Genius Eye News — Privacy Policy

Draft for attorney review. This document has not been approved by a licensed attorney and is not yet in force. Bracketed items marked [CONFIRM] describe intended product behavior that engineering must verify before launch.

Effective date: [DATE OF LAUNCH] Last updated: [DATE OF LAUNCH]

This Privacy Policy explains how [LEGAL ENTITY NAME], doing business as TRG Tech Link and Genius Eye News ("we," "us," "our"), collects, uses, discloses, and protects personal information when you use geniuseyenews.com, its city editions, newsletters, live pages, World Watch alerts, classifieds marketplace, and self-serve advertising tools (the "Service").

The short version

You can read Genius Eye News without an account.
We use first-party cookies to run the site and measure readership. Advertising cookies load only if you say yes.
We do not sell your personal information for money. If you allow advertising cookies, our ad partners may receive device identifiers, which some state laws treat as a "sale" or "sharing" — you can turn that off at any time, and we automatically honor Global Privacy Control (GPC).
We do not use your personal information to train generative AI models. [CONFIRM]
Our affiliated companies (for example Flip Master Lending) do not receive your newsletter or account information unless you ask to be contacted by them.
You have privacy rights, described in Section 10, and you can use them by emailing news@geniuseyenews.com or through our Privacy Request form at [URL].

1. Information we collect

a. Information you give us

When	What we collect
Newsletter or alert signup	Email address, the editions and topics you choose, confirmation (double opt-in) record with date, time and IP address
Creating an account	Name or display name, email, password (stored only as a salted hash), city edition preference
Posting a classified listing	Listing text, photos, category, price, location you enter for the listing (for example a neighborhood or ZIP code), contact method you choose, and for job or housing listings the details required by our Classifieds Rules (for example a pay range where state law requires it)
Buying advertising or a promoted listing	Business name, contact name, email, phone, billing address, ad creative and landing-page URLs, targeting choices (for example city edition and section), order history. Card and bank details are entered into TRGPay and its processors; we keep only a token, card brand, last four digits, and expiration date [CONFIRM]
Political advertising	Everything above, plus the identity of the sponsor, its treasurer or responsible officer, committee ID numbers, the "paid for by" disclaimer, candidate or ballot measure referenced, flight dates, amount paid, and other records that election laws require us or the advertiser to keep (see our Political Advertising Policy)
Contacting us, sending a news tip, or requesting a correction	Your name, email, message, and any files you attach
Privacy requests	Information needed to verify your identity and respond

b. Information collected automatically

Device and log data: IP address, browser type, operating system, referring page, pages viewed, time on page, and date/time of visit.
Approximate location: We infer your approximate city or region from your IP address so we can suggest the right city edition and local weather. If you choose to share your device's precise location (for example, to show local radar), we use it only to deliver that feature in that session and do not store it or share it with advertisers. [CONFIRM]
First-party cookies and similar technologies: to keep you signed in, remember your edition and consent choices, protect against fraud and abuse, and measure readership in aggregate. Details are in our Cookie Policy.
Newsletter engagement: whether a newsletter was delivered, opened, or a link was clicked, so we can keep lists healthy and improve content. [CONFIRM whether open-tracking pixels are used; if so, disclose here; consider disabling for users who opted out of analytics.]
Advertising data (only with consent): If you accept advertising cookies, third-party advertising partners may set cookies or collect device identifiers and browsing activity on the Service to show and measure ads.

c. Information from others

Payment processors used by TRGPay (card, ACH, Zelle) tell us whether a payment succeeded, was refunded, or was disputed.
Fraud and safety signals from our own screening systems and, where used, third-party fraud-prevention tools.
Public sources, such as the FEC's public database, to verify political advertisers.
Advertising partners (only if you consent to advertising cookies) may provide aggregated campaign reporting.

d. People who appear in the news

Our journalism is built from public government data and other publicly available reporting. News stories may include the names of public officials, businesses, and people involved in newsworthy events. This information is gathered and published for journalism, which is protected by the First Amendment, and is generally "publicly available information" that state privacy laws exclude. If you are named in a story and believe something is inaccurate, please use our Corrections Policy. We review requests to remove or update older stories about private individuals case by case.

e. Sensitive information

We do not ask for sensitive information such as Social Security numbers, health information, precise geolocation (beyond the session-only feature above), biometric data, or information about race, religion, sexual orientation, or immigration status, and we ask you not to include it in listings or messages. We do not sell sensitive data, and we do not use sensitive data to infer characteristics about you.

2. How we use information

Purpose	Examples
Provide the Service	Show your city edition, deliver newsletters you confirmed, publish your listings and ads, run your account
Process payments	Charge for ads and promoted listings through TRGPay, issue refunds, handle disputes, keep tax and accounting records
Safety, screening, and integrity	Automatically screen listings and ads for Fair Housing and EEO violations, prohibited items, scams, and fraud; detect bots, abuse, and security incidents
Comply with law	Keep political advertising records, respond to lawful requests, honor privacy rights and opt-outs, meet tax obligations
Measure and improve	Aggregate readership analytics to decide what to cover and to fix bugs
Advertising	Show contextual ads based on the page and edition you are reading (no cookies needed). Show personalized/targeted ads only if you consent to advertising cookies and have not opted out
Communicate with you	Respond to tips, corrections, support and privacy requests; send service and billing notices

Automated decisions. Our screening system may automatically hold or reject a classified listing or ad that appears to break our rules. These decisions concern your listing, not you personally, but you can ask for a human review by replying to the rejection notice. We do not use automated decision-making to make decisions that produce legal or similarly significant effects about readers (such as decisions about credit, housing, or employment).

Generative AI. Our newsroom software drafts stories from public data and public reporting. It does not use reader personal information, newsletter lists, or classified listings to train or fine-tune AI models. [CONFIRM with engineering, including any third-party AI vendor terms — vendor must contractually agree not to train on our data.]

3. How we disclose information

We disclose personal information only as described here:

Service providers (processors) who work for us under written contracts that limit their use of the data: our cloud hosting provider, email delivery service, payment processors used by TRGPay, fraud-prevention and security tools, customer-support tools, and AI model providers used by our newsroom (which receive public news material, not reader data). [Insert list or category list of current vendors.]
TRGPay, our affiliated payment engine, to process payments you make to us.
Affiliated companies. We do not share reader, subscriber, or classifieds data with our affiliated companies (such as Flip Master Lending) for their own marketing. If you click a "From the Genius Eye family of companies" ad and submit information on that company's site, that company's own privacy policy applies.
Other users and the public. Classified listings, the contact method you choose to display, and advertisements are public. Political ads appear in our public political ad archive, including the sponsor's name and the amount spent where required.
Advertising partners (only with consent). If you accept advertising cookies, ad-tech partners may receive cookie IDs, device identifiers, IP address, and browsing activity on our site. See Section 5.
Legal and safety. To comply with law, subpoenas, or court orders; to respond to government requests where legally required; to enforce our Terms; or to protect the rights, property, or safety of our users, the public, or us. We review demands that seek to identify confidential sources or anonymous users and resist them where we lawfully can.
Business transfers. In a merger, acquisition, financing, or sale of assets, subject to this Policy.
With your consent or at your direction.

4. Where your information is stored

We operate our own software on cloud servers operated for us by our hosting provider. Those servers may be located outside your state or country. [CONFIRM data-center region(s) — the hosting provider offers locations in Germany, Finland, the United States (Virginia and Oregon), and Singapore. If production data is in Germany or Finland, insert: "Our servers are located in the European Union."] Wherever your data is stored, it is protected as described in this Policy. The Service is intended for users in the United States; if you use it from elsewhere, you understand your information will be processed in the locations described above.

5. Advertising, "sale," "sharing," and targeted advertising

Default: no ad tracking. Advertising cookies and pixels do not load until you choose "Accept advertising cookies" in our consent banner or Cookie Settings.
If you consent, third-party ad partners may use cookies and identifiers to show you ads based on your activity across sites. Under California law that is "sharing" for cross-context behavioral advertising, and under California and several other states' laws, providing identifiers to ad partners may be a "sale" or "targeted advertising," even though we are not paid for the data itself.
Your choices: You can withdraw consent at any time through Cookie Settings or the "Do Not Sell or Share My Personal Information / Your Privacy Choices" link in our footer. Opting out stops the use of ad cookies on your browser and, if you are signed in, on your account.
Global Privacy Control: If your browser sends a GPC signal, we treat it as a valid request to opt out of sale, sharing, and targeted advertising for that browser — and, if you are signed in, for your account — without you needing to do anything else. Our site will display "Opt-out preference signal honored" when we detect it. If GPC conflicts with a setting you previously chose, we follow GPC unless you affirmatively change it.
Minors: We do not sell personal information of, or show targeted advertising to, anyone we know (or should know) is under 18. [CONFIRM: account signup age field or attestation.]
Data brokers: We do not buy personal information from data brokers to target ads. [CONFIRM.]

6. How long we keep information

Data	Retention
Server logs and security records	Up to 90 days, longer if needed to investigate an incident [CONFIRM]
First-party analytics	Aggregated or de-identified after 14 months [CONFIRM]
Newsletter subscription and consent records	While you are subscribed, plus 3 years after you unsubscribe (to prove consent and honor suppression)
Account data	Until you delete your account, plus up to 30 days in backups
Classified listings	Active period, then 12 months after expiration for fraud and dispute handling, unless you delete sooner (we keep a suppression record of removed scam listings)
Advertising orders and invoices	7 years (tax and accounting)
Political advertising records	At least 4 years after the election to which the ad relates, or longer if any law requires
Payment tokens	Until removed by you or no longer needed; raw card numbers are never stored by Genius Eye News
Privacy request records	24 months (as required by Cal. Code Regs. tit. 11, § 7101)
Correction requests and tips	As long as relevant to the related story

We delete or de-identify information when it is no longer needed for these purposes.

7. Security

We use administrative, technical, and physical safeguards appropriate to the information we hold, including encryption in transit (HTTPS/TLS), hashed passwords, access controls and least-privilege access for staff, logging, and regular backups. Payment card data is handled by PCI-DSS–compliant processors through TRGPay. No system is perfectly secure. If a data breach affects your personal information, we will notify you and regulators as required by applicable law (for example N.C. Gen. Stat. § 75-65, Cal. Civ. Code § 1798.82, Fla. Stat. § 501.171, O.C.G.A. § 10-1-912, S.C. Code § 39-1-90, Va. Code § 18.2-186.6, Md. Code, Com. Law § 14-3504, and D.C. Code § 28-3852).

8. Children

The Service is a general-audience news site and is not directed to children under 13. We do not knowingly collect personal information from children under 13, and children under 13 may not create accounts, sign up for newsletters, post listings, or buy ads. If we learn we collected such information, we will delete it. Parents can contact us at news@geniuseyenews.com. (Children's Online Privacy Protection Act, 15 U.S.C. § 6501 et seq.; 16 C.F.R. Part 312.)

9. Your choices

Newsletters: Unsubscribe with the link in any email or in account settings.
Cookies: Manage through Cookie Settings in our footer (see Cookie Policy).
Do Not Sell or Share / Targeted advertising: Footer link or GPC.
Account: Edit or delete in account settings.
Listings: Edit or delete at any time.

10. Your state privacy rights

Depending on where you live, you may have some or all of the following rights. We extend these rights to all U.S. users, whether or not your state's law currently applies to us, because it is simpler and fairer. [Business decision — attorney to confirm.]

Know / access the personal information we have about you, and the categories of sources, purposes, and recipients.
Correct inaccurate personal information.
Delete personal information we collected from or about you (subject to legal exceptions, for example political ad records and tax records).
Portability — get a copy in a portable format.
Opt out of the sale of personal information, "sharing" for cross-context behavioral advertising, targeted advertising, and profiling in furtherance of decisions that produce legal or similarly significant effects.
Limit use of sensitive personal information (California) — we do not use sensitive personal information for purposes that would trigger this right.
List of third parties — in Oregon and Minnesota, you may request a list of the specific third parties to which we have disclosed personal data; in Minnesota you may also question the result of profiling.
Appeal our decision on your request.
Non-discrimination — we will not deny service, charge different prices, or provide lower quality because you exercised your rights.

How to make a request

Online: Privacy Request form at [URL]
Email: news@geniuseyenews.com with "Privacy Request" in the subject line [CONSIDER a dedicated privacy@geniuseyenews.com]

Because we operate exclusively online and have a direct relationship with users, email and our online form are our designated request methods (Cal. Civ. Code § 1798.130(a)(1)(A)).

Verification. We verify requests by matching information you provide to information we hold (for example, by confirming control of the email address on your account or subscription). Opt-out requests do not require verification. We will not ask for more information than needed.

Authorized agents. You may use an authorized agent. We may ask the agent for signed permission and ask you to verify your identity directly, except where the agent holds a valid power of attorney.

Timing. We will confirm receipt within 10 business days and respond within 45 days, which we may extend once by up to 45 more days where reasonably necessary, with notice.

Appeals. If we decline your request, you may appeal by replying to our decision email with "Appeal" in the subject line. We will respond within 45 days (or within the shorter period required by your state, for example 60 days in Virginia). If you are not satisfied with the appeal decision, you may contact your state Attorney General (for example, Virginia: www.oag.state.va.us; Maryland: www.marylandattorneygeneral.gov).

State-specific information

States with comprehensive consumer privacy laws in force as of [DATE OF LAUNCH] (each applies only to businesses that meet its thresholds — see our compliance memo):

State	Law
California	California Consumer Privacy Act as amended by the CPRA, Cal. Civ. Code § 1798.100 et seq.; Cal. Code Regs. tit. 11, § 7000 et seq.
Colorado	Colorado Privacy Act, Colo. Rev. Stat. § 6-1-1301 et seq.
Connecticut	Connecticut Data Privacy Act, Conn. Gen. Stat. § 42-515 et seq.
Delaware	Delaware Personal Data Privacy Act, 6 Del. C. § 12D-101 et seq.
Florida	Florida Digital Bill of Rights, Fla. Stat. § 501.701 et seq. (applies primarily to very large companies)
Indiana	Indiana Consumer Data Protection Act, Ind. Code § 24-15
Iowa	Iowa Consumer Data Protection Act, Iowa Code ch. 715D
Kentucky	Kentucky Consumer Data Protection Act, Ky. Rev. Stat. § 367.3611 et seq.
Maryland	Maryland Online Data Privacy Act, Md. Code, Com. Law § 14-4701 et seq.
Minnesota	Minnesota Consumer Data Privacy Act, Minn. Stat. § 325M.10 et seq.
Montana	Montana Consumer Data Privacy Act, Mont. Code Ann. § 30-14-2801 et seq.
Nebraska	Nebraska Data Privacy Act, Neb. Rev. Stat. § 87-1101 et seq.
New Hampshire	N.H. Rev. Stat. ch. 507-H
New Jersey	N.J. Stat. § 56:8-166.4 et seq.
Oregon	Oregon Consumer Privacy Act, Or. Rev. Stat. § 646A.570 et seq.
Rhode Island	Rhode Island Data Transparency and Privacy Protection Act, R.I. Gen. Laws § 6-48.1-1 et seq.
Tennessee	Tennessee Information Protection Act, Tenn. Code Ann. § 47-18-3301 et seq.
Texas	Texas Data Privacy and Security Act, Tex. Bus. & Com. Code ch. 541
Utah	Utah Consumer Privacy Act, Utah Code § 13-61-101 et seq.
Virginia	Virginia Consumer Data Protection Act, Va. Code § 59.1-575 et seq.

Laws enacted but not yet in effect that we are preparing for: Louisiana (Jan. 1, 2027), Oklahoma (Jan. 1, 2027), Alabama (May 1, 2027), and Vermont (Jan. 1, 2028).

California residents — Notice at Collection and CCPA disclosures. In the past 12 months we have collected the following categories of personal information (Cal. Civ. Code § 1798.140(v)):

Category	Examples	Source	Business purpose	Disclosed to	Sold or shared?
Identifiers	Name, email, IP address, cookie IDs, account ID	You; your device	Provide Service, security, newsletters, ads	Service providers; ad partners (with consent)	Shared/sold only if you accept ad cookies (cookie IDs, IP)
Customer records (Cal. Civ. Code § 1798.80(e))	Billing name, address, phone, payment token	You; processors	Payments, accounting	TRGPay and processors	No
Commercial information	Ad orders, promoted listings, purchase history	You	Fulfill orders	Service providers	No
Internet activity	Pages viewed, clicks, newsletter engagement	Your device	Analytics, security, ads	Service providers; ad partners (with consent)	Only if you accept ad cookies
Approximate geolocation	City/region from IP	Your device	Edition and weather	Service providers	Only if you accept ad cookies
Audio/visual	Photos in listings and ads	You	Publish listings and ads	Public; service providers	No
Professional information	Business name, title (advertisers)	You	Ad accounts; political ad records	Public (political archive); regulators when required	No
Inferences	Edition and topic interests	Your activity	Personalize edition	Service providers	No
Sensitive personal information	Account login credentials	You	Account security only	Service providers	No

Retention periods are listed in Section 6. We do not have actual knowledge of selling or sharing personal information of consumers under 16. We do not offer financial incentives for personal information. We do not disclose personal information to third parties for their own direct marketing purposes (Cal. Civ. Code § 1798.83).

Maryland residents. We collect only personal data reasonably necessary and proportionate to provide the features you request, we never sell sensitive data, and we do not sell personal data or engage in targeted advertising for anyone we know or should know is under 18 (Md. Code, Com. Law § 14-4701 et seq.).

Virginia, Colorado, Connecticut, and other states. Our disclosures about categories of personal data, purposes, categories shared with third parties, and how to opt out of targeted advertising and sale are in Sections 1–5. You may appeal any denial of your request as described above.

Nevada residents. We do not sell "covered information" as defined by Nev. Rev. Stat. § 603A.320. You may still submit an opt-out request to news@geniuseyenews.com.

North Carolina, South Carolina, Georgia, and Washington, D.C. These jurisdictions do not currently have a comprehensive consumer privacy law in force. We nonetheless honor the rights in this Section for residents of these jurisdictions, and we follow their data-security and breach-notification laws.

11. Changes to this Policy

We will post updates here and change the "Last updated" date. If we make material changes — for example, using personal information for a new purpose or sharing it with new categories of recipients — we will notify you by email or a prominent notice before the change takes effect and, where required, ask for your consent.

12. Contact

[LEGAL ENTITY NAME] d/b/a TRG Tech Link / Genius Eye News [MAILING ADDRESS] Email: news@geniuseyenews.com (privacy requests) · admin@trgtechlink.com (legal)