Effective Date: July 01, 2022

Introduction

Eculeus Group LLC, dba EG Publishing and its subsidiaries (“EG” or “We”) respects your privacy and is committed to protecting it through our compliance with this policy. We’re providing this Privacy Policy to explain how we collect, use, and share information when you interact with us and our offerings and services. The Privacy Policy is global in nature, meaning it is applicable to all websites and offerings in the EG group of companies.

This policy describes the types of information we may collect from you or that you may provide when you visit our website, and our practices for collecting, using, maintaining, protecting, and disclosing that information.

This policy applies to information we collect:

• On our websites.
• In email, text, and other electronic messages between you and our websites.
• Through mobile and desktop applications you download from our websites, as applicable, which provide dedicated non-browser-based interaction between you and our websites.
• When you interact with our advertising and applications on third-party websites and services, if those applications or advertising include links to this policy.

It does not apply to information collected by:

• Us offline or through any other means, including on any other website operated by EG or any third party (including our affiliates and subsidiaries); or
• Any third party, including through any application or content (including advertising) that may link to or be accessible from or on our websites.

Please read this policy carefully to understand our policies and practices regarding your information and how we will treat it. If you do not agree with our policies and practices, your choice is not to use our websites. By accessing or using our websites, you agree to this privacy policy. This policy may change from time to time (see Changes to Our Privacy Policy). Your continued use of our websites after we make changes is deemed to be acceptance of those changes, so please check the policy periodically for updates.

Children

Our websites are not intended for to collect information from children under 16 years of age. We do not knowingly collect personal information from children under 16. If we become aware that such data has been collected, we will delete it. Personal information directly from children under the age of 16 is generally obtained through parental consent. A child’s parent or guardian may also request that the Personal Information of their child be deleted from our records by emailing us at: [email protected].

Information We Collect About You and How We Collect It

We collect several types of information from and about users of our websites, including information:

• By which you may be personally identified, such as name, postal address, e-mail address, telephone number, or any other identifier by which you may be contacted online or offline (“personal information”);
• That is about you but individually does not identify you; and/or
• About your internet connection, the equipment you use to access our websites, and usage details.

We collect this information:

• Directly from you when you provide it to us.
• Automatically as you navigate through the site. Information collected automatically may include usage details, IP addresses, and information collected through cookies and other tracking technologies.

Information You Provide to Us

The information we collect on or through our websites may include:

• Information that you provide by filling in forms on our websites. This includes information provided at the time of registering to use our websites, subscribing to our service, posting material, or requesting further services. We may also ask you for information when you enter a contest or promotion sponsored by us, and when you report a problem with our websites.
• Records and copies of your correspondence (including email addresses) if you contact us.
• Your responses to surveys that we might ask you to complete for research purposes.
• Your search queries on our websites.

You also may provide information to be published or displayed (hereinafter, “posted”) on public areas of our websites or transmitted to other users of our websites or third parties (collectively, “User Contributions”). Your User Contributions are posted on and transmitted to others at your own risk. Although we limit access to certain pages, please be aware that no security measures are perfect or impenetrable. Additionally, we cannot control the actions of other users of our websites with whom you may choose to share your User Contributions. Therefore, we cannot and do not guarantee that your User Contributions will not be viewed by unauthorized persons.

Information We Collect Through Automatic Data Collection Technologies

As you navigate through and interact with our websites, we may use automatic data collection technologies to collect certain information about your equipment, browsing actions, and patterns, including:

• Details of your visits to our websites, including traffic data, location data, logs, and other communication data and the resources that you access and use on our websites.
• Information about your computer and internet connection, including your IP address, operating system, and browser type.

The information we collect automatically is only statistical data and does not include personal information. It helps us to improve our websites and to deliver a better and more personalized service, including by enabling us to:

• Estimate our audience size and usage patterns.
• Store information about your preferences, allowing us to customize our websites according to your individual interests.
• Speed up your searches.
• Recognize you when you return to our websites. The technologies we use for this automatic data collection may include:
• Cookies (or browser cookies). A cookie is a small file placed on the hard drive of your computer. You may refuse to accept browser cookies by activating the appropriate setting on your browser. However, if you select this setting, you may be unable to access certain parts of our websites. Unless you have adjusted your browser setting so that it will refuse cookies, our system will issue cookies when you direct your browser to our websites.
• Flash Cookies. Certain features of our websites may use local stored objects (or Flash cookies) to collect and store information about your preferences and navigation to, from, and on our websites. Flash cookies are not managed by the same browser settings as are used for browser cookies. For information about managing your privacy and security settings for Flash cookies, see Choices About How We Use and Disclose Your Information.

We do not collect personal information automatically, but we may tie this information to personal information about you that we collect from other sources, or you provide to us.

How We Use Your Information

We use information that we collect about you or that you provide to us, including any personal information:

• To present our websites and its contents to you.
• To provide you with information, products, or services that you request from us.
• To fulfill any other purpose for which you provide it.
• To carry out our obligations and enforce our rights arising from any contracts entered into between you and us, including for billing and collection.
• To notify you about changes to our websites or any products or services we offer or provide though it.
• In any other way we may describe when you provide the information.
• For any other purpose with your consent.

We may also use your information to contact you about goods and services that may be of interest to you. If you do not want us to use your information in this way, please check the relevant box located on the form on which we collect your data (the registration form). For more information, see Choices About How We Use and Disclose Your Information.

Disclosure of Your Information

We may disclose aggregated information about our users without restriction.

We may disclose personal information that we collect or you provide as described in this privacy policy:

• To our subsidiaries and affiliates.
• To contractors, service providers, and other third parties we use to support our business.
• To a buyer or other successor in the event of a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of EG’s assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which personal information held by EG about our websites users is among the assets transferred.
• To fulfill the purpose for which you provide it.
• For any other purpose disclosed by us when you provide the information.
• With your consent.

We may also disclose your personal information:

• To comply with any court order, law, or legal process, including to respond to any government or regulatory request.
• and other agreements, including for billing and collection purposes.
• If we believe disclosure is necessary or appropriate to protect the rights, property, or safety of EG, our customers, or others.

Choices About How We Use and Disclose Your Information

We strive to provide you with choices regarding the personal information you provide to us. We have created mechanisms to provide you with the following control over your information:

• Tracking Technologies and Advertising. You can set your browser to refuse all or some browser cookies, or to alert you when cookies are being sent. To learn how you can manage your Flash cookie settings, visit the Flash player settings page on Adobe’s website. If you disable or refuse cookies, please note that some parts of our websites may then be inaccessible or not function properly.

We do not control third parties’ collection or use of your information to serve interest- based advertising. However, these third parties may provide you with ways to choose not to have your information collected or used in this way. You can opt out of receiving targeted ads from members of the Network Advertising Initiative (“NAI”) on the NAI’s website.

Changes to Our Privacy Policy

It is our policy to post any changes we make to our privacy policy on this page. If we make material changes to how we treat our users’ personal information, we will notify you. The date the privacy policy was last revised is identified at the top of the page. You are responsible for ensuring we have an up-to-date active and deliverable email address for you, and for periodically visiting our websites and this privacy policy to check for any changes.

Contact Information

To ask questions or comment about this privacy policy and our privacy practices, contact us at: [email protected].

PRIVACY NOTICE FOR CALIFORNIA CONSUMERS

Effective Date: July 1, 2022

Our Privacy Notice for California Consumers is for California residents and supplements our Privacy Policy and applies solely to visitors, users, and others who reside in California (“Consumers”, “you”). It explains how we collect, use, and share your Personal Information (defined below) and how to exercise your rights under the California Consumer Privacy Act (“CCPA”). This Policy does not apply to workforce-related Personal Information collected from California-based employees, job applicants, contractors, or similar individuals.

Where noted in this Policy, the CCPA temporarily exempts Personal Information reflecting a written or verbal business-to-business communication (“B2B Personal Information”) from some of its requirements.

Information We Collect

We collect information that identifies, relates to, describes, references, is capable of being associated with, or could reasonably be linked, directly or indirectly, with you or your device (“Personal Information”).

We do not sell your Personal Information. Although we do not sell your Personal Information or share it with third parties for their own marketing purposes, we may share it with our affiliated company(s), for the purpose of its marketing efforts.

Personal Information does not include:

• Publicly available information from government records.
• Deidentified or aggregated consumer information.
• Information excluded from the CCPA’s scope, such as:
  • Health or medical information covered by the Health Insurance Portability and Accountability Act of 1996 (HIPAA) and the California Confidentiality of Medical Information Act (CMIA);
  • Personal Information covered by certain sector-specific privacy laws, including the Fair Credit Reporting Act (FRCA), the Gramm-Leach-Bliley Act (GLBA) or California Financial Information Privacy Act (FIPA), and the Driver’s Privacy Protection Act of 1994.
• Information regarding our personnel.

Depending on the nature of the interaction with, or the services provided by us, we may have collected, the following categories of Personal Information from consumers within the preceding twelve (12) months:

CATEGORY	EXAMPLES	COLLECTED
Identifiers	Name, alias, postal address, unique personal identifier, online identifier, Internet Protocol address, email address, account name, Social Security number, driver’s license number, passport number.	Yes
Personal information categories listed in the California Customer Records statute (Cal. Civ. Code § 1798.80(e))	Name, signature, Social Security number, physical characteristics or description, address, telephone number, passport number, driver’s license or state identification card number, insurance policy number, education, employment, employment history, bank account number, credit card number, debit card number, or any other financial information, medical information, or health insurance information. Some Personal Information included in this category may overlap with other categories.	Yes
Protected Information under California or federal law	Age (40 years or older), race, color, ancestry, national origin, citizenship, religion or creed, marital status, medical condition, physical or mental disability, sex (including gender, gender identity, gender expression, pregnancy or childbirth and related medical conditions), sexual orientation, veteran or military status, genetic information (including familial genetic information).	Yes
Commercial information	Records of personal property, products or services purchased, obtained, or considered, or other purchasing or consuming histories or tendencies.	No
Biometric information	Genetic, physiological, behavioral, and biological characteristics, or activity patterns used to extract a template or other identifier or identifying information, such as, fingerprints, faceprints, and voiceprints, iris or retina scans, keystroke, gait, or other physical patterns, and sleep, health, or exercise data.	No
Internet or other similar network activity	Browsing history, search history, information on a consumer’s interaction with a website, application, or advertisement.	Yes
Geolocation data	Physical location or movements.	Yes
Sensory data	Audio, electronic, visual, thermal, olfactory, or similar No information.	No
Professional or employment-related information	Current or past job history or performance evaluations.	Yes
Non-public education information (per the Family Educational Rights and Privacy Act (20 U.S.C. Section 1232g, 34 C.F.R. Part 99)).	Education records directly related to a student maintained by an educational institution or party acting on its behalf, such as grades, transcripts, class lists, student schedules, student identification codes, student financial information, or student disciplinary records.	No
Inferences drawn from other Personal Information	Profile reflecting a person’s preferences, characteristics, psychological trends, predispositions, behavior, attitudes, intelligence, abilities, and aptitudes.	No

We obtain the categories of Personal Information listed above from the following categories of sources:

• Directly from you. For example, from forms you complete or products and services you purchase.
• Indirectly from you. For example, from observing your actions on our Website.
• Provided from third parties. For example, from a mailing list purchased from a third-party data provider.

Use of Personal Information

We may use or disclose your Personal Information we collect for one or more of the following business purposes:

• To fulfill or meet the reason you provided the information. For example, if you share your name and contact information to request a price quote or ask a question about our services, we will use that Personal Information to respond to your inquiry. If you provide your Personal Information to purchase a product or service, we will use that information to process your payment and facilitate delivery. We may also save your information to facilitate new product orders or process returns.
• To provide, support, personalize, and develop our Website, products, and services.
• To create, maintain, customize, and secure your account with us.
• To process your requests, purchases, transactions, and payments and prevent transactional fraud.
• To provide you with support and to respond to your inquiries, including to investigate and address your concerns and monitor and improve our responses.
• To help maintain the safety, security, and integrity of our Website, products and services, databases and other technology assets, and business.
• For testing, research, analysis, and product development, including to develop and improve our Website, products, and services.
• To respond to law enforcement requests and as required by applicable law, court order, or governmental regulations.
• As described to you when collecting your Personal Information or as otherwise set forth in the CCPA.
• To evaluate or conduct a merger, divestiture, restructuring, reorganization, dissolution, or other sale or transfer of some or all of our assets, whether as a going concern or as part of bankruptcy, liquidation, or similar proceeding, in which Personal Information held by us about our Website users is among the assets transferred.

We will not collect additional categories of Personal Information or use the Personal Information we collected for materially different, unrelated, or incompatible purposes without providing you notice.

Sharing Personal Information

We do not sell Personal Information. We may share your Personal Information by disclosing it to a third party for a business purpose. We only make these business purpose disclosures under written contracts that describe the purposes, require the recipient to keep the Personal Information confidential, and prohibit using the disclosed information for any purpose except performing the contract. In the preceding twelve (12) months, Company may have disclosed Personal Information for a business purpose to the third-party categories indicated in the following chart:

PERSONAL INFORMATION CATEGORY	BUSINESS PURPOSE DISCLOSURES	SALES
A: Identifiers.	Service providers, such as payment processors, and affiliates and internet cookie data recipients, like Google Analytics.	None
B: California Customer Records Personal Information categories.	Service providers, such as payment processors, and affiliates and internet cookie data recipients, like Google Analytics.	None
C: Protected classification characteristics under California or federal law.	None	None
D: Commercial information.	Affiliates	None
E: Biometric information.	None	None
F: Internet or other similar network activity.	Service providers, such as social media companies offering advertising services, and affiliates and internet cookie data recipients, like Google Analytics.	None
G: Geolocation data.	Service providers, such as social media companies offering advertising services, and affiliates and internet cookie data recipients, like Google Analytics.	None
H: Sensory data.	None	None
I: Professional or employment-related information.	Service providers, such as software companies offering recruiting or hiring services.	None
J: Non-public education information.	None	None
K: Inferences drawn from other Personal Information.	None	None

Your Rights and Choices

The CCPA provides consumers (California residents) with specific rights regarding their Personal Information. This section describes your CCPA rights and explains how to exercise those rights.

Access to Specific Information and Data Portability

You have the right to request that we disclose certain information to you about our collection and use of your Personal Information over the past 12 months (the “right to know”). Once we receive your request and confirm your identity, we will disclose to you:

• The categories of Personal Information we collected about you.
• The categories of sources for the Personal Information we collected about you.
• Our business or commercial purpose for collecting that Personal Information.
• The categories of third parties with whom we share that Personal Information.
• If we sold or disclosed your Personal Information for a business purpose, two separate lists disclosing:
• sales, identifying the Personal Information categories that each category of recipient purchased; and
• disclosures for a business purpose, identifying the Personal Information categories that each category of recipient obtained.
• The specific pieces of Personal Information we collected about you (also called a data portability request).

We do not provide a right to know or data portability disclosure for B2B Personal Information.

Deletion Request Rights

You have the right to request that we delete any of your Personal Information that we collected from you and retained, subject to certain exceptions (the “right to delete”). Once we receive your request and confirm your identity, we will determine whether any legal exception applies. We may deny your deletion request if retaining the information is necessary for us or our service provider(s) to:

1. Complete the transaction for which we collected the Personal Information, provide a good or service that you requested, take actions reasonably anticipated within the context of our ongoing business relationship with you, fulfill the terms of a written warranty or product recall conducted in accordance with federal law, or otherwise perform our contract with you.
2. Detect security incidents, protect against malicious, deceptive, fraudulent, or illegal activity, or prosecute those responsible for such activities.
3. Debug products to identify and repair errors that impair existing intended functionality.
4. Exercise free speech, ensure the right of another consumer to exercise their free speech rights, or exercise another right provided for by law.
5. Comply with the California Electronic Communications Privacy Act (Cal. Penal Code § 1546 et. seq.).
6. Engage in public or peer-reviewed scientific, historical, or statistical research in the public interest that adheres to all other applicable ethics and privacy laws, when the information’s deletion may likely render impossible or seriously impair the research’s achievement, if you previously provided informed consent.
7. Enable solely internal uses that are reasonably aligned with consumer expectations based on your relationship with us.
8. Comply with a legal obligation.
9. Make other internal and lawful uses of that information that are compatible with the context in which you provided it.

We will delete or deidentify Personal Information not subject to one of these or other legal exceptions from our records.

We do not provide these deletion rights for B2B Personal Information.

Exercising Your Rights to Know or Delete

To exercise your rights to know or delete described above, please submit a request by either:

• By phone at 888-313-7916
• By visiting our Contact Page to submit a request

Only you or a person registered with the California Secretary of State that you authorize to act on your behalf may make a verifiable consumer request related to your Personal Information. You may also make a verifiable consumer request on behalf of your minor child.

You may only make a verifiable consumer request for access or data portability twice within a 12-month period. In order for us to assist you, we ask you to provide us with information so that we may reasonably verify that you are the person about whom we collected Personal Information or are an authorized representative of that person and describe your request with enough detail for us to understand, evaluate, and respond to it.

We will ask you these or similar questions:

• Are you or the business you own or are employed by:
  • currently a business customer?
  • been a business customer in the past 12 months?
• What publication or line of business was this related to?
• What was the approximate timeframe that we worked together?
• Describe your request with sufficient detail that allows us to properly understand, evaluate, and respond to it.

We cannot respond to your request or provide you with Personal Information if we cannot verify your identity or authority to make the request and confirm the Personal Information relates to you.

You do not need to create an account with us to submit a request to know or delete.

We will only use Personal Information provided in the request to verify the requestor’s identity or authority to make it.

Response Timing and Format

We will confirm receipt of your request within ten (10) business days or within timeframe allowances specified in the CCPA. If you do not receive confirmation within the 10-day timeframe, please call at us 888-313-7916 or contact us on our contact us page.

We endeavor to substantively respond to a verifiable consumer request within forty-five (45) days of its receipt. If we require more time (up to another 45 days), we will inform you of the reason and extension period in writing.

If you have an account with us, we will deliver our written response to that account. If you do not have an account with us, we will deliver our written response by mail or electronically, at your option.

Any response we provide will only cover the 12-month period preceding our receipt of your request. The response we provide will also explain the reasons we cannot comply with a request, if applicable. For data portability requests, we will select a format to provide your Personal Information that is readily useable and should allow you to transmit the information from one entity to another entity without hindrance.

We do not charge a fee to process or respond to your verifiable consumer request unless it is excessive, repetitive, or manifestly unfounded. If we determine that the request warrants a fee, we will tell you why we made that decision and provide you with a cost estimate before completing your request.

Changes to Our Privacy Notice

We reserve the right to amend this Privacy Notice for California Consumers at our discretion and at any time. When we make substantive changes to this Privacy Notice, we will post a summary at the top of the first page of this Notice and update the Notice effective date.

Non-Discrimination

We will not discriminate against You for exercising any of Your CCPA rights.