Revised Date: August 22, 2023
In this Policy, we use “DW” or “Daily Wire” or “we”, or “us,” or “our” to refer to The Daily Wire, LLC and/or certain of its subsidiaries who are responsible for processing personally identifiable information (“Personal Data”) about you, and who are the “Controllers” in respect of your Personal Data. The DW entity responsible for the processing of your personal data is normally the company providing the particular content or activity you are engaging with. If you are still unclear about the relevant DW entity or if you have any further questions about this Policy, please contact us using the options set out below. The Daily Wire, LLC’s corporate contact address is located at The Daily Wire, LLC, Ste. 460, 1831 12th Avenue South, Nashville, TN 37203.
• Contact Information
• Collection of your Data
• Purpose and Legal Basis for Processing your Data
• Disclosure of Personal Data
• Text Messages
• Cookies and Online Tracking Technologies
• Retention of Data
• Your Legal Rights
• International Transfers of your Personal Data
• Information Security
• Information Required under Contract
• Children’s Privacy
• Automated Decision-Making and Profiling
• Contact Us
• Update History
1. Contact Information
For customers in the EU or UK, if you believe that your Personal Data has been processed in a way that does not comply with the EU or UK General Data Protection Regulation (GDPR), you have the right to lodge a complaint with your national regulator for data protection. We would, however, appreciate the chance to resolve your concerns before you approach the regulator. Please contact us using our online form.
This policy applies to information we collect:
• Via email, text and other electronic messages between you and us.
• Information collected by us offline.
It does not apply to information collected by:
• Through any other website operated by any third party (including, if applicable, our affiliates and subsidiaries).
• Any third party (including, if applicable, our affiliates and subsidiaries), through any application or content (including advertising) that may link to or be accessible from or on the Websites or the Services.
• Us as a result of an application for employment with DW, during the prospective hiring process, or relating to an individual’s actual employment with DW. Our privacy policies regarding applicants and employees are separately disclosed during the application process and employment onboarding.
3. Collection of your Data
a. Information you Provide. We may collect the following categories of Personal Data you provide to us when interacting with us, using the Websites, or viewing the Content:
- Identification Data: Information that allows us to differentiate you from other individuals. This may include demographic information, including name and surname, date of birth, gender, postal address, username, password, and answers to account security questions.
- Contact Information: Information that allows us to keep in touch with you. This may include email address and phone number.
- Payment Information: information that allows us or our third-party providers to process payments where required to grant you access to our Content, related purchase or subscription status, and payment history.
- Your Entries or Comments: Information you provide when participating in one of our promotions, sweepstakes, or one of our surveys or consumer research.
- Your Enquiries: Information you provide when you contact us seeking customer support.
- User-Generated Content: When we provide you the opportunity to upload or share user-generated content, we will collect information that you provide to us through our Content, such as photographs, video images or other content that you may upload.
- Usage Information: We and our third-party partners and service providers, such as Google Analytics, may use a variety of technologies that collect and provide information about how the Services are accessed and used. Usage Information may consist of your internet browser type and version, operating system, service provider, the webpages, videos and apps you viewed, the time you viewed them and for how long, game or video history, skill level, demographic information about you (such as your age, gender, language, location and interest areas, where available), time zone, language, and what you looked at before accessing our Services. For more information about the collection of some of this information, please also see the section on Cookies and Online Tracking Technologies.
- Device Identifiers: We may also automatically collect your IP address or other unique identifier for the computer, mobile device, technology, or other device you use to access the Services. A unique identifier is a number that is automatically assigned to your device when you access a web site or its servers, and our computers identify your device by this number. Some service providers may also provide us with the physical location of the device used to access the Services. For more information about the collection of some of this information, please also see the section on Cookies and Online Tracking Technologies.
Our Services may contain links to other sites not owned or controlled by us. When you leave our site or platform your information may be collected by a third party and subject to their privacy and cookie notice.
Where allowed by law, we do not treat anonymous consumer information as Personal Data and we reserve the right to convert, or permit others to convert, your Personal Data into anonymous data. We do not attempt to re-identify such information.
b. Collection of Your Sensitive Personal Data
We do collect other “special categories” of Personal Data about you including information required to make inferences about your political opinions, religious or philosophical beliefs, and we do not collect other “special categories” such as details about your sex life, sexual orientation, or other information about your health, including biometric data.
c. Information Collected by Third Parties
The Services may include hyperlinks in association with the Content, plug-ins, websites, locations, platforms, applications, or other services operated by third parties (“Third-Party Services”). These Third-Party Services may use their own cookies, web beacons, and other tracking technology to independently collect information about you and may solicit Personal Data from you. Their privacy policies apply in such cases, and not this Policy.
Certain functionalities on the Services permit interactions that you initiate between the Services and certain Third-Party Services, such as third-party social networks (“Social Features”). Examples of Social Features include enabling you to send content such as contacts and photos between the Content and a Third-Party Service; liking or sharing DW’s content; logging in to the Services using your Third-Party Service account; and to otherwise connect the Services to a Third-Party Service. If you use Social Features, and potentially other Third-Party Services, information you post or provide access to may be publicly displayed on the Content or by the Third-Party Service that you use. Similarly, if you post information on a Third-Party Service that references the Services your post may be used on or in connection with the Services or otherwise by DW. Also, both DW and the third party may have access to certain information about you and your use of the Services and any Third-Party Service. Third-Party Services may in certain circumstances provide DW certain Personal Data, such as identification data, demographic information, contact information, your comments and user generated content, usage information, inferences about you, and device identifiers. To the extent relevant under applicable law, where we control your Personal Data jointly with third parties, we will provide you with information about this relationship at the point of collection or through our Cookie Consent Tool.
4. Purpose and Legal Basis for Processing your Data
We use the categories of Personal Data outlined above for the following purposes and, where we are required to have a legal basis, we rely on the following legal bases:
Where you give us consent:
- Where you ask us to send marketing information to you via a medium where we need your consent
- To tailor advertisements and offers for you, where consent is required under applicable law
- Where required by applicable law, consent to place cookies and to use similar technologies. For more information please also see the section on Cookies and Online Tracking Technologies.
- On other occasions where we ask you for consent, for a purpose which we explain at that time
- Where we are providing online services to children and the relevant processing requires consent, to the extent required by law (for example because the child is below a relevant age threshold) we require parental or guardian consent to do this
- Where consent is otherwise required by applicable law.
To fulfill a contract, or take steps linked to a contract:
- To send you information about changes to our terms or policies and other transactional messages
- To process your registration or subscription on a site or app, or entry into a promotion, sweepstakes, or contest
- To process your payment and fulfil your purchased order or subscription service.
Where this is necessary for purposes which are in our, or third parties’, legitimate interests, such as:
- To provide you with access to the Services and features in the sites and apps
- To send you information you have requested
- To ensure the security of our Services and the safety of our users
- To help other organizations to enforce their rights
- To determine your approximate location and adapt our Services as appropriate
- To tailor the Services, including providing you with personalized Content in the context of our Services
- To analyze how the Services are used
- To improve our services, including analyzing your feedback and comments provided via a survey or consumer research
- To tailor advertisements and offers for you, to the extent permitted by applicable law
- To provide you with customer support.
Where this is necessary for us to comply with our legal obligations:
- In response to requests by government, regulators, judicial or law enforcement authorities conducting an investigation
- To comply with tax or accounting rules or other legal obligation under applicable law.
5. Disclosure of Personal Data
We may share your Personal Data in the following circumstances:
With your consent. We may ask for your consent to share your Personal Data with third parties for their own marketing purposes, and if you give your consent, we will share it in accordance with applicable law. For example, we may share your Personal Data with marketing and promotional partners, social media platforms, and business partners. We give you the name of the third parties that we share your Personal Data with at the time of obtaining your consent. At times, through your use of an interactive feature, a widget or an application, you may ask that we share your Personal Data with a third party, and we will do so under those circumstances in accordance with applicable law. In addition, if you choose to register for a promotion, such as a sweepstakes or contest, your Personal Data may be disclosed to third parties for purposes of the administration of such promotion and in accordance with the terms of such promotion. This may also mean that your Personal Data will be included on a winners list. If you submit user-generated content to a site or app, this content will be disclosed publicly.
Third Parties Providing Services on Our Behalf. We share data with our business partners, as well as third parties who perform functions on our behalf, such as hosting or operating our Services, sending emails, performing marketing and advertising services, and carrying out data analysis. Where you make a purchase on one of our sites or apps, we will share your Personal Data with third parties to process your card payment and deliver your order.
Affiliate Sharing. We share your Personal Data with other DW entities which are involved when we process data for the purposes listed above. We may also share your Personal Data with other DW companies for analytics purposes, account authentication, account management, and for direct marketing purposes in accordance with applicable law.
Business Reorganization. DW or any of its assets, including the Services, may be sold, or other transactions may occur in which your Personal Data may be considered one of the business assets of the transaction. In this case, your Personal Data may be transferred to the purchaser or prospective purchaser to the extent permitted by law, as part of the transaction and/or during any due diligence process.
6. Text Messages
If you provide your mobile phone number to us, we may ask for your consent to receive text message alerts from us containing product, event, or promotional information in a text or SMS message (“Text Messages”). The Text Message program allows users to receive SMS/MMS mobile messages by users affirmatively opting into the program, such as through online enrollment forms or by texting a keyword to 83400 or any successor short code to opt into the program. Your consent to receive Text Messages is not required to purchase goods or services from us. Additional terms regarding Text Messages will apply—please review the applicable terms carefully when you provide your mobile phone number.
If you consented to receiving promotions or advertising via Text Message, you can unsubscribe from receiving Text Messages at any time by replying “STOP” to one of our Text Messages or to 83400. For help, text HELP to 83400 or contact us at support.dailywire.com.
Notwithstanding anything else in this Policy, Daily Wire does not share Personal Data obtained through its short code texting program with unaffiliated third-party companies for marketing purposes.
7. Cookies and Online Tracking Technologies
Cookies, tracking pixels, web beacons, and other tracking technologies may be used by DW and third parties including other DW companies to collect information about your interactions with the Services or the emails which DW sends to you, including information about your browsing and purchasing behavior.
We use tracking technologies for the following purposes:
(a) To provide you with the services and settings you have requested: for example, letting you navigate between pages efficiently, keeping you logged in during your visit, checking for bugs and glitches in the Services, to comply with applicable law, and ensuring security of the Services. We typically collect account information such as username and password, device identifiers, usage information as it relates to glitches, bugs, or Services security issues, and the preferences you select for these purposes.
(b) To show advertisements and Content recommendations that are more relevant to your interests: for example, we use tracking technologies to remember Content that has interested you, to make Content recommendations and tailor Content, and then use this to help us serve more relevant ads to you, including when you are on another site. Tracking technologies also help limit the number of times that you see an ad, measure the effectiveness of advertising campaigns and help us and others track whether ads have been properly displayed. We typically collect contact information, device identifiers such as IP address, and usage information such as your ad interactions, browsing history, and viewing history for this purpose.
We also allow other organizations to use tracking technologies for these advertising purposes. In addition, we work with third-party platforms and websites (such as social networking platforms) to serve targeted advertisements on such third-party services and platforms to you or others, and we may convert your email address, telephone number, or other information into a unique value and provide it to these third-party platforms for matching purposes. You can find information about these third-party platforms and websites in our Cookie Consent Tool.
To the extent required by law, we will ask for your consent before setting these cookies. To learn more about certain cookies used for interest-based advertising as described above by third parties, including through cross-device tracking, and to exercise certain choices regarding such cookies, please review the websites for the Digital Advertising Alliance, Network Advertising Initiative, Digital Advertising Alliance-Canada, European Interactive Digital Advertising Alliance, and your device settings.
How to manage tracking technologies
We keep information collected from cookies for no longer than the maximum period permitted by law. We will not collect, use, or disclose your Personal Data in any ways or for any purposes that are materially different from those set forth herein. However, if we wish to do so in the future, we will provide notice and an opportunity to opt-out of such proposed collection, use, or disclosure, or to provide consent, as required by applicable law.
To the extent required by law, we will ask for your consent and provide a link to this Policy before setting any non-essential cookies (i.e., the cookies in categories (b) and (c) above) and before using pixel tags in emails sent to you (which we ask for at the same time as your direct marketing preferences). You are able to withdraw this consent at any time using the methods described below or as otherwise specified in the Services.
If you are using our Services via a browser and cookies are deployed, you can change your cookie preferences and withdraw your consent at any time using the Cookie Consent Tool. You do not need to have cookies enabled to use our Services but turning them off may affect your experience on our sites and apps.
In addition, while most web browsers are initially set up to accept cookies, many browsers have settings to allow you to prevent your browser from accepting new cookies, delete cookies, and disable cookies altogether.
Location-identifying Technologies: Subject to applicable laws, we may use GPS software, geo-filtering and other location-aware technologies to locate (sometimes precisely) you for purposes such as verifying your location and delivering or restricting content (e.g., territory restrictions) and advertising based on your location. You can turn off precise geo-location tracking through the location settings on your device.
Apple iOS, Android Devices, and Other Connected Devices: When you access certain applications from these devices, cookies, and other tracking technologies will be automatically stored to your device for the following purposes: keeping you logged in, managing parental control PINs, financial reporting, and for other purposes permitted by applicable law. These cookies are essential to the operation of the application. Depending on which device you are using, you may be able to opt out or remove these cookies from the device through the settings or by deleting the application or your account. If you use our mobile application on a connected device, we may collect a Resettable Device Identifier from your device. Resettable Device Identifiers (also known as mobile advertising identifiers) are similar to cookies and are found on many mobile devices and tablets (for example, the “Identifier for Advertisers” (or IDFA) on Apple iOS devices and the “Google Advertising ID” on Android devices), and certain streaming media devices.
8. Retention of Data
9. Your Legal Rights
Where required by applicable law, you may have the right to obtain confirmation that we maintain certain Personal Data relating to you, to verify its content, origin, and accuracy, as well as the right to access, review, port, delete, or to block or to object to, or withdraw consent to the processing of certain Personal Data (without affecting the lawfulness of processing based on consent before its withdrawal). In particular, you may ask us not to use your Personal Data when we carry out profiling for direct marketing purposes or any other processing based on your consent.
Please visit this page in order to submit a request to exercise your applicable rights and to contact us with general privacy-related questions, or you may email us at [email protected] or call 1(866) 839-2772. We may request certain information for the purpose of verifying the identity of the individual seeking access to his or her Personal Data.
DW email subscribers and subscribers of paid Content may also access and correct their contact information on file by accessing their account online.
We will make reasonable efforts to make such requested changes in our then-active and relevant consumer databases as soon as practicable, but it is not always possible to change, remove or delete your information or public postings from our databases and residual and/or cached data may remain archived thereafter if our retention of this data falls within an exemption from the fulfilment of your data subject rights under applicable law. Further, we reserve the right to retain your Personal Data (a) as permitted by applicable law; (b) as required by applicable law; and (c) for so long as reasonably necessary to fulfil the purposes for which the data is retained except to the extent prohibited by applicable law.
You can opt out of receiving email newsletters by following the opt-out instructions provided to you in those emails or by requesting to opt out by emailing us at [email protected]. If you sign up to receive SMS or MMS messages, you can unsubscribe from those messages received by replying “STOP” as detailed above. Transactional account messages will be unaffected if you opt-out from marketing communications.
You have the ability to disable or opt-out of certain cookies by going to the Cookie Preferences of your browser or by using our Cookie Consent Tool. You can reset your web browser to refuse all cookies or to indicate when a cookie is being sent. However, certain features of the Website or Services may not work if you delete or disable cookies.
In some instances, you can opt-out of receiving interest-based online ads from us, third party advertisers and ad networks. You can find more information on this process in the Cookies and Online Tracking Technologies Section above. Be advised that these opt-out tools are provided by third parties and may not be available with respect to all interest-based advertising that is presented to you. We do not control or operate these tools or the choices that advertisers and others provide through these tools. Even if you opt out of receiving interest-based advertising, you may still receive generic ads.
Rights for European Economic Area and UK Residents — If you are a resident of the EEA or UK, you have the right to:
• Find out if we use your Personal Data, to access your Personal Data, and receive copies of your personal information.
• Withdraw any express consent that you have provided to the processing of your Personal Data at any time without penalty.
• Access your Personal Data and have it corrected or amended if it is inaccurate or incomplete.
• Obtain a transferable copy of some of your Personal Data which can be transferred to another provider when the Personal Data was processed based on your consent.
• If you believe your Personal Data is inaccurate, no longer necessary for our business purposes, or if you object to our processing of your Personal Data, you also have the right to request that we restrict the processing of your data pending our investigation and/or verification of your claim.
• Request your Personal Data be deleted or restricted under certain circumstances. For example, if is using your Personal Data on the basis of your consent and has no other legal basis to use such, you may request your Personal Data be deleted when you withdraw your consent.
Withdrawing your consent will not affect the lawfulness of any processing we conducted prior to your withdrawal, nor will it affect processing of your Personal Data conducted in reliance on lawful processing grounds other than consent.
If we collect and use your Personal Data in reliance on our or a third party’s legitimate interests and those interests are not already described above, we will let you know what those legitimate interests are.
If you are not satisfied with our response, or believe we are processing your Personal Data in violation of the law, you have the right to lodge a complaint with the Supervisory Authority (also known as Data Protection Authority) or other appropriate governmental authority in your EEA Member State or the UK, as applicable. A list of Supervisory Authorities is available here: https://edpb.europa.eu/about-edpb/board/members_en.
10. International Transfers of your Personal Data
Our Content is hosted and operated by us or our service providers in the United States and other countries. As such, your Personal Data will be transferred to and processed in the United States and other countries that may not provide the same level of data protection as your home country. We provide appropriate protections for international transfers as required by law for international data transfers. With respect to transfers originating from a country or a region such as the United Kingdom or the European Economic Area (“EEA”), and if the transfer is not to a country which is the subject of an adequacy decision or adequacy regulation (or equivalent), we implement appropriate solutions to address cross-border transfers as required by applicable law such as, with relation to the EEA, standard contractual clauses approved by the European Commission; and with the UK, standard contractual clauses approved by the UK government. Under such laws, you may request a copy of the suitable mechanisms we have in place by contacting us at [email protected]. Where your consent is required by applicable law for the international transfer of Personal Data, by using the Services and providing us with your Personal Data, you consent to the international transfer of your Personal Data.
11. Information Security
DW has procedural, technical and physical security measures to help protect against the risk of loss, misuse, and alteration of information that you provide, including Personal Data. We request third parties with whom we share Personal Data to do the same. Nevertheless, such security measures may not prevent all loss, misuse, or alteration of information on the Websites or Services, and DW is not responsible for any damages or liabilities relating to any such security failures. By using the Websites or Services, you understand that there is a risk that data and communications, including email and other electronic communications, may be accessed by unauthorized third parties. The foregoing does not affect any liability that cannot be excluded or limited under applicable law.
Please do not provide your password to another person. We cannot be responsible for a data breach or other incident if a password is used by unauthorized persons.
12. Information Required under Contract
13. Children’s Privacy
Our Services are not intended for children under 13 years of age. We do not knowingly collect Personal Data from children under 13 on the Websites. If you are under 13, do not use or provide any information on the Services or through any of their features, register on the Websites, make any purchases through the Websites, use any of the interactive or public comment features of the Services, or provide any information about yourself to us, including your name, address, telephone number, email address, or any screen name or username you may use. If we learn we have collected or received Personal Data from a child under 13 without verification of parental consent, we will delete that information. If you believe we might have any information from or about a child under 13, please contact us using our online form.
To the extent that Daily Wire develops a service or portion of the Service that is intended for children, such service or portion of the Service shall be subject to additional Children’s Privacy terms available at such website, which will supersede these terms to the extent there are any conflicts.
You must be 18 years of age or older to purchase any content, product, or service offered by us through the Service. If you are less than 18 years of age and want to make any such purchase, please ask your parent or guardian to complete the purchase on your behalf. We do not otherwise knowingly collect Personal Data and Sensitive Personal Data from anyone under the age of 18 without permission.
14. Automated Decision-Making and Profiling
We do not use automated decision-making without human intervention, including profiling, in a way that produces legal effects concerning you or otherwise significantly affects you.
16. Contact Us
The Daily Wire, LLC
1831 12th Avenue South
Nashville, TN 37203
Help Center: support.dailywire.com
Email: [email protected]
You may also have a right to submit a complaint to a supervisory authority for data protection in the country where you live, where you work, or where you consider that a breach of data protection has occurred.
17. Update History