NPR Privacy Notice for EU Users

Friday, February 12, 2021 • 1:33 PM EST

National Public Radio, Inc. ("NPR," "we" or "us") owns, operates, or provides access to and NPR's mobile applications, email newsletters, and other sites, digital platforms and interactive services ("Services"). This Privacy Notice for EU Users ("Notice") applies only to the Services and does not govern the separate websites, applications, newsletters, platforms and services of NPR Member stations or of any third parties that may link to or be linked to from the Services. This Privacy Notice governs our privacy practices in handling the information we collect about individuals in the EU (including UK users, European Economic Area (EEA) users and Swiss users) who use our Services ("you" or "your"). Terms that are not defined in this Notice have the same definitions as in NPR's Terms of Use. NPR processes personal data under this Privacy Notice as a data controller. The Contact Details of NPR are listed at the end of this Notice. This Notice may be changed if there is a change in the way NPR processes personal data or if there is a change in applicable law. We will notify users of changes that are deemed material under applicable law by updating the date of this Notice and providing other information as required.

Last modified: February 9, 2021.

'Personal data' means any information relating to an identified or identifiable natural person ('data subject'). An identifiable natural person is one who can be identified, directly or indirectly, in particular by reference to an identifier such as a name, an identification number, location data, an online identifier or to one or more factors specific to the physical, physiological, genetic, mental, economic, cultural or social identity of that natural person.

Categories of Data Obtained Directly from You

NPR obtains personal data from you including your name, email address, postal address, telephone number, and payment card information. We collect this information when you:

Email, text or otherwise share a story from any of the Services.

Make a donation to NPR or a Member station or express interest in or request information about making donations.

Post, upload, or otherwise submit a comment, story idea, essay, photo, or other content ("User Materials") to NPR.

Apply for a job, internship or fellowship at NPR

Otherwise volunteer information to us or respond to a request for information through any of our Services.

If you choose to participate in a survey, we may ask you to provide your date of birth, gender, education level, information about your employment, income level and other information.

Information Obtained Automatically Through Technology

You can find our Statement Regarding Cookies and Other Tracking Technologies here.

Depending on which Services you use and how you access them, the information collected automatically through technology, such as access logs, cookies, pixels and other tracking technologies, may include:

Internet Protocol Address (IP address)

The domain name of your Internet Service Provider

The website, application, platform or service you visited before and after visiting our Services.

Information about your computer or mobile device, and their browser, operating system, settings and software.

Unique device identifiers on your mobile device, including as applicable the Apple or Google advertising identifiers.

Your approximate geographic location (derived from requested header information, such as your IP address) and/or more precise location information if you have given NPR consent to receive this information for an NPR application on your mobile device.

The dates, times, duration and frequency of your interactions with our Services, search terms, the media files you download, interact with or share, favorites you select, and your navigation path through our Services.

Listening data, including information about your interactions with NPR podcasts and other media files, such as time and date stamps for when a file is downloaded and when playback of a particular segment or sponsorship message starts, stops, is skipped or paused.

Information about your interactions with our email messages.

Any errors you encountered during your use of the Services.

If you sign in to the Services from a social networking service ("SNS"), we receive your email address and certain profile information from such SNS in accordance with its privacy policy and your SNS account privacy settings.

Information Not Obtained Directly From You

The Services use third-party analytics, cookie data collection and linking services (collectively "Analytics Services"), including Google Universal Analytics, Google Analytics Demographics and Interest Reporting and Google Ad Manager. These Analytics Services may use cookies, pixel tags, and other tracking and storage technologies to collect or receive information (not including your name or the email address you register with NPR) from the Services and elsewhere on the Internet and use that information to analyze and measure NPR's audience and target and evaluate the effectiveness of sponsorship credits. For example, NPR and Analytics Services may use first-party cookies (such as the Google Analytics cookies) and third-party cookies (such as the DoubleClick cookie) together to inform, optimize, and serve sponsorship messages based on your past interactions with our Services and other websites or services. In addition, we may use analytics data, including but not limited to, geographic, demographic, and interest reporting information to recognize and understand user preferences, make improvements, and for other operational purposes.

Purposes for Processing of Personal Data

NPR processes your data in order to:

Manage, administer, promote, analyze and improve the Services and our communications, including measuring and analyzing user traffic and usage patterns.

Respond to your questions or messages and fulfill your requests for services.

Customize the content you see and hear on our Services, including offering content from NPR Member stations associated with your account or located near you and offering other content that may be of interest to you.

Customize the sponsorship messages you see and hear on our Services and on third-party services you may use or visit.

Publish, broadcast or otherwise use User Materials.

Offer you access to NPR tours and events.

Process applications for jobs, internships, fellowships and other positions at NPR.

Manage contests, contact you for an online survey, or for editorial purposes.

Recognize you as a returning user as you access our Services using different computers, devices and browsers and to save and "remember" your registration information, settings and preferences for later visits.

Send you email newsletters and marketing, fundraising, membership and other communications from NPR and our Member stations.

To understand whether and when you read our email messages and click on links in those messages.

Analyze personal preferences or interests to provide personalized content and messages from NPR and NPR sponsors and to control the sequence and frequency of those messages.

Generate aggregate or other information that does not identify you as an individual or the devices you use to access our Services, and use and share that information for NPR's purposes.

To prevent potentially prohibited or illegal activities, comply with applicable laws, and enforce our Terms of Use and other legal rights.

We also may use the information collected from you in other ways, and for other purposes, that are described to you at the point of collection or for which we otherwise have obtained your consent.

Sharing Your Personal Data

NPR and service providers working on our behalf may share your personal data with the following categories of recipients:

Member stations, for their internal purposes and to send you email newsletters and marketing, fundraising, membership and other communications, and for other purposes disclosed at the point of collection or for which we otherwise have obtained your consent.

NPR's authorized service providers and vendors to provide services on our behalf.

NPR's authorized third-party applications to provide certain Services to you on the third-party applications.

NPR's analytics partners such as Google Universal Analytics, Google Analytics Demographics and Interest Reporting, Google Ad Manager and others.

If we sell a Service or in the unlikely event of bankruptcy.

Podcast producers.

With public authorities when required by law, to respond to subpoenas, court orders, legal process, and other law enforcement measures, and to comply with legal or regulatory obligations.

With other parties when necessary to enforce our Terms of Use, to protect the vital interests of our users or other natural persons, NPR, Member stations, and their sponsors, or when required by law.

With persons we contact on your behalf when you choose to email, text, or otherwise share a story or other content through the Services.

With social networking services, if you choose to share stories or other content with your friends and followers on the social networking service.

With other parties if the information is anonymous and aggregate.

With other parties if we have disclosed such sharing to you at the time of collection of the information or if we otherwise have your consent.

Lawful Basis for the Processing of Personal Data

NPR is required to demonstrate a lawful basis for the processing of personal data. NPR relies on legitimate interest to process data for the following purposes:

Data analytics

Managing user accounts

Operating, modifying and improving the Services

Identifying usage trends

Customizing content and user experience

Web hosting

Direct marketing

Fraud prevention

Network and information systems security

To determine the effectiveness of promotional campaigns and sponsorship messaging

To serve promotional and sponsorship messages based on user behavior and preferences.

Responding to user questions and requests for information

Comply with laws and regulations and enforce NPR's Terms of Use and other legal rights.

Consent: We process personal data based on your consent to send personalized messages from NPR and NPR's sponsors (interest based messages or sponsorship), to collect precise location information and to send promotional emails. You also may view "Your Choices" below to learn about and use cookie management tools to limit use of cookies when you visit NPR's Services, to unsubscribe from emails, and as otherwise described in "Your Rights" and "Your Choices" below. You can adjust your cookie choices in those tools at any time. Please note that an adjustment in your cookie choices will not affect any personal data that has already been processed.

Retention

Your personal data is retained no longer than is reasonably necessary to perform the processing described in this Notice and in case of any legal claims or complaints, or as required by law.

Your Rights

Subject to exemptions under applicable law (which may include, depending on the circumstances, U.S. law protecting the rights to free speech and free press or EU law protecting the rights to freedom of expression or information, including processing for journalistic purposes), you have the following rights with respect to your personal data:

To request a copy of your personal data which NPR holds;

To request that NPR provide you access to and/or rectify personal data that is inaccurate or out of date;

To request erasure of your personal data where it is no longer necessary for NPR to retain it;

If you have consented to processing, the right to withdraw consent at any time;

To request that the data controller provide you with your personal data and where possible, to transmit that data directly to another data controller, where applicable. This right of portability only applies where the processing is based on consent or is necessary for the performance of a contract and if NPR processes the data by automated means;

To request a restriction on further processing where applicable;

The right to object to processing if the processing is based on legitimate interest, is for direct marketing, or is for scientific/historical research and statistics;

To lodge a complaint with a supervisory authority.

You may exercise these rights by contacting NPR at privacy@npr.org, providing the email address you used to register with NPR, and stating your specific request in writing. NPR reserves the right to verify your identity and confirm your right to the information.

Your Choices

The following options for exercising your rights are also available:

To provide or withdraw consent to NPR Services' use of cookies, similar tracking and storage technologies, device identifiers and information about the device you use to access NPR Services, you may do the following at any time.

Browser Tools. You have the option to set your browser to accept all cookies, reject all cookies, notify you when a cookie is set, or delete cookies. Each browser is different, so select the "Help" menu in your browser for instructions on how to use the relevant tools and settings. You can also download a browser plugin and configure it to block cookies. Note that if you disable or delete cookies, you may lose access to certain features of the NPR Services.

Tools for "Interest-Based" Sponsorship Credits. You can learn more about opting out of receiving personalized or "interest-based" online sponsorship credits from our service providers, our vendors and other participating companies and you can access opt-out tools from http://www.youronlinechoices.eu.

Google Opt-Out. To prevent your data from being used by Google Analytics, click here for the Google Universal Analytics opt-out browser add-on: https://tools.google.com/dlpage/gaoptout. Google also offers opt-out features to limit the use of your information for personalized or "interest-based" sponsorship credits at https://adssettings.google.com/. To learn more about how Google uses data, visit www.google.com/policies/privacy/partners/.

Device Settings. You also may adjust the settings on your device to control NPR Services' use of device identifiers. For iOS mobile devices, go to "Settings" from your device's home screen, scroll down to "Privacy", select "Advertising", and turn on "Limit Ad Tracking." For Android mobile devices, go to "Google Settings" on your device, select "Ads"; and check the box labeled "Opt Out of Interest-Based Ads" or "Opt Out of Ads Personalization." (These device settings options may change in the future or otherwise may differ for certain devices; consult your device manufacturer's support literature for the most current information).

Please note that if you use these tools or settings to limit the collection and use of your information, you may still receive the same number of sponsorship credits, but they may not be as relevant to your interests. The tools or settings described above are specific to the device/browser. If you use a different device/browser or if your browser cookies expire, you may need to reconfigure your preferences by using the tools described above.

To withdraw consent for collection of precise device location, you may access the privacy settings of your mobile device and/or the settings of the NPR mobile application.

To withdraw consent to marketing emails or email newsletters, click the "unsubscribe" link on the email and then follow the unsubscribe instructions. You may also change your newsletter preferences by contacting us. However, even if you opt out of receiving such communications, we retain the right to send you non-marketing communications (such as information about changes to our Terms of Use or this Notice).

To cancel your NPR account, or correct or update your registration information, you may sign in to your account or contact us using the information below.

Transfer of Data Abroad

Because NPR operates the Services from the US, your personal data may be transferred to the US and/or to countries or territories outside the EEA or Switzerland not recognized by the European Commission as ensuring an adequate level of protection pursuant to the GDPR. Where required, data transfers will be made subject to the terms of the applicable EU Standard Contractual Clauses or with your consent. NPR will take all steps reasonably necessary to ensure that personal data is treated securely and in accordance with this Privacy Notice in respect of such transfer.

Security

NPR employs physical, technical and organizational safeguards to ensure an appropriate level of security for personal data, taking into account the state of the art, the costs of implementation and the nature, scope, context and purposes of processing as well as the risk of varying likelihood and security for the rights and freedoms of natural persons,

Automated Decision Making and Analysis

NPR and its data analytics and sponsorship vendors analyze user interactions with the Services to deliver personalized content to users and to serve personalized sponsorship messages. This includes tracking user preferences with respect to listening data, websites visited, Member station chosen, and search terms in order to derive a user's interests and preferences. The consequences of such processing for the data subject are that the data subject receives content that may be of interest to him or her, as well as email, online and in-app messages from NPR and NPR's sponsors that are geared towards the interests and preferences of the data subject.

Age Limits

You must be at least 18 years of age to submit any User Materials or Personal Data on or through the Services, create a public profile, or participate in any online contests. If your child is under age 16 and has provided personal data to the Services, please contact us at privacy@npr.org for deletion of the data.

Further Processing

If NPR plans to use personal data for a new purpose, it will update this Notice and communicate the changes to individuals before starting any new processing.

Contact Details

Data Protection Officer
Micah Ratner
NPR
1111 North Capitol Street, NE
Washington, DC 20002
privacy@npr.org

Data Controller
National Public Radio, Inc.
1111 North Capitol Street, NE
Washington, DC 20002, USA
privacy@npr.org