PRIVACY POLICY
1. WHO WE ARE AND WHAT THIS POLICY COVERS
Today's TopNews Newspaper ("we", "us", "our") publishes news, features, opinion and multimedia content at [WEBSITE URL] and through related mobile sites, applications, newsletters and social media pages (collectively referred to as the "Services").
We act as the data controller for personal data processed through our Services.
- Company Name: Today's TopNews Newspaper
- Publishing Company: Strategic Initiative Ltd.
- Registered Address: Strategic initiative ltd, Former Pan African Bank Building, Beside SPAR, 1st Floor, Suit 014, 3 Azikiwe Road , Port Harcourt, River State
- Privacy Contact: [PRIVACY EMAIL]
- Data Protection Officer (where required): Austin Egueno selfrise30@gmail.com
By using our Services, you acknowledge this Privacy Policy. If you do not agree with it, please discontinue using our Services.
This policy should be read together with our Terms of Use and Cookie Policy.
2. INFORMATION WE COLLECT
A. Information You Give Us
- Account and subscription details, including names, email addresses, passwords, phone numbers and billing details. Payment card information is handled by our payment processor and is not stored directly by us.
- Newsletter and news alert sign-ups, including email addresses and topic preferences.
- Comments, letters to the editor, reader submissions, polls and surveys, including photographs, videos and news tips you submit.
- Messages sent to us, including support requests, feedback, advertising enquiries and job applications.
B. Information Collected Automatically
- Device and browser information, including IP address, device type, operating system, browser type, language and screen size.
- Usage information, including articles viewed, time spent on pages, referring pages, search terms, clicks and visit dates.
- Approximate location derived from your IP address. Precise location is collected only with your permission.
- Information collected through cookies, pixels, web beacons, local storage and similar technologies.
C. Information from Third Parties
- Social login and sharing services, including Google and Facebook, where connected.
- Analytics, advertising and fraud-prevention partners.
- Payment processors confirming successful or unsuccessful transactions.
We do not knowingly collect sensitive personal information such as health, religious or political opinions unless you voluntarily include such information in a comment or submission. Please avoid publishing sensitive information about yourself or other people.
3. HOW AND WHY WE USE YOUR INFORMATION
We use personal information for the following purposes:
| Purpose | Examples | Legal Basis |
|---|---|---|
| Deliver Services | Display articles, operate accounts and subscriptions, deliver requested newsletters. | Contract; legitimate interests. |
| Personalise Content | Recommend articles and remember preferences. | Consent; legitimate interests. |
| Advertising | Display, measure and limit advertising frequency. | Consent; legitimate interests. |
| Analysis and Improvement | Measure readership, fix errors and test new features. | Legitimate interests; consent where required. |
| Communication | Respond to enquiries and send service notices or marketing. | Contract; consent. |
| Comment Moderation | Remove unlawful, abusive or spam content. | Legitimate interests; legal obligation. |
| Security | Detect bots, invalid traffic and advertising fraud. | Legitimate interests; legal obligation. |
| Legal Compliance | Respond to lawful requests and defend legal claims. | Legal obligation; legitimate interests. |
We do not sell your personal data for money. However, some privacy laws may treat certain data sharing with advertising partners as a sale or sharing of personal information. See Section 9 for your choices and rights.
4. COOKIES AND SIMILAR TECHNOLOGIES
Cookies are small text files stored on your device. We and our partners may also use pixels, tags, software development kits (SDKs), local storage and similar technologies.
We use the following categories:
- Strictly Necessary Cookies: Used for website security, login sessions, load balancing and remembering cookie choices.
- Preference Cookies: Used to remember language, layout and saved settings.
- Analytics and Performance Cookies: Used to understand how readers use our website, including through services such as Google Analytics.
- Advertising and Marketing Cookies: Used to display, target, measure and manage advertisements and detect invalid traffic.
Managing Cookies
Where required by law, we request your consent before using non-essential cookies through a consent banner.
You can change or withdraw your choices using the "Privacy Settings" or "Manage Cookies" link in our website footer, where available.
You may also block or delete cookies through your browser settings. However, some website features may not function properly.
Global Privacy Control and Do Not Track
Where required by applicable law, we recognise valid Global Privacy Control signals as requests to opt out of the sale or sharing of personal information.
Because there is no universally accepted Do Not Track standard, we do not otherwise respond to Do Not Track signals.
5. ADVERTISING AND GOOGLE
Today's TopNews Newspaper supports its journalism and publishing activities partly through advertising.
We may use Google AdSense, Google Ad Manager and other advertising partners to display advertisements on our website.
This section explains how Google and other third-party advertising vendors may use cookies and similar technologies.
A. How Google and Other Third-Party Vendors Use Cookies
- Third-party vendors, including Google, may use cookies and similar technologies to serve advertisements based on your previous visits to our website and other websites.
- Google's advertising cookies, including the DoubleClick cookie, may enable Google and its partners to serve advertisements based on your visits to our Services and other websites.
- Advertising vendors may collect IP addresses, device identifiers, browser information, pages visited and advertising interactions.
- Advertising exchanges, supply-side platforms, demand-side platforms and measurement providers may also use cookies or identifiers on your device.
These third-party vendors operate under their own privacy policies, which we encourage you to review.
B. Your Advertising Choices
- Manage personalised advertising through Google Ads Settings.
- Learn how Google uses information from websites that use its services at Google Partner Sites Policies.
- Opt out of many third-party advertising cookies through YourAdChoices (US).
- Canadian visitors may visit YourAdChoices Canada.
- European visitors may visit Your Online Choices Europe.
- Use your mobile device settings to limit or reset advertising identifiers.
- Use our Privacy Settings link, where available, to update your consent choices.
Opting out of personalised advertising does not remove advertisements. You may continue seeing non-personalised advertisements based on contextual information.
C. Personalised and Non-Personalised Advertising
Where you provide consent, or where applicable law permits, advertisements may be personalised using browsing activity and interests.
If you decline personalised advertising, we may request non-personalised advertisements based on contextual information, such as the article you are reading and your general location.
D. Our Commitments Under Google's Advertising Policies
- We do not intentionally pass personally identifiable information, such as names, email addresses or telephone numbers, to Google for advertising purposes.
- We do not include personally identifiable information in page URLs.
- We do not use sensitive personal categories such as health conditions, religion, race, sexual orientation or political affiliation for advertising targeting.
- We do not knowingly serve personalised advertisements to users under 18.
- We do not click our own advertisements or encourage others to click them.
- We monitor our website for invalid advertising traffic.
- Advertisements are clearly distinguished from editorial content and identified as advertising.
Information about advertising technology providers may be available through Google's Ad Technology Providers information and relevant consent management tools.
6. CONSENT FOR VISITORS IN THE EEA, UK, SWITZERLAND AND OTHER REGIONS
Where applicable, visitors from the European Economic Area, United Kingdom and Switzerland may be presented with a consent management platform designed to comply with relevant privacy and advertising requirements.
- You may accept all, reject all or choose preferences by purpose and vendor, where supported.
- Rejecting non-essential cookies should be as easy as accepting them.
- Your consent preferences may be stored so that you are not repeatedly asked on every visit.
- You may change your preferences through the available privacy settings.
- Consent signals may be shared with Google and other advertising vendors.
- Fresh consent may be requested periodically or when purposes and vendors change.
In other regions, including Nigeria, the United States and Brazil, we apply the consent and opt-out mechanisms required by applicable local laws.
7. SHARING AND DISCLOSURE OF INFORMATION
We share personal information only when necessary for the purposes described in this policy and, where appropriate, require recipients to protect that information.
- Service Providers: Website hosting companies, email delivery providers, payment processors, analytics providers and customer support services.
- Advertising Partners: Google and other advertising and measurement partners.
- Social Media Platforms: Platforms used for sharing articles and viewing embedded posts, videos and maps.
- Professional Advisers: Lawyers, auditors, accountants and insurers where necessary.
- Authorities and Courts: Where disclosure is required by law or necessary to protect our rights and safety.
- Business Transfers: Where our business merges, is acquired or transfers assets.
- With Your Consent: For other purposes disclosed to you when consent is obtained.
8. INTERNATIONAL TRANSFERS, RETENTION AND SECURITY
A. International Transfers
Our service providers and advertising partners, including Google, may operate in different countries. Therefore, your information may be processed outside Nigeria or your country of residence.
Where personal data is transferred internationally, we rely on appropriate safeguards recognised by the Nigeria Data Protection Act 2023, GDPR or other applicable laws.
B. Data Retention
We retain personal information only for as long as necessary to fulfil the purposes described in this policy.
| Data Category | Typical Retention Period |
|---|---|
| Account and subscription records | Life of account plus up to 6 years for legal and tax purposes. |
| Newsletter subscriptions | Until you unsubscribe. |
| Comments and submissions | Until removal is requested or required under our moderation rules. |
| Server logs and analytics | Up to 26 months. |
| Advertising cookies | Up to 13 months, depending on the vendor. |
| Support enquiries | Up to 3 years after resolution. |
After the applicable retention period, information is deleted or anonymised where reasonably possible.
C. Security
We use reasonable technical and organisational safeguards, including:
- HTTPS encryption where supported.
- Access controls and account protection.
- Staff confidentiality obligations.
- Regular security reviews.
- Measures to detect suspicious activities and unauthorised access.
No online service can guarantee absolute security. Where a personal data breach creates a legal notification obligation, we will notify the appropriate regulator and affected individuals within the time required by applicable law.
9. YOUR PRIVACY RIGHTS
Depending on your location and applicable law, you may have the following rights:
- Right of Access: Request access to personal information we hold about you.
- Right to Correction: Request correction of inaccurate or incomplete information.
- Right to Deletion: Request deletion of personal information where legally permitted.
- Right to Restrict Processing: Request restrictions on certain uses of your data.
- Right to Object: Object to certain processing activities, including direct marketing.
- Right to Withdraw Consent: Withdraw previously provided consent.
- Data Portability: Request your information in a commonly used machine-readable format.
- Automated Decisions: Receive applicable protections against solely automated decisions with significant effects.
- Right to Complain: Submit a complaint to the relevant data protection authority.
To exercise your privacy rights, contact us through [PRIVACY EMAIL].
We may request reasonable identity verification before processing a request. We will respond within the period required by applicable law.
A. California and Other US State Residents
Depending on the law applicable to you, you may have rights to know what categories of personal information we collect and disclose, request deletion or correction, and opt out of certain data sharing for cross-context behavioural advertising.
Where required, these options will be provided through a relevant privacy settings or opt-out link.
B. Marketing Emails
You may unsubscribe from marketing emails by using the unsubscribe link included in the email or contacting us directly. Essential service-related messages may still be sent where necessary.
10. CHILDREN, COMMENTS, NEWSLETTERS AND EXTERNAL LINKS
A. Children's Privacy
Our Services are intended for a general audience and are not specifically directed at children under 13, or under 18 for personalised advertising.
We do not knowingly collect children's personal information without legally required parental consent. If you believe a child has submitted personal information to us without appropriate consent, contact [PRIVACY EMAIL].
We do not knowingly use personalised advertising for users identified as under 18.
B. Comments and Reader Submissions
You are responsible for the information you publish through comments and reader submissions. Your display name and comments may be publicly visible.
We reserve the right to moderate, restrict or remove content that violates our editorial standards, community rules or applicable laws.
C. Newsletters and Push Notifications
We send newsletters and push notifications only where you subscribe or grant the necessary permission. You may unsubscribe or revoke permission at any time.
D. Links to Other Websites
Our articles and advertisements may contain links to third-party websites and services. We are not responsible for the privacy practices or content of those external platforms.
We encourage visitors to review the privacy policies of third-party websites before providing personal information.
E. Journalism and Public Interest
Where permitted by law, we may process personal information for journalistic, literary and public-interest purposes. Certain individual privacy rights may be limited where their exercise would prevent responsible journalism or conflict with applicable legal protections.
To raise a concern about an article, news report or editorial publication, contact our editorial department:
Email: [EDITORIAL EMAIL]
11. CHANGES TO THIS PRIVACY POLICY
We may update this Privacy Policy from time to time to reflect changes in our operations, website features, advertising arrangements, legal obligations or data protection practices.
When changes are made, the updated version will be published on this page with a revised effective date.
We encourage visitors to review this page periodically to remain informed about how their information is handled.
12. CONTACT TODAY'S TOPNEWS NEWSPAPER
If you have questions, concerns or requests concerning this Privacy Policy or the handling of your personal information, please contact us using the details below.
Publication: TODAY'S TOPNEWS NEWSPAPER
Published by: Strategic Initiative Ltd.
Office Address: Strategic initiative ltd, Former Pan African Bank Building, Beside SPAR, 1st Floor, Suit 014, 3 Azikiwe Road , Port Harcourt, River State
Privacy Email: [PRIVACY EMAIL]
Editorial Email: [EDITORIAL EMAIL]
Website: [WEBSITE URL]
