LHK Media

LHK Media is committed to protecting your personal data. This privacy policy (“Privacy Policy”) governs LHK Media’s use of data collected by us, including any and all personal data. Personal data is information that relates to you and may identify you as an individual. We use your personal data in line with all applicable laws. To ensure compliance and to align with LHK Media’s values around trust and transparency we have a team of privacy champions responsible for continuously implementing our global privacy program.

1. Who we are, What we do, How you can contact LHK Media, our DPO or the relevant authorities

Who we are:

This privacy policy applies to LHK Media Inc., a Delaware, USA corporation with headquarters in New York; and its affiliated subsidiaries (collectively, “LHK Media,” or “we“, “us“, “our“). We operate in various offices around the world and we partner with publishers and marketers across the globe.

Please note that LHK Medias’ subsidiary Zemanta Inc has a separate Privacy Policy, which can be found here.

What we do:

LHK Media’s mission is to serve interesting recommendations to you based on what we believe are your interests. To achieve our mission we enter into agreements with:

online publishers and partners who want to recommend relevant content to their readers (this is LHK Media Engage);
advertisers who want readers to view their content (this is LHK Media Amplify); and
third party partners who help us serve relevant recommendations.

For further information on our Amplify (advertiser) services see here and our Engage (publisher) services see here.

How to contact us:

We regularly review our compliance with this Privacy Policy. Questions, comments and requests regarding this Privacy Policy are welcomed and should be addressed in the first instance to [email protected] or by mail to LHK Media Inc., 111 West 19th Street, 3rd Floor, New York, NY 10011, USA, Attn: Privacy Questions.

If LHK Media does not satisfactorily answer your questions or concerns, you may also contact the following for advice, support or complaints:

LHK Media’s Data Protection Officer (“DPO”) at [email protected] ; and/or
the Information Commissioner’s Office, which is LHK Media’s lead supervisory authority within the European Territories.

2. Alliances and Adherence

We adhere to the Self-Regulatory Principles set forth by the Digital Advertising Alliance (DAA) and the European Interactive Digital Advertising Alliance (EDAA);
We are members in good standing of the Network Advertising Initiative (NAI), an association dedicated to responsible data collection and its use for digital advertising. We also adhere to the NAI Code of Conduct for Web and Mobile. LHK Media also adheres to the Interactive Advertising Bureau’s (IAB) Self-Regulatory Principles for Online Behavioral Advertising, and the IAB Europe OBA Framework; and
We are also TAG Brand Safety Certified here.

3. LHK Media User Types (including Opt Out Options)

Much of this Privacy Policy is divided into sections based on the way you may interact with LHK Media. You are either a Site Visitor, a User and/or a Business Partner (as defined below). Please determine what user type you are. For each user type we’ve explained what information we collect and why, what cookies and other similar technologies we use, how we share such information and your rights.

Site Visitors: You are a Site Visitor when you visit and interact with our web sites, web pages, interactive features, blogs and their respective contents at lhkmedia.in (“Our Sites“).

See more here.

(a) What information we collect and why

We want to understand what services on Our Sites interest you and we want to remind you about the services we offer when you are not on Our Sites. In order to do this, we collect the following information from your device: (i) IP address; (ii) User Agent data: device type (e.g., iPhone), browser type (e.g., Chrome), operating system (e.g., iOS); (iii) the pages visited on Our Sites (e.g., the LHK Media “About” page); (iv) the time of visit (and corresponding time zone); and (v) referring URLs and other information normally transmitted in HTTP requests (e.g. information telling us how you arrived on Our Sites).

In addition, we may also collect your name and email address if you agree to send your details to us via Our Sites (e.g., by signing up to receive our newsletter).

(b) What cookies and other similar technologies we use

Please see this Cookie Table, which is updated from time to time, under the section “Site Visitors” for a detailed list of first and third party cookies (and their corresponding retention periods) that may be used when you visit Our Sites.

(c) How we may share information

Sharing Information we learn about you on Our Sites

We do not sell and/or share personal data about you with third parties for third party marketing or advertising purposes. We may use various third parties (each listed on the Cookie Table) to help us market or advertise to you. We require that these third parties and companies agree to comply with all applicable data protection laws, keep all information shared with them confidential and to use the information only to perform their obligations to us. We do this by entering into agreements with all third parties who process personal data. If you post on our blog, your comment and information will be publicly available. Please contact [email protected] to remove your comment.

Using Third Party Services on Our Sites

Our Sites contain links to other websites that we do not own or operate. We do not control, recommend or endorse the content, products, services, privacy policies or practices of these third party websites. For example, on Our Sites you will notice clickable icons which take you to the LHK Media Facebook page or the LHK Media LinkedIn page. If you choose to click on these links, you should know that these sites are not owned or operated by LHK Media and therefore these third party websites may send their own cookies to your device and they may independently collect personal data. It is therefore important that you get familiar with the privacy policies of these third party websites.

Also see the Sharing section of this Privacy Policy.

(d) Your rights

Our Terms of Use govern your use of Our Sites and apply to you when you interact with Our Sites. You can stop using Our Sites at any time. If you do, you may also want to remove any cookies that we have placed on any device used to access Our Sites, you can do this via your browser. If during your use of Our Sites you provided your email address, any email you receive from LHK Media includes an “unsubscribe” option. In addition, you may also opt-out of direct marketing by emailing [email protected].

For Site Visitors in the European Territory, LHK Media has implemented a consent management platform (powered by OneTrust) on Our Sites that provides you with the opportunity to consent, or not consent, to cookies and similar tracking technologies. Upon accessing Our Sites, you will see a banner in the centre of the page with information about the cookies we use. You may click the banner to reject any cookies (for example, performance cookies or targeting cookies) that are not strictly necessary cookies (as defined in the Cookie Table). By pressing “I Accept” on the banner you are indicating your acceptance to cookies and similar tracking technologies. LHK Media’s lawful basis for processing personal data of European Territory Site Visitors on Our Sites is consent. In respect of all other Site Visitors not located in European Territories, we rely on our legitimate interest for processing any personal data however, this does not preclude non-European Territory Site Visitors from withdrawing consent at any time via our consent management platform.

Users: You are a User when you visit a page of a website or application of one of LHK Media’s partners where the LHK Media widget is installed or our recommendations are placed (“Partner Sites”). For example, if you visit https://news.sky.com/uk, www.spiegel.de or www.cnn.com, the LHK Media widget is implemented on those websites. You know you are engaging with an LHK Media widget when you see text referencing LHK Media (e.g., “Recommended by LHK Media”, “by LHK Media” near recommendations If you click on the hyperlinked reference to LHK Media you will see a detailed notice that enables you to navigate to LHK Media’s Interest Portal and this Privacy Policy where you can opt out of personalized recommendations. In some instances, a partner may have white-label LHK Media’s service for their own offering. In such an event, such partners must disclose their use of LHK Media in their privacy policies.

Example of an LHK Media Widget

See more here.

(a) What information we collect and why

We use UUIDs, IP Address and other Usage Information so that we can serve interesting recommendations. LHK Media’s recommendations may be paid for by an advertiser linking you to a new website or they may be organic such that the link is to another page on the same Partner’s Site. LHK Media may use high-level health interest categories to serve recommendations, that you can find here.

UUID

When you, as a User, first visit a Partner Site (e.g., CNN.com), LHK Media drops a cookie on your device in order to generate a UUID. Alternatively, if you first interact with a Partner using that Partner’s application, LHK Media receives your advertiser ID which is assigned to you by your device. We catalogue and analyze the content you consume across Partner Sites. Our recommendations are based on: (i) a UUIDs browsing history; (ii) similar browsing patterns of other Users; (iii) recommendations that are generally popular with LHK Media’s audience at this time; (iv) some randomness, and (v) targeting requirements that may be provided or requested by our Amplify clients. As an example, LHK Media may know that UUID 123 (which could be you on your iPhone X on The Guardian using Chrome as your browser) likes to read about far away holiday destinations and that people who like to read about far away holiday destinations also like to read about exotic food. When you interact with LHK Media we do not collect traditional personal data from you, like your email address or name, therefore we cannot associate your name with your UUID (for example, we do not know that John Smith, who is also UUID 123, likes to read about far away holiday destinations).

The UUID is a sequence of numbers and/or letters. This UUID attaches itself to your device and varies depending on your browser combination. In other words, LHK Media records a different UUID depending on which device and/or which browser you use when accessing the Partner Sites. For example, you will have one UUID when you visit a Partner Site from your mobile phone using the browser Safari, and a different UUID when you visit a Partner Site from your iPad using the browser Safari. LHK Media will combine and consolidate a UUID from a mobile device (handheld or tablet) from a browser that then accesses an application (or vice versa) from that same device. LHK Media does not conduct cross device tracking and therefore cannot link a user interacting with LHK Media on their phone as the same user who is interacting with LHK Media on their desktop.

IP Address

In addition to your UUID, we recognise your IP address, which we translate into geolocation and delete the last octet in order to mask the identifying information. We then use this masked information, in conjunction with information we received from other trusted third party partners (such as MaxMind) to determine a broad understanding of where you are located (e.g., New York). LHK Media will still recognise your IP address even if you opt out of personalised tracking as this is necessary to continue serving you context-based recommendations however, in such instances your IP address is not associated with your UUID and would not form part of any user profile.

Other Usage Information

In addition to your UUID and IP address, we also collect the following information from you on (a) desktop and mobile web: (i) User Agent data: device type (e.g., iPhone), browser type (e.g., chrome), operating system (e.g. iOS); (ii) the pages visited; (iii) the time of visit; and (iv) referring URLs and other information normally transmitted in HTTP requests. The above statistical information provides us with information about how many Users visited a specific page on our Partner Sites on which the LHK Media widget is installed, how long each User stayed on that page, the type of content on that page they clicked on and how they generally engaged with that page; and (b) on applications (i) application version (as it appears in App Store or Play Store); (ii) application ID or package name (as it appears in the App Store or Play Store); (iii) operating system ( e.g. IOS or Android); (iii) operating system version; and (iv) device model (e.g. iPhone X).This information is considered personal data if LHK Media associates it with a UUID.

As LHK Media does not have a direct relationship with Users interacting with Partner Sites, LHK Media relies on its partners to determine the lawful basis upon which LHK Media can process personal data. Each partner site relies on either

(b) What cookies and other similar technologies we use

LHK Media cookies

Please see the Cookie Table under “Users” for a detailed list of the First Party Cookies we use when you interact with Partner Sites where the LHK Media technology is implemented.

LHK Media pixels

In addition to LHK Media’s visible widget on Partner Sites, certain LHK Media advertisers may implement the LHK Media pixel on their websites. The LHK Media pixel determines whether the User reaching the page where the pixel is installed has an LHK Media UUID in order to provide reporting to advertisers in respect of their particular campaign. If there is a UUID associated with such end user, LHK Media allows advertisers to either retarget those UUIDs and/or provides advertisers with the total number of Users (on an aggregated and anonymised basis) that reached a particular page (for example, an advertiser does not know that UUID1234 converted but only that 1 conversion took place). LHK Media does not pass its advertisers any personal data (including your UUID) or collect any further personal data via the pixel. LHK Media does not combine information received from the LHK Media pixel information with a UUID’s profile (for example, LHK Media only tracks that 1 conversion has taken place and not the UUID123 has converted when it reaches the advertiser’s chosen page). We require advertisers to disclose the usage of the LHK Media pixel on their own websites.LHK Media may also allow certain trusted third party partners to collect data via cookies delivered through the LHK Media widget. In such cases, LHK Media does not pass these third parties the data which LHK Media collects on its Users but allows such third parties to directly collect data (including personal data) via the widget for fraud and/or security purposes or in order to provide measurement information to advertisers (such as the number of conversions and/or impressions). Any such collection shall be governed by such third parties privacy policy.

Third party pixels

If you click on a link to one of our recommendations, the advertiser sponsoring the recommendation may place cookies (or third party cookies of third parties acting on the advertiser’s behalf) on your device either through redirects prior to arriving on the destination page of the recommendations or upon reaching the destination page. Such cookies are dropped for the purposes of providing analytics to the advertiser with regards to the advertiser’s campaign (for example, to see how many users viewed the advertiser’s campaign). We require our advertisers to disclose the use of third party pixels and/or cookies to end users via their website. As these cookies and/or pixels are added at the sole discretion of our advertisers you will be subject to that advertiser’s privacy notice and/or privacy policy.

(c) How we may share information

Our Partners

LHK Media does not share and/or sell a User’s entire profiles with any third parties. However, we may share certain elements of a user profile (for example, UUID) with the following partners, including:

Brand safety, analytics and fraud partners;
Demand Side Platforms (DSP) and Supply Side Platforms (SSP);
Ad Exchanges and/or Networks; and
Demand Management Platforms.

Please see here for a list of some of our trusted partners. In addition, we may collect and/ or share some personal data with trusted partners by virtue of participating in the OpenRTB. Many of these partners are registered as IAB TCF Global Vendors and can be found here.

(d) Your rights

LHK Media opt out on desktop and mobile web

You may opt out of LHK Media’s personalized recommendations (or, if you have opted out and would like to opt back in) at any time by moving the toggle below. You may also opt out of personalized recommendations via LHK Media’s Interest Profile which is a website that provides a general visualization of the data LHK Media knows about you and may use to make its recommendations.

LHK Media opt out on apps

In order to opt-out of LHK Media’s recommendations on your mobile applications you can follow the steps below:

iOS Devices: Settings > Privacy > Advertising > Limit Ad Tracking
Android Devices: Google Settings App > Ads > Opt Out of Interest-based Advertising

Please note that an opt out via our Interest Profile and/or this Privacy Policy will not opt you out of personalised tracking on your applications. This opt out must be done via your device settings.

Additional Opt-Out Options

You may also opt out of receiving personalized ads served by us or other advertising companies through industry powered tools such as the NAI or the various DAA-based pages (DAA, http://www.aboutads.info/choices; DAAC, www.youradchoices.ca/choices , and/or EDAA www.youronlinechoices.eu). Visiting the NAI, DAA, DAAC, or EDAA consumer choice pages allows you to opt out of all some or all of the participating members’ services. Like LHK Media’s opt out, these opt outs do not mean you will no longer receive any advertising, the advertisements will just not be tailored to you. You will continue to receive advertisements, for example, based on the particular website that you are viewing (i.e., contextually based ads). Also, if your browsers are configured to reject cookies when you visit the DAA, DAAC or EDAA consumer choice pages, your opt out may not be effective as our opt out is cookie based.

IMPORTANT INFORMATION

Even though you have opted out of LHK Media’s personalised recommendations:

You will still see LHK Media recommendations. Opting out of LHK Media personalization tracking does not mean you will no longer receive recommendations from LHK Media. Instead, it means that LHK Media’s recommendations will not be personalized (i.e. they will be context based recommendations).
Your opt out will be cookie based and device/browser specific. If you browse the web from several devices and/or browsers, you will need to opt out from each device and/or browser to ensure that we prevent personalization tracking on all of them. For the same reason, if you buy a new device, change browsers or delete (or clear) the opt out cookie, you will need to opt-out again. Opting out of personalization tracking is not the same as blocking cookies.
You must not opt in to LHK Media for at least 21 days as the deletion of your profile is tied to your UUID. Your opt out from LHK Media’s personalized recommendations is effective immediately. However, if your browser permits local storage and you opt into LHK Media’s personalized recommendations (for example, by accepting a cookie banner) within 21 days of your opt out, it is possible your prior profile will be reconnected to your UUID. If you do not opt in within 21 days, your profile will be deleted and cannot be recovered.
As with most opt out cookies, the LHK Media browser opt out relies upon a cookie. The opt-out cookie is intended to be persistent to honor the user’s preferences. However, the “Intelligent Tracking Prevention” feature in iOS11 may impact the persistence of cookies across websites post a 24 hour window. We suggest using another browser or considering blocking all 3rd party cookies from the browser so that you are “opted out” without needing to rely on any company’s actual opt out methodology.
Your local storage will not be cleared. Even though you have opted out of LHK Media’s personalised recommendations your local storage will not be automatically cleared and therefore you need to clear this at a browser level in addition to your opt out.

Business Partners: You are a Business Partner when you register (or email with LHK Media) on behalf of the company you work for to use the LHK Media Amplify or LHK Media Engage Services.

See more here.

(a) What information we collect and why

You may provide certain personal data (such as email address) when you sign up for the Amplify or Engage services or otherwise communicate or interact with us. If you apply to become a Business Partner, we may request additional information from you via advertiser application forms, insertion orders and other forms. We automatically collect information about your username’s actions in the LHK Media dashboard. As an example, as an Amplify Business Partner if you change the cost-per-click for one your campaigns, LHK Media’s audit trail will have a record of all those actions.

We collect and process the personal data above in order to perform our obligations under our agreement as a Business Partner (or prospective Business Partner) with you including to:

respond to your questions and requests;
to provide you with access to certain functions and features of our Amplify or Engage services (e.g., to provide and maintain your dashboard account);
verify your identity; and
communicate with you about your account, our products, and available promotions relevant to your use of the Amplify or Engage service.

(b) What cookies and other similar technologies we use

Please see this Cookie Table under “Business Partners” for a detailed list of First and Third Party cookies (and their corresponding retention periods) we use with Business Partners.

(c) How we may share information with anyone

We may disclose certain Business Partner information to vendors, contractors, or others who assist LHK Media in delivering the services (e.g., credit card processing). Also see the Sharing section of this Privacy Policy.

(d) Your rights

If as a Business Partner you wish to verify, correct, update or request the deactivation of your information, you may go to the LHK Media dashboard in order to edit your profile preferences or contact us at [email protected]. If you are receiving LHK Media emails, you may “unsubscribe” using a link in the email. Note that unsubscribing shall not opt you out of notifications critical to providing the Amplify or Engage services (e.g., email invoices).

(e) Lawful Basis

LHK Media’s lawful basis for processing personal data of Business Partners is contractual.

4. Security Measures, Transfers Outside the EEA, Sharing and Data Retention

Security

LHK Media has a dedicated security team. We maintain tight controls over the personal data we collect, retaining it in firewalled and secured databases with strictly limited and controlled access rights, to ensure it is secure. Please see our security standards for more information.

Business Partners have access to certain password-protected features of the Amplify or Engage service. Business Partners are responsible for keeping this password confidential and for ensuring the same for their employees and/or their agents. Please remember that, unfortunately, the transmission of information via the internet is never completely secure. A common Internet scam is known as “spoofing” or “phishing.” This occurs when you receive an email from what appears to be a legitimate source requesting personal data from you. Please be aware that we will not send you any emails requesting you to verify credit card, bank information, or any other personal data. If you ever receive an email that appears to be from us requesting such information from you, do not respond to it, and do not click on any links appearing in the email. Instead, please forward the email to us at [email protected], as we will investigate instances of possible Internet fraud.

Data Transfers Outside the EU/EEA

When we transfer personal data from the European Economic Area (EEA) we will ensure such transfers are in compliance with relevant data protection laws, including, if applicable, EU Standard Contractual Clauses, or a European Commission positive adequacy decision under Article 25(6) of Directive 95/46/EC or Article 45 of the GDPR. In other words, your rights and protections remain with your data and we used approved contractual clauses and other measures designed to ensure that the recipients of your personal data protect it. LHK Media has in place the Standard Contractual Clauses between LHK Media entities to govern the transfer of data outside of the EEA.

Sharing

In addition to the description of how we may disclose your personal data for each user type, we may also disclose personal data as follows:

Within the family of companies controlled by LHK Media for internal reasons, primarily for business and operational purposes;
If we go through a business transition, such as a merger, acquisition by another company, or sale of all or a portion of our assets, your personal data will likely be among the assets transferred;
When legally required to do so (e.g., to cooperate with law enforcement investigations or other legal proceedings); and/or
To respond to a genuine emergency.

In addition, we combine your personal data with those of other users in order to share trend information and aggregate user statistics with third parties, always in aggregated and anonymized form.

Data Retention

The retention period for each of the cookies LHK Media uses (whether our own or on our behalf by third parties) is stated in the Cookie Table. More specifically, the LHK Media cookie (Obuid),which is used for tracking user actions such as clicks, expires three (3) months after a user visited a particular site within our network however, this cookie will reset if a user returns to the same site or different site within our network. In addition, we do not retain any individual data point on a User for more than 13 months. For example, if UUID 123 read an article on December 31, 2018, on February 1, 2019 that article will no longer be part of UUID 123’s profile. LHK Media also maintains a Data Retention Policy that details the retention period for personal data based on our analysis of how long the specific data is reasonably required for legal or business purposes. When we no longer need personal data, we securely delete or destroy it. Aggregated data, which cannot identify a device/browser (or individual) and is used for purposes of reporting and analysis, is maintained for as long as commercially necessary.

5. Children and Sensitive Data

Children

None of our services are intentionally directed at children under 16. We do not knowingly collect personal data from anyone under 16 years of age. If we determine upon collection that a Site Visitor, a User or a Business Partner is under 16, we will not use or maintain his/her personal data. If we become aware that we have unknowingly collected personal data from a child under the age of 16, we will make reasonable efforts to delete such information from our records. If you’re a kid, please go play in the yard, don’t use or interact with LHK Media!

Sensitive data

We do not collect or receive any sensitive categories of personal data.

6. European Territory Visitors

In compliance with certain privacy laws, in particular the European General Data Protection Regulation (GDPR), LHK Media provides specific additional rights for individuals who interact with LHK Media such as the right to access, rectification, right to object, to complaint, erasure and blockage. More specifically and under certain circumstances:

the right to request information about whether and which personal data is processed by us, and the right to demand that personal data is rectified or amended.
the right to request that personal data should be deleted.
the right to demand that the processing of personal data should be restricted.
withdraw your consent to the processing and use of your data completely or partially at any time with future application.
have the right to obtain your personal data in a common, structured and mechanically readable format.
contact our data protection officer if there are any questions, comments, complaints or requests in connection with our statement on data protection and the processing of your personal data.
the right to complain to the responsible supervisory authority if believed that the processing of your personal data is in violation of the legislation.

In addition to the above, we reference certain rights for European Territory citizens throughout this Privacy Policy. Pursuant to the GDPR, citizens from “European Territories” mean the European Economic Area (EEA), the European Free Trade Area (EFTA) and Switzerland. For the purpose of this Privacy Policy, the term “European Territories” shall continue to include the United Kingdom, even after the United Kingdom leaves the European Economic Area following Brexit. If you are in the UK, or the European Economic Areas, the controller of your data is LHK Media UK Limited.

Please email [email protected] with any questions about exercising any of the above rights.

7. California Privacy Rights

This section applies only to California residents. It describes how we collect, use and share Personal Information of California residents in operating our business, and their rights with respect to that Personal Information. For purposes of this section, “ Personal Information” has the meaning given in the California Consumer Privacy Act of 2018 (“ CCPA”) but does not include information exempted from the scope of the CCPA.

(a) Your California privacy rights.

As a California resident, you have the rights listed below. However, these rights are not absolute, and in certain cases we may decline your request as permitted by law.

Information. You can request the following information about how we have collected and used your Personal Information during the past 12 months:
- The categories of Personal Information that we have collected.
- The categories of sources from which we collected Personal Information.
- The business or commercial purpose for collecting and/or selling Personal Information.
- The categories of third parties with whom we share Personal Information.
- Whether we have disclosed your Personal Information for a business purpose, and if so, the categories of Personal Information received by each category of third party recipient.
- Whether we’ve sold your Personal Information, and if so, the categories of Personal Information received by each category of third party recipient.
Access. You can request a copy of the Personal Information that we have collected about you during the past 12 months.
Deletion. You can ask us to delete the Personal Information that we have collected from you.
Opt-out of sales. If we sell your Personal Information, you can opt-out. In addition, if you direct us not to sell your Personal Information, we will consider it a request pursuant to California’s “Shine the Light” law to stop sharing your personal information covered by that law with third parties for their direct marketing purposes.
Opt-in. We contractually prohibit our publishing and advertising clients from placing our technology on pages that target individuals younger than 16 years old. If we learn that you are younger than 16 years old, we will asking for your permission (or if you are younger than 13 years old, your parent or guardian’s permission) to sell your Personal Information before we do so.
Non discrimination. You are entitled to exercise the rights described above free from discrimination. This means that we will not penalize you for exercising your rights by taking actions such as denying you services; increasing the price/rate of services; decreasing service quality; or suggesting that we may penalize you as described above for exercising your rights.

(b) How to exercise your rights

You may exercise your California privacy rights described above as follows:

Right to information, access and deletion. You can request to exercise your information, access and deletion rights by:
- calling us toll free on 1-866-I-OPT-OUT and entering service code 253# to leave us a message.
- emailing [email protected]
Right to opt-out of the “sale” of your Personal Information. We do not sell your Personal Information in the conventional sense (i.e., for money). However, like many companies, we use services that help deliver interest-based ads to you. California law classifies our use of these services as a “sale” of your Personal Information to the companies that provide the services. This is because we allow them to collect information from our website users (e.g., online identifiers and browsing activity) so they can help serve ads more likely to interest you. To opt-out from this “sale”, click on this link which will take you to our Interest Profile where you can opt out of personalised recommendations.

We will need to confirm your identity and California residency to process your requests to exercise your information, access or deletion rights. We cannot process your request if you do not provide us with sufficient detail to allow us to understand and respond to it.

(c) Personal information that we collect, use and share

The chart below summarizes how we collect, use and share Personal Information by reference to the statutory categories specified in the CCPA, and describes our practices during the 12 months preceding the effective date of this Privacy Policy. Categories in the chart refer to the categories described above in the general section of this Privacy Policy.

LHK Media User Type	Statutory category of personal information (PI) (click for details)	Source of the PI	Purpose for collection	How we may share, disclose or “sell” information.
Site Visitors	Identifiers Online Identifiers Geolocation Data Inferences Internet or Network Information	Site Visitor	See Section 2(a) (Site Visitors).	See Section 2(c) (Site Visitors).
Users	Identifiers Online Identifiers Geolocation Data Inferences Internet or Network Information	Users	See Section 2(a) (Users).	See Section 2(c) (Users).
Business Partners	Identifiers Financial Information	Business Partners	See Section 2(a) (Business Partners).	See Section 2(c) (Business Partners).

8. “Do Not Track” Disclosure

Some browsers transmit Do Not Track (DNT) signals to websites. Because there is no common understanding of how to interpret the DNT signal, LHK Media does not currently alter, change, or respond to DNT requests or signals from these browsers. We will continue to monitor industry activity in this area and reassess our DNT practices as necessary. In the meantime, you can use the range of other tools we provide to control data collection and use, including the ability to opt out of receiving personalized recommendations in the Users section.

9. How This Privacy Policy May Change

We may change this Privacy Policy from time to time. We will place a prominent notice that will be visible to you as a Site Visitor or Business Partner, but we do not have a means of advising Users of an update by way of notice. You should check back here periodically to see if the Privacy Policy has been updated as we will always show the date of the latest modification of the Privacy Policy at the top of the page so you can tell when it was last revised.