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PRIVACY POLICY

FOR THE EUROPEAN UNION

Table of Contents



Thank you for visiting this Novel Approach LLC (“Novel Approach”) website. Your privacy is important to us, and we are committed to ensuring your privacy is respected and protected. As part of this commitment, we have prepared this Privacy Policy to explain the manner in which Novel Approach collects, uses, discloses and otherwise treats the personal information of consumers based in the European Union.

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Collection and Use of Personal Information

You are able to enjoy our publications, take advantage of our promotions and visit many areas of our websites without providing us with any personal information. However, we do collect personal information when you:

  • subscribe to one of our publications;
  • purchase, return, or exchange products offered through one of our websites or publications;
  • subscribe to one of our online newsletters, or register to participate in an online forum or community;
  • submit content to one of our publications or on-line services;
  • enter into a contest or sweepstakes;
  • respond to one of our polls or surveys; or
  • contact our customer service department with an enquiry, comment or suggestion.

Subscriptions: When you subscribe for one of our publications, we may ask you to provide your name, mailing address, e-mail address and credit card or other payment information for the purposes of fulfilling your subscription, sending you invoices, contacting you about the expiry of your subscription, and service messages about your subscription.

Product Purchases: When you purchase products offered through one of our websites or publications, we collect your credit card and other payment information and keep a history of your purchases. We use this information to process your orders, to better assist you when you visit or contact us in the future, as well as to improve our product offerings when we send you information about these in accordance with this Privacy Policy.

When you return merchandise purchased via one of our websites or request a refund or exchange, you may be asked to provide certain information, including your name, e-mail address, residential address and phone number. We collect and use this information for fraud prevention purposes.

Online Registration: You do not have to register to browse some areas of our websites. However, registration is required to receive online newsletters or to participate in certain website features, such as a community forum. When you register, you may be asked for personal information such as your name, e-mail address, and a user name and password that you select. We collect this information to identify who you are, to provide you with the service or information you requested, and/or to facilitate your participation in an on-line forum or community. We may also use this information for promotional and marketing purposes in accordance with this Privacy Policy.

Please remember that any information you disclose in these public forum or community areas becomes public information and is immediately accessible to other users, so it is important for you to carefully consider what, if any, personal information you reveal in these areas. We may use information disclosed by you in this way to promote our products and services in our advertising communications.

Information about Other People: At some of our websites and through certain promotions, you can submit personal information about other people. For example, you might submit a person’s name and e-mail address to send an electronic greeting card and, if you order a gift subscription and want it sent directly to the recipient, you may be required to submit the recipient’s name and address. We do not use the recipient’s personal information for any other purpose unless this is consistent with any further dealings which we may have with the recipient direct.

Promotions or Surveys: When you enter a contest or sweepstakes (“promotion”) or participate in a survey or poll (“survey”) we may ask you to provide your name, address, phone number and e-mail address. We use the information we collect on promotion entry forms to administer your participation in the promotions and for other purposes stated on the entry form. Our surveys ask for opinions on various issues and may be sponsored by our advertisers and partners. Most information obtained through surveys is aggregated and used internally. We may share survey information with advertisers and marketing partners in an aggregated, non-personally identifiable form. In the event personal information is requested as part of a survey, such personal information will only be provided to unaffiliated third parties after ensuring that depending on the circumstances you have either consented or not objected.

Optional Information: Occasionally, we may request demographic information (like your age or gender) or information about your interests and purchasing preferences. In most instances, you do not have to provide us with this information to receive the publication, product or service you have requested. We use this optional demographic and preference information to tailor or improve our publications, product and service offerings, including our offerings to you where this is in accordance with this Privacy Policy, as well as for internal marketing research purposes.

Customer Service: When you call one of our customer service representatives, or e-mail us with a comment or question, you may be asked for information that identifies you, such as your name, address and telephone number, to help us promptly answer your question. We may retain this information to assist you in the future, for instance with any further queries you may have or by sending you information about other publications, products or services of ours which we believe may interest you, in accordance with this Privacy Policy. We also may use your feedback, suggestions and comments to monitor and/or improve our publications, product offerings, and our websites.

Website Information: Generally, you can visit our websites without telling us who you are or providing us with any personal information. We collect the IP (Internet protocol) addresses of all visitors to our websites and clickstream and other related information such as page requests, browser type, operating system and average time spent on our websites. We use this information to monitor and improve our websites.

Cookies: To enhance your experience on our sites, many of our web pages use “cookies”. Cookies are small text files that we place in your computer’s browser to store your preferences. Cookies, by themselves, do not tell us your e-mail address or other personal information unless you choose to provide this information to us by, for example, registering at one of our sites. Once you choose to provide a web page with personal information, this information may be linked to the data stored in the cookie. A cookie is like an identification card. It is unique to your computer and can only be read by the server that gave it to you.

We use cookies to understand site usage and to improve the content and offerings on our sites. For example, we may use cookies to personalise your experience on our web pages (e.g. to recognise you by name when you return to our site, or to tailor content or product and service offerings).

Most browsers automatically accept cookies. You can set your browser option so that you will not receive cookies and you can also delete existing cookies from your browser. You may find that some parts of the site will not function properly if you have refused cookies.

Web Beacons: Our websites may also use small pieces of software code called “web beacons” or “clear gifs” to collect anonymous and aggregate advertising metrics, such as counting page views, promotion views, or advertising responses. A web beacon is an electronic image called a single-pixel or clear GIF. Web beacons can recognise certain types of information, such as a user’s cookie number, time and date of a page view, and description of the page where the web beacon is placed. You may render some web beacons unusable if you choose to reject their associated cookies. These web beacons may be used to deliver cookies that conform to our cookie policy above.

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Marketing

When we collect your personal information we may give specific disclosures at that time as to possible future use of that information for marketing purposes. Where appropriate, and invariably in the case of possible future use of your e-mail address for marketing purposes, we will also ask you to indicate your preferences as to that future use, for instance by ticking a box to opt-in or ticking a box to opt-out.

Alternatively your information may be collected automatically during your website visit as described elsewhere in this Privacy Policy. We may also combine personal information we received from you with publicly available outside records.

In all the above cases we will use this information to enhance our ability to market products and services that may be of interest to you by way of appropriate marketing messages, either during your site visit or by way of subsequent communications.

If this process leads to your being placed on our marketing mailing list, you can remove yourself from the list by clicking here (for postal mail) or here (for e-mail) or by otherwise contacting us as set out in the “How to Contact Us” section below. You can also remove yourself from an e-mail marketing list by clicking the “unsubscribe” button that appears on our e-mails.

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Disclosure of Personal Information

We will not disclose, rent, sell or otherwise transfer your personal information without your consent, except as otherwise set out in this Privacy Policy or in any specific disclosure given to you when obtaining personal information from you.

Third Party Processors and Agents: Certain personal information may be transferred among our family of companies or other third parties solely for the purposes of processing your request or arranging delivery of your subscription, product, or service you have requested. We may also transfer (or otherwise make available) your personal information to third parties who administer our contests and prize redemptions, or who provide circulation audit and other services on our behalf. We will store and process personal information in the United States or any other country in which we (or any of our affiliates, subsidiaries or agents) maintain facilities. All of our service providers are required to maintain the confidentiality and security of your personal information and to use it only in compliance with applicable data privacy laws, and are prohibited from using or disclosing your personal information for any purpose other than providing the services on our behalf or as otherwise permitted by applicable law.

Third Party Products and Services: If you are a subscriber to one of our publications or on-line newsletters, disclosures we give you when obtaining your personal information and your indicated preferences may lead to your contact information being shared with carefully selected marketing partners who will contact you by mail or e-mail with offers about products and services that may be of interest to you. You can remove yourself from the future sharing of your contact information with third parties by clicking here (for e-mail) or here (for postal mail) or otherwise contacting as set out in the “How to Contact Us” section below.

Sale or Merger of Business: It is possible that all or part of Novel Approach could merge with or be acquired by another business. If this happens we may share the information that relates to you.

Legal: We may provide your personal information in response to a search warrant or other legally valid inquiry or order, or to an investigative body in the case of a breach of an agreement or contravention of law, or as otherwise required by law. We may also disclose personal information to assist us in collecting a debt owed by you, or otherwise where necessary for the establishment, exercise or defence of legal claims.

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Third Party Websites and Advertisers

Our websites may provide links to third party websites. The inclusion of any link does not imply our endorsement of any other company, its websites, or its products and/or services. These linked websites have separate and independent privacy policies, which we recommend you read carefully. We have no control over such websites and therefore have no responsibility or liability for the manner in which the organizations that operate such linked websites may collect, use, disclose or otherwise treat your personal information.

Our websites may use reputable third parties to present or serve the advertisements that you may see at its web pages and to conduct research about the advertisements. This Privacy Policy does not cover any use of personal information that such third parties may have collected from you or the methods used by the third parties to collect that information (e.g., cookies, web beacons and clear gifs).

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Security of Personal Information

Although we take appropriate measures to safeguard the personal information in our custody and control, we need you to understand that we are unable to guarantee that your personal information will never be disclosed or accessed in a manner that is inconsistent with this Privacy Policy. We have implemented measures in an effort to maintain the confidentiality of all personal information in our custody and control, including only providing access to personal information to employees and authorized service providers who require such information for the purposes described in this Privacy Policy. We maintain administrative, technical and physical safeguards in an effort to protect against unauthorized access, use, modification and disclosure of personal information in our custody and control.

To provide you with an increased level of security online, access to your personal information on certain of our websites may be protected with a password you select. We strongly recommend that you do not disclose your password to anyone. We will never ask you for your password in any unsolicited communication.

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Accessing and Correcting your Personal Information

If you wish to access the personal information we have about you, or to correct factual errors in our records, please contact us as set out in the “How to Contact Us” section below.

To protect your privacy, we will take reasonable steps to help verify your identity before granting access or making corrections.

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Changes to this Privacy Policy

This Privacy Policy may be updated periodically to reflect changes to our personal information practices. The revised Privacy Policy will be posted on this website. We will treat your personal information in accordance with the privacy policy in place at the time of collection of such information, or as you otherwise indicate your preferences.

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How to Contact Us

Feel free to contact us at any time if:

  • you have any questions or comments about this Privacy Policy,
  • you wish to withdraw your name from an e-mail or other marketing list;
  • you wish to access and/or correct your personal information,
  • you have a complaint about the manner in which we treat your personal information.

Click here for details about how to contact us or send us correspondence at the following address.

Novel Approach LLC
330 Roberts Street
Suite 203
E. Hartford, CT 06108-3654
USA

Last updated on January 14, 2013

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