Privacy Policy

Effective Date: February 7, 2022

Welcome to First Look Institute, Inc., the home of The Intercept, The Intercept Brazil, Field of Vision, Press Freedom Defense Fund (“First Look,” “we,” “our” or “us”). At First Look, we believe in protecting the privacy of our readers, viewers, donors, and candidates for employment and seek to be fully transparent about our data practices.

This Privacy Policy describes the circumstances under which we collect, use, and share information about you through your use of our websites, your attendance at events we produce, and your donations to us (the “Services”).

We encourage you to review The Intercept’s Privacy Philosophy and our Donor Privacy Practices. To the extent there is a conflict between this Privacy Policy and our Privacy Philosophy or Donor Privacy Practices, this Privacy Policy will control.

By using the Services, you acknowledge that you have read and understand this Privacy Policy and that we will collect, use, and disclose your information as set forth below. If you have any questions about this Privacy Policy or our data practices, please contact us as set forth in “Contact Us” below.

1. COLLECTION AND USE OF YOUR INFORMATION

Sources of Information

We, or our Service Providers on our behalf, collect information from the following sources:

· Directly from you, including when you sign up for newsletters, make a donation, communicate with us, leave comments, or apply for a job with us.

· Automatically when you interact with the Services.

· From third party sources and social media that you may use to engage with us.

Information We Collect Directly From You

Below are the circumstances under which we, or our Service Providers on our behalf, collect information from you, the information we collect, and how we use that information.

Newsletters. If you sign-up for our newsletter, we will collect (1) your email address and (2) information relating to your receipt of any newsletters, and (3) actions you took with respect to the newsletters including which particular newsletter you opened, clicked, or otherwise acted on and which links you clicked on in a newsletter. We use this information to:

Send newsletters to your email address;
Send you appeals to support The Intercept by making a donation or becoming a Member; and
Understand how users engage with our newsletters and help us improve content in our newsletters and on the Services.

Donations and Membership. If you donate to First Look, including to support any of our programs such as The Intercept, Field of Vision, or the Press Freedom Defense Fund, we will collect your first and last name, zip code, postal address, email address, donation amount, reason for donating, billing information, and payment card information. We use this information to:

Facilitate your donation or membership including, processing and storing your payment card information through a payment card processor;
Send newsletters, reports, stories, appeals, event invites, event discounts, exclusive offers and thank you letters to your email and/or mailing address;
Provide access to our in-person and online events and membership only content;

Email. If you choose to email us, we will collect information associated with your email, which may include the content therein and information from your device. We may use this information to:

Respond to your email and address your requests;
Improve the Services; and
Prevent and address fraud, breach of policies or terms, and threats or harm.

Note about Confidential Communications. If you want to share confidential information, please read and use Secure Communications as set out here.

Comments. If you leave a comment on any story, feature, or document on the Services, we will collect your name, email address and comment content. We use this information to:

· Understand how users engage with our content and help us improve content on the Services; and

· Contact you for the purposes of newsgathering.

Keep in mind that any information you choose to include in comments can be seen, collected, and used by the public.

Careers. If you click on a job posting listed on the Services, you will be directed to a third-party service’s website, which will collect your first name, last name, email address, phone number resume, cover letter, LinkedIn profile, and website, as well as information from your device. We use this information to:

Evaluate and process your job application; and
Monitor and analyze trends, usage, and activities.

Information We Collect Automatically

We may automatically collect information such as:

· Device connectivity and configuration data, including the type of device you’re using (computer, mobile phone, tablet, etc.), the operating system running on that device, the type and version of browser software you’re using, the resolution of your computer monitor or other device display, and the screen colors available on your device;

· Service use data, including data about the features you use, the pages you visit, the emails you view, the website that referred you, the time of day you browse, and your exiting pages;

· Imprecise location data (e.g., location derived from an IP address or data that indicates a city or postal code level); and

· Device identifiers, including your IP address

Social Media Sharing. If you like or share any stories, features, or documents through a third-party social media service sharing tool available on the Services, we will collect information about you in connection with your post, which may include information from your device. We use this information to:

· Display and manage your post on the Services; and

· Understand how users engage with our content and help us improve content on the Services.

Videos and Podcasts. If you watch any videos or listen to any podcasts through a third-party video or podcast tool available on the Services, we will collect information about you in connection with your use of the third party tool. We use this information to:

Manage that content on the Services;
Understand how users engage with our content and help us improve content on the Services, including any videos and podcasts we develop.

If you access our content using a third party podcast or video player, please review the privacy policy for that service.

Documents. On some pages within the Services, we embed content from third party document services. If you view any content through a third- party document service tool, we will collect information from your device. We use this information to:

Manage the content on the Services; and
Understand how users engage with our content and help us improve content on the Services.

If you access documents using a third-party service your use of the service is subject to the privacy policy of that service. We encourage you to review the Privacy Policy for the document service.

Collection and Use Of Your Information From Other Sources

We may obtain information about you from other sources, and combine such information with information we have collected about you through the Services. To the extent we combine such third-party sourced information with information we have collected about you on the Services, we will treat the combined information in accordance with this Privacy Policy. These third-party sources vary over time, but have included third-party donor partners and publicly available sources.

The Services may embed content from, or link to third party websites, locations, platforms, or services. We are not responsible for and make no representations regarding the policies or business practices of any third parties. Additionally, this Privacy Policy does not apply to these third party’s content or services. We encourage you to familiarize yourself with and consult their privacy policies and terms of use.

Other Uses of the Information We Collect

In addition to the uses of specific data detailed above, we also use the information we collect to:

Send technical notices, updates, security alerts, and policy;
Prevent and address fraud, breach of policies or terms, and threats or harm;
Fulfill any other purpose disclosed to you at the time you provide the information or with your consent; and
Maintain and improve the Services.

2. TRACKING TECHNOLOGIES ON THE SERVICES

We and our Service Providers may collect and store your information in log files as well as through the use of cookies, web beacons (also known as “tracking pixels”), embedded scripts, and other tracking technologies now and hereafter developed (“Tracking Technologies”). The Tracking Technologies on the Services may include, without limitation:

Cookies. Cookies are small files that your web browser places on your hard drive for record-keeping purposes. A cookie may be a session ID cookie or tracking cookie. Session cookies make it easier for you to navigate the Services and expire when you close your browser. Tracking cookies help in understanding how you use the Services, and remain longer. Cookies may remain on your hard drive for an extended period of time. You may generally disable or remove cookies by tools available as part of most commercial browsers, and in some instances blocked in the future by selecting certain settings. If you use your browser’s method of blocking or removing cookies, some features and functionalities of the Services may not work.

Web Beacons or Tracking Pixels. Web beacons are small graphic images, also known as “internet tags” or “clear gifs,” embedded in web pages and email messages. Web beacons may be used to provide information about how our visitors use the Services and how they interact with our email newsletters and with our stories that appear on other websites.

Embedded Scripts. An embedded script is programming code designed to collect information about your interactions with the Services. It is temporarily downloaded onto your device from our web server or a third party with whom we work, is active only while you are connected to the Services, and deleted or deactivated thereafter.

Data Analytics. We also collect information about how you navigate the Services. We use this information to monitor and analyze trends, usage, and activities and to improve the Services..

Google Analytics, through the use of cookies or other Tracking Technologies, helps us analyze how users interact with and use our Services, compiles reports on website activity, and provides other services related to activity and usage on our Services. The technologies used by Google may collect information such as your location, time of visit, whether you are a return visitor, and any referring website. You can learn more about Google’s partner services and how to opt out of tracking of analytics by Google on Google’s Privacy and Terms website: https://policies.google.com/technologies/partner-sites?hl=en

Opting Out Through Browser Controls. You may be able to disable and manage some Tracking Technologies through your browser settings. If you use multiple browsers on the same device, you will need to manage your settings for each browser. Please refer to your browser’s help menu for information on how to manage cookies.

Do Not Track. Your browser or device may include “Do Not Track” functionality. At this time, we do not respond to Do Not Track signals.

3. DISCLOSURE OF INFORMATION

Our agents, vendors, consultants, and other service providers ("Service Providers") may receive or be given access to your information in connection with their work on our behalf. These Service Providers are prohibited from using your information for any purpose other than to provide this assistance, although we may permit them to use aggregate information which does not identify you or de-identified data for other purposes.

Further, we may share your information with third parties, including for the following purposes:

To investigate, prevent, or take action regarding illegal activities, intellectual property infringement, suspected fraud, situations involving potential threats to the physical safety of any person, or violations of our Terms of Service;
To comply with the law, or respond to subpoenas, court orders, or other legal process, in which case we will notify you, if and as permitted by law, and cooperate with you to submit any lawful objections to such disclosure and/or to seek an appropriate protective order limiting disclosure of the information to that strictly required by law;
In connection with, or during negotiations of, any proposed or actual merger, purchase, sale or any other type of acquisition or business combination of all or any portion of our assets, or transfer of all or a portion of our business to another business; and
To fulfill any other purpose disclosed to you at the time you provide the information or with your consent.

4. LEGAL BASES FOR PROCESSING

The laws of some jurisdictions, such as the European Union, the UK, or Brazil, require companies to tell you about the legal basis for using, sharing, or disclosing your information. To the extent those laws apply, we may rely on the following legal bases: (1) with your consent; (2) as necessary to perform our agreement to provide Services; and (3) as necessary for our legitimate interests in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy.

5. CHILDREN

The Services are not directed at children and we do not knowingly collect personal information from children under the age of 16. If you are a parent or guardian and believe we have collected information from your child, please email us here or send us a letter to First Look Institute, 114 Fifth Ave, New York, NY 10011, and we will remove such data to the extent required by law.

6. DATA SECURITY

We employ practices designed to help protect information about you from loss, theft, misuse and unauthorized access, disclosure, alteration and destruction. However, no physical or electronic security system is impenetrable. We cannot guarantee the security of our servers or databases, nor can we guarantee that information you supply will not be intercepted while being transmitted over the internet.

7. INTERNATIONAL TRANSFER

We are based in the United States. If you access the Services from outside the United States, your data may be transferred, processed, and stored in the United States and other jurisdictions. Data protection laws in the United States and other jurisdictions may be different from those of your country of residence. We will transfer your personal data in accordance subject to suitable safeguards, such as standard contractual clauses, in accordance with applicable law.

8. YOUR RIGHTS

The data controller for the personal information we process is set forth in the Contact Us section below. Depending on where you live, you may have certain rights with respect to your information. For example, under local laws, including in the European Union, United Kingdom and Brazil, you may be able to ask us to:

provide access to certain information we hold about you
update or correct your information
delete certain information
restrict the use of your information

We will respond within the time period prescribed by applicable law. Please note that many of the above rights are subject to exceptions and limitations.

We will take reasonable steps to verify your identity, including authenticating you through your email address. We may require further documentation before granting access to your information.

If you are based outside the U.S. and would like to exercise any individual right you may have please contact us at the contact information below. Please include “My Rights” in the subject line and provide a clear explanation of which right you are exercising and your country of residence in the body of the email.

Your rights and our responses will vary based on your state or country of residency. Please note that you may be located in a jurisdiction where we are not obligated, or are unable, to fulfill a request. In such a case, your request may not be fulfilled.

If you have any unresolved concerns, you may have the right to complain to your local data protection authority.

9. CALIFORNIA PRIVACY NOTICE

Shine the Light

California’s “Shine the Light” law permits customers in California to request certain details about how certain types of their information are shared with third parties and, in some cases, affiliates, for those third parties’ and affiliates’ own direct marketing purposes. If you are a California resident and wish to obtain information about our compliance with this law, please email us here, contact us at 855-818-6432 or send us a letter to First Look Institute, 114 Fifth Ave, New York, NY 10011. Requests must include “California Privacy Rights Request” in the first line of the description and include your name, street address, city, state, and ZIP code.

California Consumer Privacy Act (“CCPA”)

The CCPA provides California residents with rights with respect to your Personal Information, as that term is defined in the CCPA. To the extent that we collect Personal Information that is subject to the CCPA, that information, our practices, and your rights are described below. Capitalized terms not defined in this Policy have the meanings set forth in the CCPA.

Right to Information Regarding the Categories of Personal Information Collected, Sold, and Disclosed. You have the right to receive information regarding the categories of Personal Information we collected, sold, and disclosed.

Right to Access Information. You have the right to request access to Personal Information collected about you and information regarding the source of that information, the purposes for which we collect it, and the third parties and service providers with whom we share it.

Right to Request Deletion of Information. You have the right to request in certain circumstances that we delete any Personal Information that we have collected directly from you.

Right to Information Regarding Participation in Data Sharing for Financial Incentives. You have the right to be free from discrimination based on your exercise of your CCPA rights. We do not have any rewards programs or other financial incentives.

Right to Opt Out of Sale of Personal Information to Third Parties. You have the right to opt out of any Sale of your personal information to third parties.

How to Submit a Request. You may submit a request to exercise your rights through any one of three means:

1. By filling out a Consumer Data Request Form available here.

2. By calling us at 855-818-6432.

3. By emailing us at privacy@firstlook.org.

To protect our customers’ Personal Information, we are required to verify your identify before we can act on your request.

Data Collection and Sharing Practices. The following is a description of the personal information we collect, the sources of that information, the purposes for which we collect information, and whether we disclose that information to external parties.

Identifiers and Contact Information. We collect

· your name, phone number, email address, and contact address when you complete a transaction, such as a donation, or sign up for our events or promotions.

· your email address when you sign up for our newsletter.

· your IP address and your Device ID automatically when you use the Services.

Financial and Commercial Information. When you engage in transactions with us, such as becoming a member or making a donation

· we create records of the contribution you made, reason for the donation, as well as goods or services that you may receive in connection with your donation; and

· you provide us with payment information, which may be your credit card number or a bank account, when you complete a transaction. You have the option to store this information to your account or set up a recurring transaction. We use a third party payment processor for credit card transactions and do not receive any payment card information.

Comment Information. When you leave a comment on any story, feature, or document, we will post, display, and maintain your comment on our website.

Internet or Other Electronic Network Activity Information. We collect information about your browsing history, search history, viewing history, and information regarding your interaction with websites, applications, videos, or advertisements automatically when you utilize the Services.

Geolocation Data. As described above, we collect your IP address automatically when you use the Services. We may be able to determine your general location based on the IP address. We do not collect your precise location (e.g., your GPS coordinates).

Audio, electronic, visual, thermal, olfactory, or similar information. If you contact us via phone, we may record the call.

Professional or employment-related information. If you apply for a job with First Look, we may collect name, contact information, cover letter, LinkedIn profile, and website.

Education Information. If you apply for a job with First Look, we may collect information on the institutions you have attended, the level of education you have attained, your transcript, and writing samples.

Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics. We may analyze your actual or likely preferences through a series of computer processes. On some occasions, we may add our observations to your internal profile.

We may share any of the above-listed information with Service Providers, which are external parties that we engage for business purposes and are restricted from using Personal Information for any purpose that is not related to our engagement. The categories of Service Providers with whom we share information and the services they provide are described in this Privacy Policy.

We have not Sold any Personal Information in the past 12 months.

10. INFORMATION FOR NEVADA RESIDENTS

Residents of Nevada have the right to opt out of the sale of certain pieces of their information to other companies who will sell or license their information to others. If you are a Nevada resident and would like to make such a request, please email privacy@firstlook.org.

11. CHANGES TO THIS PRIVACY POLICY

We reserve the right to revise and/or reissue this Privacy Policy at any time. If we change this Privacy Policy in the future, we will post the revised Privacy Policy on the Services and update the “Effective Date,” above, to reflect the date of the changes. Any changes will be effective immediately upon posting of the revised Privacy Policy.

12. CONTACT US

If you have any questions or comments about this Privacy Policy or our data practices, please contact us:

By email: privacy@firstlook.org

By mail: First Look Institute Attn: Privacy 114 Fifth Ave New York, NY 10011

If you are located in Brazil, please contact us:

By email: juridico@theintercept.com