Bradley Communications Corp PRIVACY POLICY Effective Date: December 1, 2009 To review material modifications and their effective dates scroll to the bottom of the page. 1. Privacy Statement; Collection of Personal Information. 1.1 Bradley Communications Corp. (“Bradley”) owns and operates this website business. All references to “we”, “us”, this “website” or this “site” shall be construed to mean Bradley. 1.2 We understand that visitors to this website are concerned about the privacy of information. The following describes our privacy policy regarding information, including personal information, that we collect through this website. 2. Modification of Privacy Policy. We reserve the right to modify this Privacy Policy at any time, and without prior notice, by posting an amended Privacy Policy that is always accessible by clicking on the “Privacy Policy” link on this site’s home page. Your continued use of this site indicates your acceptance of the amended Privacy Policy. You should check the Privacy Policy through this link periodically for modifications by clicking on the link provided near the top of the Privacy Policy for a listing of material modifications and their effective dates. Regarding personal information, if any modifications are materially less restrictive on our use or disclosure of the personal information previously disclosed by you, we will obtain your consent before implementing such revisions with respect to such information. 3. Collection of Anonymous, Passive Information. We reserve the right to monitor your use of this site. As you navigate through this site, certain anonymous information may be passively collected (that is, gathered without your actively providing the information) using various technologies, such as cookies, Internet tags or web beacons, and navigational data collection (log files, server logs, clickstream). The following is a listing and a brief explanation of passive information collection methodologies which we may use from time to time to better understand how this site is being used. 3.1 A “cookie” is a text file that this site sends to your browser in the form of a text file The information generated by the cookie about your use of this site (including your IP address) will be transmitted to and stored. Most browsers automatically accept cookies, but they usually can be modified to decline cookies if you prefer; however, certain features of this site might not work without cookies. 3.2 “Session” cookies are temporary bits of information that are used to improve navigation, block visitors from providing information where inappropriate (the site “remembers” previous entries of country of origin that were outside the specified parameters and blocks subsequent changes), and collect aggregate statistical information on the site. They are erased once you exit your Web browser or otherwise turn off your computer. 3.3 “Persistent” cookies are more permanent bits of information that are placed on the hard drive of your computer and stay there unless you delete the cookie. Persistent cookies store information on your computer for a number of purposes, such as retrieving certain information you have previously provided, helping to determine what areas of the site you may find most valuable, and customizing the site based on your preferences on an ongoing basis. Persistent cookies placed by this site in your computer do not hold personal information. 3.4 You can set your browser to accept all cookies, to reject all cookies, or to notify you whenever a cookie is offered so that you can decide each time whether to accept it. To learn more about cookies and how to specify your preferences, please search for “cookie” in the “Help” portion of your browser. 3.5 An Internet Protocol (IP) address is a number assigned to your computer by your Internet service provider so you can access the Internet and is generally considered to be non-personally identifiable information, because in many cases an IP address is dynamic (changing each time you connect to the Internet), rather than static (unique to a particular user’s computer). The IP address can be used to diagnose problems with a server, report aggregate information, determine the fastest route for your computer to use in connecting to a site, and administer and improve the site. 3.6 “Internet tags” (also known as Web Beacons, single-pixel GIFs, clear GIFs, invisible GIFs, and 1-by-1 GIFs) tell the website server information such as the IP address and browser type related to the visitor’s computer. Tags may be placed both on online advertisements that bring people to the site and on different pages of the site. Such tags indicate how many times a page is opened and which information is consulted. 3.7 “Navigational data” (log files, server logs, and clickstream data) are used for system management, to improve the content of the site, market research purposes, and to communicate information to visitors. 4. Use and Sharing of Anonymous, Passive Information. This site may make full use of passively collected anonymous information, including without limitation the right to use such information to provide better service to site visitors, customize the site based on your preferences, compile and analyze statistics and trends, and otherwise administer and improve this site for your use. We reserve the right to share this anonymous, passive information in aggregated form. 5. 3rd Party Behavioral Ads; Google’s AdSense Network. 5.1 We reserve the right to use anonymous, passive information about your visits to this and other websites (not including your name, address, email address or telephone number) for purposes of serving our ads and third party ads that are targeted to your interests (“3rd Party Behavioral Ads”). We reserve the right to share anonymous, passive information collected on this site with third parties for purposes of serving 3rd Party Behavioral Ads. These 3rd Party Behavioral Ads do not identify you personally. Instead, they associate your behavioral data on visited sites with your browser, so that the ads your computer sees on this site are more likely to be relevant to your interests. 3rd Party Behavioral Ads require that that you be served with a cookie containing a tracking code. You may refuse the use of cookies by selecting the appropriate settings on your browser; however, please note that if you do this you may not be able to use the full functionality of this site. 5.2 We reserve the right to participate in Google’s AdSense network for purposes of serving 3rd Party Behavioral Ads. Google uses DoubleClick’s DART cookie for serving 3rd Party Behavioral Ads over the AdSense network. You may opt out of the use of the DART cookie. For information regarding how to opt out, go to http://www.google.com/privacy_ads.html. 6. Use of 3rd Party Cookies. We reserve the right to use web analytics services provided by third parties. These services use 3rd party cookies to collect anonymous, passive information about your use of this site (see explanation of cookies in Collection of Anonymous, Passive Information above). We use this information for the purpose of evaluating your use of this site, compiling reports on website activity, and providing other services. These web analytics services may also transfer this information to third parties where required to do so by law, or where such third parties process the information on the service’s behalf. 7. Collection of Personal Information; Categories. 7.1 We will ask you for personal information when you sign up to register as a reporter or publicity seeker. 7.1.1 For reporters, personal information that we collect may include one or more of the following categories: name, company name, an email address, phone number, job title, and media outlet and related website. 7.1.2 For expert/sources, personal information that we collect may include one or more of the following categories: name, physical (“snail mail”) address, an email address, phone number, fax number, website address, company name, job type, keywords for listing purposes, subject matter for email alerts, topics for which you’re qualified as an expert, information regarding your interests regarding public relations, and names and contact information of a spokesperson/contact (only if you’re not doing media interviews yourself). 7.2 We do NOT tie or link your personal information to anonymous, passive information with persistent identifiers. For example, we would not tie or link your email address (personal information) with information collected by a cookie regarding the length of time you visit our site anonymous, passive information). 8. Use And Sharing of Personal Information: General Policy And Exceptions. Our general policy is that we will use your personal information only for: the performance of the services or transaction for which it was given including the sharing of information submitted by a publicity seeker to the reporter who placed the query, our private, internal reporting for this site, and security assessments for this site, and we will not share, sell, or rent your personal information to others. The only exceptions to this general policy: (i) are described in the subsections below, and (ii) if you explicitly approve through our site. 8.1 Affiliates And Service Providers. We reserve the right to provide such information to our affiliates or subsidiaries, or trusted service providers for the purpose of hosting our servers or processing or archiving personal information for us. We require that these parties agree to privacy and security safeguards for this information that are consistent with this Privacy Policy. 8.2 Acquisition; Bankruptcy. In the event that we are acquired by or merged with a third party entity, or if we sell this website business or a line of business from this website, we reserve the right to transfer such information as part of such merger, acquisition, sale, or other change of control. In the unlikely event of our bankruptcy, insolvency, reorganization, receivership, or assignment for the benefit of creditors, or the application of laws or equitable principles affecting creditors’ rights generally, we reserve the right to transfer such information to protect our rights or as required by law. 8.3 Enforcement; Legal Process. We reserve the right to transfer such information if we have a good faith belief that access, use, preservation or disclosure of such information is reasonably necessary (i) to satisfy any applicable law, regulation, legal process or enforceable governmental request, or (ii) to investigate or enforce violations of our rights or the security of this site. 8.4 Third Parties For Direct Marketing; Your California Privacy Rights. 8.4.1 Except for reserving the right to rent physical (“snail mail”) addresses along with related name, company name, and title, we will NOT share personal information provided by experts/sources through our registration process or through a query. We do not plan to rent physical (snail mail) addresses and the related elements of personal information listed above in the foreseeable future; however, we reserve the right to do so. 8.4.2 We will NOT share personal information of reporters that we collect through our registration process. We reserve the right to collect personal information regarding reporters through other sources external to this site, and we further reserve the right to use and share the information we collect in this manner without restriction. 8.4.3 We DO reserve the right to share personal information that we collect through our opt-in process. We may provide you with the opportunity to receive promotional offers from specifically identified third-parties through their direct marketing efforts, but only if you explicitly consent (opt-in) to receive each offer. If you explicitly consent (opt-in), your personal information will be shared only with the specifically identified third-party to enable them to provide you with the offer you have requested, and then only in connection with that specific promotion and not on a continual basis. Any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should review any privacy policies posted on any of these sites before providing information to them. California Civil Code Section 1798.83 permits California residents to request certain information regarding disclosure of their personal information to third parties for purposes of direct marketing. You may request further information about our compliance with California Civil Code Section 1798.83 at the following email address: compliance.officer-at-ReporterConnection.com. Please note that we are only required to respond to one request per registrant each year, and we are not required to respond to requests made by means other than through this the address provided above. 9. Onward Transfer of Personal Information Outside Your Country of Residence. Any personal information which we may collect on this site will be stored and processed in our servers located only in the United States. By using this site, if you reside outside the United States, you consent to the transfer of personal information outside your country of residence to the United States. 10. Security of Personal Information. We follow reasonable and appropriate industry standards to protect your personal information and data. Unfortunately, no data transmission over the Internet or method of data storage can be guaranteed 100% secure. Therefore, while we strive to protect your personal information by following generally accepted industry standards, we cannot ensure or warrant the absolute security of any information you transmit to us or archive at this site. 11. Changing And Updating Personal Information. Upon request, we will permit you to request or make changes or updates to your personal information for legitimate purposes. We request identification prior to approving such requests. We reserve the right to decline any requests that are unreasonably repetitive or systematic, require unreasonable time or effort of our technical or administrative personnel, or undermine the privacy rights of others. We reserve the right to permit you to access your personal information in any account you establish with this site for purposes of making your own changes or updates, and in such case, instructions for making such changes or updates will be provided where necessary. 12. Email; Promotional Offers From Us; Opt-Out Rights. If you supply us with your e-mail address you may receive promotional offers from third party sponsors which we select; however, in these instances, we do NOT share your personal information with the third party sponsors for purposes of the mailing; we do the mailing for them. However, if you do accept any of these promotional offers, any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should be careful to review any privacy policies posted on any of these sites before providing information to them. 13. Links To Other Sites Including Online Ads. This site may contain links to other websites with whom we have a business relationship. These links may include online advertisements that we deem to be appropriate. Any information that you provide in the process of registration or purchase will be transferred to these sites. We have no responsibility or liability for the policies and practices of these sites. You should be careful to review any privacy policies posted on any of these sites before providing information to them. 14. Children’s Online Policy. We are committed to preserving online privacy for all of its website visitors, including children. This site is a general audience site. Consistent with the Children’s Online Privacy Protection Act (COPPA), we will not knowingly collect any information from, or sell to, children under the age of 13. If you are a parent or guardian who has discovered that your child under the age of 13 has submitted his or her personally identifiable information without your permission or consent, we will remove the information from our active list, at your request. To request the removal of your child’s information, please contact our site as provided below under “Contact Us”, and be sure to include in your message the same login information that your child submitted. 15. Email And Other Messages Through This Site; ECPA Notice. This site treats email messages and other electronic messages that are sent through this site and not viewable by others as confidential and private, except as required by law, including without limitation, the Electronic Communications Privacy Act of 1986, 18 U.S.C. Sections 2701-2711 (the “ECPA”). The ECPA permits this site’s limited ability to intercept and/or disclose electronic messages, for example (i) as necessary to operate our system or to protect our rights or property, (ii) upon legal demand (court orders, warrants, subpoenas), or (iii) where we receive information inadvertently which appears to pertain to the commission of a crime. This site is not considered a “secure communications medium” under the ECPA. 16. Contact Us. If you have any questions regarding this Privacy Policy, please contact the owner and operator of this website business at: Bradley Communications Corp.
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