Last Updated: May, 12, 2023

Introduction

At www.ilitchnewshub.com (“Ilitch News Hub” or “Website”), which is owned and operated by Ilitch Holdings, Inc. (“IHI,” “we,” “us,” or “our”), your privacy is important to us.  This Privacy Policy only applies to Ilitch News Hub and describes how we collect, use, and share personal information collected by Ilitch News Hubs.  In particular, this Privacy Policy describes how we collect, use, and share personal information that we collect in relation to your use of the Website, commercial emails we send, and any interactive features, widgets, plug-ins, applications, content, downloads, and/or other services that we own and control (including those made available through the Website), regardless of how you access or use them, whether via personal computers, mobile devices, or otherwise. 

This Privacy Policy applies only to our online activities and is valid for visitors to our Website with regards to the personal information that is shared with and/or collect by Ilitch News Hub. This Privacy Policy is not applicable to any information collected offline or via channels other than the Website and does not govern the data practices of other IHI entities or third parties that may interact with Ilitch News Hub.

U.S. State-Specific Disclosures:  Certain IHI entities are subject to U.S. state privacy laws which require a more detailed description of data practices.  Our U.S. State Specific Privacy Notice describes those entities’ data practices as required by such laws. If you have additional questions or require more information about our Privacy Policy, do not hesitate to contact us as described in Section 9 (Contact)of this Policy.

1. Personal Information We Collect

The personal information we collect depends on how you interact with the Website.  We collect some personal information when you provide it directly to us, while other information is collected automatically by the Website. 

We collect the information directly from you that you provide through the Website, including first and last name, email address, and telephone number.  If you submit the “Contact Us” form, we will also collect the contents of your message, which may include additional personal information you choose to share. 

In addition to personal information or other information that you choose to submit to us via the Website, we, our service providers, and third-party services may also use a variety of technologies that store or collect certain information when you visit or interact with the Website (“Usage Information”).  This Usage Information may be stored or accessed using a variety of technologies that may be downloaded to your personal computer, browser, laptop, tablet, mobile phone or other device (a “Device”) whenever you visit or interact with the Website. 

This Usage Information includes:

• internet protocol (IP) addresses,
• browser type,
• Internet Service Provider (ISP),
• date and time stamp,
• referring/exit pages, and
• possibly the number of clicks.

These are not linked to any information that is personally identifiable. The purpose of the information is for analyzing trends, administering the site, tracking users' movement on the website, and gathering demographic information.

A. Cookies and Tracking Technologies

We may use various now and later developed methods and technologies to store or collect Usage Information (“Tracking Technologies”). Tracking Technologies may set, change, alter or modify settings or configurations on your Device. Tracking Technologies include:

• Cookies: A cookie is used to store information including visitors' preferences, and the pages on the website that the visitor accessed or visited. The information is used to optimize the users' experience by customizing our web page content based on visitors' browser type and/or other information.

• Web Beacons:  A web beacon is a small graphic image or other web programming code (also known as “1x1 GIFs” or “clear GIFs”) that may be included on our Website or in our messages.  Web beacons may be invisible to you, but any electronic image or other web programming code inserted into a page or email can act as a web beacon.  Web beacons or similar technologies can be used to count visitors to the Website, to monitor how users navigate the Website, to count how many emails sent were actually opened, or to count how many particular articles or links were actually viewed.

B. Tracking Technologies and Consent

We are giving you notice of the Tracking Technologies and your limited choices regarding them so that your consent is meaningfully informed.  The Website may be limited, and some features may not be available based on what data you elect and/or consent to share with us. 

Regular cookies may generally be disabled or removed by tools that are available as part of most commercial browsers, and in some, but not all, instances can be blocked in the future by selecting certain settings.  Each browser you use will need to be set separately and different browsers offer different functionality and options in this regard.  Also, these tools may not be effective with certain Tracking Technologies.   Please be aware that if you disable or remove these technologies, some parts of the Website may not work and when you revisit the Website, your ability to limit browser-related Tracking Technologies is subject to your browser settings and limitations. 

Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

For information on third party Tracking Technologies and browser Do Not Track signals, see Section 5 (Exercising Preferences).

C. Third-Party Advertisers

Third-party ad servers or ad networks uses technologies like cookies, JavaScript, or Web Beacons that are used in their respective advertisements and links that appear on Ilitch News Hubs, which are sent directly to users' browser. They automatically receive your IP address when this occurs. These technologies are used to measure the effectiveness of their advertising campaigns and/or to personalize the advertising content that you see on websites that you visit.

Note that Ilitch News Hubs has no access to or control over these cookies that are used by third-party advertisers.  Please see the section above for information about how to manage your cookie settings.

Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Service may not work and that when you revisit the Service your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

2. How We Use Personal Information

We may information about you, including your personal information and Usage Information that is subject to this Privacy Policy for any purposes not inconsistent with statements made under this Privacy Policy, or otherwise made by use in writing at the point of collection, and not prohibited by applicable law.  These uses include, without limitation, to:

• provide you with information or services or process transactions that you have requested or agreed to receive, to send you electronic newsletters and push notifications (if you have elected to receive such notifications), to communicate with you about your use of the Website, or to provide you with special offers or promotional materials on behalf of us or third parties;
• respond to any questions, comments, or requests that you have for us or for other customer service purposes;
• enable you to participate in the Website’s features;
• verify your information is active and valid;
• better understand how users access and use the Website, both on an aggregated and individualized basis, in order to improve our Sites and Services and respond to user desires and preferences, and for other research and analytical purposes;
• assist us in determining relevant advertising and to determine the success of our advertising campaigns and to help us determine where to place our ads, including ads placed on other websites;
• contact you regarding your use of the Website and, in our discretion, changes to the Website and/or Website’s policies;
• for purposes disclosed at the time you provide your information;
• for security purposes;
• to comply with legal obligations, as part of our general business operations, and for other business administration purposes;
• where we believe we need to investigate, prevent, or take action if we think someone might be using information for illegal activities, fraud, or in ways that may threaten someone’s safety or violate this Privacy Policy; and
• otherwise to the extent not prohibited by applicable law except to the extent set forth in this Privacy Policy.

3. How and When We Share Information with Third Parties

We may share your personal information, and other information we have collected about you, as disclosed at the time you provide your information and as described below or otherwise to the extent not prohibited by applicable law except to the extent set forth in this Privacy Policy. Any of these transfers may be of local or cross-border nature.

For sake of clarity, if we de-identify data about you, or aggregate it such that it is no longer personal information or other information for which we have an obligation to you based on this Privacy Policy (or a statement made elsewhere on the Service), we may share it with others freely.

A. Marketing

If you elect to receive marketing communications, we may use your personal information to send you marketing communications.  We do not share your personal information that we have collected directly from you on the Website with third parties for those third parties’ direct marketing purposes unless we have given you the ability to choose to consent or withhold consent to such sharing at the time you provide your personal information, in which case we will honor your choice.

B. Your Consent

Your activities on the Website may, by their nature, result in the sharing of your information with third parties and by engaging in these activities you consent to that and further sharing and disclosure to third parties. Such third-party data receipt and collection is subject to the privacy and business practices of that third party, not us.

C. Service Providers

We use third-party service providers to perform certain services on behalf of us or the Website, including hosting the Website, designing and/or operating the Website’s features, tracking the Website’s activities and analytics, detecting, and preventing fraud, and enabling us to send you communications, special offers or perform other administrative services. We may provide these service providers and other third parties with access to personal information, Usage Information, and other user data, to carry out the services they are performing for you or for us. We do not authorize third-party service providers to use your information that we provide to them to send you direct marketing messages other than related to us absent your consent.

D. Protect Our Rights or Rights of Others

To the fullest extent permitted by applicable law, we may also disclose your information if we believe in good faith that doing so is necessary or appropriate: (i) to protect or defend the rights, safety or property of IHI or third parties; (ii) to investigate, prevent, or take action regarding illegal activities, or suspected fraud; (iii) to enforce this Privacy Policy and other applicable agreements and policies; (iv) as evidence in litigation or other proceedings in which we or our franchisees may be involved; and (v) to comply with legal and regulatory obligations and, to the extent not prohibited by applicable law, law enforcement requests. To the fullest extent permitted by applicable law, we have complete discretion in electing to make or not make such disclosures, and to contest or not contest requests for such disclosures, all without notice to you.

E. Affiliates and Business Transfer

We may share your personal information, Usage Information, and other information with our parent, subsidiaries, and affiliates (“Affiliates”), except as specifically set forth in this Privacy Policy or at the point of collection. We also reserve the right to disclose and transfer all such information: (i) to a subsequent owner, co-owner, or operator of the Website or applicable database; or (ii) in connection with a merger, consolidation, restructuring, the sale of substantially all of our interests and/or assets or other corporate change, or a financing, and during the course of any due diligence process (collectively, “Business Transactions”).

4. Third-Party Content and Links

The Website has functionality that allows certain kinds of interactions between the Website and third-party content, web sites, applications, platform, code ((e.g., plug-ins, application programming interfaces (“API”), and software development kits (“SDKs”)), and Tracking Technologies (collectively, “Third-Party Services”).

For example, you may have an option to use your Facebook, Google or other account provided by a Third-Party Service to interact with the Website, including posting information from the Website on the Third-Party Service (or vice versa) (“Social Features”). If we offer and you choose to use Social Features, the Third-Party Service may send personal information about you to us. If so, we will then treat it as personal information under this Privacy Policy since we are collecting it as a result of your accessing of and interaction on the Website. If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Website or by the Third-Party Service that you use, depending on your privacy settings on each. Similarly, if you post information on a Third-Party Service that references the Website (e.g., by using a hashtag associated with us in a tweet or status update), your post may be used on or in connection with the Website or otherwise by us. Also, both we and the third party may have access to certain information about you and your use of the Website and any Third-Party Service.

Third-Party Services may use their own cookies, web beacons, and other Tracking Technologies to independently, collect information about you, including Third-Party Services to which you are directed from the Website, including where you click a link and leave the Website entirely. There are certain websites and other Third-Party Services to which we may link from the Website, which are third-party websites using our name under license but with their own terms and policies, except where we have explicitly linked to this Privacy Policy.

We are not responsible for the data collection and privacy practices employed by, on or through any Third-Party Services, including where may be tracking you with their own Tracking Technologies across multiple sites and may be sharing the results of that tracking with us and/or others. These other sites can choose to associate their Tracking Technologies with you, independently collect your personal information and other data about you, and may or may not have their own published privacy policies.

We may engage and work with these Third-Party Services (as well as Vendors) to serve advertisements on the Website and/or on other online services. Some of these ads may be tailored to your interest based on your browsing of the Website and elsewhere on the Internet, which may include use of precise location and/or Cross-device Data, sometimes referred to as “interest-based advertising” (“Interest-based Advertising”), which may include sending you an ad on another online service after you have left the Service (i.e., “retargeting”). We may use Google Analytics, Adobe Analytics, or other Service Providers for analytics services. These analytics services may use cookies and other Tracking Technologies to help us analyze Website users and how they use the Website. Information generated by these analytics services (e.g., your IP address and other Usage Information) may be transmitted to and stored by these Service Providers on servers in the U.S. (or elsewhere) and these Vendors and/or Third-Party Services may use this information for purposes such as evaluating your use of the Website, compiling statistic reports on the Website’s activity, and providing other services relating to Website activity and other Internet usage. See Section 5 (Exercising Preferences) for more information on your choices regarding these services. We are not responsible for, and make no representations regarding, the policies or business practices of Third-Party Services, including how they collect, use, or share your information. These Third-Party Services may have their own terms of service, privacy policies or other policies and ask you to agree to the same. Be sure to review any available policies before submitting any personally identifiable information to or otherwise interacting with any Third-Party Services.

5. Exercising Preferences

A. Communications

You may cancel or modify our e-mail and other electronic marketing communications you receive from us by following the instructions contained within our electronic communications, including following the instructions provided in emails to click on the unsubscribe link. 

Opting out of certain communications will not affect subsequent subscriptions and, if your opt-out is limited to certain types of electronic communications, the opt-out will be so limited. Subsequent or different subscriptions will be unaffected. Please note that we reserve the right to send you certain communications relating to your account or use of the Website, and administrative and service announcements. These transactional account messages will be unaffected if you choose to opt-out from receiving our marketing communications.

B. Tracking Technologies Generally

Regular cookies may generally be disabled or removed by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. Browsers offer different functionalities and options, so you may need to set them separately. Also, tools from commercial browsers may not be effective with regard to Flash cookies (also known as locally shared objects), HTML5 cookies, or other Tracking Technologies. For information on disabling Flash cookies, go to Adobe’s website http://helpx.adobe.com/flash-player/kb/disable-third-party-local-shared.html. Please be aware that if you disable or remove these technologies, some parts of the Website may not work and that when you revisit the Website your ability to limit browser-based Tracking Technologies is subject to your browser settings and limitations.

Your browser settings may allow you to automatically transmit a “Do Not Track” signal to online services you visit. Note, however, there is no consensus among industry participants as to what “Do Not Track” means in this context. Like many online services, we currently do not alter our practices when we receive a “Do Not Track” signal from a visitor’s browser.  To find out more about “Do Not Track,” you can visit http://www.allaboutdnt.com, but we are not responsible for the completeness or accuracy of this third-party information. Some third parties, however, may offer you choices regarding their Tracking Technologies.  For specific information on some of the choice options offered by third party analytics and advertising providers, see the next section. We may, from time-to-time, and in certain jurisdictions, offer or point you to tools that allow you to exercise certain preferences regarding cookies and other Tracking Technologies associated with the Website, but such tools rely on third parties and third-party information so we do not guaranty that the tools will provide complete and accurate information or be completely effective.

• Browser Settings: Here is where you can find cookie controls for popular browsers:

• Google Chrome
• Firefox
• Internet Explorer
• Edge
• Safari

We do not represent that these third-party tools, programs, or statements are complete or accurate. You will need to do this on each browser that you use to access our Services and clearing cookies on your browser(s) may disable your preference settings. Also, our Services may not function properly or as intended if you block all or even certain cookies. Accordingly, you may want to consider the more limited opt-out choices noted in the next section.

• Mobile Device Settings: You can use mobile device settings to limit mobile tracking technologies and associated activities. For instance, you can adjust or reset the advertising identifiers on your mobile device in the device settings. iOS users can visit Settings > Privacy > Advertising > Reset Advertising Identifier. Android users can visit Google settings > Ads > Reset advertising ID. These controls work much like deleting cookies in a browser—the device is harder to associate with past activity, but tracking may still occur using the new advertising identifier.

• Ad Industry Tools: Some third parties that may collect personal information in association with your use of our online services for advertising, analytics, and other purposes. To learn more about interest-based advertising and additional opt-out choices related to it, please visit AboutAds and National Advertising Initiative. 

Please note, clearing cookies or changing settings may affect your choices and you must opt-out separately via each browser and other device you use. However, opting out does not mean you will stop seeing ads and you may continue to still see interest-based ads. Cookie-enabled opt-out signals may no longer be effective if you delete, block or clear cookies. We are not responsible for the completeness, accuracy or effectiveness of any third-party notices, tools, or choices.

C. Advertising and Analytics Tracking Technologies

Certain companies may participate in the Digital Advertising Alliance (“DAA”) AdChoices Program and may display an Advertising Option Icon for Interest-based Ads that links to an opt-out tool which allows you to exercise certain choices regarding targeting. You can learn more about the DAA AdChoices Program here. In addition, certain advertising networks and exchanges may participate in the Network Advertising Initiative (“NAI”). NAI has developed a tool that allows consumers to opt out of certain Interest-based Ads delivered by NAI members’ ad networks. You can learn more about opting out of such targeted advertising or to use the NAI tool here.  Please be aware that, even if you are able to opt out of certain kinds of Interest-based Ads, you will continue to receive non-targeted ads. Further, opting out of one or more NAI or DAA members only means that those selected members should no longer under the DAA / NAI rules deliver certain targeted ads to you. This will affect services provided by the applicable DAA / NAI members but does not mean you will no longer receive any targeted content and/or ads from non-participating parties. Also, if your browsers are configured to reject cookies when you visit the opt-out page, or you subsequently erase your cookies, use a different Device or web browser(s), or use a non-browser-based method of access, your NAI / DAA browser-based opt-out may not, or may no longer, be effective. IHI is not responsible for the effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs. However, IHI supports the ad industry’s Self-regulatory Principles for Online Behavioral Advertising and expect that ad networks IHI directly engages to serve you Interest-based Ads will do so as well, though IHI cannot guaranty their compliance.

We may also use Google Ad Services. To learn more about the data Google collects and how your data is used by it and to optout of certain Google browser Interest-Based Advertising, please visit here.  For more information about Google’s privacy practices, please visit the Google Ad and content network Privacy Policy.

We are not responsible for effectiveness of, or compliance with, any third-parties’ opt-out options or programs or the accuracy of their statements regarding their programs.

6. Security

We endeavor to incorporate commercially reasonable safeguards to help protect and secure your personal information. However, no data transmission over the Internet, mobile networks, wireless transmission, or electronic storage of information can be guaranteed to be 100% secure. Please note that we cannot ensure the security of any information you transmit to us, and you use the Website and provide us with your information at your own risk.

It is our policy to protect the confidentiality of Social Security numbers in our possession from misuse and improper disclosure by maintaining and enforcing policies and physical and electronic safeguards against misuse and improper disclosure. Unlawful disclosure of Social Security numbers is prohibited, and access to them is limited to personnel who need access to such information to perform their job functions.

7. Children's Information

Another part of our priority is adding protection for children while using the internet. We encourage parents and guardians to observe, participate in, and/or monitor and guide their online activity.

Ilitch News Hubs does not knowingly collect any Personal Identifiable Information from children under the age of 13 that requires parental consent under the Children’s Online Privacy Protection Act (“COPPA”) without such parental consent. If you think that your child provided this kind of information on our website, we strongly encourage you to contact us immediately and we will do our best efforts to promptly remove such information from our records.

8. Updates to Privacy Policy

We reserve the right to change this Privacy Policy at any time. Any changes will be effective immediately upon the posting of the revised Privacy Policy and your use of the Website indicates your consent to the privacy policy posted at the time of use. However, we will not use your previously collected personal information in a manner materially different than represented at the time it was collected without your consent. To the extent any provision of this Privacy Policy is found by a competent tribunal to be invalid or unenforceable, such provision shall be severed to the extent necessary for the remainder to be valid and enforceable.

9. Contact Us

You can contact us regarding this Privacy Policy at NewsHub@IlitchHoldings.com.

Please note that information submitted to the Website via a “contact us”, customer service or other similar function may not receive a response.  We will not use that information so provided to contact you for marketing purposes unrelated to your inquiry unless you agree otherwise.