Request to Track" permission in your iOS device settings. Depending on the applicable iOS version, instead of withdrawing consent on a device-wide basis, you may also have the option of withdrawing consent on a per-app basis by disabling tracking permissions for specific apps that appear under the "Allow Apps to Request to Track" setting in your iOS device settings (precise directions may differ depending on the applicable iOS version).
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  (d) On Android devices, you may withdraw your consent in the Google Ads settings within your Android settings by enabling the “Opt-out of Ads Personalization” setting (precise directions and the name of the setting may differ depending on the applicable Android versions and device manufacturer).

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5. With whom do we share your Personal Data?

We may share your Personal Data as described below:

5.1 Service providers.

Our service providers work on our behalf and need access to certain Personal Data in order to provide their services to us. These providers include, but are not limited to, storage and web hosting providers, payment processors, and analytics services.

5.2 Compliance with laws and assistance to law enforcement agencies.

We may disclose Personal Data when required by law, legal process, or lawful requests by public authorities, including to meet national security or law enforcement requirements. We may also disclose such data where we believe it is necessary to protect rights, property, or safety, or to prevent or stop unlawful or unethical activity.

5.3 Auditors and advisers.

We share Personal Data with our auditors, advisors, and professional service providers (such as lawyers, accountants, and insurers) to ensure regulatory compliance, support auditing, and manage disputes.

5.4 Mergers and acquisitions. 

We may transfer, sell, or otherwise share Personal Data in connection with business transactions such as mergers, acquisitions, reorganizations, bankruptcy, or sales of assets.

6. Your rights

Depending on the jurisdiction in which you reside, you may have certain rights under applicable laws regarding the collection and processing of your Personal Data:

1. Right to Access: The right to receive confirmation that we process your Personal Data, as well as access your Personal Data (for example, by receiving a copy or a representative summary thereof) and other supplementary information.
2. Right to Rectification: The right to request the update or correction of inaccurate or incomplete Personal Data which is in our control.
3. Right to Erasure: The right to request the deletion of your Personal Data.
4. Right to Restrict Processing: The right to limit the processing of Personal Data to specific purposes. 
5. Right to Data Portability: The right to receive your Personal Data in a structured, commonly used, and machine-readable format, as well as the right to transmit the Personal Data to third parties.
6. Right to Object to Processing: The right to object the processing of Personal Data for certain purposes.
7. Right to Limit the Use and Disclosure: The right to limit the use and disclosure of your Sensitive Personal Information (or an equivalent term under applicable laws).
8. Right to Withdraw Consent: The right to withdraw previously given consent. 
9. Right Not to Be Subject to Automated Decision-Making: The right not to be subject to decisions based solely on automated processing that produce legal or other significant effects.
10. Right to Opt-Out: The right to opt-out of the "Sale" or "Share" of Personal Data for "Targeted Advertising" purposes (as these terms are defined under applicable laws). 
11. Right to Non-Discrimination: The right to be free from any discrimination for exercising your rights. We will not discriminate against you by offering you different pricing or products, or by providing you with a different level or quality of services, based solely upon your request. However, in some circumstances, we may not be able to provide a service if you choose to delete your Personal Data.

Exercising your rights:

1. You may exercise certain rights through the settings available in your account dashboard.
2. You may contact us at any time via legal@newsforce.com. We will consider any requests, complaints or queries and provide you with a reply in a timely manner. Please note that we may require additional information and documents when processing your request, including certain Personal Data, in order to authenticate and validate your or any applicable authorized agent's identity and to process your request. Such additional data may also be retained for legal purposes in accordance with this Policy.
3. If you think we have infringed data protection laws, you may file a claim with the data protection supervisory authority in your jurisdiction of residency, as applicable to you.
4. In some jurisdictions, you have the right to appeal a rejection of your request. Please submit your appeal to legal@newsforce.com. If your appeal is denied, certain jurisdictions allow you to submit a complaint via the local attorney general or another competent authority responsible for handling such matters.

Please note that these rights are not absolute, and are subject to the relevant applicable laws, our own legitimate interests and regulatory requirements.

If you are a California resident, you may only designate an authorized agent to make a request on your behalf if: (i) The authorized agent is a natural person or a business entity registered with the Secretary of State of California, and (ii) you sign a written declaration that you authorize the authorized agent to act on your behalf. The request must: (i) provide sufficient information to allow us to reasonably verify you are the person about whom we collected Personal Information or an authorized agent. We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you, and (ii) describe your request with sufficient details to allow us to properly understand, evaluate, and respond to it. We will only use Personal Information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request.

7. International data transfers

Please note that we, as well as our trusted partners and service providers, may be located around the world. Any information that we collect (including your Personal Data) may be stored and processed in various jurisdictions around the world, for the purposes detailed in this Policy, including in countries that may not provide the same level of data protection as ‎the country where you reside. ‎In such cases, we will ensure that applicable safeguards and legal mechanisms are used to ensure that the transfer is aligned with the applicable data protection laws.

8. Information for US residents

This section addresses the specific disclosure requirements under applicable laws pertaining to the protection of Personal Information in the United States, including in California, Colorado, Connecticut, Utah, Virginia, Texas, Oregon, Florida, Montana, Iowa, Delaware, New Jersey, New Hampshire, Nebraska, Tennessee, Minnesota, Maryland, Indiana, and Kentucky (collectively, "US Privacy Laws").

8.1 Collection of Personal Information

In the preceding twelve (12) months, we have collected the following categories of Personal Information:

1. Category A - identifiers: For example, real name, email address, account name, and online identifiers.
2. Category B - Personal Information categories listed in the California Customer Records statute: For example, name and address.
3. Category D – commercial information: For example, products or services purchased and other purchasing or consuming histories or tendencies.
4. Category F – internet or other similar network activity: For example, IP addresses, unique device identifiers, and other information derived from your interaction with the Portal.
5. Category G - (non-precise) geolocation data.
6. Category I – professional or employment-related information.
7. Category K – Inferences drawn from other personal information: for example, inferences regarding your preferences and interactions in connection with the Portal.

8.2 Sources of Personal Information

In the preceding twelve (12) months, we have collected the above-mentioned categories of Personal Information from the following categories of sources:

1. Directly, through your activity: For example, from forms you complete on the Portal.
2. Indirectly from you: For example, when we automatically collect usage data through measurement tools.
3. From third parties: For example, from service providers, and other business partners that support the operation of the Portal.

We do not offer financial incentives to users for providing Personal Information.

8.3 Sharing and Disclosure of Personal Information

We do not "Sell" or "Share" your Personal Information for "targeted advertising" purposes, as these terms are defined under US Privacy Laws. However, We disclose Personal Information about you. In the preceding twelve (12) months we may have disclosed your Personal Information as follows:

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Any disclosure of Personal Information is limited to what is essential for the purpose of such disclosure. Recipients are required to protect the Personal Information they receive and to use it solely for the agreed purposes, in accordance with applicable laws. These third parties may independently use other Non-Personal Data for their own purposes.

8.4 Purposes for Processing 

In addition to the practices detailed in this Policy, we also use and disclose the Personal Information we collect for the following commercial and business purposes:

1. Auditing related to our interactions with you;
2. Legal compliance;
3. Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and necessary prosecution;
4. Debugging;
5. Performing services (by us or our service providers);
6. Internal research for technological improvement;
7. Internal operations;
8. Activities to maintain and improve our services; and 
9. Other one-time or short-term uses.

8.5 "Do Not Track" Settings

Cal. Bus. & Prof. Code Section 22575 also requires us to notify you how we deal with the "Do Not Track" settings in your browser. As of the effective date listed above, there is no commonly accepted response for Do Not Track signals initiated by browsers. Therefore, we do not respond to the Do Not Track settings. Do Not Track is a privacy preference you can set in your web browser to indicate that you do not want certain information about your web page visits tracked and collected across websites.

9. Minors

We do not knowingly collect Personal Data from minors (as determined under the applicable laws where the individual resides; "Minor(s)"). By accessing or using the Portal, you certify to us that you are not a Minor. In the event that we have collected Personal Data from a Minor without verification of parental consent, we will delete that information upon discovery. If you believe that we might have any information from or about a Minor, then please contact us through the contact details available below.

10. Retention

We will retain your Personal Data only as long as necessary to provide access to the Portal, comply with legal obligations, resolve disputes, and enforce our policies. Retention periods depend on the type and purpose of the data, with outdated or unused information deleted at the earliest reasonable time.

11. Data Security

We take the protection of Personal Data seriously and implement industry-standard physical, administrative, and technical measures to safeguard it. However, no system can provide absolute security. Despite our efforts, we cannot guarantee the complete protection of any Personal Data stored with us or with third parties. Transmission of information over the internet always carries some risk, and it is possible that security measures could be circumvented. Consequently, while we strive to protect your Personal Data, we cannot warrant its absolute security or privacy, and you share information at your own risk. We therefore encourage you to exercise discretion when disclosing Personal Data.

12. Third Parties

The Portal may be provided, in whole or in part, in conjunction with third-party services, technologies, or platforms that are not operated or controlled by us. Such third parties may collect and process Personal Data in accordance with their own privacy policies and practices. We do not control, and are not responsible for, the privacy practices of such third parties, and we encourage you to review the applicable privacy policies of any third-party services with which you interact.

13. Updates to this Policy

We reserve the right to change this Policy at any time. The most current version will always be posted through the Portal (as reflected in the "Last Updated" heading). You are advised to check for updates regularly. By continuing to access the Portal after any revisions become effective, you agree to be bound by the updated Policy.

14. Controlling version

This Policy has been drafted in the English language, which is the original and controlling version of this Policy. To the extent permitted by law, all translations of this Policy into other languages shall be solely for convenience and shall not control the meaning or application of this Policy. In the event of any discrepancy between the meanings of any translated versions of the Policy and the English language version, the meaning of the English language version shall prevail.

15. Contact us

If you have any further questions, please contact us by email at: legal@newsforce.com.

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