NOVELTY MAGAZINES INC. PRIVACY POLICY

The Novelty Magazines Inc. Privacy Policy was last updated on July 24, 2018.

We, Novelty Magazines Inc. and our corporate affiliates (“Novelty“, “we” or “us“), are committed to protecting and respecting your privacy. We believe in transparency and want you to feel comfortable using our platform, and we are committed to being upfront about our privacy practices.

1. Important information and who we are

a. Purpose of This Privacy Policy

This Privacy Policy (“Policy“) explains which information we collect from you, when you (“you” or “your“, the user of our Services) access and use our websites (including www.finance101.com) (the “Site“), as well as our platforms, widgets, analytics tools, and other technical applications that we may provide either through our Sites or through third-party websites or other products and services provided by us (which, together, are referred to as the “Services“), will be processed by us, and how we use such information and protect it. The Policy also wishes to make sure that you are aware of the options available to you when you access and use our Services.

b. Contact Details

If you have any questions or concerns about Novelty’s Privacy Policy or data processing or if you would like to make a complaint about a possible breach of local privacy laws, please contact us at:

Novelty Magazines Inc.

Email address: Contact@novelty.media

Postal address: 4225 Executive Square, Suite 1000, La Jolla, San Diego 92370.

Telephone number: 858-275-6570

If you are an EU resident, you have the right to make a complaint at any time to the relevant supervisory authority. We would, however, appreciate the chance to deal with your concerns before you approach such authority, so please contact us in the first instance.

c. Third-Party Links

This website may include links to third-party websites, plug-ins and applications. Clicking on those links or enabling those connections may allow third parties to collect or share data about you. We do not control these third-party websites and are not responsible for their privacy policies and practices. When you leave our website, we encourage you to read the privacy policy of every website you visit.

2. The information we collect and process from your use of the Services.

a. When you use or interact with our Services, we automatically collect (by cookies, web beacons and similar technologies) certain information, such as: (a) anonymous encrypted code representing your Internet protocol (IP) address or your device identifier (if using a mobile device) and being used as a persistent identifier, anonymous login information, browser type and version, time zone setting, browser plug-in types and versions, operating system and version, device information; as well as (b) information about a user’s visit, including the full Uniform Resource Locators (URL) clickstream to, through and from our site (including date and time); products a visitor viewed or searched for, the frequency and scope of the respective use of the Services, page interaction information (such as scrolling, clicks, and mouse-overs), the content viewed (including advertisements clicked on) and pages visited, and cookie data.

As such, the information we collect cannot be used by us to specifically identify you. Our Services do not collect any personal information, i.e. information about a natural person such as name, address, email address, phone number, or other identifier that permits direct or indirect identification of a specific individual. To the extent required, the legal grounds for collecting, processing and using your information is your consent, which you may withdraw.

In addition, when you engage with advertisements that are displayed on the Services, Novelty, third party advertisers and data service providers may use industry-wide tracking methods (e.g., cookies, web beacons, etc.) which store certain information (“Methods”) and which allow us or such third parties to collect certain data for the purpose of serving advertisements through the use of the Novelty Services (including without limitation, serving advertisements that may be of interest to you). The Methods may store non-personal information as well as a persistent identifier. In such case, you will be subject to such third-party advertisers’ privacy policy. Please note, however, that we do not control such third-party advertisers or service providers, i.e. the third-party advertisers or service providers solely determine the purposes and means of the processing of personal data and are thus data controllers. We generally do not have any access to the information so collected.

To learn more about cookies, please visit http://www.allaboutcookies.org/. You may delete or decline cookies by changing your browser settings. The “Help” function in the toolbar of most browsers should indicate how you can set your browser to notify you before accepting cookies or to disable cookies entirely. However, if you refuse to accept cookies, you won’t be able to access and take advantage of many features of our Services properly.

b. Collaboration with Google and other Third-Party Ad Networks.

We may collaborate with Google or other third party vendors or advertising networks as business partners. Google uses cookies to help serve the ads it displays on the websites of its partners, such as websites displaying Google ads or participating in Google certified ad networks. When users visit a Google partner’s website, a cookie may be dropped on that end user’s browser.

  • Third party vendors, including Google, use cookies to serve ads based on a user’s prior visits to our website or other websites.
  • Google’s use of advertising cookies enables it and its partners to serve ads to you based on you visit to our sites and/or other sites on the Internet.
  • You may opt out of personalized advertising by visiting Ads Settings. Alternatively, you can opt out of some third-party vendor’s use of cookies for interest-based advertising by visiting aboutads.info.

Please be advised that the cookies of other third-party vendors or ad networks may also be used to serve ads on our website, and therefore, please be informed as follows:

  • Third-party vendors and ad networks may serve ads on our site.
  • You may opt out of personalized advertising from such third-party vendors and ad networks under the following link: http://optout.aboutads.info/?c=2#!/
  • Alternatively, you can opt out of some third-party vendor’s use of cookies for interest-based advertising by visiting aboutads.info.

Information collected by third parties. The third parties that display advertisements on our site may use tracking technologies, such as cookies, web beacons and similar technologies, to collect information about users who view or interact with their advertisements. Unless expressly stated otherwise, our website does not provide personal information to these third parties. This information allows them to deliver targeted advertisements and gauge their effectiveness. Some of these third party advertising companies may be advertising networks that are members of the Network Advertising Initiative, which offers end users a single location to opt out of ad targeting from member companies (www.networkadvertising.org).

We also collect, use, and share aggregated data such as statistical or demographic data for any purpose. Aggregated data is not considered personal data in law as this data does not directly or indirectly reveal your identity. For example, we may aggregate usage data to calculate the percentage of users accessing a specific website feature.

3. How we use the information we collect and store

We respect your privacy. As explained above, Novelty does not collect any personal data or information that can identify you. We generally use the information that we collect and process to provide and improve our services and products, for targeted online and offline marketing, and for general research and aggregate reporting.

We use the information that we collect in order to:

  •  deliver relevant website content and advertisements to you and measure or understand the effectiveness of the advertising we serve to you;
  •  communicate back to you;
  •  provide and monetize our website; to deliver content or advertising; to perform market research or measure Website usage; and to analyse traffic counts, your interests and website performance;
  •  to perform network communications, to administer our site and to support internal operations, including troubleshooting, data analysis, testing, research, statistical and survey purposes and as part of our efforts to keep our site safe and secure;
  •  for maintaining and analysing the function of the Services’ features and offerings, advertisements, and e-mail communications, and to improve them when necessary.
  •  Respond and handle your questions and requests. In such cases, we do not store any contact information.

4. DISCLOSURE OF YOUR INFORMATION TO THIRD PARTIES

We value your privacy and will not share information except with the parties set out below for the purposes indicated in the following instances:

a. With our affiliates. This relates to companies that are legally part of the same group of companies that we are part of, or that become part of that group. Currently our affiliates are based in Israel.

b. Third-Party Service Professional and legal advisers acting as processors including lawyers, bankers, auditors and insurers based in the USA and Israel who provide consultancy, banking, legal, insurance and accounting services or who conduct general business analyses, and who require reporting of processing activities in certain circumstances.

c. Providers. We may make use of third party service providers in the course of collecting, storing and/or processing information we collect from and receive about you in order to deliver content or advertising; to perform market research or measure website usage; and to analyze traffic counts, your interests and website performance. For example, we may tell our advertisers the number of visitors to our website and the most popular features or services accessed. This information does not contain any personal information and may be used to develop website content and services that we hope you and other users will find interesting and to customize content and advertising.

d. We may disclose information that we collect (i) as a response to a legal request (such as a court order, search warrant, or subpoena) if we believe that we are required to do so by applicable law; or (ii) when we believe that such disclosure or use is necessary in order to: reveal, prevent and address fraud, intellectual property infringement, piracy, or other illegal activities; enforce this Policy or our Terms of Use, including in order to investigate potential breaches; protect our rights, property or safety, or those of our users or from members of the public from harm, as required or permitted by law; and prevent death or imminent bodily harm.

e. Third parties to whom we may choose to sell, transfer, or merge parts of our business or our assets. Alternatively, we may seek to acquire other businesses or merge with them. If a change happens to our business, then the new owners may use the information we collect in the same way as set out in this Policy.

f. We use commercially reasonable efforts to engage with third-party service providers that post a privacy policy governing their collection, processing and use of non-personal and personal information. Please note, however, that we do not control such third party service providers, i.e. the third party service providers solely determine the purposes and means of the processing of personal data and are thus data controllers.

5. Transfers of Data

Please be aware that we may transfer your information, to Israel, the European Union and other countries through certain third parties that we use to operate and manage the Site and Services, including Amazon Web Services (AWS) or Google Cloud Services.

6. Data Retention

We retain aggregated or anonymous data, which cannot identify an individual or device and is used for purposes of reporting and analysis, for as long as is necessary for the purposes set out in this Policy, including for the purposes of satisfying any legal, accounting, or reporting requirements.

7. How do We Secure Your Information?

We consider data security a top priority and we do our best to keep your information secure. We have put in place appropriate security measures to prevent information from being accidentally lost, used or accessed in an unauthorised way, altered or disclosed. Such measures include:

➢ Encrypting many of our services using SSL.
➢ Employing firewalls and intrusion detection systems.
➢ Practicing administrative, technical, and physical security procedures to help protect the information you provide us.

Please keep in mind that no method of transmission over the Internet, or method of electronic storage, is 100% secure. As a result, although we strive to protect your information, we cannot promise or guarantee that such information will be immune from any wrongdoings, malfunctions, unlawful interceptions or access, or other kinds of abuse and misuse.

If you have reason to believe that your interaction with us is no longer secure (for example, if you feel that the security of any account you might have with us has been compromised), please immediately notify us of the problem by contacting us in accordance with the “Contact Us” section above.

8. Protection of Children’s Privacy

We are concerned about the privacy and safety of children when they use the internet. Our Services are not directed to children under sixteen (16).

We will never knowingly request personally identifiable information online from anyone under the age of 16 without prior verifiable parental consent. Our Services are general audience sites and are not targeted to or intended for use by children. However, if we learn that we have received information from a child under the age of 16 without parental consent, we will delete that information from our database.

9. Your Legal Rights

If you reside in the European Union, you have certain rights under European Data Protection Law with regard to your personal data. You have the right to:

  •  Request access to your personal data (commonly known as a “data subject access request”). This enables you to receive a copy of the personal data we hold about you and to check that we are lawfully processing it.
  •  Request correction of the personal data that we hold about you. This enables you to have any incomplete or inaccurate data we hold about you corrected, though we may need to verify the accuracy of the new data you provide to us.
  •  Request erasure of your personal data. This enables you to ask us to delete or remove personal data where there is no good reason for us continuing to process it. You also have the right to ask us to delete or remove your personal data where you have successfully exercised your right to object to processing (see below), where we may have processed your information unlawfully or where we are required to erase your personal data to comply with local law. Note, however, that we may not always be able to comply with your request of erasure for specific legal reasons which, if applicable, will be notified to you at the time of your request.
  •  Object to processing of your personal data where we are relying on a legitimate interest (or those of a third party) and there is something about your particular situation which makes you want to object to processing on this ground as you feel it impacts on your fundamental rights and freedoms. You also have the right to object where we are processing your personal data for direct marketing purposes. In some cases, we may demonstrate that we have compelling legitimate grounds to process your information which override your rights and freedoms.
  •  Request restriction of processing of your personal data. This enables you to ask us to suspend the processing of your personal data in the following scenarios: (a) if you want us to establish the data’s accuracy; (b) where our use of the data is unlawful but you do not want us to erase it; (c) where you need us to hold the data even if we no longer require it as you need it to establish, exercise or defend legal claims; or (d) you have objected to our use of your data but we need to verify whether we have overriding legitimate grounds to use it.
  •  Request the transfer of your personal data to you or to a third party. We will provide to you, or a third party you have chosen, your personal data in a structured, commonly used, machine-readable format. Note that this right only applies to automated information which you initially provided consent for us to use or where we used the information to perform a contract with you.
  •  Withdraw consent at any time where we are relying on consent to process your personal data. However, this will not affect the lawfulness of any processing carried out before you withdraw your consent. If you withdraw your consent, we may not be able to provide certain products or services to you. We will advise you if this is the case at the time you withdraw your consent.

If you wish to exercise any of the rights set out above, please contact us under: contact@novelty.media.

You will not have to pay a fee to access your personal data (or to exercise any of the other rights). However, we may charge a reasonable fee if your request is clearly unfounded, repetitive or excessive. Alternatively, we may refuse to comply with your request in these circumstances.

We may need to request specific information from you to help us confirm your identity and ensure your right to access your personal data (or to exercise any of your other rights). This is a security measure to ensure that personal data is not disclosed to any person who has no right to receive it. We may also contact you to ask you for further information in relation to your request to speed up our response.

We try to respond to all legitimate requests within one month. Occasionally it may take us longer than a month if your request is particularly complex or you have made a number of requests. In this case, we will notify you and keep you updated.

If you do not reside in the European Union but you believe that you have a right to restriction of processing or a right to object to processing under your local laws, please contact Novelty at contact@novelty.media

10. Changes to Our Privacy Policy

Any changes we may make to our privacy policy in the future will be posted on this page and, where appropriate, notified to you by e-mail. Please check back frequently to see any updates or changes to our privacy policy. To the extent permitted by law, your continued use of our Services following the posting of changes to this Policy or providing notice to you, whichever occurs first, means that you accept those changes.

11. General

If any provision of this Policy is deemed invalid by a court of competent jurisdiction, the invalidity of such provision shall not affect the validity of the remaining provisions of this Policy, which shall remain in full force and effect, provided, however, that in such event this Policy shall be interpreted so as to give effect, to the greatest extent consistent with, and permitted by, applicable law, to the meaning and intention of the excluded provision as determined by such court of competent jurisdiction.

12. Governing Law and Jurisdiction

This Policy shall be governed by the laws of the State of Delaware, without respect to its conflict of laws principles. We each agree to submit to the personal and exclusive jurisdiction of the federal and state courts located in Delaware, and waive any jurisdictional, venue, or inconvenient forum objections to such courts.

13. Note to International Users

We are a private company incorporated under the laws of Delaware, USA. If you are located elsewhere, the information you provide to us or that we collect will be transferred to the USA and governed by applicable laws and regulations and this Privacy Policy. Some of this information may be transferred to, processed and stored by our service providers in other countries.

Residents of the State of California may request a list of all third parties to which we have disclosed personal information during the preceding year for the third parties’ direct marketing purposes. If you are a California resident and want a list, you should send a request to: contact@novelty.media or, contact us at:4225 Executive Square, Suite 1000, La Jolla, San Diego 92370.

ATTN: Lirit Belisha, Chief Finance Officer

You need to provide the statement “Your California Privacy Rights” in the subject field of your e-mail or on the envelope or post card and in the actual request. For all requests, please include your name, street address, city, state, and zip code. We will not accept requests via telephone or by facsimile. We are not responsible for notices that are not labelled or sent properly, or that do not have complete information.