This document applies specifically and exclusively to the relationship between The Nordic Press, Inc., the publisher of Vaba Eesti Sõna newspaper, and its subscribers (print or electronic). Where the subscriber relationship is a result of gifting by a third party, the recipient of the gift subscription will be asked to accept the same policy as a regular subscriber except as noted below. These terms do not apply to any suppliers, vendors, advertisers, employees with whom separate contractual arrangements will apply.
Commitment to Privacy
Compliance with Regulations
Definition of Personal Information
Personal information is any information that is related to an identified or identifiable natural person. Individuals are identifiable if they can be directly or indirectly identified, especially by reference to an identifier such as a name, an identification number, location data, an online identifier. In practice, these also include all information which are or can be assigned to a person – for example, a telephone, credit card or personnel number of a person, account data or customer number or address are all personal information.
Definition of Non-Personal Information
We may also collect information that is related to you but that does not personally identify you (“non-personal information.”) Non-personal Information also includes information that could personally identify you in its original form, but that we have modified (for instance, by aggregating, anonymizing or de-identifying such information) in order to remove or hide any Personal Information. For example, we might be interested in assessing how subscriptions are distributed geographically in order to make sure that we are serving all areas adequately.
Information we Collect About You
When interacting with our organization, you will be prompted to create an account which may hold personal information such as your name, mailing address, email address, telephone number, payment details and login details. This is the only information that we will directly solicit from you, unless we explicitly ask your permission in other circumstances (e.g. asking you to participate in reader surveys).
Lawful Basis for Processing
THE NORDIC PRESS collects personal information about you in connection with your subscription to our publications and we only process Personal Information where we have a lawful basis for doing so.
- i. User consent: As a subscriber you have given us explicit permission to process Personal Information for the purpose of delivering your subscription. You have the right to withdraw this consent at any time. You can manage your preferences within your account or by contacting us.
- ii. Legitimate business purposes – As a business and a publisher, we need to process the personal information explicitly defined above in order to conduct our operations and deliver you a subscription product..
- iii. Contractual necessity – .We need to process the above personal information in order to meet our contractual responsibility to deliver subscriptions and receive payment for them.
- iv. Legal obligation – We have certain obligations under the law regarding how we process information, safeguard customer information and how we retain records of financial relationships to customers. .
Collection of Information from Children
The Nordic Press does not knowingly enter into financial arrangements with children under the age of 16 and thus will not collect any information on children, and if it is discovered that such information has been entered into out database, it will be deleted. In the case of gift subscriptions made directly to children (as opposed to through schools, etc.), no financial information will be collected and to the extent that a delivery address will be needed, Nordic Press will endeavor to secure parental or legal guardian approval for use of that address.
Methods to Collect Information
THE NORDIC PRESS collects information from you, through our interactions with you. The information we collect depends on the context of your interactions with THE NORDIC PRESS and the choices you make, including your privacy settings and the products and features you use. We may also obtain information about potential subscribers from third parties or from publicly available websites.
Information Collected Automatically
THE NORDIC PRESS may collect aggregate Technical Information about use of our internet subscriptions. When a reader visits our websites, their web browser automatically sends information about “views” of the pages. “Technical Information” is information that does not, by itself, identify a specific individual but which could be used to indirectly identify you. We will not, however, use such information for identifying any individuals. Gathering Technical Information helps us ensure our websites and other services work correctly and support our customer analytic efforts.
Cookies and Similar Technologies
We will not use “cookies” that can be used to identify personal preferences of our subscribers unless we request explicit permission to do so, with the following exceptions:
Cookies We Use
(i) Essential cookies: These cookies enable necessary features and services on our site. Without these cookies, the services you have asked for cannot be provided.
(ii) Functional cookies: These cookies allow our site to remember your preferences. The purpose of these cookies is to personalize your how you interact with the subscribed offering and avoid your having to re-select preferences every time you visit our site.
Ability to Disable Technologies
Some web browsers (including some mobile web browsers) provide settings that allow you to control or reject cookies or to alert you when a cookie is placed on your computer, tablet or mobile device. Although you are not required to accept cookies, if you block or reject them, you may not have access to all features available through our services. For more information, visit the help page for your web browser or see http://www.allaboutcookies.org.
Consequences of Disabling Technologies Please note that if you disable your web browser’s cookies and other technologies, certain features of our website and services will be disabled and you will limit the functionality we can provide when you visit our site.
Information Collected from External Sources
THE NORDIC PRESS may also collect information about you from external sources to help us correct or supplement our records, improve the quality or personalization of our services to you, and prevent or detect fraud.
Publicly Available Information THE NORDIC PRESS may collect information that is publicly available. For instance, information you’ve submitted in a public channel (e.g., blog, forum, social network) may be read, collected and may be used to personalize your experience.
Information You Provide Us
THE NORDIC PRESS collects Personal Information about you in connection with your subscription or when you otherwise provide your Personal Information to us. When using our website, you will be prompted to create an account which may hold personal information such as name, mailing address, email address or credit card information. When contacting us, you may be required to
submit contact information. When communicating with THE NORDIC PRESS, all communications will be transmitted and stored by us. To be clear, you may be providing Personal Information when you are: (i) communicating with THE NORDIC PRESS via phone calls, chats, emails, web forms, social media and other methods of communication; (ii) subscribing to THE NORDIC PRESS; (iii) making a donation; (iv) purchasing something; or (v) applying for a job.
How We Use Your Information
THE NORDIC PRESS uses your personal information only with your consent to provide you information and services. We use your personal information:
- To provide our service: To fulfill your requests for products and services and communicate with you about those requests, such as related to your subscription, to purchase advertising, or submitting content;
- To improve our service: To respond to reviews, comments, or other feedback you provide us;
- To bill our customers: To securely process your payment information to take payments, give refunds, and detect/prevent fraudulent activity. We will also update your payment information in the event that a payment is unsuccessful.
- To communicate product changes or offers.
- For the purpose of advertising.
- To administer prize draws and contests.
Disclosure of Personal Information to Third Parties
THE NORDIC PRESS will not sell your Personal Information to others THE NORDIC PRESS will only share Personal Information with vendors and service providers that we have written agreements with to help us provide the subscription product to you.
Disclosure of Personal Information for Legal and Safety Reasons
THE NORDIC PRESS may be required to disclose personal information to the authorities, law enforcement agencies, government agencies or legal entities. We may disclose information by law, litigation or as a matter of national security to comply with valid legal process including subpoenas, court orders or search warrants, and as otherwise authorized by law. We may also need to disclose personal information in the event of an emergency that threatens an individual’s life, health or security.
Disclosure of Personal Information via Links to Third-Party Websites, Services and Applications
THE NORDIC PRESS may provide the ability to access other websites, devices, apps, features, products and services (e.g., gift cards), which operate independently from us and will have their own privacy notices or policies, which we strongly suggest you review. To the extent any linked website, device, app, feature, product or service is not owned or controlled by us, we are not responsible for its content, any use of the website, device, app, feature, product or service or the privacy practices of the operator of the website, device, app, feature, product or service.
International Transfer of Personal Information
THE NORDIC PRESS is located in the United States of America. All subscription information is stored and processed in the U.S. We do not transfer personal information to other countries or organizations.
Security Measures to Protect Personal Information by Third Parties
We require that our third-party service providers and partners agree to keep all confidential information we share with them and to use the information only to perform their obligations in the agreements we have in place with them. These third-party service providers and partners are expected to maintain privacy and security protections that are consistent with THE NORDIC PRESS’s privacy and information security policies. We rely on the following third parties to fulfill our organization’s mission:
- PayPal – payment processor
- Intuit (QB) – business accounting software package
- Facebook – to communicate with the public, including periodic advertisements.
- Facebook Sharing
- Twitter – microblogging and social networking service
- MailChimp – marketing platform
- Hosting Provider – WPEngine.com, United States of America
- Web consultant – The VL Studios, New York, NY
- Printer mailing company – Atlantic Color Corp., Long Island, NY
- YouTube Provided by Google, Inc.
- Google Analytics
- Google Adworks
Security Measures Taken to Protect Personal Information by Us
Security of all information is of the utmost importance for THE NORDIC PRESS. THE NORDIC PRESS uses technical and physical safeguards to protect the security of your personal information from unauthorized disclosure. We use Secure Socket Layer (SSL) as a standard security technology for establishing and encrypted link between our server and a visitor to our site to keep all information secure. We also make all attempts to ensure that only necessary people and third parties have access to personal information. Nevertheless, such security measures cannot prevent all loss, misuse or alteration of personal information and we are not responsible for any damages or
liabilities relating to any such incidents to the fullest extent permitted by law. In the case of a data breach, we will notify you without delay of any loss, misuse or alteration of personal information that may affect you. We will notify relevant regulatory bodies of a breach.
Data Retention and Storage
THE NORDIC PRESS retains your information for interacting with you, for as long as your account is active, and/or if is reasonably necessary to provide you with any related products and services. THE NORDIC PRESS will also retain your information as reasonably necessary to comply with our legal obligations, resolve disputes and enforce our agreement for a period of 10 years. We may also retain cached or archived copies of your information for a reasonable period. At any point in time, you can withdraw consent and we will immediately stop processing your information.
Your Privacy Rights
You can choose what personal information will be stored about you by THE NORDIC PRESS. If at any point in time you wish know what information we process about you, you can request to access the information by contacting email@example.com You can ensure that any account, contact or financial information is up-to-date and can correct, update or delete inaccuracies to the information by contacting us or ask us to no longer use your personal information. We will respond to your request to access within 30 days. In some cases, however, we may limit or deny your request if the law permits or requires us to do so, infringes on the privacy of other individuals or internal procedures, or if we are unable to verify your identify.
If at any time your contact information changes, please notify us and we will update your contact information.
Inquiry, Complaint and Dispute Process
How to Contact Us
THE NORDIC PRESS
Eve Saar, Business Manager
243 East 34th Street
New York, NY 10016
Phone Number: 1-212-686-3356