Bauer Publishing

PRIVACY SHIELD PRIVACY POLICY

Last Updated: December 13, 2016

This Privacy Shield Privacy Policy (this "Policy") applies to all personal information received by Bauer Publishing Group in the United States from the European Economic Area (EEA) (which includes the member states of the European Union (EU) plus Iceland, Liechtenstein and Norway) and from Switzerland. This Policy also applies to all personal information previously received under the U.S.-EU Safe Harbor Framework and still held by Bauer. This Policy sets out our practices for collecting, using, maintaining, protecting and disclosing that personal information.

DEFINITIONS

For purposes of this Policy, the following definitions shall apply:

"Agent" means any third party that collects or uses personal information under the instructions of, and solely for, Bauer or to which Bauer discloses personal information for use on Bauer's behalf.

"Bauer" means Bauer Publishing Group, including Bauer Media Group, USA, LLC; Heinrich Bauer North America, Inc.; Heinrich Bauer Publishing, L.P.; Bauer Magazine, L.P.; Bauer Publishing Company, L.P., and Bauer Media Sales, Inc.; and any of its subsidiaries, predecessors and successors in the United States.

"Personal information" means any information or set of information that identifies or could be used by or on behalf of Bauer to identify (together with other information) a living individual. Personal information does not include information that is anonymized or aggregated.

"Sensitive information" means any personal information that reveals race, ethnic origin, political opinions, religious or philosophical beliefs, trade union membership, information that concerns health or sex life, and information about criminal or administrative proceedings and sanctions.

EU-U.S. PRIVACY SHIELD PRINCIPLES

Bauer participates in and complies with the EU-U.S. Privacy Shield Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from European Union member countries. Bauer has certified that it adheres to the Privacy Shield Principles of Notice, Choice, Accountability for Onward Transfers, Security, Data Integrity and Purpose Limitation, Access, and Recourse, Enforcement, and Liability, which are the basis for the principles of this Policy. If there is any conflict between this Policy and the Privacy Shield Principles, the Privacy Shield Principles shall govern. To learn more about the Privacy Shield program, and to view Bauer’s certification, visit https://www.privacyshield.gov/.

U.S.-SWISS SAFE HARBOR PRINCIPLES

Bauer complies with the U.S.-Swiss Safe Harbor Framework as set forth by the US Department of Commerce regarding the collection, use, and retention of personal information from Switzerland. Bauer has certified that it adheres to the Safe Harbor Privacy Principles of Notice, Choice, Onward Transfers, Security, Data Integrity, Access, and Enforcement. If there is any conflict between this Policy and the Safe Harbor Principles, the Safe Harbor Principles shall govern. To learn more about the U.S.-Swiss Safe Harbor, and to view Bauer’s certification, please visit http://www.export.gov/safeharbor.

Notice

Where Bauer collects personal information directly from individuals in the EEA and Switzerland, it will publicly inform them about its compliance with the EU-US Privacy Shield and/or Swiss-US Safe Harbor participation in clear, concise language. This personal information may include basic contact information like name and email address, and billing information. Bauer uses this information to provide requested services and products to customers, customer support for such services and products, to bill customers, and to correspond with customers.

Bauer receives personal information about individuals in the EEA and Switzerland collected by Bauer’s European affiliates. Bauer uses this information to provide analytical and other data processing services to its affiliated companies. Bauer also receives information about employees of Bauer who are located in the EEA and Switzerland, and which is transferred in the context of the employment relationship. Bauer uses this information for internal employment and human resources purposes.

Bauer will subject all personal information received via the Privacy Shield and U.S.-Swiss Safe Harbor Framework to their respective Privacy Principles. Bauer is subject to the investigative and enforcement authority of the Federal Trade Commission (FTC), is obliged to disclose personal information in response to lawful requests by public authorities, for law enforcement, and national security purposes, and has potential liability for onward transfers to third parties. Additionally, an individual may be allowed to invoke binding arbitration to resolve disputes under certain limited conditions.

Choice

Bauer will offer individuals the opportunity to choose whether their personal information is to be used for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual. An individual may opt-out of such uses of their personal information by contacting us at the address given below.

Bauer will not use sensitive personal information for a purpose other than the purpose for which it was originally collected or subsequently authorized by the individual unless Bauer has received the individual’s affirmative and explicit consent (opt-in).

Data Integrity

Bauer will use personal information only in ways that are compatible with the purposes for which it was collected or subsequently authorized by the individual. Bauer will take reasonable steps to ensure that personal information is relevant to its intended use, accurate, complete and current.

Transfers to Agents

Bauer may disclose personal information to third party agents that perform functions on Bauer’s behalf, including but not limited to, providers of analytical, hosting, payment processing and other support services. These entities may have access to personal information if needed to perform their functions for Bauer. Bauer does not transfer personal information to non-agent third parties.

For information received under the Privacy Shield, Bauer will require its agents to safeguard personal information consistent with this Policy by contract obligating the agent to provide at least the same level of protection as is required by the Privacy Shield Principles. Under certain circumstances, Bauer may bear liability for onward transfers of personal data from the EEA where its agent processes personal data inconsistent with the Privacy Shield Principles.

For information received under the Safe Harbor, Bauer will obtain appropriate assurances from its agents that they will safeguard personal information consistent with this Policy. Examples of appropriate assurances include the following: a contract obligating the agent to provide at least the same level of protection as is required by the Safe Harbor Principles, and the agent being subject to the Swiss Federal Act on Data Protection, its own Safe Harbor certification, or another Swiss FDPIC adequacy finding.

Access and Correction

Bauer acknowledges the right of individuals to access their personal data. Upon request, Bauer will grant individuals reasonable access to personal information that it holds about them. In addition, Bauer will take reasonable steps to permit individuals to correct, amend, or delete information that is demonstrated to be inaccurate or incomplete. An individual may request to access their information, or otherwise correct, amend, or delete their information by contacting us at the address given below.

Security

Bauer will take reasonable and appropriate precautions to protect personal information in its possession from loss, misuse and unauthorized access, disclosure, alteration and destruction.

Enforcement

Bauer will conduct compliance audits of its relevant privacy practices to verify adherence to this Policy. Any employee that Bauer determines is in violation of this policy will be subject to disciplinary action.

Bauer is subject to the investigative and enforcement authority of the FTC.

Dispute Resolution – Privacy Shield

In compliance with the EU-U.S. Privacy Shield Principles, Bauer commits to resolve complaints about your privacy and our collection or use of your personal information. EU individuals with inquiries or complaints regarding this Policy should first contact Bauer at the address given below. Bauer will investigate and attempt to resolve complaints regarding use and disclosure of personal information by reference to the principles contained in this Policy.

Bauer has further committed to refer unresolved privacy complaints under the EU-U.S. Privacy Shield Principles to the BBB EU PRIVACY SHIELD, a non-profit alternative dispute resolution provider located in the United States and operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit the BBB EU PRIVACY SHIELD web site at www.bbb.org/EU-privacy-shield/for-eu-consumers/ for more information and to file a complaint. Under certain limited conditions, an individual may be able to invoke binding arbitration as provided under the Privacy Shield to address an otherwise unresolved complaint.

Dispute Resolution – Safe Harbor

In compliance with the U.S.-Swiss Safe Harbor Principles, Bauer commits to resolve complaints about your privacy and our collection or use of your personal information. Swiss citizens with inquiries or complaints regarding this Policy should first contact Bauer at the address given below. Bauer will investigate and attempt to resolve complaints regarding use and disclosure of personal information by reference to the principles contained in this Policy.

Bauer has further committed to refer unresolved privacy complaints under the U.S.-Swiss Safe Harbor Principles to an independent dispute resolution mechanism operated by the Council of Better Business Bureaus. If you do not receive timely acknowledgment of your complaint, or if your complaint is not satisfactorily addressed, please visit http://www.bbb.org/us/safe-harbor-complaints for more information and to file a complaint.

CONTACT INFORMATION

Questions regarding this Policy should be submitted to Bauer by mail to:

Privacy Shield/Safe Harbor Coordinator
Bauer Publishing Group
270 Sylvan Avenue
Englewood Cliffs, New Jersey 07632

Or by e-mail to privacypolicy@bauerpublishing.com

LIMITATIONS & CHANGES

Adherence by Bauer to these Privacy Shield and Safe Harbor Principles may be limited (a) to the extent required to respond to a legal obligation; (b) to the extent necessary to meet national security, public interest or law enforcement obligations; and (c) to the extent expressly permitted by an applicable law, rule or regulation.

This Policy may be amended from time to time, consistent with the requirements of the Privacy Shield and Safe Harbor Principles. The amended Policy will be made publicly available via Bauer’s website.