RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM PRIVACY POLICY

5.6 FOR RESIDENTS OF THE EUROPEAN ECONOMIC AREA AND THE UNITED KINGDOM

This section of the Privacy Notice applies if you are in the United Kingdom or in a country that is a member of the EU/EEA and supplements the Privacy Policy.

Zhengming is the data controller of your personal data as defined under the UK Data Protection Act of 2018 and the EU GDPR.

Legal Basis for Data Processing

In addition to the purposes for which we collect and process your Personal Data as set out in the Privacy Policy, we do so under the following legal basis:

We process your personal data as necessary to perform a contract that we have with you. For example, we need to process your personal data to deliver a product or service you bought, to allow you to take part in one of our sweepstakes or competitions, or to send you a trial subscription that you have requested.

We process your personal data for certain purposes with your consent; for example, to select personalized ads. Please see the section of this notice titled Third Party Online Advertising below. Where you have given consent for processing activities, you have the right to withdraw your consent at any time.

We sometimes use your personal data on the ground that there is a legitimate reason to do so. For example, we may use your information where it would help achieve our business objectives or to facilitate a benefit to you. We only rely on legitimate interests if the reason for using your information is fair and lawful. Our legitimate interests in processing personal data include:
• To support a free press, including journalistic activities of societal importance;
• To support individual and societal rights to receive information;
• To develop, deliver and maintain relevant and engaging products, services and some aspects of advertising;
• To understand when our audiences engage with us or other organizations;
• To build a clearer understanding of who our audiences are in order to better serve them;
• To protect the safety and interests of Zhengming (including our employees and journalists) from harm or threats of harm; and
• To carry on the business of a commercial organization.
We also process your personal data when we have a legal or regulatory obligation or to defend claims.

UK/EU/EEA Data Subject Rights

In addition to the rights of access, correction or rectification and deletion or erasure, as described in the Privacy Policy, UK and EU/EEA data subjects have other rights over how their personal data is processed and can exercise these right at any point in time. Below is an overview of these rights, many of which are subject to exceptions under applicable law.

The right to object to or restrict processing. Under certain circumstances, you have the right to object to or restrict our processing of your personal data. For example, where we process personal data based on our legitimate interests, you may object to this. We will need to carefully consider your request, as there may be circumstances which require us, or allow us, to continue processing your personal data. However, you have an absolute right to object to our processing of your personal data for direct marketing purposes, and no exception applies to such a request.

The right to data portability. You have, subject to certain exceptions, the right to obtain a copy of your personal data in a structured, machine-readable format, and to ask us to share this data to another controller.

The right to withdraw consent. If you have given your consent to process your personal data, you have the right to withdraw that consent at any time by taking the actions explained in the “Your Choices” section of the Privacy Policy. This will not affect the lawfulness of the processing based on your consent before its withdrawal.

The right to lodge a complaint with a Supervisory Authority. You have the right to lodge a complaint directly with the relevant Supervisory Authority about how we process your personal data.

Retention of Personal DataWe will keep your personal data for as long as we need it to fulfill the purposes set out in our Privacy Notice, or while there is a legitimate reason for doing so, and as otherwise required or permitted by applicable law, such as in relation to our record retention obligations.

International Data TransfersAs the Services are hosted in the United States, the personal data of our UK/EU/EEA users is hosted in the United States, and we may further transfer such personal data to countries that may not have data protection rules that require the same level of protection as in the UK/EU/EEA, however, we will put in place appropriate mechanisms and controls to protect your data. We may use these data transfer mechanisms – and not consent – as the legal basis for our own transfers of personal data from within the UK and EEA (even when other aspects of our handling of personal data take place based on consent).

Third Party Online AdvertisingWe enable certain third party advertising exchanges to place advertisements on our sites, as further described in our Cookie Notice. With your consent, those advertising exchanges collect your IP address and/or a unique advertising ID that is used by the advertising exchange to identify you across the internet. Please see our Cookie Notice for more information about managing cookies and other similar technologies.

The European Digital Advertising Alliance (“EDAA”) has developed a guide to online behavioral advertising and has developed an opt-out page to manage online behavioral advertising preferences with EDAA member companies available at www.YourOnlineChoices.eu In addition, we participate in the IAB Europe Transparency and Consent Framework (the “Framework”) and operate a Consent Management Platform that helps us to comply with its specifications and policies.