Privacy Policy

1. Personal Data We Collect from You

This Privacy Policy applies to the personal data that we obtain in various contexts. We use the term “personal data” – also called “personal information” or “personally identifiable information” in the laws of some jurisdictions – to refer to information that reasonably identifies, relates to, describes, or can be associated with you. Data that has been deidentified or that otherwise cannot reasonably be related back to a specific person is not considered personal data.

The following are the categories and types of personal data that we or our third-party partners may collect from or about you, depending on how you interact with the Properties:

• Identifiers and contact information, such as your name, email, mailing address, phone number, and account name;

• Commercial information, such as credit card number, debit card number, or any other financial information; records of products or services purchased, obtained, or considered; records of donations made; or other purchasing or consuming histories or tendencies;

• Professional or employment-related information, such as your job title, employer, employment history, or resumes and CVs;

• Geolocation or other information that permits us to determine your location;

• Device and online identifiers and related information, including internet protocol (IP) address, mobile ad identifiers, data collected from cookies, beacons, and pixel tags, and similar unique identifiers;

• Internet or other electronic network activity information, including, but not limited to, browsing history, search history, and information regarding your interaction with an internet website, application, mobile app, or advertisement; and

• Any other personal data that you voluntarily provide us.

2. How We Collect Your Personal Data

Personal Data You Provide

We collect personal data that you provide to us directly. This may include, but is not limited to:

• Information you provide when you contact us via email or through other Internet-enabled communications;

• Information you provide when you create a profile or account, or subscribe to one of our Services;

• Your responses to surveys that you choose to complete for us;

• Information you provide when you enter a contest or other promotion sponsored by us;

• Details relating to transactions that you carry out through our Properties, including any orders that you ask us to fulfill, and any payment or other financial information you provide to us relating to such orders;

• Details relating to donations that you make via the Properties; and

• Any other information that you provide us on or through the Properties.

Personal Data We Collect Automatically

When you visit our Properties, open or click on emails we send you, or interact with our advertisements, we or third parties we work with may automatically collect certain information using technologies such as cookies and other tracking technologies described below.

• Cookies and Similar Technology

"Cookies" are pieces of information that may be placed on your computer by a website for the purpose of collecting data to facilitate and enhance your communication and interaction with that website. Such data may include, for example, the address of the websites you visited before and after you visited our Properties, the type of browser you are using, your Internet Protocol (IP) address, what pages in the Properties you visited and what links you clicked on, the region where your device is located, and geographic information based on your IP data. We may store some information on your device or device hard drive as a cookie or similar type of file (such as clear gifs, web beacons, tags, and similar technologies that work on mobile devices) to collect data related to usage of the Properties. We may also use cookies to customize your visit to the Properties and for other purposes to make your visit more convenient or to enable us to enhance the Properties and Services. For additional information about our use of cookies on the Properties, please see the section below titled Cookies and Your Choices. 

• Tracking Pixels

We use tracking pixels to collect information from users of our Properties. A tracking pixel is a transparent graphic image (the size of a 1x1 pixel on your device screen) that is placed on a webpage of our Properties and, in combination with cookies, allows us to collect information regarding your use of that webpage. We may also place tracking pixels in our email messages to collect information regarding your interaction with our email and any URL links included in the contents of the email. These tracking pixels trigger ads on participating websites and tell us when an advertisement we run on another website has been clicked on. This information helps us evaluate which advertisements are more appealing to users.

• Clickstream Data

As you use the Internet, a trail of electronic information is left at each website you visit. This information, which is sometimes referred to as "clickstream data," can be collected and stored by a website's server. Clickstream data can tell us the type of computer and browsing software you use and the address of the website from which you linked to the Properties. We may collect and use clickstream data as a form of aggregate information to anonymously determine how much time visitors spend on each page of our Website or App, how visitors navigate throughout the Properties, and how we may tailor our web pages to better meet the needs of visitors. This information will be used to improve our Properties and our Services.

• Analytics

We may work with third-party vendors who use the technologies described in this section to conduct website analytics to help us track and understand how visitors use our Properties and other Services. One such provider is Google Analytics, a web analytics service provided by Google LLC (“Google”). Google Analytics uses cookies to help analyze how users use the Website. The information generated by these cookies about your use (including your IP address) will be transmitted to and stored by Google on servers in the United States. Google will use this information for the purpose of evaluating your use of the Website, compiling reports on activity for its staff, and providing other services relating to web page activity and internet usage. Google may also transfer this information to third parties where required to do so by law, or where such third parties process the information on Google's behalf. You may refuse the use of cookies by selecting the appropriate settings in your browser. By using the Website and accepting cookies, you consent to the processing of data about you by Google in the manner and for the purposes set out above. Please refer to the currently available opt-outs for Google Analytics by visiting https://tools.google.com/dlpage/gaoptout/. You may obtain additional information about Google Analytics by visiting the section titled "How Google uses information from sites or apps that use our services,” located at www.google.com/policies/privacy/partners/.

• Social Media Platforms and Networks

If you interact with us on social media or use features, such as plugins, widgets, or other tools made available by social media platforms or networks in connection with our Properties, we may collect information that you share with us on social media or that such platforms share with us. Please review the privacy policies and settings of the social media platforms and networks that you use for more information about their privacy practices.

• From Other Sources

We may obtain information about you from other sources, such as data analytics providers, marketing or advertising vendors, fraud prevention vendors, vendors that provide other services on our behalf, or publicly available sources.

3. How We Use Your Personal Data

We collect and use personal data for the following purposes:

• To communicate with you, which may include: contacting you about and providing you and our clients with our Services; responding to your direct inquiries, requests, issues or feedback, and providing customer service; and adding you to our mailing lists and sending you emails from time to time;

• To provide our products and services, which may include: operating the Properties, and providing you with any specific services that you have requested; creating, maintaining, and otherwise managing your account, profile, or subscription; delivering content and product and service offerings relevant to your interests; and fulfilling your orders and/or completing the transactions you have requested, processing your payments and donations, and providing you receipts and order updates;

• For marketing and promotional purposes, which may include: marketing Company goods and services or those of our affiliates, business partners, and other third parties; providing you advertising for products and services that may be of interest to you; building groups of readers with shared interests, sometimes called audiences, so that advertisers can reach readers likely to be interested in their messages on our Properties and across other websites and apps; and administering sweepstakes, contests, and other similar promotions;

• For analytics and personalization, which may include: identifying trends and making inferences about you and your interactions with us or our affiliates or our business partners; conducting research and analytics to improve our services and product offerings or those of our affiliates and business partners; understanding how you interact with our Properties, advertisements, and communications with you to determine which of our products or services are the most popular, and to improve our Properties and marketing campaigns; and providing personalized recommendations about our products and services;

• For security and fraud prevention, which may include: helping maintain the safety, security, and integrity of our Properties, databases and other technology assets, and business; detecting security incidents; protecting against malicious, deceptive, fraudulent, or illegal activity; and prosecuting those responsible for that activity; and investigating suspected fraud, harassment, or other violations of any law, rule, or regulation, or the policies for our Properties;

• To comply with legal obligations, which may include: establishing or exercising our rights and defending against legal claims; responding to law enforcement requests and as required by applicable law, court order, legal process, or governmental regulation; and acting in connection with a bankruptcy proceeding or the sale, merger, or change of control of the Company or the division responsible for the services with which your information is associated;

• For any additional purposes that you specifically consent to.

We reserve the right to supplement your personal data with information we gather from other sources which may include online and offline sources. We may collect information that is not personal data (“non-personal data”), including anonymous or aggregate data, or information lawfully made available from federal, state, or local government records. Because non-personal data does not personally identify you, we may collect, use, and disclose such information for any purpose permitted by law. In some instances, we may combine non-personal data with personal data. If we combine any non-personal data with personal data, the combined information will be treated by us as personal data to the extent that it is capable of personally identifying you. We reserve the right to develop and derive aggregate data (meaning information that relates to a group or category of individuals, from which individual identities have been removed) from personal data in order to enhance and maintain the Properties, and such aggregate data will be treated as non-personal data.

4. How We Disclose or Share Your Personal Data

In addition to using your personal data ourselves for the reasons stated above (and as otherwise mentioned in this Privacy Policy), we may disclose your personal data to other affiliates and entities in the following instances:

• Service Providers

We may share your personal data with third-party service providers who may use your information to provide us with services including, but not limited to: website hosting, certain data analytics services, infrastructure provision, information technology services, customer service, email delivery services, payment processing, order fulfillment and shipping, auditing, and anti-fraud monitoring. These service providers may have access to personal data that is necessary to perform their functions, but they are only permitted to do so in connection with performing services for us. They are not authorized by us to use the information for their own benefit.

• Corporate Affiliates

We may share personal data with our corporate affiliates and subsidiaries, who process personal data on our behalf, where necessary to provide a product or service that you have requested, or in other circumstances with your consent or as permitted or required by law.

• National Review Institute

National Review, Inc. is a wholly owned subsidiary of National Review Institute ("NRI"), and together we operate under the National Review brand. By default, donations that you make through the Properties are made to NRI. At times, donations may be requested to National Review, Inc. Clear designation of which legal entity your donation is being made to will be present at the time of donation check-out. National Review, Inc. and NRI share donor and subscriber information with each other to process donations and issue receipts, to administer your subscriptions and memberships, and to coordinate our communications with you, in each case as described in this Privacy Policy. This Privacy Policy applies to NRI’s use of that information. NRI may also rent donor and subscriber names and postal addresses to other organizations for their direct mail marketing campaigns.

• Business and Advertising Partners

We may share your personal data with third parties who partner with us to promote products and services, provide marketing and advertisements, conduct data analytics, or use the data for other commercial purposes. We do not control how these third parties use and share your personal data once they receive it. You will need to contact such third parties directly for information about their privacy practices or to exercise any rights you may have (including if you would like to opt out of marketing messages).

• Legal Compliance and to Defend Our Rights

We may disclose personal data and other information as we believe necessary or appropriate: (a) under applicable law, including laws outside your country of residence; (b) to comply with legal process; (c) to respond to requests from public and government authorities including public and government authorities outside your country of residence; (d) to enforce our Terms of Service; (e) to protect our operations or those of any of our affiliates; (f) to protect our rights, privacy, safety or property, and/or that of our affiliates, you, or others; and (g) to allow us to pursue available remedies or limit the damages that we may sustain.

• Business Transfers

We may share your personal data and other information with third parties in connection with a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of the assets of the Company, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which the assets transferred may include information about the users of our Properties.

• Non-Personal Data

We may share non-personal data with unaffiliated third parties, such as business and advertising partners, manufacturers, distributors, and retailers, to improve and enhance your experience using the Properties, and for our own market research activities. We publicly commit to maintain and use the information in deidentified or aggregate form, and not to attempt to re-identify the information.

Please note that if you specifically consent to additional uses of your personal data, we may use your personal data in a manner consistent with that consent.

5. Links to Other Sites and Social Media Services

We may create links to other websites that we think may be of interest to you, such as providers of various products and services. We may also provide links that allow you to send or forward a post from our Properties through or to third-party social media sites, or other means of electronic communication, such as an email or text messaging service. We do not endorse any other websites, providers, or services by providing such links, and this Privacy Policy applies only to your use of our Properties. We are not responsible for the privacy policies of any websites and services we link to on our Properties, and you should read the privacy policies of each site you visit to determine what data that site may collect about you.

6. Targeted Advertising

We may ourselves, or with third-party vendors, use your information to deliver targeted advertising to you when you visit our Properties or other websites. Cookies, clickstream data, and other similar technologies described above may be used in this process. For example, if you are searching for information on a particular product, we or our vendor may cause an advertisement to appear on other websites you view with information on that product. This form of advertising, sometimes called “interest-based advertising,” “online behavioral advertising,” or “cross-context behavioral advertising,” enables us and our vendors to know about your interests in connection with the delivery of a specific ad. To make the ads you see more relevant, and more valuable to the advertisers who support us, we and our advertising partners may group readers with similar interests into audiences (for example, readers who follow national security or business coverage). Advertisers can then reach those audiences on our Properties and through advertising networks on other websites and apps. We believe that such advertising is helpful because it allows you to see advertisements that are relevant to your interests.

You may opt out of receiving targeted ads from certain data and advertising partners that participate in certain industry self-regulatory programs. The Digital Advertising Alliance (“DAA”) provides a website at www.aboutads.info/consumers with information about how to opt out of targeted advertising from some or all of the DAA’s participating companies. Please note that by opting out, you will continue to see generic advertising that is not tailored to your specific interests and activities.

For targeted advertisements delivered through mobile apps, users may opt out of certain ads or reset advertising identifiers via their device settings. To learn how to limit ad tracking or to reset the advertising identifier on your iOS or Android device, visit the following links:

• iOS – https://support.apple.com/en-us/HT202074

• Android – https://support.google.com/ads/answer/2662922?hl=en.

You can also install the DAA’s AppChoices app on your device to opt out of targeted advertising by certain providers, and to select system-level advertising preferences on your device (such as “Limit Ad Tracking” on Apple devices, or “Opt-out of Interest-based ads” on Android devices).

Finally, the Network Advertising Initiative (“NAI”) provides information about how to opt out of targeted advertising on your web browser, mobile device, and smart TV or streaming device. For more information from the NAI on how to opt out of targeted advertising in these different environments, visit: https://thenai.org/how-to-opt-out/.

7. How We Protect Your Personal Data

Personal data is maintained on our servers or those of our vendors, and is accessible by authorized employees, independent contractors, representatives, and agents as necessary for the purposes described in this Privacy Policy. We use reasonable and appropriate physical, technical, and organizational safeguards designed to promote the security of our systems and protect the confidentiality, integrity, availability, and resilience of personal data. However, no method of safeguarding information is completely secure, and we cannot guarantee that our safeguards will be effective or sufficient. If you have reason to believe that your interaction with us is no longer secure, please immediately notify us of the problem by using the information in the section below titled Contacting Us.

8. Data Retention

We will retain your personal data for as long as your inquiry is active or as needed to provide you with the Properties, and for a reasonable time thereafter in accordance with our standard procedures or as necessary to comply with our legal obligations, to resolve disputes, and to enforce our agreements. Even if we delete some or all of your information, we may continue to retain and use anonymous or aggregate data, or any other data that constitutes non-personal data. While deletion is pending, we may securely store your personal data in backup archives in accordance with our routine data backup procedures, and if we do so, your data will be securely stored and isolated from any further processing until deletion is possible.

9. Cookies and Your Choices

We and our partners use cookies and similar technologies on the Properties. A cookie is a small file of letters and numbers that may be stored on your browser or on the hard drive of your device. Cookies help us distinguish you from other users of the Properties, and this enables us to improve the Properties, provide relevant advertising, and offer you a good experience.

Types of Cookies We Use

Essential cookies. These are cookies that are required for the operation of the Properties. They include, for example, cookies that enable you to log into secure areas or make use of electronic payment services.

Analytics/Performance cookies. These cookies allow us and our service providers to recognize and count the number of visitors and to see how visitors move around the Properties. This helps us improve the way the Properties work, for example, by ensuring that users can find what they are looking for easily. These cookies are not used to target you with online advertising.

Functionality cookies. These are used to recognize you when you return to the Properties. They enable us to personalize our content for you, greet you by name, and remember your preferences (for example, your choice of language or region).

Advertising/Marketing cookies. These cookies record your visit to the Properties, the pages you have visited, and the links you have followed. We use this information to make the Properties and the advertising displayed on them more relevant to your interests. We may also share this information with third parties for this purpose, as described in the section titled Targeted Advertising.

Cookies are either “session” cookies, which are deleted when you end your browser session, or “persistent” cookies, which remain until their deletion by you or the party who served the cookie.

Managing Your Cookies

You can manage the cookies on our Website by selecting “Accept All” or “Decline Non-Essential” on our cookie consent banner. Selecting “Accept All” allows us to store all of the types of cookies described above on your device, and selecting “Decline Non-Essential” allows us to store only essential cookies on your device.

Because essential cookies are needed to deliver the Properties to you, you cannot refuse them. However, you can block or delete them by activating the settings on your browser that allow you to refuse some or all cookies. Further information on cookies is available at www.allaboutcookies.org. By deleting our cookies or disabling future cookies, you may not be able to access certain areas or features of our Properties or some of their functionality may be affected. Note that cookie-based opt-outs must be performed on each device and browser on which you wish to opt out. For example, if you have opted out on your device browser, that opt-out will not be effective on your mobile device. Be advised that cookie-based opt-outs are not effective on some mobile services.

10. Opting Out of Marketing Messages

We may send you marketing messages via email. If you receive a marketing message from us, you may unsubscribe from future messages in accordance with our standard unsubscribe process (such as by using the unsubscribe link included in an email), or by sending an unsubscribe request to us at privacy@nationalreview.com. We will process your request within a reasonable time after receipt. Please note that if you opt out in this manner, certain aspects of our services may no longer be available to you. If you have signed up for text messages from us, you can reply STOP to any message at any time to stop receiving them.

11. Nevada Privacy Rights

If you are a resident of Nevada, you have the right to opt out of the sale of certain personal data that we have collected (or may collect) from you to data brokers or other third parties. You can exercise this right by emailing us at privacy@nationalreview.com with the subject line “Nevada Do Not Sell Request.”

12. Cross-Border Data Transfers

If you submit personal data to us, that information may be processed in a jurisdiction where privacy laws may be less stringent than those in your country of residence. By submitting your personal data to us, you agree to the transfer, storage, and processing of such information in foreign jurisdictions including, but not limited to, the United States. Where applicable, we may use model clauses approved by the laws of your jurisdiction (such as Standard Contractual Clauses approved by the European Commission) for cross-border data transfers. 

13. Children's Privacy

Our Properties are intended for users ages 18 and over, and we do not knowingly collect personal data from children under the age of 18. When we become aware that personal data (or other information that is protected under applicable law) from a child under 18 has been collected, we will use all reasonable efforts to delete such information from our databases. If you believe we might have any personal data from or about a child under 18, please contact us by using the information in the section below titled Contacting Us.

14. Changes to This Policy

We reserve the right, at our discretion, to change, modify, add, or remove portions from this Privacy Policy at any time, provided that any such modifications will only be applied prospectively. We encourage you to periodically review the Website for the latest information on our privacy practices. Your continued use of the Properties following the posting of any changes to this Privacy Policy means you accept such changes. If we make a material change to this Privacy Policy or our privacy practices and believe that such changes will affect your personal data, we will take reasonable electronic measures to notify you of such changes and, where required by applicable law, provide a reasonable opportunity for you to opt out of any further materially different collection, processing, or transfer of previously collected personal data under the changed policy. The process by which we notify you of material changes may include email or a pop-up notification on the Website, depending on how you interact with us.

15. Contacting Us

If you have any questions about our privacy or security practices, you can contact us at privacy@nationalreview.com, or via the following mailing address: National Review, 19 West 44th Street, Suite 1701, New York, NY 10036.

16. Additional U.S. State Privacy Rights

If you are a resident of California, Virginia, Colorado, Connecticut, Utah, Texas, Oregon, Montana, Iowa, Delaware, Nebraska, New Hampshire, New Jersey, Tennessee, Minnesota, Maryland, Indiana, Kentucky, Rhode Island, or another U.S. state that has similar comprehensive privacy legislation (collectively, “Covered States”), you may have specific rights regarding your personal data under: the California Consumer Privacy Act (“CCPA”), Virginia Consumer Data Protection Act, Colorado Privacy Act, Connecticut Data Privacy Act, Utah Consumer Privacy Act, Texas Data Privacy and Security Act, Oregon Consumer Privacy Act, Montana Consumer Data Privacy Act, Iowa Consumer Data Protection Act, Delaware Personal Data Privacy Act, Nebraska Data Privacy Act, New Hampshire Data Privacy Act, New Jersey Data Privacy Act, Tennessee Information Protection Act, Minnesota Consumer Data Privacy Act, Maryland Online Data Privacy Act, Indiana Consumer Data Protection Act, Kentucky Consumer Data Protection Act, Rhode Island Data Transparency and Privacy Protection Act, and similar laws in other U.S. states (collectively, "State Privacy Laws"). This section describes the rights that consumers of Covered States have and explains how to exercise those rights. To be clear, these rights are granted only to the extent that you are considered a consumer of a Covered State and we are acting as a “controller” or “business” (as applicable) under State Privacy Laws with respect to your personal data.

The categories of personal data we process, our purposes for processing your personal data, the categories of personal data that we share with third parties, and the categories of third parties with whom we share it are set forth in the terms of the Privacy Policy above.

Information We Collect; How We Collect It; How We Use It

General information regarding our collection, use, and disclosure of personal data is set forth in the Privacy Policy above.

In the past 12 months, we have collected categories of personal data described in the section of the Privacy Policy above titled Personal Data We Collect from You, and we have collected this information from the sources described in the section titled How We Collect Your Personal Data. Depending on your level of interaction with us, we may not have collected your personal data from all of the categories listed in the Privacy Policy above. We collect and use your personal data for the business or commercial purposes described in the section titled How We Use Your Personal Data, and retain it pursuant to the section titled Data Retention.

We disclose the categories of personal data described in the section Personal Data We Collect From You to service providers or contractors for business purposes, as described under the heading “Service Providers” in the section titled How We Disclose or Share Your Personal Data. Additionally, we may sell and/or share for targeted advertising the following categories of personal data to the categories of recipients listed below:

• Identifiers and contact information – advertising networks; social media and advertising platforms; data and audience partners that help advertisers reach readers; organizations that rent our postal mailing lists

• Commercial information – advertising networks; analytics providers

• Geolocation information – advertising networks; analytics providers

• Device information and unique identifiers – advertising networks; analytics providers

• Internet or other electronic network activity information – advertising networks; analytics providers

• Inferences drawn from collected information – advertising networks; analytics providers

As of the latest date of this Privacy Policy, we do not collect, use, or sell personal data for the purpose of training large language models.

Rights to Your Information

In addition to the rights set forth in our Privacy Policy, State Privacy Laws may, depending on your state of residence, provide you with the following rights:

• Right to know. You may have the right to know whether we process your personal data and to access such personal data. You may also have the right to request that we disclose certain information to you about our collection, use, or disclosure of your personal data. Residents of Minnesota or Oregon have the right to: (i) confirm additional information about the categories of personal data we have processed about them; and (ii) obtain a list of third parties to which we have disclosed the personal data of Minnesota or Oregon consumers. Residents of Delaware or Maryland have the right to obtain a list of the categories of third parties to which we have disclosed the personal data of Delaware or Maryland consumers.

• Right to data portability. You may have the right to obtain a copy of your personal data that you previously provided to us in a portable and, to the extent technically feasible, readily usable format that allows you to transmit the data to another business without hindrance, where the processing is carried out by automated means.

• Right to delete. You may have the right to delete personal data that you have provided to us or that we have obtained about you. Please note that we may deny such request if the requested deletion falls under an exception as set forth in the State Privacy Laws.

• Right to correct. You may have the right to correct inaccuracies in your personal data, taking into account the nature of the personal data and the purposes for which we process it.

• Right to opt out. You have the right to opt out of the processing of your personal data for purposes of: (i) targeted advertising; (ii) the sale of personal data; or (iii) profiling in furtherance of decisions that produce legal or similarly significant effects concerning you. As of the latest date of the Privacy Policy, we process personal data or share it with third parties for the purposes of targeted advertising, which certain State Privacy Laws also treat as a sale of personal data. To our knowledge, we do not sell the personal data of minors under 18 years of age or share it for targeted advertising. We do not engage in profiling decisions based on your personal data that produce legal or similarly significant effects concerning you. If you wish to opt out of the processing of your personal data for any of the above purposes, please visit the web page Your Privacy Choices.

  For residents of California, Colorado, Connecticut, Delaware, Maryland, Minnesota, Montana, New Hampshire, New Jersey, and Oregon, we will also treat opt-out preference signals as valid opt-out requests. In particular, we recognize and endeavor to honor Global Privacy Control (“GPC”) signals as a valid mechanism for consumers to exercise their rights to opt out of the sale of their personal data or sharing of that data for targeted advertising. When you enable the GPC signal in your browser or through a supported extension, to the extent allowable pursuant to our available technology configurations, our systems will endeavor to automatically process this signal as a request to opt out of the sale of your personal data or sharing of that data for targeted advertising. Please note that the GPC signal applies only to the browser or device where it is enabled. If you use multiple browsers or devices, you must enable GPC on each one individually. Additionally, while the opt-out will be honored for online sales and sharing of personal data for targeted advertising, other privacy choices, such as opting out of offline sales or sharing, may require additional action. For more information about GPC and how to enable it, visit https://globalprivacycontrol.org.

• Right to nondiscrimination. You have the right not to be retaliated against or receive discriminatory treatment by us for the exercise of your privacy rights. Unless permitted by the State Privacy Laws, we will not:

  • Deny you goods or services;

  • Charge you different prices or rates for goods or services, including through granting discounts or other benefits, or imposing penalties;

  • Provide you a different level or quality of goods or services; or

  • Suggest that you may receive a different price or rate for goods or services or a different level or quality of goods or services.

How to Exercise Your Rights; Verifying Your Identity

To exercise any of your privacy rights, or if you have any questions about your privacy rights, you may contact us by:

• Calling us at 800-464-5526

• Emailing us at privacy@nationalreview.com

• Visiting the Your Privacy Choices web page

With the exception of opt-out requests (which do not require verification), after submitting a request, we will take steps to verify your identity in order for us to properly respond and confirm that it is not a fraudulent request. In order to verify your identity, we will ask, at a minimum, that you provide your name, email address, and relationship to us, so that we can seek to match this information with the information existing in our systems. When providing us this information, you represent and affirm that all information provided is true and accurate. If we are unable to verify that the consumer submitting the request is the same individual about whom we have collected personal data, we may contact you for more information, or we may not be able to meet your request.

Only you (or for California residents, an agent legally authorized to act on your behalf) may make a verifiable request to know, delete, correct, or obtain a copy of your personal data. If you are making a request as the authorized agent of a California consumer, we will ask you to also submit reliable proof that you have been authorized in writing by the consumer to act on such consumer’s behalf. If you are making a request as the parent or legal guardian of a known child regarding the processing of that child’s personal data, we may ask you to submit reliable proof of your identity.

Response Time; Your Right to Appeal

We will make every effort to respond to your request within 45 days from when you contacted us. If you have a complex request, State Privacy Laws allow us up to 90 days to respond. We will contact you within 45 days from when you contacted us to inform you of the need for additional time and the reason for such extension. We may charge you a reasonable fee to cover administrative costs if your requests are manifestly unfounded, excessive, or repetitive.

If we decline to take action on a request that you have submitted, we will inform you of our reasons for doing so, and provide instructions for how to appeal the decision. Depending on your state of residence you may have the right to appeal within a reasonable period of time after you have received our decision. If you have this appeal right, within 60 days (45 days for residents of Colorado and Minnesota) of our receipt of your appeal, we will inform you in writing of any action taken or not taken in response to the appeal, including a written explanation of the reasons for the decision. If we deny your appeal, we will provide you with a method for contacting your state attorney general’s office to submit a complaint.

Notice of Financial Incentive

We may offer you financial incentives for the collection, sale, retention, and use of your personal data. The material terms of each program will be made available to you before you sign up. Please note that participating in incentive programs is entirely optional. You will have to affirmatively opt into the program in order to participate, and you can opt out of each program (i.e., terminate participation and forgo the ongoing incentives) prospectively by following the instructions in the applicable program description and terms. Under the CCPA, these Programs may be considered “financial incentives.”

Examples of the financial incentives we may offer include: (1) access to one free article on NationalReview.com during a single month period when you register with your email address (the “Free Month Program”); (2) a thank-you gift when you make a donation or a purchase (the “Gift Program”); and (3) other variations of access to content for a limited period of time when you register on the website.

For the one free article on NationalReview.com during a single month program, we collect identifiers and contact information (such as your name or email address). For the Gift Program, we collect identifiers and contact information (such as your name, email address and mailing address) and commercial information (such as the donations and purchases you make). We use this information as described in this Privacy Policy, including to deliver the benefit, to keep in touch with you, and, subject to your choices, for advertising.

You opt in to a Program by affirmatively agreeing to its terms by checking a consent box when you sign up. Taking part is always voluntary. You may withdraw at any time by contacting us at privacy@nationalreview.com or by using the designated method set forth in the Program’s terms. Withdrawing may end the benefit going forward, but it will not affect any subscription, purchase or donation you have already made.

As a good-faith estimate, we consider the value of your personal data to be reasonably related to the value of the benefit offered, which, for the Free Month Program, is equal to the price of one month of access, and for the Gift Program, is equal to the fair market value of the thank-you gift.

California “Shine the Light”

In addition to the above rights, under California Civil Code Section 1798.83 (“Shine the Light”), California residents may have the right to request in writing from businesses with whom they have an established business relationship: (a) a list of the categories of personal data, as defined under Shine the Light, such as name, email address, and mailing address, and the type of services provided to the customer that a business has disclosed to third parties (including affiliates that are separate legal entities) during the immediately preceding calendar year for the third parties’ direct marketing purposes; and (b) the names and addresses of all such third parties. To request the above information, please contact us by email at privacy@nationalreview.com. If you do not want your personal data shared with any third party who may use such information for direct marketing purposes, then you may opt out of such disclosures by sending an email to us at privacy@nationalreview.com.

17. European Privacy Rights

IF YOU ARE SITUATED IN THE EUROPEAN ECONOMIC AREA, SWITZERLAND, OR THE UNITED KINGDOM, THIS SECTION APPLIES TO OUR COLLECTION, USE, AND DISCLOSURE OF YOUR PERSONAL DATA AND ADDITIONAL RIGHTS YOU HAVE UNDER APPLICABLE LAW.

References to the “GDPR” throughout this section include, as applicable: the EU General Data Protection Regulation 2016/679; the UK Data Protection Act 2018 and the GDPR as it forms part of the law of England and Wales, Scotland, and Northern Ireland by virtue of section 3 of the European Union (Withdrawal) Act 2018; and the Swiss revised Federal Act on Data Protection, SR 235.1, effective September 1, 2023.

Legal Basis

We will only use your personal data, as that term is defined under the GDPR, when the law allows us to. Most commonly, we will use your personal data in the following circumstances:

• Where we need to perform the contract we are about to enter into or have entered into with you.

• Where it is necessary for our legitimate interests (or those of a third party) and your interests and fundamental rights do not override those interests.

• Where you have consented to a certain use of your personal data.

• Where we need to comply with a legal or regulatory obligation.

Data Controller

National Review is the data controller of all personal data collected through our Properties. To contact us, please see the section of the Privacy Policy titled Contacting Us.

Provision of personal data and failure to provide personal data

Where we need to collect personal data by law or under the terms of a contract we have with you, and you fail to provide that data when requested, we may not be able to perform the contract we have or are trying to enter into with you (for example, to provide you with our services). In this case, we may not be able to provide certain services to you.

Collection of personal data from third-party sources

We may obtain personal data and other information about you from public sources and through our third-party partners who help us provide our products and services to you.

Withdrawing your consent

If we are relying on your consent to process your personal data, you have the right to withdraw your consent at any time by contacting us at privacy@nationalreview.com.

Data Transfer

We may transfer personal data from the EEA, Switzerland, and the UK to the USA and other countries, some of which have not been determined by the European Commission or the UK Secretary of State to have an adequate level of data protection. Where we use certain vendors, we may use specific contracts approved by the European Commission or the UK Secretary of State which give personal data the same protection it has in Europe. For more information about how we transfer your data, please contact us at privacy@nationalreview.com.

Use of your personal data for marketing purposes

We may use your personal data for marketing purposes, including to form a view on what we think may be of interest to you, and to decide which products, services, and offers may be relevant for you. You will receive marketing communications from us if you have requested information from us or used our services and, in each case, if you have consented to our use of your personal data for marketing purposes.

Automatic Decision-Making and Profiling

We do not currently make decisions based solely on automated processing, including profiling, that produce legal or similarly significant effects concerning you.

Data Subject Rights

If you are situated in the EEA, Switzerland, or the UK, under the GDPR, as a data subject, you have the right to:

• Request access to your personal data (commonly known as a "data subject access request"). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.

• Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.

• Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below); where we may have processed your information unlawfully; or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request for erasure for specific legal reasons which will be notified to you, if applicable, at the time of your request.

• Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.

• Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data's accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise, or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.

• Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.

• Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

• Lodge a complaint with a supervisory authority. If you are situated in the EEA, Switzerland, or the UK and have any complaints regarding our privacy practices, you have the right to make a complaint at any time to your local supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach your supervisory authority, so please contact us in the first instance.

To exercise your rights under the GDPR or to submit a complaint regarding our privacy practices, please contact us at privacy@nationalreview.com. Please note that in order for you to assert your data subject rights, we may need to verify your identity. This is a security measure to ensure that your personal data is not wrongfully modified or deleted, or disclosed to any person who has no right to receive it. In order to verify your identity, we may need to gather more personal data from you than we currently have.