Privacy Notice
Last Updated: December 27, 2024
This notice describes how Sherwood Media (“we,” “our,” or “us”) handles your personal information when you use the following “Sherwood Services”:
Our email newsletters, Snacks, Snacks UK, Chartr, and The Wrap
Our website, sherwood.news
Our pages or ads on social media networks, like our Facebook and Instagram pages
Anywhere we gather information from or about you and refer you to this Privacy Notice, such as where you participate in a contest or promotion that includes an authorized reference to this Privacy Notice
How we handle information about you depends on which Sherwood Services you use and how you use them.
If you have questions, please don’t hesitate to contact us at privacy@sherwoodmedia.com.
Table of Contents
What Information Do We Gather About You?
The following describes the information we collect and how we obtain it.
Information You Voluntarily Give Us
For Registration and Participation:
When you sign up for or participate in a Sherwood Service, we collect your contact information, including your name and email address. We may also collect other identifiers, such as an account name and a unique ID number that we assign you.
For Reader Surveys, Research, Panels and Experience Programs:
We gather personal information through questionnaires, surveys and other similar feedback programs. These programs may seek information regarding your interests in various topics.These programs may seek information that is considered sensitive under applicable laws such as your age, ethnicity, race, gender, family characteristics and income. Participation is typically voluntary. We use service provider platforms to support these programs and personal information is disclosed to them as described below with respect to service providers in general.
Information Collected Automatically
When you use Sherwood Services, we collect some information automatically. The technologies we use to assist with this data collection include cookies, web beacons, pixels, tags, scripts, and software development kits (or SDKs). For more information about how to manage tracking methods on Sherwood Services, read the “What Are Your Rights and Choices?” section below.
The categories of personal information we collect automatically include:
Identifiers and Device Information:
Our services use a variety of technologies in order to automatically receive, record and/or log information about the device you are using, including unique identifiers. The items we collect include:
Your IP address and inferred location
Cookie identifiers
Your operating system and browser (e.g., type, version, and configuration)
Your browser language
Device identifiers (such as MAC address)
Advertising identifiers
We combine this data with other information we collect about you.
Other Usage Data:
We collect information about certain internet and network activity on Sherwood Services, including your interactions with our website, such as the URLs of any pages you visit on our sites and apps, the URL of the website from which you came to our sites, how long you spent on a page, access times, search queries, and other details about your use of and actions on our Services. This also includes your interactions with marketing and advertisements on Sherwood Services.
Inferences; Information We Create or Generate
We infer new information from other data we collect, including using automated means such as machine learning. These inferences include information about your likely preferences or other characteristics (e.g., article topics, writers, teams or markets of interest to you).
Information Collected from Other Sources
Affiliates
We may receive information about you from our affiliates, including our parent company, Robinhood Markets, as well as other Robinhood entities. This information may include email addresses, other contact information, and data about the way you interact with other Robinhood products and services.
Social Media Platforms and Other Third-Party Services:
(Social media platforms include services like Instagram, Facebook, X, TikTok, Snap and other platforms. Third-party services include services like Google.)
We may receive information from you when you interact with our pages, groups, accounts or posts on social media platforms, such as identifiers (including IP addresses or device-specific IDs that platforms might share), impressions (e.g., click-through data), and interactions (e.g., likes). We collect information in connection with our ad campaigns that surface on other platforms, such as the ads you click on and other interactions with our ads.
What Do We Do with the Information We Collect about You?
We use each of the categories of personal information described above to operate, improve, understand and personalize our Services, and for the following business and commercial purposes.
We Provide the Sherwood Services
We use your information to help you use and navigate Sherwood Services, such as:
Making a Sherwood Service available to you or otherwise meeting or fulfilling the purposes for which you provided the information to us
Providing customer service
Responding to your inquiries, requests, suggestions or complaints
Sending service-related transactional messages (e.g., a change in our Terms of Service, Terms of Sale, or other terms and conditions) and otherwise communicating with you about Sherwood Services
Letting you take part in paid services, polls, promotions, surveys, panels, research and comments
We Develop Products and Services and Analyze Data.
We may analyze data on our users’ subscriptions and other usage behaviors. This helps us make business and marketing decisions. This allows us to understand how users interact with Sherwood Services and to improve and develop Sherwood Services, including testing new features, research, surveys, analysis, and product development.
We use third party analytics providers. Google Analytics is one of the analytics providers we use on certain Sherwood Services. You can find out how Google Analytics uses data and how to opt out of Google Analytics.
We Carry Out Administrative or Legal Tasks
For auditing, legal or regulatory purposes: We verify that our internal processes work as intended and comply with legal, regulatory and contractual requirements. More broadly, we process information to comply with legal, regulatory and contractual obligations and to respond to law enforcement requests (our sharing for these purposes is described below).
For fraud and security monitoring: We detect and prevent cyberattacks or unauthorized robot activities, protect against or deter fraudulent, illegal, or harmful actions, and maintain the safety, security, and integrity of Sherwood Services.
For customer satisfaction: We assess users’ satisfaction with Sherwood Services and our customer care team.
We Advertise and Market to You, Including Personalized Advertising
We and third parties (DataWrapper, Document Cloud, Flourish, Google, Heap, Infogram, Kalshi, LinkedIn, Megaphone, Meta, Permutive, Parse.ly, Reddit, SailThru, Spotify, TikTok, Truth Social, Twitch, Usercentrics, and X (formerly Twitter) may use cookies, pixels, device identifiers and similar technologies to collect information from and about your use of our websites, including when we use third-party advertising and analytics services to better understand your online activity and serve you targeted advertisements, both on and off the Sherwood Services. Information collected and processed by these partners is subject to those partners’ own policies. For example, we use Google to serve ads on Sherwood Services. Google may use cookies or unique device identifiers, in combination with their own data, to show you ads based on your visit to sherwoodmedia.com and other sites. You can opt out of the use of certain Google cookies by visiting the related Google privacy policy.
The information that is collected may be collected over time and combined with information collected on different websites and online services and across your devices, including to deliver targeted advertising to you, both on and off the Sherwood Services. You may be able to control collection of your personal information as described in this section using industry self-regulatory tools. For example, DAA Webchoices Browser Check, NAI Opt Out of Interest-Based Advertising, and the AppChoices app offer tools for this purpose. For more information about your rights and choices with respect to marketing and advertising, please see the “What Are Your Rights and Choices?” section below.
We and our partners may also collect your information (including name, email, IP address, phone number and/or information about your browser, operating system, and preferences) from third parties for the purposes of personalized marketing to you. We may also send you targeted email newsletters or promotional emails.
We Aggregate (or De-identify) Personal Information into Larger Findings
Sometimes we aggregate or de-identify information so that it can no longer identify you, as defined under applicable laws. This helps us better understand and represent our users, such as when we measure ad performance, create audiences for advertising or marketing interest-based segments or compile survey results. We can use and disclose this aggregated or de-identified information for any purpose, unless an applicable law says otherwise.
To Whom Do We Disclose or Share the Information We Gather for Business and Commercial Purposes?
Within the Robinhood Set of Companies
Our affiliates may access your information for the purposes listed here. Our affiliates include our parent company, Robinhood Markets, as well as other Robinhood entities.
With Service Providers:
We work with service providers, as defined above, to carry out certain tasks, including the following business purposes:
Maintaining technology and related infrastructure
Offering you customer service
Serving and targeting ads and measuring ad performance (including counting ad impressions of unique visitors, verifying positioning and quality of ad impressions and auditing compliance with these specifications and other standards)
Presenting surveys
Distributing emails
List processing and analytics
Managing and analyzing research
Managing promotions
Detecting security incidents, protecting against malicious, deceptive, fraudulent, or illegal activity, and debugging to identify and repair errors that impair existing intended functionality.
When performing these tasks, service providers often have access to your personal information.
We sometimes allow them to use aggregated or de-identified information for other purposes, in accordance with applicable laws.
With Other Third Parties:
There are situations when we disclose your personal information to third parties beyond our service providers, including:
i. We may provide information to third parties for advertising and marketing purposes as described above.
ii. We may provide information about participants in our sweepstakes, contests and similar promotions to the promotions’ sponsors.
iii. In the event of a reorganization, merger, sale, joint venture, assignment, transfer or other disposition of all or any portion of our business, assets or stock (including in connection with any bankruptcy or similar proceedings), we would have a legitimate interest in disclosing or transferring your information to a third party — such as an acquiring entity and its advisers.
iv. We preserve or disclose personal information if the law requires us to do so. We can also preserve or disclose personal information if we believe it would be necessary to:
Comply with the law or with legal process
Protect and defend our rights and property
Protect against misuse or unauthorized use of the Sherwood Services
Protect the safety or property of our personnel, users or the general public (e.g., if you provide false information or attempt to pose as someone else, we could share your information to help investigations into your actions)
Cooperate with government authorities, which could be outside your country of residence.
v. Any purpose for which we obtain your consent in accordance with applicable laws.
Your public activities also may be disseminated to third parties, such as via APIs.
As described above, we may disclose aggregated or de-identified information for any purpose, unless an applicable law says otherwise.
What Are Your Rights and Choices?
We provide a variety of ways for you to control the personal information we hold about you, including choices about how we use that information. In some jurisdictions, these controls and choices are enforceable as rights under applicable law. The choices described below are limited to the specific email address, phone or device used. They won’t affect different email addresses, phones or devices used, or subsequent subscriptions.
In General
i. Communications Preferences
Email:
We offer a variety of commercial emails and email newsletters. You can unsubscribe from commercial emails and email newsletters from Sherwood Media by following the instructions near the bottom of relevant emails. You can also email us at privacy@sherwoodmedia.com.
ii. Access, Correct, Change/Update, Delete or Restrict Processing of Your Personal Information
In some jurisdictions, you may exercise the following choices in accordance with local laws:
Access, modify or delete the personal information we have about you
Be informed of or receive an electronic copy of the personal information we have about you, for data portability.
Restrict, or object to, how we process personal information about you
For example, in the European Union and the United Kingdom, you have the right to object to, or obtain a restriction of, the processing of your personal information under certain circumstances; and where the processing is based on your consent, you have a right to withdraw that consent at any time for future processing.
If you’d like to exercise any of the above choices, please contact privacy@sherwoodmedia.com or you can contact us at the address below.
In some jurisdictions, you can designate an authorized agent to make a request on your behalf. In order to do that, please provide the agent with written permission, signed by you, authorizing the agent to submit the request on your behalf. The agent must submit that written permission along with the request. We may contact you to verify your identity — and the authorized agent’s permission — before a response to the request is sent.
We’ll respond to your request in a manner consistent with applicable law, including any exceptions that may result in a request being denied in whole or in part.
In some cases, your request doesn’t ensure complete removal of the content or information. For example, we might need to keep certain information for recordkeeping purposes, or to complete a transaction you began prior to requesting a change or deletion (e.g., if you make a purchase or enter a promotion, you might not be able to change or delete the personal information provided until after the completion of the purchase or promotion).
iii. Opt Out of Targeted Advertising and “Sales or Sharing” of Personal Information
Residents of certain jurisdictions, including California, may have rights to opt out of “processing for targeted advertising,” "sale” and “sharing" (as defined under applicable law) with respect to their personal information. If you reside in one of those jurisdictions, in order to exercise your right to opt out of targeted advertising or "sales" of your personal information, please click on the “Your Privacy Choices” link at the bottom of the webpage where your information is being collected or email us at privacy@sherwoodmedia.com. We also honor legally recognized browser-based opt-out preference signals within the United States, such as the Global Privacy Control (“GPC”) signal. If you choose to opt-out using a browser-based signal, you will need to renew your opt-out choice if you visit our website from a new device or browser or if you clear your cookies because your opt-out choice will be linked to your browser only. We do not knowingly “sell” or “share” the personal information of individuals under 16 years old.
iv. Browser and Platform Controls
Cookie Controls:
Most web browsers are set to accept cookies by default. If you prefer, you can go to your browser settings to learn how to delete or reject cookies. If you choose to delete or reject cookies, this could affect certain features or services of our websites. If you choose to delete cookies, settings and preferences controlled by those cookies, including advertising preferences, may be deleted and may need to be recreated. For more information about how we use cookies, please refer to our Cookie Policy.
Do Not Track:
Some browsers include a "Do Not Track" (DNT) setting that can send a signal to the websites you visit indicating you do not wish to be tracked. Unlike the GPC described above, there is not a common understanding of how to interpret the DNT signal; therefore, our websites do not respond to browser DNT signals. Instead, you can use the range of other tools to control data collection and use, including the cookie controls and advertising controls described above.
Mobile Advertising ID Controls:
iOS and Android operating systems provide options to limit tracking and/or reset the advertising IDs.
Email Web Beacons:
Most email clients have settings which allow you to prevent the automatic downloading of images, including web beacons, which prevents the automatic connection to the web servers that host those images.
vi. California “Shine the Light” Privacy Rights
Under the California “Shine the Light” law, California residents can opt out of certain sharing of personal information to third parties (and sometimes affiliates) for their direct marketing purposes. We do not disclose your personal information as defined in the Shine the Light law.
vii. Other Rights and Choices
You will not receive discriminatory treatment by us for the exercise of your privacy rights.
How Long Do You Retain Data?
We store your personal information for as long as needed (including to comply with our legal obligations, resolve disputes, or enforce our agreements), or permitted, based on the reason why we obtained it (consistent with the reasons set out in this Privacy Notice and applicable law).
How Do You Protect My Information?
We protect your personal information with appropriate organizational, technological and physical safeguards — but we cannot guarantee its absolute security. If you have reason to believe your interaction with us is no longer secure, notify us immediately.
Are There Guidelines for Children?
Sherwood Services are intended for a general audience and are not directed at children under (13) years of age.
We do not knowingly gather personal information (as defined by the U.S. Children’s Privacy Protection Act, or COPPA) in a manner not permitted by COPPA. If you are a parent or guardian and you believe we have collected information from your child in a manner not permitted by law, contact us at privacy@sherwoodmedia.com. We will remove the data to the extent required by applicable laws.
How Is Information Transferred Internationally?
Sherwood Media is headquartered in the United States. If you are located outside the United States, your information is collected in your country and then transferred to the United States — or to another country in which we (or our affiliates or service providers) operate.
If we transfer your data out of the European Economic Area (E.E.A.), the United Kingdom and/or Switzerland, we implement at least one of the three following safeguards:
We transfer your information to countries that have been recognized by the European Commission as providing an adequate level of data protection according to E.E.A. standards (see the full list of these countries).
We take steps to ensure that the recipient is bound by contractual obligations, including E.U. Standard Contractual Clauses together with addenda or language to cover the UK and/or Switzerland, as applicable, and additional safeguards to protect your personal data. You can see a copy of these clauses.
We confirm that the service provider to which we are transferring data has an active self-certification under the EU-U.S. Data Privacy Framework (DPF), the UK Extension to the EU-U.S. DPF, and/or the Swiss-U.S. DPF, as applicable.
You can find out more about the rules on data transfers here: https://commission.europa.eu/law/law-topic/data-protection_en.
In certain situations, the courts, law enforcement agencies, regulatory agencies or security authorities in those countries might be entitled to access your personal information.
What Is Our Legal Basis?
In some jurisdictions, like the European Union and the European Economic Area, we only collect, use or share information about you when we have a valid reason. This is called a “lawful basis.” Specifically, this is one of the following:
The consent you provide to us at the point of collection of your information
The performance of the contract we have with you
The compliance of a legal obligation to which we are subject, or
The legitimate interests of Sherwood or a third party. “Legitimate interest” is a technical term under international laws, including the European Union General Data Protection Regulation. It means that there are good reasons for the processing of your personal information, and that we take measures to minimize the impact on your privacy rights and interests. “Legitimate interest” also refers to our use of your data in ways you would reasonably expect and that have a minimal privacy impact.
We have a legitimate interest in gathering and processing personal information: (1) to ensure that our networks and information are secure; (2) to deliver our services and to administer and conduct business within Sherwood; (3) to prevent fraud; (4) to conduct our marketing activities; (5) to address your requests, complaints, or inquiries; and (6) to improve our products and services.
What about Third-Party Services?
Some Sherwood Services contain links to third-party websites, resources, vendors and advertisers. These third parties are not Sherwood Services. We do not control (and are not responsible for) third party content or privacy practices. These third parties may independently collect and solicit information about you and affect your data preferences when you access the Sherwood Services on third-party digital properties. Any personal information you provide to them is not covered by this Privacy Notice. These third parties have their own policies and practices about data, which may include what information they share with us, your rights and choices on their services and devices, and whether they store information in the U.S. or elsewhere. We encourage you to familiarize yourself with their privacy policies and terms of use.
How Are Changes to this Privacy Notice Communicated?
We periodically update this Privacy Notice and will post any changes on this page by updating this Policy. If we make a significant or material change in the way we collect, use or share your personal information, we will notify you in advance of the changes taking effect. We will do this via email or prominent notice within Sherwood Services. If you object to any change, you can stop using the Sherwood Services.
After we post any changes on this page, your continued use of Sherwood Services is subject to the updated Privacy Notice.
How Can You Contact Us?
If you have any questions, please email us at privacy@sherwoodmedia.com.