Privacy Policy and Notice at Collection for California Residents

Last Updated: September 12, 2025

This CCPA Privacy Policy and Notice at Collection for California Residents (this “California Privacy Policy”) applies to Paddock Publications, Inc. and its affiliates (collectively “Paddock”, “we,” “us,” or “our”) processing of personal information of California residents to the extent the information is subject to the California Consumer Privacy Act of 2018 as amended, including by the California Privacy Rights Act of 2020 and any applicable regulations (“CCPA”). For example, this California Privacy Policy does not apply to personal information collected pursuant to various exemptions including for (i) information collected subject to the federal Gramm-Leach-Bliley Act and its implementing regulations, (ii) medical and health information covered by HIPAA, and (iii) de-identified or publicly available information.

Personal Information We Collect, Use, Disclose, Share, or Sell

Categories of Personal Information We Collect, Categories of Sources of Personal Information, Business or Commercial Purposes for Which Personal Information Will Be Used, and Third Parties with Whom Personal Information is Sold, Shared, or Disclosed.

We collect information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked, directly or indirectly, with a particular consumer or household (“personal information”). The chart below includes information collected for various types of individuals, such as our customers, employees, and others. As a result, not all of the categories of collected personal information described below may be applicable to you. Within the last twelve (12) months and on an ongoing basis, we have collected and plan to collect the following categories of personal information from the sources identified below for the business and commercial purposes indicated, and disclosed, shared, or sold (as indicated) such categories of personal information with the specified categories of third parties.

Category of Personal Information	Examples of Personal Information Collected	Categories of Sources of Personal Information Collected	Business or Commercial Purpose(s) for Which Collected, Disclosed, or Shared.	Categories of Third Parties to Which Personal Information is Disclosed, or Shared.
Identifiers	First and last name, email, phone number, address, age, internet protocol address, email address, account name, payment information, or other similar identifiers.	From you, our “personnel” (meaning employees and independent contractors), or our partners.	“We use this personal information for performance of our services and for our business operations or for human resources purposes. For example: Registration for a user account or newsletter, Tracking transaction information, Providing you with the services that you request, such as by completing transactions, Communicating with you, for example to respond to inquiries, To help maintain the safety, security, and integrity of our website, information systems, databases and other technology assets, To create, maintain, customize, and secure accounts with us, For testing, research, analysis, and product development, including to develop and improve our website, products and services. To communicate with Personnel and evaluate performance, To keep track of records related to our relationship with Personnel, To evaluate applicants to work with our team, To allow Personnel physical access to our premises.”	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”
Characteristics of protected classifications	Age, national origin, religion, citizenship, marital status, physical or mental disability, genetic information or ancestry, sex, veteran or military status.	From you, our personnel, or our partners.	“We use Personnel’s personal information for our business operations or human resource functions, including: To keep track of Personnel’s eligibility to work in the United States, For reporting to government agencies or regulators, or To provide appropriate services and benefits to all Personnel.”	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”
Commercial Information	Payment information, or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	From you, our personnel, or our partners.	“We use this personal information for performance of our services and for our business operations. For example: Providing you with the services that you request, such as by completing transactions, Providing you with information about our products or services that may be of interest to you, Developing additional products or services, or Communicating with you, for example to respond to inquiries.”	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”
Biometric Information	We do not collect this category of personal information.
Internet or other electronic network activity information	“Browsing history, search history, online behavior, interest data, and interactions with our and other websites, applications, systems and advertisements. Network traffic and other electronic or internet activity performed when acting as our personnel through our systems.”	From you or our partners.	“We use this personal information for performance of our services and for our business operations or human resource functions. For example: To provide access to our website and the information about our products and services contained therein, For the security of our website and information systems, Providing you with information, including communications about products that may be of interest to you To support, personalize, improve our website, products or services. To facilitate Personnel’s use of our information systems, To protect our information systems and other property from harm or damage, To secure our information systems against attacks or misuse, or To verify compliance with our policies, procedures, and workplace rules.”	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”
Geolocation data	Geographic tracking data, physical location and movements.	From you directly	“We use this personal information for performance of our services and for our business operations. For example: Facilitate services provided related to remote worksite management, Verification purposes, To locate appropriate resources and services that we can offer to you.”	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”
Sensory Data	Images and audio, video or call recordings created in connection with our business activities	From you or our personnel, or automated collection practices	We collect this information as the result of Personnel’s use of other systems to facilitate the security of our offices and information systems and use it for our internal business operations, such as facilitating product registration or recording customer service interactions.	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”
Professional or employment-related information	“Business contact details in order to provide you our services at a business level, job title as well as work history and professional qualifications if you apply to work with us. Current and/or past employment history, payroll records, benefits records, leave documentation, or medical records.”	From you, our personnel, or our partners.	“We use these categories of Personal information for our business operations, including human resources to support: Evaluating job applicants’ suitability for a job opening, Making decisions about promotion and determinations about seniority, Evaluation of Personnel and their performance, or To verify Personnel’s licenses or certifications.”	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”
Non-public education information (as defined in the Family Educational Rights and Privacy Act (20 U.S.C. 1232g, 34 C.F.R. Part 99))	Student records and directory information.
Inferences drawn from other personal information	A person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities and aptitudes.	From partners we work with and our personnel.	“We use this personal information for performance of our services, and for our business operations or human resource functions. For example: To support, personalize, improve our website, products or services, We collect this information to evaluate job applicants’ suitability for a job opening.”	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”
Sensitive Personal information	“Personal information that reveals: a Social Security number or other government identifier; account login information or a financial account number with associated credentials; contents of mail, email, or text messages. Or any of the following: collection and analysis of information that concerns a consumer’s health information. Information about a known minor.”	“From our personnel. We do not collect sensitive personal information about our readers.”	“We use this personal information for performance of our services, and for our business operations or human resource functions. For example: To manage human resources and benefits for our Personnel, We collect this information to evaluate job applicants’ suitability for a job opening.”	“Vendors and other industry service providers; Other third parties with which you or we maintain a relationship regarding your services or products; Government agencies including to support regulatory and legal requirements; Affiliates.”

Information about our Personal Information Processing Activities

Additional details of how we process personal information is set forth in the chart above.

Personal information is retained based on internal retention policies, which typically requires retention for a period of seven years. Information is segregated by legal retention requirements and maintained in accordance with various local, state, federal, and other legal requirements. Personal information will not be retained beyond the reasonably foreseen need to retain the information for legal or business purposes.

We do not sell consumers’ personal information.

We share personal information (for purposes of cross-context behavioral advertising).

We do not sell or share (for purposes of cross-context behavioral advertising) the personal information of minors under 16 years of age.

We share cookies with third parties as described in our online privacy policy. To opt-out of the sharing of information with third parties in this context, please review our online privacy policy for instructions or adjust your browser settings accordingly.

We do not use or disclose Sensitive Personal Information (as defined in the table above) for purposes other than the following:

To perform the services or provide the goods reasonably expected by an average consumer who requests those goods or services.
To prevent, detect, and investigate security incidents that compromise the availability, authenticity, integrity, or confidentiality of stored or transmitted personal information,
To resist malicious, deceptive, fraudulent, or illegal actions directed at the business and to prosecute those responsible for those actions.
To ensure the physical safety of natural persons.
For short-term, transient use, including, but not limited to, nonpersonalized advertising shown as part of a consumer’s current interaction with the business, provided that the personal information is not disclosed to another third party and is not used to build a profile about the consumer or otherwise alter the consumer’s experience outside the current interaction with the business.
To perform services on behalf of the business.
To verify or maintain the quality or safety of a product, service, or device that is owned, manufactured, manufactured for, or controlled by the business, and to improve, upgrade, or enhance the service or device that is owned, manufactured by, manufactured for, or controlled by the business.
To collect or process Sensitive Personal Information where such collection or processing is not for the purpose of inferring characteristics about a consumer.

Your Privacy Rights

Submitting Consumer Requests

If you wish to request that we take action with respect to your Personal Data, you may submit a consumer request by email to webmaster@dailyherald.com, or phone at 847-427-4300 (Toll Free).

Only you, or someone legally authorized to act on your behalf, may make a verifiable consumer request related to your personal information. You may also make a verifiable consumer request on behalf of your minor child. Making a verifiable consumer request does not require you to create an account with us.

When you submit a verifiable consumer request, we will take steps to verify your request by email or telephone call. In some cases, we may request additional information in order to verify your request or where necessary to process your request. If we are unable to adequately verify a request, we will notify the requestor. Authorized agents will be required to provide proof of their authorization and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent.

We will only use personal information provided in a verifiable consumer request to verify the requestor’s identity or authority to make the request. We cannot respond to your request or provide you with personal information if we cannot verify your identity or authority to make the request and confirm the personal information relates to you.

Right to Know and Access Your Information

You have the right to request that we disclose to you certain descriptions and categories of the personal information we collect, use, disclose, share, or sell about you. For example, you may request the following through a consumer request:

The categories of personal information we have collected about you.
The categories of sources from which the personal information is collected.
The business or commercial purpose for collecting, selling, or sharing personal information.
The categories of third parties to whom we disclose the personal information.
The specific pieces of personal information we have collected about you.

You may make up to two disclosure requests in any 12 month period. See above for additional details on making a consumer request.

Right to Request Deletion

You have the right to request that we delete your personal information. See above for additional details about how to submit a consumer request.

You should be aware, however, that California law allows us to retain your personal information under certain conditions, even if you have asked us to delete it, such as when retaining your personal information is necessary for us to complete a transaction with you or provide you with a good or service you have requested. We will notify you of any denial of your deletion request and the reason for such denial.

Right to Request Correction

You have the right to request that we correct your personal information. See above for additional details about how to submit a consumer request.

Right to Non-Discrimination for Exercise of Consumer Privacy Rights

We will not discriminate against you because you have chosen to exercise any of your privacy rights provided by the CCPA.

Right to Opt-Out of the Sharing or Sale of Personal Information

We may share personal information we collect about you with third parties for purposes of cross-context behavioral advertising. We do not sell personal information we collect about you, as the term “Sale” is defined by the CCPA. You may opt out of the sharing (for purposes of cross-context behavioral advertising) of your personal information by signaling an opt-out preference by making an opt-out request.

To submit a request under the Right to Opt-Out, please provide the information necessary to identify the consumer to whom the request should be applied and reasonable identifying information that you are authorized to make the request and submit an email requesting your “Right to Opt-Out” to our contact point below.

Once you make an opt-out request, we will wait at least twelve (12) months before asking you to reauthorize personal information sales. However, you may change your mind and opt back in to personal information sharing or sale at any time by contacting us.

Authorized agents will be required to provide proof of their authorization to submit opt-out requests and we may also require that the relevant consumer directly verify their identity and the authority of the authorized agent in limited circumstances.

Right to Non-Discrimination for Exercise of Consumer Privacy Rights

We will not discriminate against you because you have chosen to exercise any of your privacy rights provided by the CCPA.

Using an Authorized Agent

You may use an authorized agent to submit a consumer request. To use an authorized agent, you will need to (i) provide written instruction to your agent, and verify your identity to us, or (ii) provide a power of attorney pursuant to California Probate Code Sections 4000 to 4465.

Contact Us

Please read this Policy carefully to understand our practices regarding how we process CCPA personal information. If you have any questions or comments about this notice, the ways in which we collect and use your information described here and in the Paddock website Privacy Policy, your choices and rights regarding such use, or wish to exercise your rights under California law, please do not hesitate to contact us at:

Email: webmaster@dailyherald.com; Phone: 847-427-4300