THE DLMvn PRIVACY NOTICE

Effective Date: December 20, 2023

1. INTRODUCTION

This Privacy Notice explains how DLMvn & Company, Inc. and its subsidiaries (collectively, “DLMvn”, “our”, “us”, or “we”) collect, use, and disclose personal data about you when you use our websites, mobile sites, applications (“apps”), or other online products and services that link to this Privacy Notice, subscribe to our print newspaper, attend our conferences or events, and/or receive our newsletters or emails (collectively, the “DLMvn Services”). If there is a conflict between this Privacy Notice and a DLMvn Services corporate subscription agreement, the DLMvn Services corporate subscription agreement will take precedence.

By using the DLMvn Services, you acknowledge you have read and accept this Privacy Notice.

The DLMvn Services are intended for general audiences, and we do not knowingly collect personal data from minors under 16 years of age.

2. DATA WE COLLECT

DLMvn may obtain information about you from a variety of sources. This includes personal data you provide to us directly, data we obtain from other sources, and data we gather through automated means.

2.1 Data You Provide to Us

We collect personal data that you provide to us when you interact with the DLMvn Services, including the following:

Contact or identifier data when you sign up for DLMvn Services, such as your name, postal address (including billing and shipping address), email address, telephone or mobile phone number.
Transactional and financial information to process transactions, such as credit or debit card number and related payment information.
Information you provide when you register for an event or conference, such as your occupation or interests.
User-generated content when you participate in a community forum or otherwise post content that others can read or view, such as your comments, username, or profile picture.
Information you provide when you create a profile, participate in a sweepstakes, contest or game, or take a survey, such as your education, investments, other financial information, interests, or gender.
Information you provide when you use an interactive feature (such as text, chat, chatbot, or article sharing options) or scan or use our QR codes, such as your mobile phone number.
Customer service information, such as messages and other information you address to us through online forms, text, chat, by email, over the phone, or by postal mail.

2.2 Data We Receive from Other Sources

We may receive personal data about you in connection with the DLMvn Services from publicly and commercially available sources, DLMvn Affiliates (defined in Section 4.1), business partners (such as social networking services with which you engage), and, if applicable to you, the third-party provider of your subscription (such as your employer or educational institution). Such personal data may include:

Purchasing data, including information about your transactions and purchase history, membership in loyalty programs, or information about advertisements you have seen or acted upon, including your interaction with advertisers’ products and services.
Demographic data, such as gender, age range, educational level, household income range.
Occupational data, such as profession, position, title, and industry.
Preferences and shopping interests.
Geolocation data.
Your activities on other Internet sites or mobile apps, such as information about content, products, services, or advertisements you have seen or interacted with, including the content, products, or services of our advertisers.
If you log in with or connect a social networking profile (e.g., Facebook) with a DLMvn Service, we may obtain information about you, such as your user ID or user name and other data you have permitted those networks to share with us consistent with your privacy settings on the applicable social networking service.

2.3 Data Collected By Automated Means Through Our Services

We gather by automated means (such as cookies, web beacons, web server logs, and similar technologies) certain information through the DLMvn Services. Such data may include:

Your IP address.
Device information, such as unique identifier and connection information, including mobile device advertising IDs (e.g., Apple IDFA or Google AAID).
Your device type and settings, software used, browser type, and operating system.
Language preferences.
Viewing behavior, including the content you view and for how long.
Web pages and advertisements you view and links you click on within, and search queries you may have run on, the DLMvn Services.
Other usage data, such as the websites or other services you visited before visiting the DLMvn Services (referring URL), access times, and other details about your use and interactions on our Services.
Location information, including the city, state, and zip code associated with your IP address, information derived through Wi-Fi triangulation, and precise location information from GPS-based functionality on your mobile apps, with your consent.
Your phone number and mobile carrier details in connection with some of our mobile apps.

For more information on the various types of automated means we use to gather information, please see our Cookie Notice.

3. HOW WE USE THE DATA WE OBTAIN

We may use the personal data we collect from and/or about you for the purposes set forth below.

3.1 To Provide and Manage the DLMvn Services

This may include to:

Provide our products and services, including to process and fulfill your subscription, or complete a transaction that you requested.
Create and manage online accounts.
Provide customer support, including via online chat or chatbot, and to respond to inquiries.
Send information about your relationship or transactions with us.
Provide technical support.
Deliver relevant content and suggestions (e.g., if you use multiple products, we may use your reading history or activity to personalize the content delivered to you across products).
Conduct research for potential articles if you choose to respond to a journalism survey.
Communicate about, and administer participation in, online games, sweepstakes, contests, promotions, special events, rewards programs, surveys, or market research.
Send promotional materials, alerts regarding available offers, product or service information, events, and other communications, including via text/SMS messages if you provide your mobile phone number and opted in to receive such messages (“Text Messages”). Your consent to receive Text Messages is not required to purchase goods or services from us.
If you register for a product, we may use your information to allow you to sign in to several DLMvn or DLMvn Affiliate websites or apps, as appropriate, with the same user ID.

3.2 To Measure and Improve Our Products and Services/Conduct Analysis

This may include to:

Operate, evaluate, and improve our business (including developing, enhancing, analyzing, and improving our Services; managing our communications, performing data and statistical analytics, and performing accounting, auditing, and other internal functions).
Monitor and analyze the extent of your use of the DLMvn Services, to inform modifications, enhancements, or updates to the DLMvn Services, or to make marketing or pricing decisions.

3.3 To Allow You To Share User-Generated Content

Certain features on the DLMvn Services give you an opportunity to interact with us and others. These features include collaboration tools, community forums, chats, submitting a letter to the editor, creating community profiles, rating, tagging, and commenting on articles. If you choose to use these features, any information you choose to share (such as your name, username, email address, picture or image, likes, status, and comments) becomes public and can be used for purposes over which we have no control. We are not responsible for any information you choose to submit and make public through these interactive features.

3.4 To Deliver Interest-Based Advertising (aka Targeted Advertising)

As described in this Privacy Notice and our Cookie Notice, we, as well as our third-party service providers, may obtain information about your online activity to provide you with advertising about products and services tailored to your individual interests. We also engage third-party online advertising companies, advertisers, and ad networks to help target our messaging to visitors through interest-based and contextual means. These third parties may collect information about your activities on our DLMvn Services and on other websites or apps including offline purchases, for such purpose. The networks use this information to show you advertisements on the DLMvn Services or other third-party websites and apps that may be tailored to your individual interests. This information also helps us track the effectiveness of our marketing efforts. To the extent required by applicable law, we will obtain your consent before using your information for interest-based advertising. To learn how to opt out of online interest-based advertising (or, as it may be called in some jurisdictions, targeted advertising), please follow the instructions in the Your Choices and Rights section below.

3.5 To Protect The Rights Of DLMvn And Others

DLMvn may use your personal data as we believe to be necessary or appropriate in order to:

Protect against, identify, and prevent fraud and other unlawful activity, claims, and other liabilities.
Secure, protect, and defend the privacy, safety, or property of the DLMvn Services, and our employees and agents, or users.
Comply with and enforce legal requirements, including laws outside your country of residence, relevant industry standards, contractual obligations, and our terms of service and other policies.
Respond to inquiries from third parties, including inquiries from law enforcement authorities.

We may combine information we obtain about you for the purposes identified in this Section 3. We may use information we collect from you in other ways for which we provide specific privacy notices at the time of collection.

4. DATA SHARING

We may share your personal data with:

4.1 Our Subsidiaries and Affiliated Businesses

We may share your personal data with our subsidiaries and affiliated companies (collectively, “DLMvn Affiliates”) for the purposes described in this Privacy Notice, including for each company’s marketing purposes (with your consent if required by applicable law). A list of DLMvn Affiliates is available in annual reports accessible here. Users who visit DLMvn Affiliates’ services should still refer to their separate privacy policies, which may differ in some respects from this Privacy Notice.

4.2 Subscription/Access Providers

If your subscription or other access is provided in whole or in part by your employer, educational institution, or other third party, we may share with them information about your access to and use of your subscription or other product or service, including for access through educational institutions, your name, and email address.

4.3 Our Service Providers

We may share some or all of your personal data identified above, as necessary for the specific services, with our service providers, who provide services to us or to you on our behalf (e.g., sending email or Text Messages on our behalf, processing payments, fulfilling orders or delivering subscriptions, or improving or customizing the DLMvn Services). These third-party service providers are not authorized to use it for any other purpose than the specific service they are providing to us or to you on our behalf.

4.4 Our Business Partners

We may share your data with business partners to provide you with co-branded services or features that you participate in, such as conferences, events, contests, sweepstakes, or other promotions (“Co-Branded Services”). These Co-Branded Services may be hosted by the DLMvn Services or on the third party’s service. The business partner’s use of your information will be governed by its privacy notice.

4.5 With Third Parties for Direct Marketing

We may share your information with third-party partners whose offerings we think may be of interest to you. For example, if you subscribe to the U.S. edition of The Wall Street Journal or Barron’s print publications, we may share your print mailing address with unaffiliated third-party companies whose products and services may be of interest to you. While many of our subscribers appreciate receiving offerings from these companies, if you prefer that we do not share your information for this purpose, please refer to the Your Choices and Rights section below.

The above paragraph does not apply to personal data collected through our WSJ Amenity Text-To-Me Service.

4.6 With Social Networking Services

As discussed in Section 2.3 of our Privacy Notice and in our Social Networking Services Notice, we may share your information when you log into or connect a social media service account with the DLMvn Services. The Services may also offer you the ability to share information to a social networking site (e.g., Facebook, Twitter), by using integrated tools (e.g., Facebook “Like” button, or Twitter “Tweet” button). To control this sharing of information, please review and adjust your privacy settings for the relevant social network. The social networking service’s use of the shared information will be governed by its privacy notice.

4.7 For Legal Requirements and Proceedings

We may disclose your personal data to law enforcement authorities or other government officials if we are required to do so to comply with subpoenas, court orders, legal processes, or other government measures, and to comply with other legal obligations. We may also disclose information if we believe disclosure is necessary or appropriate in connection with an investigation of suspected or actual fraud or illegal activity.

4.8 With Other Third Parties To Complete A Corporate Transaction

We may disclose information we have about you in the event we sell or transfer all or part of our business or assets (including in the event of a merger, reorganization, dissolution, or liquidation) to the third party or its advisors involved in such corporate transaction.

4.9 With Third Parties for the Protection of the Services and Our Users

We may disclose your personal data to protect and defend the rights, interests, and safety of the Services and our users, our subsidiaries and affiliates, and our and their employees, contractors, and agents; and to protect the security of our Services, including when we believe necessary or appropriate to prevent physical harm or financial loss.

5. YOUR CHOICES AND RIGHTS

5.1 Your Choices

We offer you many choices and you may have certain rights in connection with the personal data we collect about you.

5.1.1 Email Communications

You may ask us to remove your information from our marketing mailing lists by changing your account settings through the appropriate link on the website account services page. For example, WSJ subscribers and registered users may update their marketing and newsletter preferences at the following link: Wall Street Journal Emails and Alerts. You can also unsubscribe from our marketing mailing lists by following the “Unsubscribe” link at the bottom of each email. Even if you unsubscribe from our marketing communications, we may still need to send you communications related to your use of the DLMvn Services, such as account-related information, service announcements, or personalized communications about your home-delivery account.

5.1.2 Push Notifications and Text Messages

If you have installed a mobile app and you wish to stop receiving push notifications, you can change the settings either on your mobile device or through the app. You can opt out of text message alerts at any time by following the instructions in the text message you receive.

5.1.3 Sharing Print Customer Information With Unaffiliated Third Parties

If you are a WSJ U.S. edition or Barron’s print subscriber, you may also opt out from our sharing of your print mailing address with unaffiliated third parties for their direct marketing by contacting Customer Service.

5.1.4 Browser Controls

You have choices about whether cookies or similar technologies are placed on your computer or mobile device. For more information, visit our Cookie Notice.

You may also choose to opt out of our use of data that we or our third-party service providers collect about your activities to provide you with tailored advertising about products or services of interest to you. To learn more about how to opt out of such interest-based advertising, please see the “How You Can Manage Cookies” section in our Cookie Notice or visit the consumer opt-out pages at DAA or NAI.

5.1.5 To Change Mobile App Privacy Settings

You may change the privacy settings for DLMvn apps by accessing and updating privacy settings and permissions within the mobile app or on your mobile device.

5.2 Your Rights

Subject to applicable law, you may have certain rights to access, review, update, correct inaccuracies in, or delete your personal data in our custody and control by submitting a request here, or by contacting us as specified in the “Contact Us” section below.

For security purposes, we will seek to verify your identity – in part by requesting certain information from you – as part of our process. For instance, you may need to provide your name and email address. For certain types of requests, we may also need to ask you for additional information to verify your identity. Once we have verified your identity, we will respond to your request as appropriate.

5.2.1 The Right to Access and Rectification or Correction

You may have the right to access, correct, or update your personal data at any time. Additionally, online subscribers and registered users may access their personal data online by signing into their accounts and visiting the appropriate account management sections of our websites. Please note that if you have subscribed or registered for our print and online editions, or for more than one of our publications or services, you may need to update your information for each separately.

Where you have provided your consent for our use of your personal data, you have the right to withdraw your consent and we will apply your preferences going forward.

5.2.2 The Right to Deletion

Under certain circumstances, you may have the right to request that we delete your data. If you wish to delete the personal data we hold about you, please let us know and we will take reasonable steps to respond to your request in accordance with applicable legal requirements. Certain data may be exempt from such requests under applicable law. We may also need to retain certain types of data so that we can provide the DLMvn Services to you. If you ask us to delete your data, you may no longer be able to access or use our Services.

5.3 For California Residents

For additional information for residents of the State of California, click here.

5.4 For Colorado, Connecticut, Virginia & Utah Residents

For additional information for residents of the States of Colorado, Connecticut, the Commonwealth of Virginia, and Utah, click here.

5.5 For Nevada Residents

If you are in Nevada, you may have the right to request that we do not “sell” (as defined under Nevada law) your personal data by submitting a request here.

5.6 For Residents of the European Economic Area and the United Kingdom

For additional information for residents of the United Kingdom or a country that is a Member of the European Union or European Economic Area, click here.

6. HOW WE PROTECT PERSONAL DATA

DLMvn uses a combination of administrative, technical, organizational, and physical measures to safeguard personal data in its possession against accidental, unlawful, or unauthorized loss, use, access, disclosure, or modification. We make reasonable efforts to ensure a level of security appropriate to the risk of the processing, taking into account the costs of implementation and nature of the processing of personal data. However, no one can guarantee the complete safety of your information. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by contacting us as set forth in the Contact Us section below.

7. OTHER IMPORTANT INFORMATION

7.1 Do Not Track Disclosure

Some browsers or other tools include “Do Not Track” (DNT) features which, when turned on, send a signal to websites you visit indicating you do not wish to be tracked across websites over time. However, since no technology standard for DNT signals has been developed or adopted to date, DLMvn does not currently respond to DNT signals.

7.2 Transfers of Personal Data

Your personal data may be stored, transferred to, and processed in any country where we have facilities or in which we engage service providers. These countries may be outside your country of residence, including the United States, and may have different data protection laws than in the country in which you initially provided the data. Applicable laws in the United States and/or other countries may allow the courts, law enforcement, and national security authorities to access your personal data when in such country.

If you are a user located outside the United States or the country to which your information may be transferred, you understand (and, as permitted under applicable law, consent to) having any personal data processed in the United States or such country. When we transfer your data, we will protect that data as described in this Privacy Notice.

7.3 Collection of Personal Financial Information by a Payment Service

In some cases, we may use an unaffiliated payment service to allow you to purchase a product or service or make payments (“Payment Service”). If you wish to purchase a product or service or make a payment, in such a case, you will be directed to a Payment Service webpage. Any information that you provide to a Payment Service will be subject to the applicable Payment Service’s privacy notice, rather than this Privacy Notice. We have no control over, and are not responsible for, any Payment Service’s use of information collected through any Payment Service.

7.4 Links to Affiliates and Third-Party Sites or Apps

The DLMvn Services may also be linked to sites or apps operated by third parties and may carry advertisements or offer content, special offers, functionality, games, or applications developed and maintained by third parties, using iframes, tools, or plug-ins (“Linked Services”). These third-party Linked Services may use automated means to collect information about you and your use of these features. Some of these third-party sites may be co-branded with a DLMvn logo, even though they are not operated or maintained by us.

DLMvn is not responsible for the privacy practices of such third parties, and once you leave the DLMvn Services or click an advertisement, or sign up for a special offer, you should check the applicable third-party privacy notice.

7.5 Updates to Privacy Notice

DLMvn may periodically update this Privacy Notice without prior notice to reflect changes in our privacy practices and the DLMvn Services. If we modify the Privacy Notice, we will update the Effective Date and the changes will become effective as of the date we post such Notice. We will notify you of any material changes by posting a prominent notice on the DLMvn Services indicating we have updated this Privacy Notice.

8. CONTACT US

If you have questions about this Privacy Notice or how we or our service providers handle your personal data, please contact our privacy team at email@dlm.vn.

Or you may write to: Attention: Privacy
DLMvn & Company, Inc.
8213 U.S. Route 1 North
Monmouth Junction, NJ 08852

If you are located in the EU/EEA or UK, the entity responsible for the collection and processing of personal data in connection with the DLMvn Services is DLMvn & Company, Inc. (U.S.) (contact information provided above). If you have a corporate or group subscription agreement, the entity responsible for the collection and processing of your personal data is the entity with whom your company, professor, or school has a direct relationship (e.g. by contract).