Privacy Policy

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1. Welcome

This Privacy Policy (“Policy”) explains how we collect, use, store, protect, and share your personal information through our services. Lessin Media Company is the data controller of the personal information collected through the services (as defined in our Terms of Service Agreement (“Terms”). Lessin Media Company is referred to in this Policy as “The Information”, “we”, “our” or “us”.

How we handle your information depends on which services you use, and how you use them. This Policy is grouped into these sections:

• About us and this Policy;

• Information we collect & why we use it;

• When we disclose information to others;

• How to control your privacy;

• Information about local privacy laws

We encourage you to read this Policy carefully. If you have questions, please contact [email protected].

2. About us and this Policy

This Policy is designed to explain how we process your personal information and how you can exercise control over our processing. Capitalized terms that are used but not defined in this Policy are defined in our Terms. The Terms describe how the Service works in general, and establish a contract between you and us governing your use of the Service.

Contact us

If you have any questions or feedback about this Policy, email us at [email protected].

Changes to this Policy

Because the Service changes often, this Policy may change over time. Anytime we modify the Policy, we will post a revised version on the Service and update the Last Updated date above. If we intend to use your personal information in a way that is materially different from the ways described at the time of collection, we will notify you before the material changes to this Policy take effect, so you have time to review them. If we have your contact information (such as your email or phone number), we will notify you that way. We may also post a temporary notice on the Service, or notify you by other means to the extent required by law.

We encourage you to review the Last Updated date periodically to ensure you’re aware of the current Policy. By using or accessing the Service, you signify that you have read, understand and agree to be bound by this Policy and the Terms.

When this Policy applies

This Policy applies to information we and the Service collect from you, effective as of the Last Updated date above. However, some collection and use of information falls outside this Policy:

• Outside services: The Service may link to, embed, integrate or otherwise connect you with third-party websites, services or other events or activities that are not owned or controlled by The Information (“Outside Materials”). Outside Materials are not part of the Service. We do not control (and are not responsible for) Outside Materials and their providers’ privacy practices. Information you provide to third parties is not covered by this Policy. These third parties have their own policies and practices about data, which may include what information they share with us, your rights and choices on their services and devices, and where they store information. We encourage you to familiarize yourself with their privacy notices and applicable contractual terms.

• Key example: embedded content:

  Many of our articles and pages embed third-party containers in their content, such as YouTube videos or X posts interspersed within an article. Third-party content embedded by third parties constitute Outside Materials. We do not control the technologies used by video players and other embedded content experiences. For example, YouTube controls the player for any embedded YouTube video, and whether its video content will be served to you if you interact with the YouTube video.

  When you interact with embedded video, information about your requests, such as their originating IP address, may be collected by the player. The player may also collect information about the URL of your browser (a page on the Service), without any involvement of our Service itself.

• Our personnel: If you are a current or former employee or contractor of ours, including a contributor, this Policy does not apply to you. Reach out to your human-resources partner or supervisor with any inquiries about your personal information.

• When we don’t control your information: If we receive your information in our role as a service provider to another business, our agreement with that business governs our use of your information. We will refer any questions or concerns of yours to that business.

Embedded video and experiences

3. Information we collect & why we use it

We collect certain information when you use the services. This includes information you provide through the services, information we collect automatically (through cookies, log files, device identifiers, clear gifs, etc.), and information we receive from other sources. This also includes information you may provide to third-party service providers while using our services.

This section describes, comprehensively, how the Service collects and uses your information, and our legal basis for that processing. Under certain data protection laws like GDPR, companies must have a “legal basis”—a valid reason—to process personal information. We rely on different legal bases to process your information for the purposes described in this Policy.

Any personal information that The Information obtains from other third-party sources will be processed by The Information in accordance with this Policy and all applicable laws. For example, our use and transfer of information via Google APIs will adhere to the Google API Service User Data Policy, including its Limited Use requirements.

Comments and other user-generated content

We offer you the ability to post content that other users can read (e.g., comments). Anyone can read, collect and use any personal information that accompanies your publicly posted/disclosed content and publicly available profile information. See the “Interacting with the Service and User Content” section of our Terms for more information.

Security

The Information cares about the security of your information, and uses commercially reasonable physical, administrative, and technological safeguards to preserve the integrity and security of all information collected through the website. However, no security system is impenetrable and we cannot guarantee the security of our systems 100%. We cannot guarantee or warrant the security of any information you provide us, and you provide it at your own risk. We cannot promise that your information will remain absolutely secure in all circumstances. We are not responsible for the circumvention of any privacy settings or security measures we may provide.

In the event that any information under our control is compromised as a result of a breach of security, The Information will take reasonable steps to investigate the situation and where appropriate, notify those individuals whose information may have been compromised and take other steps, in accordance with any applicable laws and regulations.

4. Data Enhancement

We infer new information from other data we collect (like your page visits, search and AI Tools queries and newsletter clickthroughs) including using automated means. These inferences include information about your likely preferences, interests or other characteristics (e.g., writers, topics, content types, industries or companies). As described in this Policy, we use these inferences (“Enhanced Data”) for purposes of personalization, to improve our services, to market the Service to you and to create audience characteristics our advertisers can use in campaigns.

Information Collected from Other Sources

• Privately Owned Databases: Marketing, data analytic and social media-owned databases give us access to a range of information — like public data, survey data and more. This data sometimes includes your mailing address, your gender, your age, your household income and other demographic data.

• Social Media Platforms and Other Third-Party Services: If you provide your social network account credentials to us or use a Social Login, you understand some content and/or information in those accounts may be transmitted into your account with us. We also receive data from you when you interact with our pages, groups, accounts or posts on social media platforms (like Instagram, X, TikTok, Snap and others). This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles. We and other users of social data may link that data to you.

• Workplace and Schools: When your employer or school buys an organization-wide subscription to the Service, they sometimes provide us with your name and organization email address to grant you access as a user.

5. Our disclosures of personal information

This section describes how and why we exchange personal information with contractors and third parties. It also describes exchanges made for certain purposes, like advertising, legal reasons and consensual direct marketing. We may also disclose information that has been deidentified for these purposes.

As noted elsewhere in this Policy, to the extent regulators take the position that our disclosure of your information is a “sale,” we will take steps designed to opt you out of such disclosure if you are a resident of an applicable jurisdiction and you exercise your right not to have your personal information “sold.” If you’re using Global Privacy Control, we detected that and already turned off sharing for you. See How to control your privacy below for further information. You may also have to contact third parties to opt out of certain disclosures. We are not responsible for any third party’s failure to comply with opt-out requests.

Using Third-Party Vendors to Advertise or Market the Service to You

We use marketing vendors to market the Service to you. For example, we use Google’s Dynamic Remarketing tag. When you visit the Service, the Google Dynamic Remarketing tag collects data through redirects of your web requests to third party entities. We didn’t create Google’s tag, and many others use it too. Data from that tag is used to inform ad placements on the Service and elsewhere. We often target ads at people who have visited or registered for the Service but have not subscribed or purchased anything. The ads are also targeted at people with similar traits or behaviors to our subscribers or customers.

We periodically send you targeted email newsletters or promotional emails. For information on opting out of these emails, see How to control your privacy below.

In the past twelve months, we have shared these categories of personal information with third parties to personalize advertising:

• Device information (including personal identifiers)
• Commercial information
• Personal identifiers (email addresses)
• Internet activity
• Geolocation

Creation of Audiences for Third-Party Advertisers

We gather data and work with service providers and third parties to show you, and measure the performance of, personalized ads on behalf of advertisers. This data comes from ad tracking technologies set by us or the third party (e.g., cookies), the information you provide (e.g., your email address), your use of the Service (e.g., your reading and account activity history), information from advertisers or advertising vendors (e.g., demographic data) and anything inferred from any of this information. We try to limit how our third-party advertising technology vendors use information they collect from you. Most providers require us to enter contracts that allow them to optimize their ad services and products. Essentially, they combine any information they may gather about you through our Service with information they receive from their other clients. This helps them target ads to you on behalf of their other clients, not just us.

For example, we use Google to serve ads on the Services. Google uses cookies or unique device identifiers, in combination with their own data, to show you ads based on your visit to the Service and other sites. You can opt out of the use of certain Google cookies by visiting the related Google privacy policy.

We also identify groups of users to whom to serve personalized ads on behalf of our advertisers using Enhanced Data to build models that measure users’ attributes, like their demographic information or their interests. Working with service providers, we use these measurements to group users by common attributes for use in targeting ad campaigns on our sites and apps.

We also target third-party advertising to you and other users through matching services, such as LinkedIn’s Matched Audiences or Meta’s Custom Audiences. At times, we may use information that directly identifies you, including name, email address, or phone number, to return a new or preexisting identifier matching that information. In most cases, the directly identifying information is hashed or otherwise obscured before it is matched to any third-party dataset. We may store the identifier in our first-party cookie for our use in online, in-app, and cross-channel advertising and it may be shared with advertising companies to enable interest-based and targeted advertising.

Functional disclosures

In addition to the advertising and marketing purposes described above, we contract with companies or individuals to provide certain services related to the functionality and features of the Service, including payment processing, email and hosting services, software development, shipping and fulfillment, data management, and administration of contests and other promotions. We refer to them as “contractors.” Contractors include our business partners who offer a service to you jointly with us, or who partner with us to provide our services to you.

We may disclose information about you, such as Personal Identifiers, Commercial Information, Internet Activity and Device Information, to contractors as necessary for them to perform their services. Contractors are not permitted to use information about you for any other purpose. In the past twelve (12) months, we have disclosed these types of information to the following types of contractors:

• Analytics providers, namely Google Analytics, Mixpanel and Optimizely, to tell us how the Service is performing for visitors, such as which parts interest visitors and how long they visit before leaving. Among other data, they may receive your IP address. They may also create a unique identifier based on your visit(s).

• Various hosting services and data processors to provide the infrastructure of the Service, such as Cloudflare, which ensure that traffic is from real people, not computers. Among other data, they may receive your IP address but do not collect the content of user communications.

• Cloud storage providers, namely Amazon Redshift, to warehouse and serve data from and about the Service, including information we maintain about you.

• Payment providers, namely Stripe, Inc., to process payments between you and us, such as for subscriptions or products. These providers receive information about your order in order to tie your payment process to your order. We don’t receive all of the information you may provide to them as part of that process (for instance, we don’t receive full payment-account numbers).

• Privacy providers, namely OneTrust, to help us ensure you are informed of your privacy rights on the Service and manage your preferences and consents.

• Support providers, namely Zendesk, to provide assistance to you when you request it. They are able to retrieve information about you that is relevant and necessary to your requests, such as account information and order details.

For legal reasons

Finally, we may disclose personal information:

• In response to subpoenas, court orders, or other legal processes; to establish or exercise our legal rights; to defend against legal claims; or as otherwise required by law. In such cases we reserve the right to raise or waive any legal objection or right available to us;

• When we believe it is appropriate to investigate, prevent, or take action regarding illegal or suspected illegal activities; to protect and defend the rights, property, or safety of our company, our users, or others; and in connection with the enforcement of our Terms and other agreements; or

• In connection with a corporate transaction, such as a divestiture, merger, consolidation, or asset sale, or in the unlikely event of bankruptcy.

With your consent or at your request

We may periodically ask for your consent to disclose your information to third parties. Whenever we ask your consent for this reason, we will summarize the purpose and scope of the disclosure. For example, we may offer discounts to you if you consent to join our mailing list or participate in a promotion involving direct marketing communications.

• When we seek your consent on the Service, a tickbox or disclaimer near an action button (e.g., ‘submit’) will explain that by ticking the box or taking that action, the third party named on the page will receive the information submitted or described.

• To be clear, we only exchange information about you with third parties for direct marketing purposes if you opt in, and will only do so until you opt out.

6. How long we retain your information

We retain your information only as long as we need it for the purposes described under Information we collect & how we use it, except when longer retention is required by our compliance policies and efforts toward applicable legal, tax, accounting and regulatory requirements.

How long we need information for those purposes varies by category, and even within categories. These retention determinations always consider the amount, nature, and sensitivity of the personal information, the potential risk of harm from its unauthorized use or disclosure, whether we can achieve those purposes without using the personal information.

For example, we delete some activity data as soon as you exit the Service, whereas we may retain records of your payments for services and events for several years as required by law or contract, such as agreements with our payment processors or under our accounting standards.

7. Use by minors

The Service is intended for adult users. We do not knowingly collect information from anyone under the age of 16, and we do not share or sell information about anyone under 16 without affirmative authorization. If we learn that we have collected information from a person under age 16, we will delete that information as quickly as possible.

• If you are under 16: Please leave the Service. If you’ve already sent us information, please contact us at [email protected] first so we can delete it.

• If you are a parent or guardian of a person under 16 years of age and you believe that person provided information to us, please contact us at [email protected].

8. How to control your privacy

In General

As a user of the Service, you have rights and choices about your personal information. We want you to be in control of your information, so we want to remind you of the following options and tools available to you:

• Account controls: You can update the personal information in your account through the account settings made available on the Service. Any updated information will be reflected in our records and throughout the Service promptly.

• Content opt-outs: You may opt-out of any newsletters or promotional communications from us by clicking on the “unsubscribe link” provided in such communications. We make every effort to promptly process all unsubscribe requests. You may not opt out of Service-related communications (e.g., account verification, transaction reports/confirmations, administrative updates, technical and security notices, and changes or updates to our services, features, Policy, and Terms).

• Exercising rights: If any of the local privacy laws listed below apply to you, see Requesting information to exercise your rights. These rights are provided only to human account holders, and are not available to employers or other legal entities, except as required by law.

• Disallowing location data collection: We do not collect your precise geolocation, but we will receive or infer your general location from your browser, device or the origin of your web requests. Most browsers and devices offer location sharing controls, which may be configurable on a domain-by-domain basis.

• Tracking Technology & Cookies. We use OneTrust to allow users to consent to or reject cookies and certain other tracking, “selling”, or “sharing” of your data. You may also turn off select tracking software and cookies that have been placed on your computer by following the instructions on your browser. On a mobile device, you may turn off select mobile trackers through your mobile device settings. However, if you prevent the use of tracking technology and cookies on your computer or mobile device, it will affect the availability and functionality of our Platform.

• Browser and third party platform controls:

  • Ad Choices: To find out more about third-party targeted advertising networks and similar entities that use these technologies, see https://youradchoices.com/. To opt-out of certain providers’ use of such technologies please visit https://optout.aboutads.info/?c=2&lang=EN or the AppChoices app to opt out on mobile.

  • Global Privacy Control: Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out of data "sales" or “sharing” as defined under applicable laws. When the Service detects such a signal, we will respect your choices indicated by a GPC setting as required by applicable law. The Service’s GPC processing is facilitated by our privacy provider.

  • Do Not Track: Unlike the GPC described above, there is no common understanding of how to interpret a Do Not Track signal; therefore, our websites do not respond to browser DNT signals.

  • Email Web Beacons: Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.

International Data Transfers

If you reside outside the United States, we transfer information about you for processing in the United States. By providing your information to us, you consent to the processing of the information in the United States. The transfer of this information to the United States is necessary for the performance of our contract for use of the Service.

When we transfer personal data subject to GDPR outside of The Information, we use standard contract clauses approved by the EU for this purpose, or another appropriate transfer mechanism.

Note that U.S. law is not equivalent to laws in other countries, such as GDPR in Europe or PIPEDA in Canada. As of the Last Updated date, the U.S. has not been deemed an ‘adequate’ jurisdiction under GDPR for the purposes of international data transfers. However, the EU and the U.S. are negotiating the terms of an adequacy determination that may go into effect in the years to come.

Requesting information

Submitting requests

To exercise any rights described in this Policy, please contact us or use our webform (when available). Your request must:

• provide sufficient information to identify you and the law that applies to you, such as your name, e-mail address, home or work address, or other information we maintain.

• not include social security numbers, driver’s license numbers, third-party account numbers, credit or debit card numbers, or health information.

Verifying requests

We verify requests by first confirming the source of the request and then by matching the information submitted to the information we maintain. If your request is unclear or we are unable to authenticate your identity, we will respond with direction on how to remedy the deficiencies, in accordance with law that applies to you.

If we cannot verify the identity of the individual making the request, we may deny it, in full or in part.

Responses to requests

We will respond to your request as quickly as we can, taking into account the nature of your request and the volume of pending requests. The content of our response will vary with the nature of your request, but will always respond in accordance with any deadlines or requirements specified by the laws that applies to you.

Under certain circumstances, we may be unable to provide responsive personal information, such as when disclosure would create a substantial, articulable and unreasonable risk to the security of the information, customers’ account with us, or the security of our systems or networks. We do not disclose account passwords or any other non-personal information that enables access to an account.

Please understand, however, that we reserve the right to retain an archive of any deleted information, to the extent permitted by law. We may also retain deidentified or aggregate data derived from information about you.

Appealing decisions

Residents of California, Colorado, Connecticut, and Virginia may appeal a decision we have made regarding their requests by contacting us or using our webform (when available).

9. Information about local privacy laws

The Service operates from the United States, but this Policy applies worldwide. Our practices generally do not differ based on your location, but your rights and choices depend in part on the law where you live.

If any of these local privacy laws apply to you, that section overrides any contrary descriptions elsewhere in the Policy as they relate to you. If you have questions about your rights under other data privacy laws, please contact us or use our webform (when available).

EU, UK and Switzerland

Overview: As described in the How to control your privacy section of this Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in the European Union and Switzerland are afforded the right to certain additional information with respect to their personal information under the GDPR. If you reside in any of those jurisdictions, this section applies to you.

Data retention and destruction: We retain personal information until we determine it is no longer needed for the processing purposes for which we collected or retained it, or for as long as required for legal compliance.

Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in the European Union and Switzerland have additional rights that you can exercise by contacting us. Those rights include:

• Right of access to your personal data

• Right to rectify your personal data if they are incorrect

• Right to erase your personal data

• Right to limit the processing of your personal data

• Right to the portability of your personal data

• Right to object to the processing of your personal data

• Right to withdraw consent (withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal)

Additionally, you may contact The Information’s Data Privacy Officer by emailing [email protected] or using our webform (when available).

United States

The Service is designed to adhere to the principles set forth in the U.S. Video Privacy Protection Act (VPPA), namely to prevent the nonconsensual disclosure of information that identifies you and video you watch to third parties. However, please note that certain parts of the Service embed Outside Materials, which may directly collect information that identify you and video you watch.

Except as otherwise stated in this Policy or as required by law, we do not disclose personally identifiable information related to your video viewing activities to third parties without your express consent. You acknowledge, however, that we may disclose viewing activity in deidentified form, and we may disclose information the VPPA allows to be disclosed without express consent.

Users in Certain U.S. States

Overview: As described in the “How to control your privacy" section of the Policy, all our users have control over their information and can limit what data we process. If you are a resident of California, Colorado, Connecticut, Utah, Virginia or another state with a similar data-privacy law, you may have additional rights that you (or, in certain states, an authorized agent acting on your behalf) can exercise by contacting us, including the right to:

• More information about the categories and specific pieces of personal information we have collected and disclosed for a business purpose in the last 12 months

• Access and/or receive a copy of certain personal information we hold about you

• Correct your personal information

• Delete certain personal information we hold about you

• Receive information about the financial incentives that we offer to you, if any

• Opt out of the processing your personal information for purposes of profiling in furtherance of decisions that produce legal or similarly significant effects, if applicable

You also have the right to not be discriminated against for exercising your rights. You may also have the right to opt out of “sales” of your information and “sharing/processing of your information for targeted advertising.”

Certain information may be exempt from the requests above under applicable law. For example, we need to retain certain information in order to provide our services to you. We also need to take reasonable steps to verify your identity before responding to a request. If you are an authorized agent submitting a request on a user’s behalf (where permitted), we may require proof of your written authorization before processing the request. Depending on applicable law, you may have the right to appeal our decision to deny your request.

If you have any questions about these rights, wish to exercise them, or request an appeal, please reach out to us at [email protected] or via our webform (when available).

California users

In addition to the rights described above, consumers residing in California are afforded the right to certain additional information with respect to their personal information under the California Consumer Privacy Act (“CCPA”). If you are a California resident, this section applies to you.

We collect the following categories of personal information: identifiers (such as your username, the email address you used to sign up, and your phone number if you’ve chosen to provide it); commercial information (a record of what you’ve bought from The Information, if anything); financial data (payment information and your history of purchases from The Information); internet or other network information (how you interact with the services); location information (because your IP address may indicate your general location); inference data about you (for example, what content you may be interested in); and other information that identifies or can be reasonably associated with you. For more information about what we collect and the sources of such collection, please see Information we collect & why we process it above. To the extent we collect or use sensitive personal information as defined by law (such as the CCPA), we do so in accordance with applicable legal requirements, and we only use or disclose it for purposes for which the CCPA does not provide a right to limit.

• We “share” and sell personal information: As described under Our disclosures of personal information above.

• Why we collect personal information: We collect personal information for the business and commercial purposes described in Information we collect & why we process it above.

• Disclosure of personal information: We may share your personal information with third parties as described in Our disclosures of information to others above. We disclose the categories of personal information mentioned in that section for business or commercial purposes.

• Data retention: We retain personal information as described in How long we retain your information above.

California’s “Shine the Light” law gives residents of California the right under certain circumstances to request information from us regarding the manner in which we share certain categories of personal information (as defined in the Shine the Light law) with third parties, as defined under applicable law, for their direct marketing purposes. We only share your personal information with third-parties for their own direct marketing purposes with your consent and, if you have consented, only until you withdraw your consent.

Brazil

Overview: As described in the How to control your privacy section of this Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in Brazil are afforded the right to certain additional information with respect to their personal information under the Lei Geral de Proteção de Dados (LGPD). If you are a Brazilian resident, this section applies to you.

Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in Brazil have additional rights that you can exercise by contacting us. Those rights include:

• Right of access to your personal data

• Right to rectify your personal data if it is incorrect

• Right to erase your personal data

• Right to limit the processing of your personal data

• Right to the portability of your personal data

• Right to object to the processing of your personal data

• Right to withdraw consent (withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal)

• Right to the review of decisions based on the processing of personal data carried out exclusively by automated means

Questions or concerns about your privacy? You can email us at [email protected] or use our webform (when available).

Canada

Overview: As described in the How to control your privacy section of this Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in Canada are afforded the right to certain additional information with respect to their personal information under the Personal Information and Electronic Documents Act (PIPEDA). If you are a Canadian resident, this section applies to you.

Exercising your rights: Users in Canada have additional rights that you can exercise by contacting us. Those rights include:

• Right of access to your personal data

• Right to rectify your personal data if they are incorrect

• Right to withdraw consent (withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal)

• Right to file a complaint regarding the processing of your personal data with the Office of the Privacy Commissioner of Canada

Additionally, you may contact The Information’s Data Privacy Officer by emailing [email protected] or using our webform (when available).

Republic of Korea

Overview: As described in the How to control your privacy section of this Policy, all our users have control over their information and can limit what data we process. In addition to these rights, users residing in the Republic of Korea are afforded the right to certain additional information with respect to their personal information under the Personal Information Protection Act. If you are a Republic of Korea resident, this section applies to you.

Data retention and destruction: We retain personal information until we determine it is no longer needed for the processing purposes for which we collected or retain it or for legal compliance.

Exercising your rights: All our users have control over their information and can directly edit or delete information from their account and limit what data we process. Users in the Republic of Korea have additional rights that you can exercise by contacting us. Those rights include:

• Right of access to your personal data

• Right to rectify your personal data if they are incorrect

• Right to erase your personal data

• Right to limit the processing of your personal data

• Right to the portability of your personal data

• Right to object to the processing of your personal data

• Right to withdraw consent (withdrawing consent does not affect the lawfulness of processing based on consent before withdrawal)

Additionally, you may contact The Information’s Data Privacy Officer by emailing [email protected] or using our webform (when available).