Privacy Policy
Technical disclosure of data handling, multi-tenant separation, reader telemetry, and authentication on the My Online Paper platform.
Draft for Review — Requires Owner & Legal Approval
This document represents an engineering and architectural privacy policy draft formulated strictly from verified application mechanics and data storage implementations in the current codebase. It does not constitute formal legal counsel or a finalized compliance guarantee and must undergo formal legal and ownership review before being designated as an approved, legally binding platform policy.
1. Scope & Multi-Tenant Architecture
My Online Paper operates as a multi-tenant cloud SaaS platform. The application maintains three distinct data planes:
- Publisher Workspaces: Dedicated namespaces partitioned by unique publication tenant IDs. Newsroom content, articles, categories, author profiles, and staff assignments belong exclusively to the publishing organization.
- Public Publication Readers: Anonymous public consumers who read digital articles and browse electronic paper editions across
/pub/[publicationSlug]or custom publication domains. - Platform Administration: Superadministrative oversight for infrastructure liveness, custom domain mapping, and audit inspection.
Tenant database collections are segregated in Google Cloud Firestore. Public projections are explicitly serialized to exclude private internal metadata before delivery to readers.
2. Publisher & Staff Authentication
For authorized newsroom personnel (owners, editors, and reporters), identity and authentication are managed using Google Firebase Authentication:
- Credential Protection: Passwords and credentials are encrypted and evaluated directly by Firebase Authentication services. User passwords are never saved, persisted, or logged into application Firestore databases or server logs.
- Data Minimization: Platform administrative directories store only operational account metadata: user ID (UID), email address, display name, and active tenant memberships.
- Anti-Impersonation Safeguards: Platform administrators have zero capability to impersonate tenant users or assume tenant user identity sessions.
3. Public Reader Telemetry & Anonymous Analytics
Public readers can consume articles and digital editions freely without mandatory account registration:
- Non-Blocking Telemetry: When readers view an article or e-paper edition, lightweight telemetry events are dispatched via
navigator.sendBeaconor keepalive fetch requests to record page-level viewership. - Aggregated Metrics: Metrics collected include timestamp, publication ID, article or edition slug, device classification (mobile, tablet, desktop), and referring domain.
- No Third-Party Ad Trackers: The platform does not deploy third-party advertising trackers, pixel networks, or cross-site user fingerprinting cookies.
- Daily Aggregation: Raw viewership events are aggregated server-side into daily summary counts to prevent granular longitudinal tracking of individual reader habits.
4. Media Assets & Publication Documents
News photography, publication branding logos, and electronic edition PDFs are stored within Google Cloud Storage and Firebase Storage:
- Storage paths are partitioned by tenant namespace (e.g.,
tenants/[tenantId]/...). - Public reading assets (featured article images, processed e-paper edition pages) are served via secure public URLs.
- Publishers retain control over reader PDF downloading capabilities for their respective print editions.
5. Audit Logging & Platform Security
To maintain system integrity, detect unauthorized access, and protect publisher accounts, the platform maintains server-side immutable audit logs:
- Administrative actions (lifecycle status adjustments, staff role assignments, domain mappings) record the actor UID, action timestamp, and sanitized metadata.
- Audit logs are written exclusively via the server-side Admin SDK and cannot be modified or deleted by clients or administrators.
- Sensitive fields such as passwords and session tokens are strictly sanitized from audit log payloads prior to storage.
6. Cloud Infrastructure & Hosting
Platform services and data storage are hosted in Google Cloud Platform data centers in the United States (us-central1 region), utilizing Firebase App Hosting, Cloud Firestore, Cloud Storage, and Google Cloud IAM.
7. Cookies & Client-Side Storage
The platform implements strictly necessary session mechanisms and avoids cross-site surveillance:
- Essential Authentication Cookies: Secure session tokens (e.g.,
__session) are utilized exclusively to authenticate authorized newsroom staff and maintain publisher admin sessions. - Reader Privacy: Public readers browsing client newspaper articles and e-papers do not receive persistent tracking cookies or advertising identifiers.
- No Third-Party Ad Cookies: The platform does not set third-party marketing, retargeting, or advertising network cookies.
8. Purposes of Processing & Legal Grounds (Pending Legal Review)
Platform data handling occurs for the following operational purposes:
- Service Delivery: Hosting digital publications, rendering e-paper editions, processing news articles, and managing staff accounts (contract performance).
- Platform Security: Detecting unauthorized access, preventing cross-tenant data leaks, and maintaining immutable audit logs (legitimate operational interests).
- Reader Telemetry: Generating aggregated readership metrics without reader profiling (legitimate interest with data minimization).
Note: Formal statutory legal bases under international frameworks (such as GDPR Art. 6 or CCPA disclosures) require formal owner and legal counsel ratification.
9. Data Retention, Archival & Deletion
- Active Tenants: Publisher newsroom articles, media, and staff profiles remain active until deletion or workspace status modification by the publisher.
- Suspended Tenants: When a publication is suspended, data is retained in a secure dormant state, allowing reactivation or data export.
- Security Audit Logs: System audit logs are preserved for security monitoring and fraud prevention. Specific statutory retention schedules will be posted following legal review.
10. User Rights & Access Requests
Registered newsroom personnel and individuals may submit inquiries concerning their stored account information, request profile corrections, or inquire regarding tenant data deletion by contacting our privacy desk at support@myonlinepaper.com.
11. Privacy Inquiries & Review Status
For questions concerning this technical privacy draft, data handling architecture, or publisher privacy settings, please reach out to: