PRIVACY POLICY
PRIVACY POLICY OF "RCA TELEGRAM NEWS CALIFORNIA"
Publisher, responsible business and privacy contact
SCANDIC TRUST GROUP LLC is responsible for the collection, use and disclosure of personal information described in this Privacy Policy where it determines the purposes and means of that processing. References to "we", "us" and "our" mean SCANDIC TRUST GROUP LLC in its capacity as the publisher and service provider of "RCA TELEGRAM NEWS CALIFORNIA".
SCANDIC TRUST GROUP LLC
IQ Business Centre
Bolsunovska Street 13–15
01014 Kyiv / Ukraine
Email: [email protected]
Legal form: limited liability company incorporated under Ukrainian law, LLC.
Registration number: 1010351020000018952.
The address above is our operational and correspondence address. Privacy inquiries, complaints and requests to exercise your rights may be sent to this address or to the email address above. The registration number identifies the Ukrainian company and is not a California or United States company registration number.
Registered office and company address
SCANDIC TRUST GROUP LLC
Oksamytova Street 1-b, Office 30
Sofiivska Borshchahivka
Kyiv Region - 08147 / Ukraine
Technical operation and administration
SCANDIC ASSETS FZCO
Dubai Silicon Oasis DDP
Building A1/A2
Dubai - 342001 / United Arab Emirates
Telephone: +971 54 221 5217.
SCANDIC ASSETS FZCO provides technical services within the scope of its appointment. Access to personal information must be limited to the information and functions necessary for the assigned work. Where the California Consumer Privacy Act requires a service-provider or contractor agreement, the arrangement must satisfy the applicable contractual restrictions, including restrictions on retaining, using, disclosing, selling or sharing information outside the permitted purposes. A company’s legal role depends on its actual activities, decisions and contractual obligations. Technical involvement or membership of the same corporate group does not, by itself, establish an exemption from privacy requirements or unrestricted permission to exchange information.
Commercial cooperation
LEGIER Beteiligungs mbH
Kurfürstendamm 14
10719 Berlin
Federal Republic of Germany
Commercial register: HRB 57837
Register court: Amtsgericht Charlottenburg, Berlin
VAT identification number: DE413445833
Telephone: +49 30 99211 3469
Fax: +49 30 99211 3225
Email: [email protected]
Where LEGIER Beteiligungs mbH is involved in an advertising inquiry or commercial arrangement, personal information may be disclosed to it only for a specified lawful purpose and to the extent necessary for its role. Commercial cooperation does not give that company unrestricted access to reader, subscriber or editorial information. Where it determines its own purposes for using information, its responsibilities and the relevant privacy information must be identified in connection with the particular service. Commercial contact information must not automatically be combined with reader profiles or confidential editorial records.
Introduction and scope
This Privacy Policy explains how personal information is handled in connection with the websites, applications, editorial activities and other services of "RCA TELEGRAM NEWS CALIFORNIA". It addresses collection, purposes, disclosures, international processing, retention, security and privacy rights. Provisions concerning accounts, subscriptions, orders, newsletters, comments, events or other additional functions apply where those functions are actually provided. References to external technologies describe the processing associated with their use and do not mean that every technology mentioned is active on every page. Information supplied when a particular service collects information supplements this Policy and must accurately identify the processing concerned. Your statutory rights do not depend on accepting this Policy, and reading or accepting it does not constitute consent to advertising, tracking, recording or other processing requiring a separate choice.
Applicable United States and California law
The principal California framework includes the California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and subsequent legislation, referred to below as the "CCPA", together with its implementing regulations. The CCPA applies according to its definitions, business thresholds, territorial requirements and exemptions; foreign incorporation does not itself remove obligations arising under it. Other relevant California laws include the California Online Privacy Protection Act, the California Invasion of Privacy Act, statutory security and breach-notification requirements, and applicable constitutional and common-law privacy protections. Federal requirements may include section 5 of the Federal Trade Commission Act, the Children’s Online Privacy Protection Act and its implementing Rule, the Electronic Communications Privacy Act, the Video Privacy Protection Act and the CAN-SPAM Act. These laws have different scopes and do not establish an identical set of rights for every person or processing activity. Additional laws applicable because of a person’s location or a particular service remain unaffected.
A) General information on personal information processing
Personal information includes information that identifies, relates to, describes, is reasonably capable of being associated with, or could reasonably be linked to a particular person or household within the meaning of the applicable law. Depending on the activity, this may include names, contact details, account identifiers, correspondence, transaction records, contributions, photographs, recordings, IP addresses, device information and information about the use of our services. Replacing a name with an identifier, hashing an email address or combining information into a profile does not necessarily make it anonymous. Deidentified and aggregate information must satisfy the relevant legal definitions and safeguards before being treated as outside rules governing personal information. Collection, use, disclosure and retention must remain reasonably necessary and proportionate to the disclosed purposes and comply with applicable restrictions.
Categories of information and notices at collection
The categories relevant to the activities described in this Policy include the following, according to the service used and information actually provided or generated:
- Identifiers and contact information, including names, postal addresses, email addresses, account names, online identifiers, IP addresses and similar identifiers.
- Customer and transaction information, including subscription details, orders, billing records, payment status, correspondence and information necessary to administer an agreement.
- Internet or other electronic-network activity, including requested pages, interactions with available features, referring-page information, device characteristics and technical event records.
- Approximate location information derived from a network connection, where used for an identified purpose; precise geolocation requires separate consideration as sensitive personal information.
- Audio, visual or similar information, including material voluntarily submitted, published contributions and recordings or images associated with an identified service or editorial activity.
- Professional or employment-related information where relevant to business correspondence, a submitted application or a specific editorial matter.
- Preferences and inferences where a disclosed personalization or advertising function actually creates or uses them.
- Sensitive personal information where necessary for a specifically identified activity or voluntarily included in a communication, subject to the additional protections described below.
A notice at collection must identify the categories actually collected, the purposes, the applicable retention period or criteria, and whether the information is sold or shared where the CCPA requires those disclosures. Required disclosures concerning the preceding twelve months must reflect actual practices, including the relevant categories of information and recipients. A list of possible service functions does not establish that every category has been collected, sold or shared. Information must not be collected for an undisclosed additional purpose or used incompatibly without the notices, consent or other measures required by law.
Purposes and legal requirements
The purposes relevant to our services include providing requested content, administering accounts or subscriptions, responding to correspondence, processing transactions, maintaining security, investigating faults, handling privacy requests, meeting applicable legal obligations and conducting lawful journalistic activities. Optional functions may involve newsletters, personalization, audience measurement or advertising, subject to the specific information and choices required for those activities. United States and California privacy law do not generally use the same universal list of processing grounds as Article 6 of the European Union General Data Protection Regulation. Describing an activity as necessary for a contract or a legitimate business interest does not override a California opt-out right, a recording-consent requirement, a statutory prohibition or a binding privacy commitment. Where consent is required, it must relate to the particular activity and satisfy the applicable legal standard.
Exceptional processing and additional protections
Information may need to be preserved or disclosed to comply with a valid legal obligation, protect a person from a serious threat, investigate fraud or a security incident, or establish, exercise or defend legal claims. Such circumstances must be assessed individually and do not authorize unrestricted collection or disclosure. Requests from public authorities must be evaluated for legal validity, scope and any applicable confidentiality or source-protection requirements. Information retained for a legal or security purpose must not automatically remain available for unrelated advertising. A general reference to safety, crime prevention or the public interest is not a substitute for satisfying the law governing the particular use.
Sources of personal information
We obtain information directly from people who contact us, register for an available service, submit material, place an order or make a privacy request. Technical information may arise when a device requests content or interacts with an available feature. Other sources may include authorized representatives, service providers involved in a requested transaction and sources relevant to legitimate editorial work, including interviews, public records, contributors and published material. Information obtained from another organization for a commercial purpose must have an identified lawful source and use. Public availability does not authorize unrestricted collection, combination or republication. The CCPA’s exclusions for publicly available information and lawfully obtained, truthful information concerning matters of public concern must be applied according to their actual definitions.
Editorial and journalistic processing
Personal information may be handled when researching, verifying, preparing, publishing, correcting and retaining journalistic material. Relevant protections include the First Amendment to the United States Constitution and Article I of the California Constitution, together with applicable privacy, defamation and confidentiality rules. The CCPA includes exceptions relevant to exercising free speech and other legal rights, including the deletion exception in California Civil Code section 1798.105(d)(4). These provisions do not create a blanket exemption for every activity of a newspaper. Accounts, subscriptions, payment administration, advertising profiles and ordinary audience tracking require their own assessment. The public interest in reporting does not automatically justify unlawful methods of obtaining information or unnecessary disclosure of private details.
Privacy, confidential sources and editorial archives
Editorial decisions take account of the nature and sensitivity of information, its accuracy, the circumstances in which it was obtained, its relevance to a matter of public concern and the consequences of publication. Particular care is required with children, health information, intimate matters, criminal allegations and vulnerable individuals. Confidential sources and unpublished material require appropriate safeguards, including consideration of Article I, section 2(b), of the California Constitution, California Evidence Code section 1070 and other applicable protections. Those protections are not an unrestricted exemption from every lawful demand or judicial process. Retaining an article in a journalistic archive requires consideration of the relevant rights and interests; neither automatic removal of accurate historical reporting nor indefinite retention of every underlying record follows merely from describing information as archival.
External platforms and distribution services
Where our content is made available through social networks, video or audio platforms, applications, connected televisions or voice assistants, the platform operator may process information for its own purposes. Such services may include X, Facebook, Instagram, YouTube, Telegram, TikTok, Apple services, Amazon services, Google services, Roku, Huawei, Spotify or other distribution platforms where actually used. A normal link, an embedded player and an externally loaded image can involve different disclosures. An embedded resource may contact its provider when a page loads, before you interact with it. Having an account with a platform or accepting its terms does not establish general consent to every disclosure from our website. Our responsibility for processing that we determine or initiate remains subject to applicable law.
Technical information and voice assistants
When content is requested from our servers, technical records may be generated. Depending on the service and connection, these may contain:
- The requested page or file and the date and time of access.
- The amount of information transferred, response status and technical error information.
- The IP address and information about the browser, operating system or device.
- Referring-page information where transmitted by the browser or platform.
- Network or connection information available as part of the request.
Technical records are used for delivery, troubleshooting and security within the purposes described in section E. Their collection does not authorize unrelated advertising profiles or unrestricted combination with other records. Providers of voice assistants may process commands, recordings, transcripts or interaction records according to their services and settings. Use of a voice assistant does not necessarily mean that "RCA TELEGRAM NEWS CALIFORNIA" receives the original recording or complete conversation.
Sensitive information and criminal allegations
The CCPA gives particular treatment to specified sensitive personal information, including certain government identifiers, financial-account credentials, precise geolocation, specified communications content, genetic information, biometric information used for identification and information concerning health, sexual life, sexual orientation, racial or ethnic origin, religious or philosophical beliefs, or union membership. The applicable obligations depend on the information, purpose and statutory exceptions. Information must not be treated as unrestricted merely because someone voluntarily includes it in correspondence. Ordinary photographs or voice recordings are not automatically biometric identifiers, although processing them to identify a person can engage additional requirements. Criminal allegations and other potentially damaging editorial information require careful verification and privacy assessment even where a particular category does not fall within the CCPA’s definition of sensitive personal information.
B) Contacting us
When you contact us by email, telephone or an available contact form, we process the information needed to understand and respond to your inquiry, including your contact details and the content of your message. Correspondence may concern a requested service, an editorial matter, an order, a privacy right or a legal obligation. Please provide only information relevant to the matter. Without sufficient information, we may be unable to investigate or reply. Contacting us does not subscribe you to advertising or authorize unrelated profiling. Where a call or communication is recorded, applicable notice and consent requirements must be satisfied before recording begins. The fact that a participant or recording system is outside California does not necessarily exclude California law. Routine correspondence is retained while the matter is being handled and thereafter under the limits and exceptions in section H.
C) Reservations, orders, subscriptions and user accounts
Where these services are offered, we process the identification, contact, account, contractual, order and payment information necessary to provide them. Account information may include credentials, preferences, subscription status and records of account administration. Required information and the consequences of not providing it must be explained when it is collected. Optional information and marketing choices must remain distinguishable from information needed for the service. Payment providers may process information independently for payment, authentication, fraud prevention or regulatory purposes; their involvement does not necessarily give us access to full card or bank details. Subscription information must not be used to conceal an unrelated advertising purpose. Account closure, subscription cancellation and a request to delete personal information are distinct matters, and we will help clarify a request that concerns more than one of them.
D) Accounting and statutory record retention
Financial and transaction records are retained for the period required by the law applicable to the company and transaction concerned. Relevant requirements may arise from tax, accounting, payment, consumer-protection or other legislation. A retention period applicable to a particular United States taxpayer or transaction does not automatically govern every record held by an overseas company. Where California’s Automatic Renewal Law requires evidence of affirmative consent, the applicable verification records must be maintained for at least three years, or one year after termination of the contract, whichever is longer. Other records may be subject to different requirements. The ordinary retention limits in section H do not override a specific statutory duty or necessary legal hold. Records kept for accounting or legal purposes must not remain available for unrelated marketing merely because retention is required.
E) Technical provision of the website and operational security
Technical information is processed to deliver requested content, maintain functionality, investigate faults and protect services against unauthorized access, attacks and misuse. The information used must be reasonably related and proportionate to those purposes. Security or service delivery must not be used as a label for unrelated advertising surveillance. Technical suppliers receive access only to the extent necessary for their work and subject to the applicable contractual and legal restrictions. Routine operational records are retained for the shortest period justified by their purpose, subject to the maximum and exceptions in section H. A specific incident may justify separately preserving relevant evidence, with restricted access, while the incident or associated legal matter is addressed.
Cloudflare and cdnjs
Where Cloudflare services are used for content delivery, network protection or distribution of technical resources through cdnjs, the provider may receive IP addresses, request times, requested-resource details and technical information transmitted by the browser. The purposes and legal requirements depend on the particular service and configuration. Necessary security or delivery processing must be distinguished from optional audience analysis, advertising or independent use by a recipient. Storage of a technical resource in a browser cache is not the same as retention of personal information in server logs. The use of a content delivery network does not automatically make every related disclosure exempt from notice, consent or opt-out requirements. Relevant recipient arrangements and overseas processing are addressed in section G.
Google Fonts and externally loaded resources
Where fonts or other resources are loaded directly from Google or another external provider, the browser may disclose the IP address, requested resource and associated technical information to that provider. The absence of cookies does not necessarily mean that no personal information is processed. The connection must be assessed according to its purpose, necessity, recipients and actual consequences. Serving a font file locally avoids the separate browser request to the external font provider for that file. Information about an external resource must distinguish technical delivery from any additional tracking or independent use of information.
F) Cookies, device access and tracking technologies
Cookies and similar technologies may store information on your device, recognize a browser or collect information about interactions with a service. Relevant technologies include browser storage, tracking pixels, software identifiers, session-replay tools and device fingerprinting. California and federal requirements depend on how a technology operates and what information it collects or discloses. Descriptions such as "cookieless", "statistics", "personalization" or "optimization" do not determine whether notice, consent or an opt-out mechanism is required. A technology that transmits identifiers or viewing activity to another organization must be assessed as a disclosure even if no directly identifying name is included.
Consent, opt-out rights and legally permitted processing
California law does not impose one universal consent rule on every cookie or technical operation. The applicable requirements may instead concern notice at collection, the right to opt out of sale or sharing, restrictions on sensitive information, children’s information, interception or recording, or a specific federal statute. Where prior consent is required, the relevant activity must remain inactive until legally effective consent has been obtained. Where an opt-out applies, the activity must respect that choice within the applicable requirements. A general statement that processing benefits the business does not override those rules. Consent to one purpose does not automatically authorize another purpose or disclosure to additional recipients.
Statistics used to improve our services
Service statistics may be used to understand performance, identify faults and improve content or functionality. The information used must be limited to what is appropriate for the disclosed purpose. Aggregate reporting must not be confused with the collection of identifiable event records before aggregation. Information can remain personal information where it can reasonably be linked to a person or household, even if the final report contains only totals. A recipient’s use of information across unrelated customers or services requires separate assessment and may affect its status as a service provider or third party. Describing an activity as analytics does not establish that it falls outside the CCPA’s sale or sharing provisions.
Your choices and withdrawal of consent
Where consent is required, silence, continued browsing, preselected options or general acceptance of the Terms of Service do not, by themselves, establish legally effective authorization for a separately regulated activity. Optional purposes must be explained clearly, and choices must not be obtained through misleading design or unnecessary obstacles. Privacy and cookie choices may be communicated through the available service controls or to [email protected]. Withdrawal ends further reliance on the withdrawn consent, subject to the applicable law; it does not automatically invalidate earlier lawful processing. Browser controls may block or delete cookies, but deleting a cookie does not necessarily communicate a request to every recipient or remove information already held. A request to stop marketing is distinct from a request to delete an account or cancel a subscription.
Remembering cookie and language choices
Our own ordinary cookie and preference records are retained for no longer than twelve months from the last active choice, subject to the limited compliance and evidential retention described in section H. A record used to remember a privacy decision must not be repurposed as an advertising identifier. A language preference is retained for the relevant session or, where a persistent preference is requested, for the necessary period up to twelve months. Browser session restoration may affect the practical lifetime of a session cookie. These are policy limits, not a statement that California law prescribes one universal cookie duration. Expiration of a preference record does not authorize deliberate circumvention of an opt-out, and a further visit does not itself renew consent.
Cloudflare Web Analytics
Where Cloudflare Web Analytics is used, the service may process information concerning page views, performance, referring pages and browser or device characteristics. Its actual configuration, recipient uses and disclosures must be assessed under applicable law; describing analytics as privacy-focused does not establish a legal exemption. Cloudflare’s product documentation describes retention of unsampled beacon information for seven days, followed by sampling or aggregation, and access to historical reports for the preceding six months. Sampling does not itself establish that information is anonymous. These product periods do not determine the retention periods of every other Cloudflare service, security record or log. Applicable consent and opt-out requirements remain relevant to the actual implementation.
Advertising, personalization and measurement purposes
Where the relevant functions are offered, separately explained purposes may include:
- Selecting advertising using limited information.
- Creating profiles for personalized advertising.
- Using profiles to select personalized advertising.
- Creating profiles to personalize content.
- Using profiles to select personalized content.
- Measuring advertising performance.
- Measuring content use and performance.
- Analyzing audiences using statistics or information from different sources.
- Developing and improving services.
- Selecting content using limited information.
This list does not authorize every activity or establish that all of them take place. For an active purpose, the information collected, recipient categories, relevant choices and retention must be disclosed as required. Advertising permission must not be expanded to unrelated purposes. Sensitive inferences and information concerning children require additional consideration. Industry frameworks, including IAB systems, do not replace statutory requirements or establish unrestricted permission for unidentified organizations or unspecified future uses.
Sale, sharing and Global Privacy Control
Under the CCPA, a sale can include a disclosure of personal information for monetary or other valuable consideration. Sharing includes specified disclosures for cross-context behavioral advertising, whether or not money is exchanged. A disclosure to an advertising or analytics provider must therefore be assessed according to its actual operation and contractual restrictions; calling the recipient a partner does not settle the issue. Where these activities occur within the CCPA’s scope, the required disclosures and methods for opting out must be provided. A "Do Not Sell or Share My Personal Information" control, or a legally permitted alternative, must operate as required. Qualifying opt-out preference signals, including Global Privacy Control, must be honored without requiring a separate email, an account or unnecessary identity verification. Where a signal can be associated with a known consumer or account, it must be applied to the associated information as required by law. A browser signal is not treated as consent to unrelated processing, and the absence of a signal does not establish affirmative consent where consent is required.
Sensitive-information limits and browser signals
Where sensitive personal information is used or disclosed for purposes giving rise to the CCPA’s right to limit, the required notice and means of exercising that right must be provided. Uses limited to purposes permitted by the statute and regulations are assessed according to those exceptions. A general browser "Do Not Track" setting and a legally recognized opt-out preference signal are not necessarily equivalent. A signal meeting California’s requirements is treated according to those requirements, regardless of its label. Privacy choices must not be undermined by hidden settings, repeated demands to reconsider or a claim that paid advertising alone makes all associated tracking necessary.
G) Recipients and international processing
Personal information is disclosed only for an identified lawful purpose and to the extent justified by that purpose. Depending on the activity, recipients may include technical service providers, providers involved in a requested transaction, communication providers, professional advisers subject to confidentiality, relevant editorial contributors and competent authorities or courts where disclosure is lawful. Identifiers and contact information may be needed to deliver communications or administer a requested service; transaction information may be needed by payment or accounting providers; technical records may be needed by hosting and security providers. Editorial information is handled according to the separate considerations described above. Disclosures for advertising require the additional assessment and choices described in section F. Common ownership or a commercial relationship does not itself authorize sharing.
Principal organizations and service-related recipients
The relevant roles include:
- SCANDIC TRUST GROUP LLC, Ukraine: publisher and responsible organization for the activities described in this Policy that it determines and undertakes.
- SCANDIC ASSETS FZCO, United Arab Emirates: technical operation and administration, with access limited to its actual tasks and the applicable arrangements.
- LEGIER Beteiligungs mbH, Germany: commercial cooperation where involved in a specific advertising inquiry or agreement.
- Cloudflare, Inc., United States: where the relevant content-delivery, security, cdnjs or Web Analytics services are used.
- The relevant Google service provider: where Google-hosted fonts, YouTube or other Google resources are used, according to the particular service and responsible entity.
- Payment, communication and other service providers: where involved in an actual order or service, with their identity or legally required recipient information explained in the relevant service information.
Information about recipients must reflect actual disclosures. Where the law requires historical category-by-category disclosure of recipients, a general list of organizations does not replace that requirement. Requests for available recipient information may be made through the privacy contact above.
Overseas processing and remote access
The publisher is established in Ukraine, and the technical company is established in the United Arab Emirates. Commercial cooperation may involve Germany, and particular technology providers may process information in the United States or other locations. Information may therefore be handled in a country different from the country in which you live. Access by an overseas organization can constitute a disclosure even where the server remains in the United States. Foreign processing does not remove California rights or obligations that otherwise apply. The relevant recipients, purposes, access restrictions, security measures and contractual requirements must be assessed before information is made available.
Contractual safeguards and restricted transactions
Where the CCPA requires a service-provider, contractor or third-party agreement, the agreement must specify permitted purposes and include the legally required restrictions and protections. A general confidentiality clause is not necessarily sufficient. Information must not be made available under an arrangement that permits prohibited secondary use or defeats an applicable opt-out. Federal restrictions may also apply to certain transactions involving United States government-related information or bulk sensitive personal information under the Department of Justice Data Security Program, 28 C.F.R. Part 202. Those restrictions depend on the transaction, information, parties and applicable exceptions; ordinary overseas processing is not automatically prohibited or automatically permitted. A recipient’s marketing description of its security does not replace the assessment of its actual role and obligations.
Additional protections where European law applies
The European Union General Data Protection Regulation applies separately where its territorial requirements are satisfied, including qualifying activities connected with offering services to people in the European Union or monitoring their behavior there. In that event, the applicable requirements concerning legal grounds, transparency, individual rights, processor arrangements and international transfers must also be addressed. Transfers subject to Chapter V require an applicable adequacy decision, appropriate safeguards or a valid exception. A provider’s location, the use of encryption or a general reference to standard contractual clauses does not establish that the relevant transfer requirements have been met. This Policy does not treat European law as applying automatically to every California-related activity or treat California law as replacing protections that apply independently.
H) Retention and deletion of personal information
Under this Policy, the ordinary maximum for our own routine operational records is twelve months from the event specified below. Information is deleted or deidentified earlier where it is no longer necessary, provided any deidentification satisfies the applicable legal requirements. Longer retention is limited to what is justified by a continuing service, a specific legal obligation, legal claims, continuing respect for a privacy choice or a properly assessed journalistic purpose. A maximum period does not justify keeping unnecessary information until that period expires.
- Inquiries and correspondence: while the matter is being handled and ordinarily no longer than twelve months after closure, subject to necessary legal or evidential retention.
- Accounts and contracts: while necessary for an active account or continuing agreement, followed by retention of necessary remaining records for ordinarily no longer than twelve months after closure or termination, except for applicable accounting, legal or claims requirements.
- Technical and security records: for the shortest period justified by their operational purpose and ordinarily no longer than twelve months from recording; evidence of a particular incident may be retained separately while necessary for investigation or related legal proceedings.
- Cookie and preference records: ordinarily no longer than twelve months from the last active choice, with shorter periods appropriate to the function.
- Consent and withdrawal records: while necessary to demonstrate and respect the relevant choice, subject to specific statutory requirements and limited evidential retention.
- CCPA request records: where the CCPA recordkeeping regulations apply, records of requests and responses are retained for at least twenty-four months, with the required security and use restrictions.
- Automatic-renewal consent records: for the period required by California’s Automatic Renewal Law where applicable, as described in section D.
- Marketing suppression and privacy opt-out records: a minimum record may be retained for as long as necessary to respect the choice and prevent the prohibited activity from resuming.
- Accounting and tax records: for the statutory period applicable to the company, transaction and record concerned.
- Journalistic material and archives: for the period justified by the editorial purpose, public interest, source protection and freedom of expression, with appropriate review and safeguards.
- Information processed independently by external providers: according to their actual service, role and applicable law; our ordinary twelve-month limit does not determine their independent retention or extend a shorter applicable period.
Deletion must also be reflected in backup management. Information temporarily remaining in backups must be protected from ordinary use and removed through the applicable replacement or deletion cycle, subject to any lawful preservation requirement. Restoring a backup must not permanently undo an earlier deletion or privacy choice. Legal holds must be limited to relevant information and reviewed when the reason for preservation ends.
I) Your rights
Where the CCPA applies, California residents have the following rights, subject to the conditions and exceptions governing each right:
- Notice: to receive the required information about collection, purposes, retention, sale or sharing and available choices.
- Knowledge and access: to request the categories and specific pieces of personal information collected, the categories of sources, the relevant purposes and the recipient information required by law.
- Deletion: to request deletion of personal information, subject to exceptions such as applicable legal obligations, security, legal claims and protected expression.
- Correction: to request correction of inaccurate personal information, taking account of its nature and the purposes for which it is processed.
- Portability: to receive information in the accessible and, where applicable, portable and readily usable format required by law.
- Opt-out of sale or sharing: to direct a covered business not to sell or share personal information, including through a qualifying opt-out preference signal.
- Limitation of sensitive-information use and disclosure: to restrict specified uses or disclosures where the statutory right applies.
- Non-discrimination: to exercise applicable rights without unlawful discrimination or retaliation.
Other rights may arise under federal law, another state’s law or an independently applicable legal regime. A right to receive information does not require disclosure of another person’s protected information or credentials whose disclosure is prohibited. Any exception must be applied to the particular request rather than used as a blanket refusal.
Your right to opt out and withdraw authorization
An opt-out of sale or sharing does not require you to explain why you object. An applicable request to limit sensitive-information use is likewise assessed under its specific rules. A business must not require a verified consumer request for an ordinary sale-or-sharing opt-out, although information reasonably necessary to identify the affected records may be needed. Where the CCPA’s restrictions on requesting renewed authorization apply, the business must ordinarily wait at least twelve months before asking an opted-out consumer to authorize sale or sharing again. Passage of twelve months does not itself cancel the opt-out. A request to stop commercial email must also be honored under the applicable requirements. A limited suppression record may remain necessary to ensure that a choice continues to be respected.
Requests concerning journalism and published material
Requests concerning an article, image, recording or editorial record are assessed in their specific context. Please identify the material and explain the correction, deletion or other action sought where this will help us locate and assess it. Confidentiality of sources, the rights of other people, freedom of expression, accuracy, the public interest and relevant legal restrictions must be considered. Information being embarrassing or unfavorable does not automatically require removal, and prior publication does not automatically justify continued publication. Where appropriate, a correction, update, qualification, anonymization or limitation of access may address the concern. Any restriction on an applicable privacy right must have a legal basis rather than rest solely on a general assertion of editorial independence.
How to exercise your rights and response periods
You may send requests to [email protected] or to the publisher’s correspondence address above. A request need not cite legislation. Please identify the right or action sought and provide enough information to locate the relevant records. You are not required to create an account solely to exercise CCPA rights. Where applicable, requests to know, delete or correct are acknowledged within ten business days and answered within forty-five calendar days after receipt. An extension of up to a further forty-five calendar days is permitted only under the applicable conditions, with notice and reasons within the initial period. The response period runs from receipt and is not automatically postponed until identity verification is completed. Sale-or-sharing opt-outs and requests to limit sensitive-information use must be implemented as soon as feasibly possible and no later than fifteen business days where those regulatory limits apply. That maximum is not permission to delay an action that can reasonably be implemented sooner. Requests are normally free; any fee or refusal must satisfy the specific legal requirements.
Identity verification and authorized agents
Verification must be proportionate to the request, the information concerned and the risk of unauthorized disclosure or deletion. We may compare information you provide with information already held and request additional information where reasonably necessary. A complete identity document is not automatically required. Information obtained for verification must not be used for unrelated purposes and must be retained only as justified by that function or a specific legal requirement. An authorized agent may submit a request where permitted by law. We may require evidence of the agent’s authority and, for requests subject to verification, confirmation of identity or authorization consistent with the applicable rules. Different requirements apply where a legally sufficient power of attorney is provided. Verification procedures must not be used to obstruct a valid opt-out.
Access searches, response scope and reasons for decisions
Responses must cover the information required by the applicable right and explain any lawful limitations. Under the CCPA, a request may concern information beyond the preceding twelve months where the statutory conditions are satisfied, including the provisions concerning information collected on or after 1 January 2022. Any reliance on impossibility, disproportionate effort or another exception must satisfy the relevant legal requirements. The existence of many records is not, by itself, a sufficient reason to disregard a request. Information may need to be withheld or redacted to protect another person, security credentials, legal privilege or another legally protected interest. Where a request is denied in whole or in part, the response must explain the basis to the extent required by law. An internal complaint does not automatically extend the original response deadline.
California direct-marketing disclosures
California Civil Code section 1798.83, commonly known as the "Shine the Light" law, provides specified disclosure rights concerning personal information shared with third parties for their own direct-marketing purposes where its conditions are satisfied. An eligible request may be sent to [email protected] with sufficient information to identify the relevant customer relationship. The law generally permits one qualifying request per calendar year and requires a response within thirty days when submitted through the designated channel, subject to its scope and exceptions. This right is distinct from the CCPA’s sale-or-sharing opt-out and does not mean that every disclosure for service delivery is a direct-marketing disclosure.
Privacy complaints and competent authorities
You may complain directly to us using the contact details above. We will assess the complaint according to its substance and urgency, investigate as appropriate and communicate the outcome. An internal complaint does not remove access to a competent authority or an available court remedy. California privacy complaints may be submitted to the California Privacy Protection Agency or the California Attorney General within their respective jurisdictions. The Federal Trade Commission also receives reports concerning matters within its federal consumer-protection and privacy jurisdiction. Regulatory complaint procedures do not necessarily provide individual legal representation or resolve a private compensation claim.
California Privacy Protection Agency
ATTN: Complaints
400 R Street, Suite 350
Sacramento, CA 95811
United States of America
Telephone: +1 916 572 2900.
Privacy contact and responsibility
The publisher’s privacy contact is [email protected]. This contact point receives requests concerning the activities described in this Policy and routes them to the appropriate responsible personnel. A technical provider, commercial partner or overseas company does not become a designated legal representative or data protection officer merely by being named here. Where a particular law independently requires an appointment or additional contact method, that requirement remains applicable. Internal allocation of responsibilities does not remove the publisher’s obligations or prevent you from addressing a request directly to it.
J) Security and personal information breaches
Personal information must be protected by reasonable measures appropriate to its nature and the risks involved. Depending on the activity, these include access restrictions, confidentiality controls, secure authentication, suitable encryption, maintenance, recovery arrangements and supplier oversight. Measures must be reviewed as systems and risks change. California Civil Code section 1798.81.5 applies within its statutory scope, and the CCPA imposes additional security obligations on covered businesses. No system can guarantee that every incident will be prevented. Under California Civil Code section 1798.82, qualifying notifications to affected California residents are generally required within thirty calendar days after discovery or notification of a breach, subject to permitted delays concerning law enforcement, determining the scope of the breach or restoring the reasonable integrity of the system. Where notification is required to more than 500 California residents as a result of a single breach, the required sample notice must be submitted to the California Attorney General within fifteen calendar days after notification to consumers. The definition of a reportable breach, required contents and permitted notification methods must be assessed under the statute. Other applicable laws may impose additional requirements.
Risk assessment and responsible use of technology
Processing presenting significant privacy or security risks requires assessment proportionate to those risks. This may include cross-context behavioral advertising, sensitive-information processing, intrusive monitoring or qualifying automated decisions. The CCPA regulations effective from 1 January 2026 introduce specific risk-assessment, cybersecurity-audit and automated-decisionmaking requirements, with different coverage and transition dates. Risk-assessment obligations must be applied according to the processing activity and the applicable transitional provisions. Cybersecurity-audit certification deadlines are phased, with the first deadlines beginning in 2028 for covered businesses in the relevant revenue category. Those later certification dates do not suspend security duties already in force. A supplier’s description of a product as secure, anonymous or compliant does not replace assessment of its actual use within our services.
K) Disputes, judicial remedies and compensation
This Policy does not restrict the right to complain to a competent authority, seek an available court remedy or claim compensation where the legal requirements are met. California Civil Code section 1798.150 provides a limited private right of action for specified security incidents under its conditions; it does not create a general private damages action for every CCPA violation. Other remedies may arise under applicable privacy, interception, confidentiality, contract or consumer-protection law. Entitlement to damages, injunctive relief, costs or other relief depends on the relevant legal requirements and circumstances. No automatic compensation amount is promised, and no general exclusion of liability is imposed by this Policy. Privacy remedies do not depend on participation in an online dispute-resolution platform. Jurisdiction, procedure and limitation periods are determined by applicable law, and internal correspondence does not automatically suspend those periods.
L) Relevant legislation and case law
The following legislation and decisions inform the processing and protections described in this Policy. Each applies according to its scope, the facts and subsequent legal developments.
- California Consumer Privacy Act of 2018, as amended by the California Privacy Rights Act of 2020 and subsequent legislation, California Civil Code section 1798.100 and following: governs covered businesses’ collection, use, disclosure and retention of personal information, consumer rights, security and enforcement.
- California Code of Regulations, Title 11, Division 6: contains implementing requirements concerning notices, consumer requests, verification, opt-out preference signals, contractual restrictions, recordkeeping, risk assessments, cybersecurity audits and automated decisionmaking, subject to the applicable compliance dates.
- California Online Privacy Protection Act, Business and Professions Code sections 22575–22579: requires qualifying commercial websites and online services to provide a conspicuous privacy policy with prescribed information about their practices.
- California Invasion of Privacy Act, Penal Code section 630 and following: governs specified interception, eavesdropping and recording activities, including the requirements and exceptions relevant to sections 631 and 632.
- California Civil Code sections 1798.81.5 and 1798.82: address reasonable security and notification of qualifying breaches, including the notification requirements applicable from 2026.
- California Civil Code section 1798.83: governs specified disclosures concerning third-party direct marketing.
- California Business and Professions Code section 22581: provides qualifying registered minors with rights concerning removal of information they have posted, subject to statutory conditions and exceptions.
- Article I, sections 1 and 2, of the California Constitution, California Evidence Code section 1070 and California Code of Civil Procedure section 1986.1: address privacy, freedom of expression and specified protections for journalistic sources and material.
- Section 5 of the Federal Trade Commission Act, 15 U.S.C. section 45: prohibits unfair or deceptive acts or practices within its scope, including relevant misrepresentations about privacy and security.
- Children’s Online Privacy Protection Act, 15 U.S.C. sections 6501–6506, and Children’s Online Privacy Protection Rule, 16 C.F.R. Part 312: govern qualifying collection, use and disclosure of information concerning children under thirteen, including the amended Rule’s requirements.
- Electronic Communications Privacy Act, including applicable provisions of 18 U.S.C. sections 2510–2523 and 2701–2713: governs specified interception and access to electronic communications, subject to the relevant definitions and exceptions.
- Video Privacy Protection Act, 18 U.S.C. section 2710: restricts specified disclosures of personally identifiable information concerning consumers of covered video services.
- CAN-SPAM Act of 2003, 15 U.S.C. section 7701 and following: governs qualifying commercial email, including identification and opt-out requirements.
- Department of Justice Data Security Program, 28 C.F.R. Part 202: restricts or prohibits specified transactions involving covered information and parties within its scope.
- Shulman v. Group W Productions, Inc., 18 Cal.4th 200 (1998), decided 1 June 1998: distinguishes protection for newsworthy publication from liability for intrusive methods of obtaining information.
- Kearney v. Salomon Smith Barney, Inc., 39 Cal.4th 95 (2006), decided 13 July 2006: addresses the application of California recording law to calls involving California residents and recording undertaken in another state.
- In re Facebook, Inc. Internet Tracking Litigation, 956 F.3d 589 (9th Cir. 2020), decided 9 April 2020: addresses claims concerning tracking through third-party websites, privacy expectations and the application of interception and related laws; the decision does not establish that every use of an embedded resource is unlawful.
- Calhoun v. Google, LLC, 113 F.4th 1141 (9th Cir. 2024), decided 20 August 2024: emphasizes assessment of what a reasonable user would understand from the relevant disclosures when determining consent to particular information collection. General statements do not automatically resolve the effect of more specific representations.
- Applicable accounting, tax, consumer-protection and recordkeeping legislation: governs retention where the company, transaction and records concerned fall within the relevant requirements.
References to these laws and decisions do not imply approval of the publication by a regulator or establish that every statute applies to every service feature.
M) Additional information about particular services
Newsletters and electronic marketing
Where newsletters or promotional communications are offered, the subscription process must explain their nature and the information used. Commercial email falling within the CAN-SPAM Act must use accurate transmission information and nondeceptive subject lines, include the required identification and valid postal address, and provide a clear means of opting out. A qualifying opt-out must be honored within ten business days, without a fee or unnecessary information requirements. Messages must not be sent through another party to circumvent an opt-out. You may unsubscribe through the mechanism in the message or by contacting [email protected]. Additional consent requirements apply where another relevant law requires them. A request for a newsletter does not authorize unrelated disclosure of an address to third parties for their own marketing.
Newsletter measurement and service messages
Subscribing to a newsletter does not automatically authorize every form of individual tracking of message opening, reading or link use. Tracking pixels and similar techniques require assessment under the laws applicable to the particular collection and disclosure, including the CCPA and relevant communications-privacy requirements. Necessary messages concerning an account, payment, security incident or service request must remain limited to their purpose and must not be used to circumvent an objection to marketing. Combining promotional content with an operational message can affect the legal classification of that message. Subscription information is retained while needed to provide the requested communications, followed by the limited retention and suppression arrangements in section H.
Embedded content, social networks and affiliate links
Embedded video, audio, images, social functions and other external resources may disclose an IP address, device information, the page visited and interaction details to their providers. Disclosure may occur without a platform account, while being signed in can allow the provider to associate activity with that account. Elements requiring consent must not be activated before legally effective consent is obtained. Disclosures constituting sale or sharing must respect applicable opt-outs and qualifying browser signals. A link to a provider’s privacy notice does not replace information or choices for which we are responsible. Receiving a commission from an affiliate link does not itself establish permission to track the user or disclose personal information.
YouTube, external video resources and viewing information
Where YouTube is embedded, both the player and an externally hosted preview image can initiate connections to Google or YouTube servers. A preview image may disclose technical information before playback begins. Activating the player may involve further requests, cookies, local storage or account-related processing, depending on configuration and settings. A privacy-enhanced player does not necessarily eliminate every disclosure. Where the Video Privacy Protection Act applies, disclosure of covered viewing information must satisfy that statute. Consent relied upon under its consent provision must be informed and in writing, including qualifying electronic consent, separate from other legal or financial obligations, and subject to the prescribed withdrawal arrangements. Advance consent under that provision cannot exceed two years or continue after withdrawal. A general cookie choice or acceptance of this Policy does not automatically satisfy those requirements.
Examples of Google cookie durations
Google’s product information describes the following examples. Actual use depends on the service, location, settings and account status; inclusion here does not mean that every cookie is placed through our website.
- "YSC": associated with functions during a browsing session and ordinarily retained for that session.
- "__Secure-YNID": used for YouTube functions and troubleshooting, with a stated duration of six months; Google identifies it as replacing "VISITOR_INFO1_LIVE".
- "PREF": stores playback or display preferences and expires eight months after the user’s last use.
- "SOCS": remembers Google cookie choices, with a stated duration of thirteen months.
A cookie’s expiry period is not the same as the retention period for information already transmitted to a provider. Product descriptions of functionality or security do not determine the legal classification of every disclosure. Information concerning the actual implementation must remain accurate, and applicable choices must be respected.
Profiling and automated decisions
Personalization can involve evaluating identifiers, viewed content and interactions to infer interests or preferences. Such processing may create a profile even where it does not produce a significant decision about the person. Advertising and sensitive-information restrictions depend on the actual information and uses involved. California’s CCPA regulations establish additional requirements for covered uses of automated decisionmaking technology to make significant decisions concerning matters such as financial services, housing, education, employment or healthcare. The relevant automated-decisionmaking requirements have a compliance date of 1 January 2027 for covered uses already in operation before that date. They must not be presented as a universal existing right to human review of every content recommendation. Applicable privacy, discrimination, consumer-protection and risk-assessment requirements must nevertheless be observed according to their own scope and effective dates.
Children and young people
Children’s information requires particular care and explanations appropriate to their age and understanding. The Children’s Online Privacy Protection Act and its Rule apply to covered child-directed services and qualifying operators with actual knowledge that they collect personal information from children under thirteen. Where required, verifiable parental consent must be obtained before collection, use or disclosure, and the applicable parental access, deletion and consent-withdrawal rights must be respected. The amended Rule, with a general compliance date of 22 April 2026, includes separate consent requirements for certain third-party disclosures, including targeted advertising, together with security and retention requirements. Under the CCPA, sale or sharing of information known to concern a child under sixteen requires the prescribed affirmative authorization; for children under thirteen, authorization must come from a parent or guardian. Where California Business and Professions Code section 22581 applies, qualifying registered users under eighteen may request removal of content they posted, subject to the statutory conditions and exceptions. These rules do not establish a general minimum age for reading publicly accessible news. Age verification must not become a reason to collect unnecessary identity documents.
Events, competitions, photographs and access control
Where events, competitions, reservations or controlled access are offered, the relevant collection must be explained at the time, including the required information, purpose, recipients and retention. Participation does not automatically include permission for unrelated marketing. Photography, filming, audio recording or security monitoring requires assessment under the applicable privacy and recording rules. Attendance alone is not blanket consent to every future promotional use of a person’s image or information. Particular care is required with children and sensitive circumstances. Identity checks, dates of birth and copies of documents may be requested only where justified by the actual purpose. Security footage must be retained for a period appropriate to that purpose and deleted earlier than the general maximum in section H where continued retention is unnecessary.
Financial incentives and differences in service
Where a program offers a financial incentive or a difference in price or service connected with the collection, retention, sale or sharing of personal information, the applicable CCPA requirements must be assessed. Any required notice must explain the material terms, the information involved, how to participate or withdraw and the legally required relationship between the incentive and the value of the information. Consent must not be obtained through deceptive design. Exercising a privacy right must not result in unlawful discrimination. The existence of a paid subscription does not, by itself, establish that the subscription is a financial-incentive program or permit unrestricted use of subscriber information.
Changes to this Privacy Policy
This Policy may be updated to reflect changes in services, information practices or applicable law. Where the CCPA requires an annual update, the Policy must be reviewed and updated at least once every twelve months, and material changes must be communicated in a manner appropriate to their significance. Before collecting additional categories of information or using information for an additional purpose, the required notices, compatibility assessment and any necessary consent must be addressed. Publication of a new Policy, silence or continued use does not itself establish consent to new processing. A previously exercised opt-out must not be overridden by a policy revision. Consent may be withdrawn in accordance with the applicable law; there is no general two-week deadline limiting that right. The date below identifies the latest revision of this text.
Contact:
"RCA TELEGRAM NEWS CALIFORNIA"
Email: [email protected]
© 2026 "RCA TELEGRAM NEWS CALIFORNIA" - All rights reserved, subject to statutory exceptions.
Last updated: 1 November 2026.