Privacy Policy

This Policy was last updated on May 21, 2025.

PLEASE READ THIS PRIVACY POLICY CAREFULLY TO UNDERSTAND HOW WE TREAT YOUR PERSONAL INFORMATION AS WELL AS YOUR CHOICES AND RIGHTS. IF YOU DO NOT AGREE WITH THIS POLICY, YOU SHOULD NOT ACCESS OR USE OUR SITE OR APP OR ENGAGE IN COMMUNICATIONS WITH US.

Introduction

Freedom Forum (referred to as “we,” “us,” and “our”) is committed to protecting the privacy and security of your personal information. We also believe in transparency, and this Policy explains how we treat your personal information.

When Does This Policy Apply?This Policy describes our practices for the personal information for which we are a “data controller” under applicable law. By way of example, this includes personal information collected when you:

• Visit our website, www.freedomforum.org (the “Site”), or use the Today’s Front Pages mobile application (the “App”);
• Receive communications from us, including emails, phone calls, faxes, texts, video chats, etc.;
• Complete surveys from us; and
• Request information from us online.

How Do We Process Personal Information?

Who is responsible for your Personal Information?For purposes of applicable law, including the EU General Data Protection Regulation, 2016/679 (the “GDPR”), we act as a data controller with respect to the personal information described below. In this role, we are responsible for implementing the applicable data protection principles and for safeguarding personal information.

What Personal Information Do We Collect?We collect and process the following personal information from you for the purposes set forth below, including in the “Other Processing Activities” section of this policy. You may choose not to provide us with any personal information, but you will not be able to access portions of the Site or App that require personal information.

Category	Description and Purpose
Contact Information	When you visit our Site, use the App, purchase products, request our services, or register for our newsletter or events or programs with us, we may ask you for your name, address, telephone number, email address, or other contact details. We process Contact Information to operate our Site, App, and organization; to provide products and services to you; to provide customer support; to honor our terms of use and contracts; to ensure the privacy and security of our Site, App, and services; to maintain our databases and back-ups; to manage our relationships with you; to administer surveys, promotions, and other engagement features; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; and to keep records of our communications with you. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site, App, and operations; the proper management of our relationships; and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Account Information	When you create an account with us, in addition to your Contact Information, we collect your username or account ID and the password that you choose to create. We don’t require you to register or provide personal information to view our Site or access much of its content. But, you may be required to create an account to use certain features, order products, use our App, or receive certain offers. We use Account Information to operate our Site, App, and organization; to provide products and services to you; to provide customer support; to honor our terms of use and contracts; to ensure the privacy and security of our Site, App, and services; to maintain our databases and back-ups; to manage our relationships with you; to administer surveys, promotions, and other engagement features; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes. The legal basis for this processing is our legitimate interests in the proper administration of our Site, Apps, and operations, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Order and Payment Information	If you purchase products from us, our payment processor will receive your credit/debit card number, security code, and expiration date; other applicable financial information; and your billing information and address. We will also receive your shipping details. We keep records of the products purchased along with your Contact Information. We use Order and Payment Information to operate our Site, App, and organization; to provide our products and services to you; to provide customer support; to ensure the privacy and security of our Site, App, and services; to administer surveys, promotions, and other engagement features; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to keep records of our communications with you; to determine user interests; to develop new products and services; for usage analytics purposes; to process and complete payments and other transactions, including refunds or returns; and to detect fraud and prevent loss. The legal basis for this processing is our legitimate interests in the proper administration of our Site, App, and operations, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Cookies and Similar Technologies Cookie Settings	Our Site and App use cookies and similar technologies. Please see the “Cookies and Similar Technologies” section of this Policy for more information. If you choose to disable cookies and similar technologies, some areas and features of the Site may not work properly. We process Cookies and Similar Technologies to operate our Site, App, and organization; to provide products and services to you; to provide customer support; to ensure the privacy and security of our Site, App, and services; to administer surveys, promotions, and other engagement features; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes. Where required by law, we rely on your express opt-in consent for the use of marketing, performance, and analytic cookies and similar technologies. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our Site, Apps, and operations.
Usage Information	When you visit our Site or use the App, we automatically collect information from your browser and your device, including the date and time of your access, your Internet Protocol (IP) address or unique device identifier, your browser type, and data about which pages you visit and how you navigate the Site or App. We process Usage Information to operate our Site, App, and organization; to provide products and services to you; to provide customer support; to ensure the privacy and security of our Site, App, and services; to administer surveys, promotions, and other engagement features; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes. The legal basis for this processing is our legitimate interests in the proper administration of our Site, Apps, and operations.
Your Communications and Feedback	If you contact us, sign up for one or more of our mailing lists, submit a question or review, send us a message, or otherwise inquire about our products or services, in addition to your Contact Information, we will receive the subject matter of your message and any comments, content, or other information that you choose to provide. You can decide how much information you want to share with us in those communications. If you receive email communications from us, we may use certain tools to capture data related to if/when you open our message and click on any links or banners it contains. If you want to make a comment on a blog post on the Site, we will collect your name, email address, Site, and your comment. We process Your Communications and Feedback to operate our Site, App, and organization; to provide products and services to you; to provide customer support; to ensure the privacy and security of our Site, App, and services; to administer surveys, promotions, and other engagement features; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to keep records of our communications with you; to determine user interests; and to develop new products and services. The legal basis for this processing is consent or, where applicable, our legitimate interests in the proper administration of our Site, App, and operations, the proper management of our relationships, and the performance of a contract between you and us and/or taking steps, at your request, to enter into such a contract.
Sensitive Personal Information	We may collect information regarding your racial or ethnic origin, gender, citizenship status, political opinions, religious or philosophical beliefs, financial information, or data concerning your sexual orientation. We will collect this personal information with your express consent or as otherwise permitted by applicable law. We process Sensitive Personal Information to analyze use of our services, to serve you the content and functionality you request, to ensure the privacy and security of our services, to develop new services, to enhance your experience, and for surveys and applications that are consistent with our organizational mission. The legal basis for this processing is your consent.
Third Party Information	In addition to the information that we collect from you directly, we may also receive information about you from other sources, including third parties, business partners, our affiliates, or publicly available sources. We process Third Party Information to operate our Site, App, and organization; to provide products and services to you; to provide customer support; to ensure the privacy and security of our Site, App, and services; to administer surveys, promotions, and other engagement features; to maintain our databases and back-ups; to manage our relationships with you; to serve you the content and functionality you request; to enhance your experience and provide you with a more personal and interactive experience; to communicate with you; to keep records of our communications with you; to determine user interests; to develop new products and services; and for usage analytics purposes The legal basis for this processing is our legitimate interests in monitoring and improving our Site, App, and operations.

Other Processing Activities. We may also process any of the personal information identified in this Policy when necessary for the following:

• The establishment, exercise, or defense of legal claims, whether in court, administrative, or other proceedings. (The legal basis for such processing is our legitimate interest in the protection and assertion of our legal rights, your legal rights, and the legal rights of others.)
• Obtaining or maintaining insurance coverage, managing risks, or obtaining professional advice (The legal basis for this processing is our legitimate interest in the proper protection of our business.)
• Compliance with federal, state, or local laws (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
• Compliance with a civil, criminal, or regulatory inquiry, investigation, subpoena, or summons by federal, state, or local authorities and cooperation with law enforcement agencies concerning conduct or activity that we, a service provider, or a third party reasonably and in good faith believe may violate applicable law (The legal basis for this processing is compliance with a legal obligation to which we are subject.)
• Collection, use, retention, or disclosure of information that is deidentified or aggregated.
• Purposes that are consistent with, related to and/or ancillary to the purposes and uses described in this Policy for which your personal information was provided to us.

We may process your personal information in connection with any of the purposes and uses described in this Policy on one or more of the following legal grounds:

• Because it is necessary to perform the services you have requested or to comply with your instructions or other contractual obligations between you and us;
• To comply with our legal obligations as well as to keep records of our compliance processes;
• Because our legitimate interests, or those of a third-party recipient of your personal information, make the processing necessary, provided those interests are not overridden by your interests or fundamental rights and freedoms;
• Because you have chosen to publish or display your personal information on a public area of the Site, such as a comment area;
• Because it is necessary to protect your vital interests;
• Because it is necessary in the public interest; or
• Because you have expressly given us your consent to process your personal information in a particular manner.

We do not use personal information for making any automated decisions affecting or creating profiles other than as described herein.

Location of Processing. We are located and established in the United States, and your personal information will be transferred to, stored, and processed in the United States and other countries in which we or our partners, service providers, or agents maintain operations. By sending us personal information or using the Site or the App, you agree and consent to the processing of your personal information in locations such as the United States, which may not offer the levels of protection required in other countries. We rely on recognized legal bases to lawfully conduct cross-border/international transfers of personal information, such as express consent, when transfer is necessary for us to deliver services pursuant to an agreement, or when the transfer is subject to safeguards that assure the protection of the personal information.

Cookies and Similar Technologies

What are First-Party and Third-Party Cookies? A “cookie” is a small file created by a web server that can be stored on your device (if you allow) for use either during a particular browsing session (a “session” cookie) or a future browsing session (a “persistent” cookie). “Session” cookies are temporarily stored on your device and remain there until they expire at the end of your browsing session. “Persistent” cookies remain stored on your device until they expire or are deleted by you. Local shared objects (or “flash” cookies) are used to collect and store information about your preferences and navigation to, from, and on a website. First-party cookies are set by the website you are visiting, and they can only be read by that site. Third-party cookies are set by a party other than the website you are visiting.

What are “Similar Technologies”? In addition to cookies, there are other data collection technologies, such as Internet tags, web beacons, pixels (clear gifs, pixel tags, and single-pixel gifs), and navigational data collection (log files, server logs, etc.) that can be used to collect data as you navigate through and interact with a website. For example, web beacons are tiny graphics with unique identifiers that are used to understand browsing activity. UTM codes are strings that can appear in a URL when you move from one web page or website to another. The string can represent information about your browsing, such as which advertisement, page, or publisher sent you to the receiving website.

What Cookies and Similar Technologies Are in Use and Why Do We Use Them?

If you use the Today’s Front Pages Mobile Application, we collect the following information via Google Analytics: age; the store from which the app was downloaded and installed; app version; country; device brand; device category; device model; the time at which the user first opened the app, rounded up to the next hour; gender; the interests of the user (e.g., “Arts & Entertainment, Games, Sports”); the language setting of the device OS (e.g., en-us or pt-br); OS version; and whether the user is “New” (First opened the app within the last 7 days) or “established” (First opened the app more than 7 days ago). We process this information to analyze use of the mobile application and our services, to operate the mobile application, to serve you the content and functionality you request, to ensure the privacy and security of our mobile application and services, to develop new services, to enhance your experience, to track visits to the mobile application, to provide you with a more personal and interactive experience on the mobile application, and to improve our marketing efforts. The legal basis for processing of strictly necessary cookies is our legitimate interests in the proper administration of our App and operations.

Other Third-Party Technologies. Some third parties may use data collection technologies to collect information about you when you browse the Internet. We do not control these third parties’ technologies or how they may be used. If you have questions about targeted content, you should contact the responsible party directly or consult their privacy policies.

Choices About Cookies. Most web browsers are set by default to accept cookies. If you do not wish to receive cookies, you may (a) choose to not allow certain cookies and technologies by adjusting your preferences via the cookies consent banner, or (b) set your browser to refuse all or some types of cookies or to alert you when cookies are being stored. These settings may affect your enjoyment of the Site’s functionality. In addition, adjusting the cookie settings may not fully delete all of the cookies that have already been created. To delete them, you should review your web browser settings after you have changed your cookie settings. The links below provide additional information about how to disable cookies or manage the cookie settings:

• Google Chrome
• Firefox
• Microsoft Edge
• Safari for Mac and iPhone

You may learn more about internet advertising practices and related consumer resources at https://youradchoices.com/control, https://thenai.org/about-online-advertising/faq, and http://www.networkadvertising.org/choices.

How Do We Share or Disclose Your Personal Information? When we are acting as a data controller and where permitted by applicable law, we may share your information for the purposes described below.

Category	Disclosure Contexts
Affiliates	We may share your personal information with our subsidiaries and affiliates and with their respective officers, directors, employees, and agents.
Transactions	We may disclose your personal information in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets.
Disclosures with Your Consent	We may ask if you would like us to share your personal information with other unaffiliated third parties who are not described elsewhere in this Policy. We will only disclose your personal information in this context with your consent.
Legal Obligations and Rights	We will disclose your personal information in response to subpoenas, warrants, court orders or other legal process, and when required to comply with relevant laws. We may also share your personal information in order to establish or exercise our legal rights, to pursue and defend against legal claims, and to investigate, prevent, or take action regarding possible illegal activities, suspected fraud, safety of person or property, or a violation of contract. We may also disclose personal information as needed to protect vital interests.
Public	Some areas of our Site, including our blog, may offer forums or provide the opportunity for users to post comments or reviews in a public forum. Please remember that any information that is disclosed in these areas becomes public information, and you should exercise caution when deciding to disclose your personal information. If you decide to submit your personal information in these areas, you do so at your own risk and acknowledge that the information will be publicly available.
Service Providers	We may share your personal information with our agents, contractors, service providers, insurers, and professional advisors (including attorneys, accountants, consultants, and auditors) that need access to the information to provide services on our behalf or perform functions for us. Among other things, the recipients help us to administer the Site and App; support our provision of products or services requested by you; provide technical support; send marketing, promotions and communications to you; provide payment processing; and assist with other legitimate purposes permitted by law.
Deidentified or Aggregated Data	We may disclose aggregated information and information that does not identify any specific individual, such as groupings of demographic data and customer preferences.

How Long Do We Store and Use Your Personal Information?

We will retain and use your personal information for as long as is necessary to fulfill the purposes for which it was collected, to comply with our business requirements and legal obligations, to resolve disputes, to protect our assets, to provide our services and fulfill our organizational mission, and to enforce our agreements.

We take reasonable steps to delete the personal information we collect when (1) we have a legal obligation to do so, (2) we no longer have a purpose for retaining the information, and (3) if you ask us to delete your information, unless we determine that doing so would violate our existing, legitimate legal, regulatory, dispute resolution, contractual, or similar obligations. We may delete your personal information if we believe it is incomplete, inaccurate, or that our continued storage of your personal information is contrary to our objectives or legal obligations. When we delete data, it will be removed from our active servers and databases, but it may remain in our archives when it is not practical or possible to delete it.

We may retain and use anonymous, de-identified, and/or aggregated information for as long as is permitted under applicable law.

How Do We Protect Your Personal Information?

We have adopted security measures that are designed to protect the personal information under our control. From time to time, we review our security procedures and consider new technologies and methods.

However, no security system is perfect, and no data transmission is 100% secure. Although we strive to protect personal information, we cannot guarantee or warrant the security of any information transmitted to or from our Site or App. Your use of the Site and App are at your own risk. We cannot guarantee that your personal information will remain secure in all circumstances.

The safety and security of your personal information also depends on you. Where you use a password for access to restricted parts of the Site, you are responsible for keeping the password confidential. Do not share your password with anyone.

If a data breach compromises your personal information, we will notify you and any applicable regulator when we are required to do so by applicable law.

Your Rights and Choices

Please use the “Contact Us” details provided at the end of this Policy to exercise your rights and choices under this Policy. We honor requests when we are required to do so under applicable law.

Email Opt-Out and Communication Preferences. If you no longer wish to receive communications from us, you may opt-out of receiving emails by clicking the unsubscribe link available at the bottom of our emails, and you may opt-out of other communications by contacting us at [email protected]. Please provide your name and contact information in your request, and we will respond to your request in accordance with applicable law.

Cookies. You may opt-out of optional cookies via the cookies consent banner, and you can adjust your cookies preferences for the Site at any time by clicking here:

Cookie Settings

Updating Your Personal Information. Our goal is to keep your information accurate, current, and complete. If any of your information changes, please let us know via the “Contact Us” details at the end of this Policy.

Complaints. If you believe that your rights relating to your personal information have been violated, please contact us via the “Contact Us” details provided at the end of this Policy.

California Residents. Under California Civil Code Section 1798.83, California residents who provide personal information in obtaining products or services for personal, family, or household use may be entitled to request and obtain from us once each calendar year information about the information we shared, if any, with other businesses for direct marketing uses. We do not currently share your personal information with third parties for those third parties’ direct marketing purposes. Please be aware that not all information sharing is covered by California’s “Shine the Light” requirements, and only information regarding covered sharing (if any) will be included in our response. As a part of the California Online Privacy Protection Act, all users of our Site may make any changes to their information at any time by contacting us at [email protected].

Nevada Residents. Nevada residents may submit a verified request to us at [email protected] to request that we not make any sale (as defined under Nevada law) of any covered information (as defined under Nevada law) that we have collected or will collect about you. Please provide your name and contact information in your request, and we will respond to your request in accordance with Nevada law.

EU/EEA and UK Residents. If you are located in the EU, EEA or UK, you have the following rights. All requests should be sent to the address noted in the “Contact Us” section of this Policy, and we will fulfill requests to the extent required by applicable law.

• Right of Access. To the extent required by law, you have the right to receive confirmation as to whether or not personal data concerning you are being processed, and, where that is the case, access to the personal data and the following information: the purposes of the processing; the categories of personal data concerned; and the recipients or categories of recipient to whom the personal data have been or will be disclosed. We will provide a copy of your personal information in compliance with applicable law.
• Right of Rectification. Our goal is to keep your personal information accurate, current, and complete. Please contact us if you believe your information is not accurate or if it changes.
• Right to Erasure. In some cases, you have a legal right to request that we delete your personal information when (1) it is no longer necessary for the purposes for which it was collected, (2) consent has been withdrawn in certain instances, (3) you have objected to the processing in certain instances, (4) the personal information has been unlawfully processed, (5) the personal data have to be erased for compliance with a legal obligation; and (6) the personal data were collected in relation to the offer of information society services. However, the right is not absolute. When we delete personal information, it will be removed from our active servers and databases; but, it may remain in our archives when it is not practical or possible to delete it. We may also retain your personal information as needed to comply with our legal obligations, resolve disputes, or enforce any agreements.
• Right to Restrict Processing. You have the right to restrict the processing of your data when (1) the accuracy of the personal data is contested, for a period enabling us to verify the accuracy of the personal data; (2) the processing is unlawful and you oppose erasure and request a restriction instead; (3) we no longer need the personal data, but you need us to keep it for the establishment, exercise, or defense of legal claims; or (4) you have objected to us processing the personal information, pending resolution of the objection.
• Right to Object. In certain circumstances, you have the right to object to the processing of your personal information where the processing is necessary for performance of a task carried out in the public interest, for our legitimate interests, or for the legitimate interests of others. You also have the right to object where personal data are processed for direct marketing purposes or for scientific or historical research purposes or statistical purposes.
• Right to Withdraw Consent. If you have provided your consent to the collection, processing, and transfer of your personal information, you may have the right to fully or partially withdraw your consent. Once we have received notice that you have withdrawn your consent, in whole or in part, we will no longer process your information for the purpose(s) to which you originally consented and have since withdrawn unless there are compelling legitimate grounds for further processing that override your interests, rights and freedoms or for the establishment, exercise, or defense of legal claims. Withdrawal of consent to receive marketing communications will not affect the processing of personal information for the provision of our services.
• Right to Complain. If you believe we have not processed your personal information in accordance with applicable law, we encourage you to contact us at [email protected]. You may also have the right to make a complaint to the relevant Supervisory Authority or seek a remedy through the courts. A list of Supervisory Authorities for residents of the EU or EEA is available at: https://edpb.europa.eu/about-edpb/board/members_en. UK residents may contact the UK Supervisory Authority here: https://ico.org.uk/make-a-complaint/data-protection-complaints/. If you need further assistance regarding your rights, please contact us using the contact information provided below and we will consider your request in accordance with applicable law.

Third-party Sites and Services

This Policy does not apply to any third-party websites or applications or services provided by third parties.

The Site and App may include links to and content from third parties. These links are to external resources and third parties that have their own privacy policies. It may not always be clear to you which links are to external, third-party resources. If you click on a third-party link, you will be redirected away from the Site or App. You can check the URL to confirm whether you have left this Site or App.

We cannot and do not (1) guarantee the privacy or security practices of third parties or any content provided by third parties, (2) control third parties’ independent collection or use or your information, or (3) endorse any third-party information, products, services, applications, or websites.

Any information provided by you or collected from you by a third party will be governed by that party’s privacy policy and terms of use. You should review their privacy policy and terms of use carefully.

Children

We are a non-profit organization, and our Site, App, activities, and services are not directed to children under the age of 13, and we do not knowingly collect information online from children under the age of 13. No one under the age of 13 may access, browse, or use the Site or App or provide any information to us online. If we learn that we have collected or received personal information from a child under the age of 13 online without a parent’s or legal guardian’s consent, we will take steps to stop collecting that information and to delete it. If you believe we have received any information from a child under the age of 13 online, please contact us using the “Contact Us” details provided at the end of this Policy.

For more information about the Children’s Online Privacy Protection Act, please visit the Federal Trade Commission’s website.

Updates and Changes to This Policy

We may update this Policy from time to time. If we change this Policy, we will post to the revised version of this Policy on our Site. The updated policy will be effective immediately upon posting. If we make material changes, we will also notify you through a notice on the homepage of the Site for a reasonable period of time. We may also notify you about changes to this Policy by email.

You should carefully review this Policy before using the Site or App, and you should review it from time to time so that you are aware of its current terms. Your continued use of the Site or App after the “Last Updated” date will constitute your acceptance of and agreement to any changes and to our collection, use, and sharing of your information according to the then-current Policy. If you do not agree with this Policy, you should not use the Site or the App.

Contact Us

For more information, or if you have any questions or concerns regarding this Policy, wish to exercise your rights, or wish to lodge a complaint with us, you may contact us using the information below, and we will do our best to assist you. Please note, if your communication is sensitive, you may wish to contact us by postal mail or telephone.

In writing: 610 Water St SW, Ste 300, Washington, DC 20024
By phone: (202) 292-6100
By email: [email protected]