At Nudge, Inc., our mission is to help people reach their financial goals. We want you to understand how we handle your personal information. We also want you to know your rights and choices.
This policy describes how we handle your personal information when you use the “Nudge, Inc.,” listed below:
Our websites, like Nudge.solutions
Our apps, like the Nudge Solutions app
Our pages or ads on social media networks, like our Facebook and Instagram pages
How we handle information about you depends on which Nudge, Inc. you use — and how you use them. For example, we use different information about free subscribers and premium subscribers
Be aware that certain Nudge, Inc. work differently. Some have additional terms that supplement this policy.
What Information Do We Gather about You?
The information we gather about you depends on the context. By and large, it’s information about you that can personally identify you — either on its own or when combined with other information.
The following describes the information we collect and how we obtain it.
(A) Information Collected through Nudge, Inc.
- information You Voluntarily Give Us
For Registration: When you sign up for a Nudge, Inc. Service (e.g., a subscription), we collect your contact information and account credentials. Once you’re registered, we assign you a unique ID number. This ID number helps us recognize you when you’re signed in.
For Billing: to process payments or donations, we collect and use your payment information. This can include your name, your address, your telephone number, your email address, your credit or debit card information and any other relevant information.
For User-Generated Content: We offer you the ability to post content that other users can read (e.g., comments). Anyone can read, collect and use any personal information that accompanies your posts. See the Comments F.A.Q., or read the User-Generated Content section in our Terms of Service for more information. We do not have to publish any of your content. If the law requires us to take down, remove or edit your personal information, we will comply to the required extent.
For Reader Surveys, Research, Panels and Experience Programs: We gather information through questionnaires, surveys and feedback programs, including demographic information like your age, ethnicity, race, or gender. We also conduct similar research for advertisers. We ask you for your consent to use this information when you participate in these programs and events.
Personal Contacts Data: We never scan your device for your contacts or upload that data. With your consent, we do comply with your requests to collect data about your friends, family or acquaintances (e.g., Refer a Friend campaigns). This functionality is only meant for U.S. residents. By using it, you acknowledge and agree that both you and your contacts are based in the United States — and that you have everyone’s consent for us to use their contact information.
Information Collected Automatically:
When you use Nudge, Inc., we collect some information automatically. The technologies we use to assist with this data collection include cookies, web beacons, tags and scripts and software development kits (or SDKs). We use these technologies on our digital properties, including our websites and apps, as well as in our email communications.
- The categories of personal information we collect automatically include:
Identifiers and Device Information:
When you visit our Services, including our websites, apps, and email communications, our servers automatically log information about the device you are using, including unique identifiers. If your browser doesn’t accept our cookies or similar technologies, you can’t access certain parts of our websites (e.g., your account). The items we log include:
Your IP address
Your operating system and browser (e.g., type, version, and configuration)
Your browser language
Device identifiers (such as MAC address)
- We combine this data with other information we collect about you.
Other Usage Data:
We collect certain internet and network activity on our Services, including our websites and apps, such as the URLs of any pages you visit on our sites and apps, the URL of the website from which you came to our sites, how long you spent on a page, access times and other details about your use of and actions on our Services.
A Note about Sensitive Personal Information
We generally don’t want to gather sensitive information about you. This includes:
Government-issued IDs (such as your driver’s license, passport or social security number)
Your racial or ethnic origin
Your political opinions
Your religion or other beliefs
Your health, biometric or genetic characteristics
Any trade union membership
Your sexuality (information about your sex life or sexual orientation)
Any criminal background
The content of your private communications (other than messages you may send to us)
However, some laws define account access information, such as a username and password, as sensitive personal information, but we collect that information only for the accounts you create directly with us and not for any other account you may have with a third party.
Finally, there are situations when we request certain of the above information , but you can decline to answer. Outside those situations we would prefer you never share these types of information with us.
(B) Information We Create or Generate.
We infer new information from other data we collect, including using automated means to generate information about your likely preferences or other characteristics (“inferences”).
(C) Information Collected from Other Sources.
Privately Owned Databases:
Marketing, data analytic and social media-owned databases give us access to a range of information — like public data, survey data and more. This data sometimes includes your mailing address, your gender, your age, your household income and other demographic data.
Social Media Platforms and Other Third-Party Services:
(Social media platforms include services like Facebook. Third-party services include services like Google)
You can link your social media or other third-party account to a Nudge, Inc. Service. By linking the services, you authorize us to collect, store and use any information they may give us (e.g., your email address).
We also receive information from you when you interact with our pages, groups, accounts or posts on social media platforms. This includes aggregate data on our followers (e.g., age, gender and location), engagement data (e.g., “likes,” comments, shares, reposts and clicks), awareness data (e.g., number of impressions and reach) and individual users’ public profiles.
What Do We Do with the Information We Collect about You?
(A) We Provide Nudge, Inc..
- We use your information to help you use and navigate Nudge, Inc., such as:
Making Nudge, Inc. available to you
Arranging access to your account
Providing customer service
Responding to your inquiries, requests, suggestions or complaints
Completing your payments and transactions
Sending service-related messages (e.g., a change in our terms and conditions)
Letting you take part in paid services, polls, promotions, surveys, panels, research and comments.
(B) We Personalize Your Experience.
We track your interests to personalize your experience using technology like algorithmic recommendations and machine learning. We also show you prices, promotions, products or services we believe you’ll find interesting, based on demographic and usage data.
(C) We Develop Products and Services, and Do Analysis.
We analyze data on our users’ subscriptions, purchases and usage behaviors. This helps us make business and marketing decisions.
For example, our analysis, which includes the use of technology like machine learning, lets us predict preferences and price points for our products and services. It helps us determine whether our marketing is successful. It also shows us characteristics about our subscribers, which we sometimes share in aggregate with advertisers.
Google Analytics is one of the analytics providers we use. You can find out how Google Analytics uses data and how to opt out of Google Analytics.
(D) We Carry Out Administrative Tasks.
For auditing: We verify that our internal processes work as intended and comply with legal, regulatory and contractual requirements.
For fraud and security monitoring: We detect and prevent cyberattacks or unauthorized robot activities.
For customer satisfaction: We assess users’ satisfaction with Nudge, Inc. and our customer care team.
(E) We Advertise or Market Nudge, Inc. to You.
We market our Nudge, Inc. to you. Sometimes we use marketing vendors to do this.
We serve ads through websites, locations, platforms and services operated and owned by third parties. Often these ads are targeted at people who have visited or registered for a Nudge, Inc. Service but have not subscribed to or purchased anything. The ads are also targeted at people with similar traits or behaviors to our subscribers or customers.
(F) We Aggregate (or De-identify) Personal Information into Larger Findings.
Sometimes we aggregate or de-identify information so that it can no longer identify you, as defined under applicable laws. This helps us better understand and represent our users, such as when we measure ad performance, create advertising interest-based segments or compile survey results. We can use and disclose this aggregated or de-identified information for any purpose, unless an applicable law says otherwise.
To Whom Do We Disclose the Information We Gather?
(A) Within Nudge, Inc. Company:
Our affiliates may access your information for the purposes listed here.
(B) With Service Providers:
- We work with service providers, as defined above, to carry out certain tasks, including:
Processing your payments
Fulfilling your orders
Maintaining technology and related infrastructure
Offering you customer service
Serving and targeting ads
Measuring ad performance
List processing and analytics
Managing and analyzing research
When performing these tasks, service providers may have access to your personal information.
We sometimes allow them to use aggregated or de-identified information for other purposes, in accordance with applicable laws.
(C) With Other Third Parties:
There are situations when we disclose your information to third parties beyond our service providers.
It is worth noting how practices of certain vendors and changes in law outside of our control have changed what we can say about this.
While we try to control the behavior of our vendors that we understand to be service providers, some of those vendors engage in activities beyond our control that may be seen by a regulator as the activities of “third parties,” not service providers.
The following provides more information about the circumstances in which we know we are disclosing personal information to third parties that are not service providers.
i. We provide information to websites, locations, platforms and services operated and owned by third parties in connection with marketing, as described in Section2(e) above.
ii. We provide information about participants in our sweepstakes, contests and similar promotions to the promotions’ sponsors. In those cases, we notify you when you provide us the information.
iii. We process payments you make through Nudge, Inc. with external services. There are two ways this can happen:
We collect your information and provide it to the third-party service for processing.
The third-party service collects your information for processing.
iv. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we would have a legitimate interest in disclosing or transferring your information to a third party — such as an acquiring entity and its advisers.
v. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we would have a legitimate interest in disclosing or transferring your information to a third party — such as an acquiring entity and its advisers.
Comply with the law or with legal process
Protect and defend our rights and property
Protect against misuse or unauthorized use of the Nudge, Inc.
Protect the safety or property of our personnel, users or the general public (e.g., if you provide false information or attempt to pose as someone else, we could share your information to help investigations into your actions)
Cooperate with government authorities, which could be outside your country of residence.
vi. We disclose public activities in our RSS feeds, APIs and other distribution formats. Your public activities could thus appear on other websites, blogs or feeds.
What Are Your Rights and Choices?
We provide a variety of ways for you to control the personal information we hold about you, including choices about how we use that information. In some jurisdictions, these controls and choices are enforceable as rights under applicable law.
(A) In General
- Communications Preferences
The choices described below are limited to the email address, phone or device used. They won’t affect subsequent subscriptions.
We offer a variety of commercial emails and email newsletters. You can unsubscribe from them by following the instructions near the bottom of the email.
Mail or Telephone Promotions:
You can ask us to unsubscribe from our mail or telephone solicitations. In some jurisdictions, as discussed elsewhere in this Policy, you can also ask us to not share your information with third parties for marketing purposes. To do so, call us. You may also email us with “Opt Out” in the subject line and your account number and phone number in the body of the email.
You can opt out any time by adjusting your device settings, or uninstalling our app.
You can opt out of text alerts any time by replying “STOP,” or any alternative keyword we’ve shared with you.
We complete any opt-out request as quickly as we can. This opt-out request won’t prohibit us from sending you important nonmarketing notices.
ii. Access, Correct, Change/Update, Delete or Restrict Processing of Your Personal Information
In some jurisdictions, you may exercise the following choices:
Access, modify or delete the personal information we have about you
Be informed of or receive an electronic copy of the personal information we have about you, for data portability.
Restrict, or object to, how we process personal information about you
For example, in the European Union and the United Kingdom, you have the right to object to, or obtain a restriction of, the processing of your personal information under certain circumstances; and where the processing is based on your consent, you have a right to withdraw that consent at any time for future processing.
If you’d like to exercise any of the above choices, contact us via email at [email protected]. In your request, please be specific. State the information you want changed, whether you’d like your information suppressed from our database or whether there are limitations you’d like us to put on how we use your personal information. Please use the email address linked to that personal information — we only complete requests on the information linked to your email address. To verify your identity, we will email the email address you provide us, and which matches our records, and wait for your response. In some instances, we may also ask for additional information. This is how we verify your identity before complying.
In some jurisdictions, you can designate an authorized agent to make a request on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.
We’ll respond to your request in a manner consistent with applicable law, including any exceptions that may result in a request being denied in whole or in part.
We might need to keep certain information for recordkeeping purposes, or to complete a transaction you began prior to requesting a change or deletion (e.g., if you make a purchase or enter a promotion, you might not be able to change or delete the personal information provided until after the completion of the purchase or promotion).
In some cases, your request doesn’t ensure complete removal of the content or information (e.g., if another user has reposted your content).
iv. Browser and Platform Controls
Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our websites. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated.
Global Privacy Control:
Some browsers and browser extensions support the Global Privacy Control (“GPC”) that can send a signal to the websites you visit indicating your choice to opt-out from certain types of data processing, including data sales. In certain territories, when we detect such a signal, we will make reasonable efforts to respect your choices indicated by a GPC setting as required by applicable law.
Global Privacy Control:
Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
Mobile Advertising ID Controls:
iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.
Email Web Beacons:
Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.
Virginia Opt Out of Targeted Advertising:
Effective January 1, 2023, residents of Virginia have the choice to opt out of targeted advertising. In order to exercise your choice as a Virginia resident, please click on “Do Not Sell/Share My Information” link on the bottom of the webpage where your information is being collected.
v. Other Rights and Choices
You will not receive discriminatory treatment by us for the exercise of your privacy rights.
This Policy has been designed to be accessible to people with disabilities. If you experience difficulties accessing this Policy, please contact us at [email protected]. If you’d like, you can lodge a complaint with a data protection authority. A list of E.U. data protection authorities is available. But we encourage you to first contact us with any questions or concerns.
In some jurisdictions, you may appeal to us if we refuse to take action on your exercise of certain choices described above. In order to appeal such a refusal, please contact us at [email protected], using the subject line “Appeal of Refusal to Take Action on Privacy Request” and provide the relevant information in the email.
(B) California Privacy Rights
If you are a California resident, you have certain rights with respect to your personal information.
i. Notice at Collection
At or before the time of collection, you have a right to receive notice of our practices, including the categories of personal information and sensitive personal information to be collected, the purposes for which such information is collected or used, whether such information is sold or shared and how long such information is retained.
ii. Rights to Know, Correction and Deletion
iii. “Do Not Sell or Share My Personal Information”
To the extent Nudge, Inc. “sells” your personal information (as the term “sell” is defined under the CCPA), you have the right to opt-out of that “sale” on a going-forward basis at any time.
If you’re a California resident, you have a right to opt-out from the “sale” or “sharing” of your personal information with third parties who are not our service providers (as those terms are defined under the California Consumer Privacy Act and the California Privacy Rights Act, or “CCPA” for short in this Policy). To exercise this right, click the Do Not Sell/Share My Information link on the bottom of the webpage where your information is being collected or go to “Account” and then “Settings” and “About This App” and click the “Do Not Sell/Share My Information” link there. You can also submit a request to opt-out by emailing us at [email protected] with the subject line “California Resident - Do Not Sell or Share.” Finally, if your browser supports it, you can turn on the Global Privacy Control to opt-out of the “sale” or “sharing” of your personal information.
If you have an account with Nudge, Inc. and are logged in, we will save your preference and honor your opt-out request across browsers and devices so long as you remain logged in. If you are not logged in, or do not have an account with any Nudge, Inc. listed above, your opt-out of the “sale” or “sharing” of personal information will be specific to the browser or device from which you have clicked “Do Not Sell/Share My Personal Information” and until you clear your cookies (or local storage in apps) on this browser or device.
We do not knowingly “sell” or “share” (as those terms are defined by the CCPA) the personal information of minors under 16 years old.
iv. Right to Limit Use and Disclosure of Sensitive Personal Information
If you are a California resident, effective January 1, 2023, you have a right to limit our use of sensitive personal information for any purposes other than to provide the services or goods you request or as otherwise permitted by law. To opt-out from such additional purposes, contact us via email at [email protected].
v. Authorized Agents
You can designate an authorized agent to make a request to exercise your rights under the CCPA on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We will contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.
vi. Non-Discrimination Rights
You may exercise any of your rights listed in this section without fear of unlawful discrimination.
vii. Record of Requests
We keep a record of requests that we received from California residents.
For data deletion and data access requests, our readers submit requests through email. In the email, they must indicate whether they reside in California. We then send an identity verification email to the user. If the user does not verify their identity in 45 days, their request will be denied. If the user does verify in 45 days, we begin to fulfill their request.
viii. California “Shine the Light” Privacy Rights
Under the California “Shine the Light” law, California residents can opt out of our sharing of their information to third parties (and sometimes affiliates) for their direct marketing purposes.
To do so, email us at [email protected] with “Shine the Light Opt Out” in the subject line and your account number and phone number in the body of the email.
ix. Removal of Content for California Minors
If you’re a California resident under 18 years old and you’re registered with a Nudge, Inc. Service, you can ask us to remove content or information you’ve posted to a Nudge, Inc. Service. Email us at [email protected] with “California Under 18 Content Removal Request” in the subject line and tell us what you want removed. We will make reasonable efforts to remove the post from public view, although we cannot ensure the complete removal of the content and may retain the content as necessary to comply with our legal obligations, resolve disputes and enforce our agreements.
5. How Long Do You Retain Data?
We store your personal information for as long as needed, or permitted, based on the reason why we obtained it (consistent with applicable law). This means we might retain your personal information even after you close your account with us.
When deciding how long to keep your information, we consider:
How long we have had a relationship with you or provided a Nudge, Inc. Service to you
Whether we are subject to any legal obligations (e.g., any laws that require us to keep transaction records for a certain period of time before we can delete them)
Whether we have taken any legal positions (e.g., in connection with any statutes of limitation).
Rather than delete your data, we might de-identify it by removing identifying details.
6. How Do You Protect My Information?
We protect your personal information with appropriate organizational, technological and physical safeguards — but we cannot guarantee its absolute security. We recommend that you use complex and unique passwords for your Nudge, Inc. accounts and for third-party accounts linked to them. Do not share your password with anyone.
If you have reason to believe your interaction with us is no longer secure, notify us immediately.
7. Are There Guidelines for Children?
Nudge, Inc. are intended for a general audience and are not directed at children under (13) years of age.
We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or COPPA) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at [email protected]. We will remove the data to the extent required by applicable laws.
8. How Is Information Transferred Internationally?
The New York Times Company is headquartered in the United States. If you are located outside the United States, your information is collected in your country and then transferred to the United States — or to another country in which we (or our affiliates or service providers) operate.
In certain situations, the courts, law enforcement agencies, regulatory agencies or security authorities in those countries might be entitled to access your personal information.
9. What Is Our Legal Basis?
In some jurisdictions, like the European Union and the European Economic Area, we only collect, use or share information about you when we have a valid reason. This is called a “lawful basis.” Specifically, this is one of the following:
The consent you provide to us at the point of collection of your information
The performance of the contract we have with you
The compliance of a legal obligation to which we are subject, or
The legitimate interests of Nudge, Inc. or a third party. “Legitimate interest” is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights and interests. “Legitimate interest” also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact.
We have a legitimate interest in gathering and processing personal information, for example: (1) to ensure that our networks and information are secure; (2) to administer and generally conduct business within Nudge, Inc.; (3) to prevent fraud; and (4) to conduct our marketing activities.
10. What about Third-Party Services?
As mentioned above, some Nudge, Inc. are offered on third-party digital properties (such as third-party websites, frameworks, and domains) which can affect our data practices and your data preferences. For example, we use Google AMP to help Nudge, Inc. load quickly on mobile devices. We also use third-party properties to facilitate other Nudge, Inc..
If you set your data preferences while using one of these third-party digital properties, your preferences will only be saved with respect to Nudge, Inc. on that specific third-party digital property. Your preferences will not carry over when you use the Nudge, Inc. on Nudge, Inc.s’s own digital properties. And, your preferences will only be saved on Google AMP and other third-party digital properties until your cookies are cleared. Once your cookies are cleared, you will need to reset your data preferences for each third-party digital property used to access Nudge, Inc..
If your browser settings allow for cross-site tracking (e.g., allows for trackers to follow your preferences across websites), you can set your preferences on The Times’s digital properties so that your preferences will be remembered when you access the Nudge, Inc. through Google AMP. However, if your browser settings do not allow for cross-site tracking, your preferences on The Times’s own digital properties will not carry over to the Nudge, Inc. you access through Google AMP.
If you are an European resident and you do not accept trackers (other than essential trackers) while using Nudge, Inc. on AMP, you will be served non-personalized ads. If you do not accept trackers (other than essential trackers) while using the Nudge, Inc. on Nudge, Inc.’s digital properties, you will receive Nudge, Inc. ads or no ads at all.
We will post any changes on this page by updating this policy. If we make a significant or material change in the way we collect, use or share your personal information, we will notify you at least 30 days prior to the changes taking effect. We will do this via email or prominent notice within Nudge, Inc.. If you object to any change, you can stop using Nudge, Inc..
12. How Can You Contact Us? Who Is the Controller of Your Personal Information?
If you have any questions, email us at [email protected].