Slate’s Privacy Policy

Our data-collection practices.

Last updated: January 4, 2024

The Slate Group LLC (“Slate,” “we,” or “us”) is committed to bringing you information tailored to your individual needs. This Privacy Policy describes how we collect, use, and disclose information through the websites, mobile applications, and other online services and products that link to or post this Privacy Policy (collectively, the “Services”). Please read the entire Privacy Policy before using our Services. By using the Services, you consent to the terms of this Privacy Policy and our Terms of Service.

We may sell or share your Personal Information as further described below.

If you are located in California, Colorado, Connecticut, Nevada, Virginia or Utah and would like to opt-out of the sale or sharing of your personal information click here, the button below, or email us at privacy@slate.com.

California Consumer Privacy Act (CCPA) Opt-Out Icon

Please see Your State Privacy Rights for more information on how we respond to consumer requests.

You do not need to create an account with us to exercise your opt-out rights. We will only use and retain personal information provided in an opt-out request to review and comply with the request.

1. Information Collection

A. Information You Provide.

We collect personal information from you when you use the Services. “Personal information” means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

• Contact information, such as name, e-mail address, postal address, and telephone number;
• User name, display name, and password;
• Demographic information, such as age, race, and gender;
• Payment information, such as credit card number and expiration date, through a third-party payment processor*;
• Communications preferences;
• Search queries;
• Stories, comments, photos, and other information posted in our interactive online features;
• Correspondence and other information that you send to us; and
• Additional information as otherwise described to you at the point of collection or pursuant to your consent.

*If you use the Site to make purchases, we will also collect certain payment information, such as payment card, PayPal, Square, or other financial account information, and billing address. A third-party payment processor collects that information; we do not store your credit card information.

Personal Information once “de-identified” is not subject to this Privacy Policy and we may treat it as non-Personal Information and use it without obligation to you except as prohibited by applicable law.

B. Information Automatically Collected.

We also collect certain information automatically when you visit the Services (“Usage Information”), including:

• Your browser type and operating system;
• Your Internet Protocol (IP) address, which is the number automatically assigned to your computer whenever you access the Internet and that can sometimes be used to derive your general geographic area;
• Geolocation information, including precise information;
• Transaction data on items you purchase on our site or through our partners;
• Other unique identifiers, including mobile device identification numbers;
• Sites or mobile apps you used before and after using the Services;
• Pages you view and links you click on within the Services;
• Information collected through cookies, web beacons, and other technologies;
• Information about your interactions with e-mail messages, such as the links clicked on and whether the messages were opened or forwarded; and
• Standard Server Log Information.

We may use cookies, pixel tags, and other technologies to automatically collect Usage Information:

o  Cookies and Pixel Tags

Cookies are small bits of information that are stored by your computer’s web browser. You can decide if and how your computer will accept a cookie by configuring your preferences or options in your browser. However, if you choose to reject cookies, you may not be able to use certain online products, services or features on the Services.

Pixel tags are very small images or small pieces of data embedded in images, also known as “web beacons” or “clear GIFs,” that can recognize cookies, the time and date a page is viewed, a description of the page where the pixel tag is placed, and similar information from your computer or device.

o   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.

o   Location-identifying Technologies

GPS (global positioning systems) software, geo-filtering, and other location-aware technologies locate (sometimes precisely) you for purposes such as verifying your location, understanding the geographic distribution of our users, and delivering or restricting relevant content based on your location.

o   Device Fingerprinting

Device fingerprinting is the process of analyzing and combining sets of information elements from your device’s browser, such as JavaScript objects and installed fonts, in order to create a “fingerprint” of your device and uniquely identify your device and applications.

o   In-App Tracking Methods

There are a variety of tracking technologies that may be included in mobile applications, and these are not browser-based like cookies and cannot be controlled by browser settings. Some use device identifier, or other identifiers such as “Ad IDs” to associate app user activity to a particular app and to track user activity across apps. You can stop all collection of information via our mobile applications by uninstalling them. Also, you may be able to exercise specific privacy choices, such as enabling or disabling certain location-based services, by adjusting the permissions in your mobile device and/or Slate’s iOS or Android mobile applications.

For further information on tracking technologies and your choices regarding them, please see Section 6 below.

 Analytics and Advertising Tracking Technologies.

We allow outside entities to place and read their own cookies, web beacons, and other technologies to collect information through the Services. For example, our vendors may use these technologies to collect information (i) that helps us with traffic measurement, research, and analytics, and (ii) that is used to serve advertisements on our Services and across the Internet and on other apps tailored to your apparent interests. To the extent we combine information from outside services with Personal Information we collect directly from you on the Services, we will treat the combined information as Personal Information under this Privacy Policy. Otherwise, the information collected and stored by outside entities remains subject to their policies and practices, including whether they continue to share information with us, the types of information shared, and your choices on what is visible to others on third party services.

We use various analytics services that may use cookies or other tracking technologies to help us analyze how users interact with and use the website, compile reports on the website’s activity, and provide other services related to website activity and usage. These technologies may collect information such as your IP address, time of visit, whether you are a return visitor, and any referring website. The information generated by these providers will be transmitted to and stored by them and will be subject to their privacy policies. For a full list of third party partners with links to their privacy policies and opt-out options, including analytics services, see our Third Party Partners page.

You may choose whether to receive interest-based advertising by submitting opt-outs. Some of the advertisers and service providers that perform advertising-related services for us and our partners may participate in the Digital Advertising Alliance (“DAA”) Self-Regulatory Program for Online Behavioral Advertising. To learn more about how you can exercise certain choices regarding Interest-based Advertising, visit http://www.aboutads.info/choices, and http://www.aboutads.info/appchoices for information on the DAA’s opt-out program for mobile apps. Some of these companies may also be members of the Network Advertising Initiative (“NAI”). To learn more about the NAI and your opt-out options for their members, see http://www.networkadvertising.org/choices/. You can also opt out of interest-based advertising within mobile apps based on advertising identifiers on your device (for example, through cross-app tracking). See the Advertising and Privacy options under your device’s Settings for more information. Please be aware that, even if you are able to opt out of certain kinds of interest-based advertising, you may continue to receive other types of ads. Opting out only means that those selected members should no longer deliver certain interest-based advertising to you, but does not mean you will no longer receive any targeted content and/or ads (e.g., from other ad networks). Slate is 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.

Choices About How We Use and Disclose Your Information and Do Not Track Disclosures.

Some web browsers may transmit signals such as “do-not-track” (DNT) or Global Privacy Control (GPC) to the websites with which the user communicates. Because of differences in how web browsers incorporate and activate this feature, it is not always clear (especially with DNT), whether users intend for these signals to be transmitted, or whether they even are aware of them. Slate will endeavor to take action in response to these signals.

Globally, Slate will interpret the browser “do-not-track” signal as an opt-out signal of the Sale of Personal Information to the US Privacy API. For more information on “do-not-track” and Global Privacy Control, visit http://www.allaboutdnt.com and https://globalprivacycontrol.org/.

Residents of California, Colorado, Connecticut, Virginia or Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information. To exercise this right, please visit our “Do Not Sell or Share My Personal Information” webpage.

C. Information from Other Sources

We obtain information about you from other sources, including service providers (as defined under the California Consumer Privacy Act) and third party services, and combine such information with information we have collected about you. To the extent we combine such information from outside sources with Personal Information we have collected about you on the Services, we will treat the combined information as Personal Information under this Privacy Policy. We are not responsible for the accuracy of any information provided by outside sources.

2. Use and Retention of Information

We use and retain information that we collect through the Services for a variety of purposes, including to:

• Provide you with the products, promotions, services, newsletters, and information you request and respond to correspondence that we receive from you;
• Customize and personalize your use of the Services;
• Provide Slate Plus users with premium content, products, promotions, and information;
• Contact you via email and otherwise about products, services, and events that we think might be of interest to you;
• Contact you with surveys, legal notices, and other information that may be relevant to your use of the Services;
• Maintain or administer the Services, perform business analyses, or for other internal purposes to improve the quality of our business, the Services, and other products and services we offer;
• Publish stories, comments, and other information posted in our interactive online features;
• Process employment applications and inquiries;
• Create articles and other content;
• Detect, investigate, and prevent activities that may violate our policies or may be fraudulent or illegal;
• Deliver advertising, including interest-based advertising, to show you relevant ads both on our Services and elsewhere, and measure the effectiveness and reach of ads; and
• As otherwise described to you at the point of collection or pursuant to your consent.

3. Sharing of Information

We want you to understand when and with whom we may share the information we collect. We share information that we collect through the Services as follows:

•  Corporate Parents, Affiliates, and Subsidiaries. We share your information with our corporate parents, subsidiaries, and other affiliated entities as needed to process your questions or respond to your requests.

• Service Providers. We share your information with our agents and service providers that perform certain functions or services on our behalf, such as to host the Services, manage databases, host a store or other e-commerce platform, perform analyses, conduct surveys, place Slate-branded content on third-party websites, or send communications and newsletters for us.

• Select Business Partners. We share your information with select business partners so that they can provide you with special offers, promotional materials, advertisements and other materials that may be of interest to you.

Residents of California, Colorado, Connecticut, Virginia or Utah may have additional personal information rights and choices. Please see Your State Privacy Rights for more information.

To exercise this right, please visit our do not sell or share my information webpage.

• Other Parties When Required By Law or as Necessary to Protect the Services. We will disclose your information to outside entities in order to protect the legal rights, safety, and security of Slate, our corporate parents, affiliates, and subsidiaries, and the users of our Services; enforce our Terms of Service; prevent fraud (or for risk management purposes); and comply with or respond to law enforcement or legal process or a request for cooperation by a government or other entity, whether or not legally required.

In Connection With a Transfer of Assets. If we sell all or part of our business, or make a sale or transfer of assets, or are otherwise involved in a merger or business transfer, or in the event of bankruptcy, we may transfer your information to one or more third parties as part of that transaction.

• Other Parties With Your Consent. We share information about you when you consent to such sharing, including when you post information to a user profile or a public area of the Services, such as a chat room, forum, blog, or other community tool.

• Aggregate Information. We disclose to third parties information that does not describe or identify individual users, such as aggregate website usage data or demographic reports.

4. Social Networking Services

Slate has worked with certain social media providers to offer you their social networking services through our Services. For example, you can use social networking services, including but not limited to Facebook, X (formerly Twitter), and others to share information about your experience on our Services with your friends and followers on those social networking services. These social networking services may be able to collect information about you, including your activity on our Services. These social networking services also may notify your friends, both on our Services and on the social networking services themselves, that you are a user of our Services or about your use of our Services, in accordance with applicable law and their own privacy policies. If you choose to access or make use of social networking services, we may receive information about you that you have made available to those social networking services, including information about your contacts on those social networking services.

You also may be able to link an account from a social networking service (e.g., Facebook, Twitter) to an account through our Services. This may allow you to use your credentials from the other site or service to sign in to certain features on our Services. If you link your account from an outside site or service, we will collect information from those accounts, and any information that we collect will be governed by this Privacy Policy.

5. Links to Other Sites and Services

The Services contain links to other websites or online services that are operated and maintained by outside entities and that are not under the control of or maintained by Slate. Such links do not constitute an endorsement by Slate of those other websites, the content displayed therein, or the persons or entities associated therewith. This Privacy Policy does not apply to this outside content. We encourage you to review the privacy policies of other websites or services.

6. Communication Preferences

You may choose to receive promotional communications (including emails and text messages), newsletters, and similar communications from us. You may opt out of receiving certain promotional communications from us at any time by (i) for promotional emails, by clicking on the opt-out or “unsubscribe” link included in the commercial e-mails you receive”. Please note that your opt-out is limited to the e-mail address or phone number used and will not affect subsequent subscriptions. Opt-out requests for e-mail may take up to 10 business days to be effective. Your opt-out request will not apply to messages that you request or that are not commercial in nature.

7.  Children’s Privacy

The Services do not knowingly collect, use, or disclose personal information from, nor do we direct the Services to, anyone under the age of 18.

No one under age 18 may provide any personal information to the Site. If you are under age 18, do not use or provide any information on this Site or through any of its features, register on the Site, make any purchases through the Site, use any of the interactive or public comment features of this Site, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or user name you may use. If we learn we have collected or received personal information from a child under age 18 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13 please contact us at privacy@slate.com.

8. Data Security

We maintain reasonable security procedures to help protect against loss, misuse, unauthorized access, disclosure, alteration or destruction of the information you provide to us. Please note that no data transmission or storage can be guaranteed to be 100% secure. As a result, we cannot guarantee or warrant the security of any information you disclose or transmit to us online and cannot be responsible for the theft, destruction, or inadvertent disclosure of your information.

You are responsible for maintaining the confidentiality of your account password and for any access to or use of the Services using your password, whether or not authorized by you. Please notify us immediately of any unauthorized use of your password or account or any other breach of security.

9. International Users

Please note that the Services are directed towards users who reside in the United States. By using the Services, you consent to the collection, storage, processing, and transfer of your information in and to the United States, or other countries and territories, pursuant to the laws of the United States, where permitted by law. Some of these countries may not offer the same level of privacy protection as your own. Any such transfers will comply with safeguards as required by relevant law. If applicable, you may have a right to claim compensation for damages caused by a breach of relevant data protection laws.

Residents of the EEA, Switzerland of the UK

If you are a resident of the EEA, Switzerland, or the U.K., the following information applies:

Purposes of processing and legal basis for processing

As explained above, we process personal data as defined under data protection laws in various ways depending upon your use of the Services. We process personal data 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 interest in providing the Services where those interests do not override your fundamental rights and freedom related to data privacy.

Right to lodge a complaint

Users that reside in the EEA, Switzerland, or the U.K. have the right to lodge a complaint about our data collection and processing actions with the supervisory authority concerned. Contact details for data protection authorities are available here.

Transfers

Personal information we collect may be transferred to, and stored and processed in, the United States or any other country in which we or our affiliates or subcontractors maintain facilities. We ensure that transfers of personal information to a third country or an international organization are subject to appropriate safeguards as described in Article 46 of the GDPR.

Individual Rights

If you are a resident of the EEA, Switzerland, or the U.K., you are entitled to the following rights, which may be exercised by contacting us as described below. In order to verify your identity, we may require you to provide us with personal information prior to accessing any records containing information about you.

• The right to request data erasure. You have the right to have your data erased from our website if the data is no longer necessary for the purpose for which it was collected, you withdraw consent and no other legal basis for processing exists, or you believe your fundamental rights to data privacy and protection outweigh our legitimate interest in continuing the processing.

• The right to restrict or object to our processing. You have the right to restrict or object to our processing if we are processing your data based on legitimate interests or the performance of a task in the public interest as an exercise of official authority (including profiling); using your data for direct marketing (including profiling); or processing your data for purposes of scientific or historical research and statistics.

If you are accessing Slate in our iOS or Android apps from the EU, Switzerland, or the U.K., you may revoke consent at any time by tapping Settings (if not signed n)/Manage Account (if signed in) > Cookie Preferences.

Slate tracks when EEA, Swiss, and UK readers grant consent for Slate to collect and process data through the use a consent management platform: OneTrust. To verify your current settings, you can use the button below:

California Consumer Privacy Act (CCPA) Opt-Out Icon

If you are an EEA, Swiss, or U.K. reader and would like additional information about how to opt out of data collection by our partners, please visit our Third Party Partner Page.

If you would like additional information about how to opt out of data collection by our partners, please visit our Third Party Partner Page.

12. Privacy Policy Updates

We may modify this Privacy Policy at any time by posting revisions to the Services or other appropriate notice. Your continued use of the Services after any modification to the Privacy Policy will constitute your acceptance of the new terms and conditions, where permitted by law.

13.  Contact Us

If you have any questions about this Privacy Policy, you may contact us at:

The Slate Group, LLC
15 MetroTech Center, 8th Floor
Brooklyn, NY 11201
Email: privacy@slate.com

Data Protection Representative Contact Information

If you are located in the EEA or Switzerland:

Kaplan Ireland Education Limited
Attn: EU/EEA Data Protection Representative
13/14 Aungier Street, Dublin 2, D02 WC04 Ireland

If you are located in the U.K.:

Kaplan UK Limited
Attn: UK Data Protection Representative
Palace House, 3 Cathedral St, London SE1 9DE, England

YOUR STATE PRIVACY RIGHTS

State consumer privacy laws may provide their residents with additional rights regarding our use of their personal information.

Colorado, Connecticut, Virginia, and Utah each provide their state residents with rights to:
• Confirm whether we process their personal information.
• Access and delete certain personal information.
• Data portability
• Opt-out of personal data processing for targeted advertising and sales.

California Consumer Privacy Act (CCPA) Opt-Out Icon

Colorado, Connecticut, and Virginia also provide their state residents with rights to:
• Correct inaccuracies in their personal information, taking into account the information’s nature processing purpose.
• Opt-out of profiling in furtherance of decisions that produce legal or similarly significant effects.

Nevada residents have the right to opt out of the sale of certain pieces of their personal information to other companies who will sell or license their information to others.

To exercise any of these rights, or appeal a decision, please send an email to privacy@slate.com. To opt-out of the sale of your information, you may also visit https://slate.com/do-not-sell.

For all verifiable consumer requests, we will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at privacy@slate.com.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

The following applies to California residents:

• The right to know:
• the categories of personal information we’ve collected and the categories of sources from which we got the information;
• the business purposes for sharing personal information; and
• the categories of third parties with whom we’ve shared personal information;
• The right to access the specific pieces of personal information we’ve collected;
• The right to delete your information;
• The right to opt-out of automated decision-making and the sale or sharing of your information.
• The right to correct information;
• The right to limit use and disclosure of sensitive information.

California residents also have the right to not be discriminated against if they choose to exercise their privacy rights.

Information We Collect

We collect offline and online personal information. Personal information means information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household.

In particular, we have collected the following categories of personal information from consumers within the last twelve (12) months:

Category: A. Identifiers.
Examples: A real name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number, or other similar identifiers.
Collected: YES

Category: B. . Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e)).
Examples: A name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education,
employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information,
or health insurance information. Some personal information included in this category may overlap with other categories.
Collected: YES (Slate employment only)

Category: C. Protected classification characteristics under California or federal law.
Examples: Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).
Collected: YES

Category: D. Commercial information.
Examples: Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.
Collected: YES

Category: E. Biometric information.
Examples: Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.
Collected: NO

Category: F. Internet or other similar network activity.
Examples: Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.
Collected: YES

Category: G. Geolocation Data
Examples: Physical location or movements.
Collected: YES

Category: H. Sensory data.
Examples: Audio, electronic, visual, thermal, olfactory, or similar information.
Collected: YES

Category: I. Professional or employment-related information
Examples: Current or past job history or performance evaluations.
Collected: YES

Category: J. Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).
Examples: Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.
Collected: NO

Category: K. Inferences drawn from other personal information.
Examples: Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.
Collected: YES

Category: Sensitive Personal Information
Example: Government identifiers (social security, driver’s license, state identification card, or passport number)
Collected: NO
Example: Complete account access credentials (user names, account numbers, or card numbers combined with required access/security code or password)
Collected: NO
Example: Precise geolocation
Collected: NO
Example: Racial or ethnic origin
Collected: NO
Example: Religious or philosophical beliefs
Collected: NO
Example: Union membership
Collected: NO
Example: Genetic data
Collected: NO
Example: Mail, email, or text messages contents not directed to us
Collected: NO
Example: Unique identifying biometric information
Collected: NO
Example: Health, sex life, or sexual orientation information
Collected: NO

A and B: Personal Identifiers and Identifiers:

• We collect your name, telephone number, email address, postal address, user name, display name, self-selected avatar, and password when you create an account or contact us via our Services. We use this information to provide our services, respond to your requests, and send information and advertisements to you.

• We collect your social media handle and basic account information when you interact with our services through social media such as Facebook, and Twitter. We use this information to improve our services, respond to your requests or complaints, and send information and advertisements to you.

• We collect your payment information, such as credit card number and expiration date, when you provide it to us, or to a service provider working on our behalf, when you complete a transaction. We use this information to facilitate payments and transactions through a third-party payment processor.

C. Protected Classification Characteristics Under California or Federal Law:

• We collect or infer your age, race, color, ancestry, national origin, citizenship, religion or creed, marital status, disability status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status when you interact with our websites or mobile apps.

• We collect or infer your disability status, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions). We do not otherwise collect your medical information or health information.

• We use this information to carry out our obligations and enforce our rights arising from any contracts entered between you and us, to better understand the makeup of our audience and provide aggregate statistics on our audience to partners, and to provide you with targeted information and offers.

D. Commercial Information:

• When you engage in transactions with us, we create records of personal property, products, or services purchased, obtained, or considered, as well as other purchasing or consuming histories or tendencies.

• We collect this information from you, from your devices when you interact with our websites or mobile apps, and from Slate employees when you interact with them and provide Personal Information.

• We use this information to carry out our obligations and enforce our rights arising from any contracts entered between you and us for products or services purchased and to provide you with information, products, or services that you request from us. We also use this information to measure the effectiveness of our Services, to improve the content we produce and products we recommend, and to provide you with targeted information, advertisements, and offers.

E. Biometric Information: We do not collect information about your physiological, biological, or behavioral characteristics.

F. Internet or Other Electronic Network Activity Information:

• We collect a unique numerical identifier, assigned to you by a first-party cookie, automatically when you use our services in order to identify you, provide our Services, prevent fraud, and provide you with targeted advertising and offers.

• We collect your IP address automatically when you use our Services. We use this information to identify you, gauge online activity on our website, measure the effectiveness of online services, applications, and tools, and serve targeted advertisements based on your online activities.

• We collect your Device ID automatically when you use our Services. We use this information to monitor your use and the effectiveness of our Services, to identify you, and to provide you with targeted information and offers.

• We collect information about your browsing history, search history, and information regarding your interaction with websites, applications, or advertisements automatically when you utilize our Services.

• We use this information to help maintain the safety, security, and integrity of our website, services, databases and other technology assets, used to support our business, and for testing, research, analysis, and product development, including to develop and improve our website and services.

G. Geolocation Data:

• We use this information to help maintain the safety, security, and integrity of our website, services, databases and other technology assets, used to support our business, and for testing, research, analysis, and product development, including to develop and improve our website and services. We also use this information to provide you with targeted information and offers.

• We use this information to understand the geographic distribution of our users, to enable location-based advertising, and to provide you with targeted information and offers.

H. Sensory data (Audio, electronic, visual, thermal, olfactory, or similar information):

• We may collect visual information in the form of photos and videos taken at Slate events.

I. Professional or employment-related information:

• We collect or infer information about your professional memberships, certifications, licenses or credentials, such as when you provide Slate with this information via a survey.

• We use this information to understand our users and to provide this information to advertisers (e.g., segments of users in specific roles such as “c-suite”).

J. Education information:

• We use this information to understand our users and provide advertisers with segments of users with specific backgrounds (e.g. “well educated”).

K. Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics:

• We analyze your actual or likely preferences through a series of processes and add our observations to your internal profile. We use this information to help us better understand our users and the content they want to consume; to build segments for targeted advertisements; to gauge and develop our marketing activities; to measure the appeal and effectiveness of our services, applications, and tools; and to provide you with targeted information, advertisements, and offers.

Selling and Sharing of Personal Information

The CCPA prohibits a third party from reselling personal information unless you have received explicit notice and an opportunity to opt-out of further sales. The following businesses receive personal information from us and may resell that information. To opt-out of those sales, please visit the third-party opt-out notices on our Third Party Partners Page.

You have the right at any time to direct us not to sell your personal information and opt-out by clicking on “Do Not Share or Sell My Personal Information”, which is located in the footer of our pages and at https://slate.com/do-not-sell.On certain occasions, we sell information to third parties or buy information from third parties.

An external party may be considered a third party either because the purpose of sharing the Personal Information is not an enumerated business purpose under California law, or because our contract does not restrict them from using Personal Information for other purposes. To “sell” information means to disclose it to an external party for monetary or other benefit. We sell or buy the following information:

Personal Identifiers: We provide your IP address and Device ID to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.

• Commercial Information: We provide information about your commercial transactions with us to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.

• Internet or Other Electronic Network Activity Information: We provide information about your Internet or other electronic network activity information to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.

• Geolocation Data: We provide information about your geolocation to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.

• Inferences drawn to create a profile about a consumer reflecting the consumer’s preferences or characteristics: We provide our observations about you to co-marketing partners, advertising platforms, social media platforms, analytics providers, and marketing companies.

We also will disclose information to external parties who are not listed here when required by law or to protect our company or for other purposes, as described in our Privacy Policy, including to respond to law enforcement requests or as required by applicable law or court order.

Over the past 12 months we have “sold” personal information within the above listed categories to the following categories of entities:

• Co-marketing partners

• Advertising platforms

• Social media platforms

• Marketing companies

We will not sell personal information of minors under 18 years of age without affirmative authorization.

Sharing Personal Information: Service Providers

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 our Privacy Policy.

We disclose your personal information to service providers who perform services and functions on our behalf. When we disclose personal information to our service providers, we enter a contract that describes the purpose and requires the recipient to keep that personal information confidential and not use it for any purpose except for fulfilling requirements and services being performed under contract.

Exercising Your Rights

The CCPA provides consumers (California residents) with specific rights regarding their personal information. This section describes those rights and explains how to exercise those rights.

You may exercise your California rights by emailing a verifiable consumer request to privacy@slate.com, or you may use this form to request deletion of your information.

You are not required to create an account with us in order to submit a verifiable consumer request. However, we do consider requests made through your password protected account sufficiently verified when the request relates to personal information associated with that specific account.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information.

Request to Access Your Personal 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. To protect our customers’ personal information, we are required to verify your identity before we can act on your request.

As part of our verification process of your request we ensure reasonable measures are in place to detect fraudulent requests and prevent unauthorized access to your personal information. We are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent by associating the information provided in the request to any personal information previously collected by us or use a third-party identity verification service.

We will disclose the following information to you upon receiving your verifiable request:

• The categories of personal information we collected about you.
• Specific pieces of personal information we collected about you.
• The categories of sources for the personal information we collected about you.
• Our business purpose for collecting that personal information.
• The categories of third parties with whom we share that personal information.
• The categories of personal information that were disclosed or sold to third parties.
• Our business or commercial purpose for selling or disclosing the personal information, if applicable.

Requests to Delete Your Personal Information (Right to Request Deletion)

You have the right to request in certain circumstances that we delete any of your personal information that we have collected from you and retained, subject to certain exceptions. You may submit such a request as described below. To protect our customers’ personal information, we are required to verify your identify before we can act on your request. Once we receive and confirm your verifiable consumer request, we will delete (and direct our service providers to delete) your personal information from our records, unless an exception applies. We may have a reason under the law why we do not have to comply with your request, or why we may comply with it in a more limited way than you anticipated. If we do, we will explain that to you in our response.

Submitting Request to Know or Delete

To exercise the rights described above, you can contact us by submitting your request by:

• Send an email to privacy@slate.com
• Submit your request online using this form

Only you or your authorized agent may make a verifiable consumer request related to your personal information. If you use an authorized agent to submit a request on your behalf, we may require that you (1) provide the authorized agent written permission to do so, and (2) provide a copy of the authorization or provide a copy of a power of attorney that complies with California Probate Code so that we can verify the identity of the authorized agent.

In verifying requests, we employ reasonable measures to detect fraudulent requests and prevent unauthorized access to your personal information. To meet our obligations, we are required to verify your identity, and the identity of your authorized agent, if the request is submitted via an agent, by associating the information provided in your request to personal information previously collected by us.

If we suspect fraudulent or malicious activity on or from the password-protected account, we may decline a request or request that you provide further verifying information.

We will not require you to create an account with us in order to make a request.  We will only use personal information provided in a request to verify your identity or authority to make the request.

Response Timing and Format

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. The verifiable consumer request must:

• Provide sufficient information that allows us to reasonably verify you are the person about whom we collected personal information or an authorized representative.
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

For all verifiable consumer requests, we will confirm receipt of your request within ten (10) business days. If you do not receive confirmation within the 10-day timeframe, please contact us at privacy@slate.com.

We endeavor to respond to a verifiable consumer request within forty-five (45) days of receipt, though we will respond to sales opt-out requests withing fifteen (15) days of receipt. If we require more time (up to 90 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any disclosures we provide will only cover the 12-month period preceding receipt of the verifiable consumer request. The response we provide will also explain the reasons we cannot comply with a request, if applicable.

For data portability requests, we will select a format to provide your personal information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Right to Opt Out of the Sale of Personal Information to Third Parties

You have the right to opt out of any sale of your personal information to third parties.

To exercise this right, please visit our “Do Not Share or Sell My Personal Information” page. Please note that your right to opt out does not apply to our sharing of personal information with service providers, who are parties we engage to perform a function on our behalf and are contractually obligated to use the personal information only for that function.

Other California Privacy Rights

Pursuant to California Civil Code Section 1798.83, California residents who provide us with personal information in obtaining products or services for personal, family, or household use are entitled to request and obtain from us, one time per calendar year, information about the customer information we shared, if any, with other businesses for their own direct marketing uses.

If you are a California resident and you have questions about our practices with respect to sharing information with third parties for their direct marketing purposes and your ability to exercise choice, please send your request to the following email address: privacy@slate.com or write to us at the following mailing address:

The Slate Group, LLC
15 MetroTech Center, 8th Floor
Brooklyn, NY 11201
Email: privacy@slate.com

You must put the statement “Your California Privacy Rights” in the subject field of your e-mail or include it in your writing if you choose to write to us at the designated mailing address. You must include your name, street address, city, state, and ZIP code. We will respond to you at your mailing address or, at our option, your e-mail address. We are not responsible for notices that are not labeled or sent properly, or do not have complete information.

Obtaining this Notice in an Alternative Format

You may obtain this notice in an alternative format by contacting us at privacy@slate.com.